This Privacy Policy explains how Spencil Design, LLC (“Spencil”, “we”, “us”, or “our”) may collect, use, and disclose your personal information in connection with www.Spencil.co and our other websites or digital properties that link to this Privacy Policy (collectively, the “Website”), our mobile applications (collectively, the “App”), our email communications and other engagement through social media services, our surveys and promotions, and our related services (collectively with the Website, the App, and the other activities described here, the “Service”), and in certain offline scenarios.

Personal information Spencil collects

The following are categories (with non-exhaustive examples) of personal information we may collect about you:

Categories	Examples
A. Individual Identifiers & Demographic Information	Contact data, such as your name, address, phone number, or email address. Demographic data, such as general location information like city, state or geographic area.
B. Geolocation Data	Precise location or geolocation data, when you authorize Spencil to collect such information from your device when using the App.
C. Commercial Information	Payment data, such as the information you may provide to make purchases (such as your payment method and credit or debit card number) or to receive payments as a Designer (such as your bank account number and routing number). Profile and account data, such as your account name and password, the designers or clients you have contacted, order history, your reviews, products you have purchased, your design boards, and gift card information. Communications, such as email messages, phone calls, social media interactions, and other communications. Survey responses, such as color preferences, use and occupants of your space, and other personal preferences and information relevant to creating comprehensive designs in connection with our style quizzes, and/or other information you provide when you participate in one of our surveys. Preferences, such as your preferences for receiving marketing and other communications and your design interests.
D. Professional or Employment-Related Information	Application data, such as your resume/CV, education, employment history, job qualifications, and other information you submit when applying as a Designer or other role.
E. Internet or Network Activity	Device data, such as your identifiers related to your phone, tablet, computer, or other device, operating system type and version number, manufacturer and model, browser type, screen resolution. Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
F. Sensory Data	Design images, such as the photos, images, dimensions, room layouts, design renderings, plans, recommendations, and other design information you may submit to or receive from a designer or otherwise. Call data, such as recordings of the calls you make to our customer service team, designers, or other Spencil team members.
G. Inferences Drawn from Personal Information	Profiles reflecting your preferences and other characteristics, such as inferences regarding your preferences when using the Services and other characteristics about your interactions with us that we may combine with other personal information we collect about you as described in this table.

How Spencil collects your information

We collect information about you in various ways, including in connection with the sources described below.

Personal Information You Provide. We collect personal information you provide to us, such as when you register to use the Service, make a purchase, complete an application to become a Spencil designer or otherwise join our company, communicate with or submit information or content to us, communicate with designers or clients, take a style quiz, respond to a survey, and/or interact with other Users during a design project or post about your project. If you are a designer (a “Designer”), the Service will also collect any information you add to your Profile, as well as any communications you have through the Service. As part of this, we will collect any interim or design renderings, plans, or recommendations, which we shall own, and we may use (or share) for any purpose. In some cases, we may identify you as the source of such materials by including your name and photograph.

Business Partners and Other Third Parties. We may also collect information about you from our business partners, social media networks and data providers, and we may add that information to information you provide to us and other personal information we collect.

Social Media Platforms. If you are a Client, you may register using a social network, such as Facebook or Pinterest. We collect information from the social network when you use your social media credentials to log into the Service. For example, when you log in with your Facebook credentials, we may collect the information you have made publicly available in Facebook, such as your name and profile picture. We may also obtain any other information you have authorized Facebook to share with third party applications. For example, if you authorize us to access your Pinterest or Houzz accounts, we (and your designer(s)) may access and collect the photos, images, or other content that you have pinned there. We may also collect social media information when you interact with us via our social media accounts.

Referrals. If you provide us with contact information (including emails) of any friends we may contact those friends and say you have referred us to them. We may also receive information about you from your friends, if they provide us information about you. You should not give us any contact information for anyone unless you have their permission to do so. You may only provide us contact information for actual people you know who live in the United States and are 16 or older.

Location Information from Your Mobile Device. We may collect and store your location information if you enable your mobile device to send it to us. Collection of this information may improve the provision of the Service.

Automatic Data Collection, Cookies, and Related Technologies. The Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics. We, our service providers, and our business partners may automatically log personal information about you, your computer or device, and your activity over time on our Service and other sites and services, such as identifiers, device data, online activity data, and geolocation data, including by using cookies and similar technology. Like many online services, the Service may use the following technologies to facilitate our automatic data collection:

• Cookies, which are small text files placed in visitors’ computer browsers to store their preferences, make navigation between pages more efficient, help us understand user activity and patterns, and facilitate online advertising.
• Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
• Software development kits, or SDKs, which are third-party computer code used in connection with our App for a variety purposes, including to provide us with analytics regarding the use of our App, to integrate with social media, add features or functionality to our App, or to facilitate online advertising. SDKs may enable third parties to collect information directly via our App.

How Spencil uses your personal information

Service Delivery. We use information to deliver our Service, including but not limited to:

• provide, support, personalize, and develop our Service, products, and services;
• fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery;
• facilitate new product orders or process returns;
• post your reviews, feedback, