PLEASE SCROLL DOWN AND READ THESE PRIVACY POLICY CAREFULLY BEFORE ACCESSING AND USING THE SPLAITOR WEBSITE

Updated and Affective as of August 29, 2023

Welcome to Splaitor, a platform designed to keep you informed, engaged, and connected. Your privacy is of utmost importance to us, and we are committed to safeguarding your personal information. This Privacy Policy outlines how Splaitor (“we,” “our,” or “us”) collects, uses, shares, and protects information related to your use of our website, services, and products (collectively referred to as “Services”).

The Privacy Policy is meant to help you understand:

• What types of information we collect
• How we use that information
• With whom we share the information
• What measures we take to protect it

By accessing or using our Services, you agree to the collection, storage, usage, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with the practices described, it is your responsibility to discontinue using our Services immediately.

Please read this Privacy Policy carefully. It should be reviewed in conjunction with our Terms of Service, which also govern your use of the Services. This Privacy Policy applies to all users, including both those who use the Services without being registered or subscribing to any Services and those who have registered or subscribed.

This Privacy Policy is subject to changes, which will be updated on this page. You are encouraged to review it frequently to stay informed about how we are helping to protect the personal information we collect.

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at privacy@splaitor.com.

What Information We Collect

At Splaitor, we collect various types of information to provide, maintain, and improve our Services. This section outlines the types of information we may collect from you or that you may provide to us.

Type of Data	Examples	Purpose
Personal Information	Name, Email, IP Address	User identification, Communication
Usage Data	Pages Visited, Time Spent on Pages, Links Clicked	Website Optimization, User Experience Improvement
Cookies	Session Cookies, Persistent Cookies, Third-Party Cookies	User Preferences, Website Functionality

Personal Information

When you register or subscribe to our Services, you may provide us with personal information, which includes but is not limited to:

• Your name
• Email address
• Username

Technical Information

While interacting with our Services, certain technical information may be automatically collected, such as:

• IP address
• Geolocation data
• Browser type and version
• Operating system
• Device type
• Date and time of access
• Pages visited on our website

Usage Data

We collect data about how you use our Services, including:

• The articles you read
• Time spent on our Services
• Features you use
• Click-throughs
• Any other interaction within our Services

Cookies and Tracking Technologies

We employ various tracking technologies like cookies, web beacons, and similar mechanisms to collect information for analytics and personalization. These technologies gather:

• Session information
• User preferences
• Other information related to user interaction with our Services

User Contributions

Any content or material you upload, post, or otherwise contribute to our Services (e.g., comments, reviews, feedback) is considered user contributions and may be stored and displayed as part of our Services.

Communication Data

When you contact us via email, social media, or other forms of communication, we may keep a record of that correspondence.

By using our Services, you consent to the collection of this information as described above. If you do not agree with the collection of this information, you should cease using our Services immediately.

How We Collect Information

In order to provide you with a tailored and efficient experience, we employ a variety of methods to collect information from and about you. Some of this data is provided directly by you when you register for our Services, subscribe to newsletters, or fill out forms on our website. Additionally, we gather technical information automatically as you interact with our Services through various tracking technologies, including cookies, server logs, and other automated data collection tools. If you contact us for support or send us email inquiries, we collect the information contained within that communication. Moreover, we may occasionally collect information from third-party sources, such as social media platforms, if you choose to link or integrate them with our Services. All these methods help us understand your needs and preferences, improve our Services, and ensure the safety and security of our platform.

How We Use Collected Information

We use the information we collect primarily to enhance your user experience and improve the quality of our services. While we generally do not authenticate your identity or collect payment information, the data we do gather serves multiple purposes. For example, personal information you voluntarily provide is used for personalizing content, enabling tailored communication through newsletters and promotional materials, and sending important service updates. Technical data, such as IP addresses and device information, is crucial for optimizing site performance, troubleshooting, and bolstering security measures. We also analyze usage data to understand interaction patterns, which helps us refine our features and content. Cookies and other tracking technologies are used to remember your preferences and settings, facilitating a more personalized service. Communication data, which includes any information provided when you contact us, is used to handle your inquiries, comments, and feedback. Lastly, we may use collected information to meet legal obligations, resolve disputes, and enforce our terms and policies. Overall, the data we collect supports our goal of providing you with a service that meets your needs in the most efficient and enjoyable manner possible

How We Share Your Information

We take your privacy seriously and are committed to not selling or leasing your personal information to third parties. However, there are specific circumstances where information sharing may occur. For instance, we may share aggregated, anonymized data with advertisers or analytics providers to improve our services and offer more targeted content. If you interact with social media features on our platform, the data you share is governed by the privacy policies of those third-party social media companies. In cases of legal requirements, we may disclose your information to law enforcement agencies, regulatory organizations, or in court proceedings if required by law. We may also share information with our service providers who perform functions on our behalf, such as email delivery or customer service; these entities are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Additionally, in the event of a merger, acquisition, or asset sale, your personal information may be transferred as part of the transaction. Finally, non-personal, aggregated, or de-identified information may be shared freely. We strive to ensure that any third parties with whom we share information adhere to adequate data protection principles to safeguard information from unauthorized access or disclosure.

Cookies and Tracking Technologies

We employ cookies and other tracking technologies to enhance your user experience, analyze trends, administer the website, track user movements around the site, and gather demographic information about our user base as a whole. Cookies are small files placed on your computer’s hard drive or in device memory that helps us to, among other things, improve our website and your experience, see which areas and features of our website are popular, and count visits. We also use cookies to keep you logged in, remember your preferences and settings, and tailor ads to your interests.

We may also utilize web beacons, pixel tags, and other tracking technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website.

You have the option to manage your cookies preferences, including disabling them altogether through your browser settings. However, it’s important to note that disabling cookies might affect the availability and functionality of our services. You can also opt-out of tracking technologies by following the instructions provided by each third-party analytics provider.

Third-Party Services and Links

Our website may include links to external websites, applications, or services, as well as integrations with social media platforms, payment gateways, or other third-party services for enhanced functionality and user experience. Please note that these third-party services have their own privacy policies and data collection practices. We are not responsible for the privacy practices, policies, or content of these external services. When you click on a third-party link, you will be directed to that third party’s site, which is entirely independent of our control. Therefore, we strongly advise you to review the privacy policies of these third-party websites and services before engaging with them or providing them with any personal information.

If you choose to use a third-party service through our website, the information you share with that third-party is not covered by this Privacy Policy. We cannot guarantee the security and privacy of data you provide to third parties, and we disclaim any responsibility or liability for their policies or actions.

Data Security

We prioritize the security of your personal information and implement a variety of security measures designed to maintain the safety of your data. We employ technological safeguards such as firewalls, encryption techniques, and secure socket layer technology to protect against unauthorized access, alteration, disclosure, or destruction of your personal information. Additionally, we restrict access to your personal information to employees, contractors, and agents who need to know that information to perform their job functions. They are contractually obligated to keep this information confidential and adhere to our privacy and security policies.

However, it’s important to note that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information to the best of our ability, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the website.

In the event of a data breach that affects your personal information, we will take appropriate actions in line with legal requirements, which may include notifying you and relevant authorities.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting obligations. The retention period may vary depending on the type of data and how it is used. After this period, your personal information will be deleted or anonymized so that it can no longer be linked back to you.

We periodically review our data retention policies to ensure compliance with applicable laws and regulations. If you deactivate or delete your account, some of your information may still be stored in our databases for record-keeping purposes, but it will no longer be accessible to third parties or used for any active processing.

It’s also important to note that we may be required to retain certain data for a longer duration if it is subject to a legal obligation, like court orders or ongoing judicial proceedings.

Your Rights and Choices

You have several rights regarding the personal information we hold about you, subject to local data protection laws. These may include the right to:

• Access: Request access to your personal information stored on our systems.
• Correction: Rectify or update inaccurate or incomplete personal information.
• Deletion: Request the deletion of your personal information, subject to certain exceptions.
• Objection: Object to the processing of your personal information for specific purposes, such as direct marketing.
• Restriction: Temporarily restrict the processing of your personal information in certain circumstances.
• Portability: Request a copy of your personal data in a structured, commonly used, and machine-readable format, where applicable.
• Withdraw Consent: If the processing is based on your consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, you can contact us through the methods specified in the “Contact Us” section of this Privacy Policy. We will respond to your request within a reasonable timeframe, in accordance with applicable laws.

Please note that we may require additional information to verify your identity before we can fulfill your request. Additionally, there may be circumstances where we are legally entitled to reject your request or retain certain information.

Children’s Privacy

Splaitor is not intended for use by children under the age of 13. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. Should we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us at children-privacy@splaitor.com.

For individuals who are under the age of 18 but at least 13 years old, we allow them to request the removal of any User Contributions or information they have posted on our website. However, this request for removal does not ensure complete or comprehensive removal of the content or information posted on the website.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so we encourage you to review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make significant changes to this policy, we will notify you here, by email, or through a notice on our homepage, to offer you the opportunity to review the changes before they become effective. Your continued use of the website following the posting of any modifications to this Privacy Policy signifies your acceptance of those changes. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the website.

Additional Provisions for California Residents

In compliance with the California Consumer Privacy Act of 2018 (CCPA), as amended, and other California privacy laws, this section is particularly for California residents. It outlines the rights you hold regarding your personal data. For the purpose of this section, “personal data” refers to information identifying, associated with, or reasonably linked to a California resident or household. This excludes publicly accessible data and other exceptions as provided by law.

Categories of Personal Data We Gather

Within the past year, the data categories we’ve gathered, as defined under CCPA, include:

• Identifying details like your name, email, IP address, and other account or device identifiers.
• Commercial data, including transaction history and services considered or purchased.
• Web activity data including how you interact with our platform.
• Geolocation specifics, derived from enabled services like WiFi and GPS.
• Professional and employment data like your job title and company details.
• Inferences about your preferences and interests based on your usage data.

Source of Data Collection

For further details on the origins of this data, refer to the “How We Collect Information” section.

Utilization of Your Data

We use the collected data categories for various business objectives outlined in the “How We Use Collected Information” section.

Disclosure of Personal Data

We disclose your personal data to third parties and service providers for business purposes as detailed in the “How We Share Your Information” section. These disclosures include sharing for cross-context behavioral advertising and analytics.

Your Privacy Rights

As a California resident, you can:

• Request details about your data we collect and use, up to twice every 12 months.
• Ask for deletion of your data under specific conditions.
• Opt-out of data “selling” or “sharing.”
• Request correction of inaccurate data.
• Non-discrimination for exercising your privacy rights.

To execute these rights, please email us at privacy@splaitor.com.

Opt-Out Rights

You can opt-out of the sharing or sale of your personal data by contacting us at privacy@splaitor.com.

California Shine the Light Law

California residents can request a list of data categories we have shared with third parties for their own direct marketing during the past calendar year, along with the names of those third parties. To make such a request, please contact us at privacy@splaitor.com and specify that you’re making a “California Shine the Light” request.

This section is meant to provide comprehensive information in compliance with California law. For any inquiries or to exercise your rights, please reach out to us at privacy@splaitor.com.

Additional Provisions for Virginia Residents

This section specifically caters to Virginia residents and is in accordance with the Virginia Consumer Data Protection Act (“VCDPA”). Below, you’ll find explanations of your particular rights regarding your personal information and the methods you can use to exercise these rights.

Categories of Information We Accumulate

As outlined in other parts of this Privacy Policy, we collect a range of personal data from you. Certain pieces of this data are designated as “sensitive data” under the laws of Virginia, including:

• Precise Geolocation Information

How We Handle Your Data

The personal data we collect is used for the purposes described elsewhere in this Privacy Policy, specifically in the sections referring to the utilization of your information. Any sensitive data collected will also be used for these stated purposes.

Sharing Your Data

We may disseminate your personal information to trusted service providers who assist us in various capacities. We do not engage in the “sale” of your personal data as it is defined by Virginia law.

However, we do share certain kinds of data, like cookies, with third parties for the purpose of delivering targeted advertising. How to opt out of such sharing is provided in a separate section of this Privacy Policy.

Your Legal Rights in Virginia

If you are a resident of Virginia, you are granted specific rights concerning your personal data:

• Access Right: You can request to view or receive an electronic copy of the personal data we hold about you.
• Correction Right: You have the option to rectify any incorrect or incomplete data about you that we may hold.
• Deletion Right: You are entitled to request the removal of your personal data from our databases.
• Opt-Out Right: You can choose to prevent the use of your data for targeted advertising, or for its sale or profiling.
• Non-Discrimination Right: You won’t face any form of discrimination for exercising any of the above rights.

For the verification process, you may be required to provide identification details such as your name and email address. These details will be cross-referenced with our existing records.

To activate any of these rights send an email to privacy@splaitor.com for specific requests.

Should you disagree with our handling of a previous request, you may contact us via the email address above or report it to the Office of the Attorney General of Virginia.

For a more in-depth understanding of your privacy rights under Virginia law or to exercise these rights, please contact us through the aforementioned channels.

Additional Provisions for Residents of the United Kingdom, Switzerland, and European Union

This section is explicitly designed for individuals who reside within the European Economic Area (EEA), United Kingdom (UK), Switzerland, or any other territory where similar privacy regulations apply. This part of the Privacy Policy ensures our compliance with regulations like the General Data Protection Regulation (GDPR) and its UK counterpart, among other applicable local laws.

Definition of Personal Data

In the context of this section, “personal data” refers to any information that can be used to identify an individual, either directly or indirectly.

Role as Data Controller or Data Processor

Splaitor may function either as a “data controller” or a “data processor” depending on the situation. Typically, we act as a data controller for the data you provide via our services. On occasion, we act as a data processor when servicing a client who retains the role of data controller. Should you have questions about your data under such circumstances, it is advisable to consult the client’s privacy policy as they are the data controller.

Legal Grounds for Processing Data

We process your personal data based on one or more of the following legal grounds:

• Fulfillment of contractual obligations
• Legitimate interests pursued by us or third parties
• Compliance with legal requirements
• Your explicit consent, which can be revoked at any time

Legitimate Business Interests

We may use your personal data to serve various legitimate business objectives. Such interests include but are not limited to improving our services, ensuring secure and hassle-free user experiences, and targeted marketing, which will always be weighed against your rights and interests.

Your Rights Under GDPR

If you are a resident of the territories mentioned above, you have specific rights concerning your personal data:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can correct inaccuracies in your personal data.
• Right to Erasure: You can request the removal of your data.
• Right to Portability: You can ask for a portable version of your data.
• Right to Object: You can object to our processing of your data.

To exercise these rights, send an email to privacy@splaitor.com. We may require additional information for verification and will respond within 30 days. If we are processing your information on behalf of a client, your request will be forwarded to that client for further action.

If you believe that we have not complied with GDPR, you have the right to lodge a complaint with a Data Protection Authority.

Data Retention and Transfer

We will retain your personal data only as long as necessary for the purposes for which it was collected. When transferring your data outside of the EEA or UK, we ensure adequate safeguards are in place, in compliance with GDPR requirements.

By using our services, you acknowledge and agree to the data practices described in this section. For a deeper understanding of your rights under GDPR, feel free to contact us at privacy@splaitor.com.

Contact

For any questions, concerns, or further clarification regarding our Privacy Policy, GDPR compliance, or any other privacy-related matters, please contact us at:

Email: privacy@splaitor.com

We are committed to resolving any issues you may have and will respond to your inquiry as promptly as possible.

Your privacy is important to us, and we encourage you to reach out for any clarifications you may need. Thank you for using Splaitor.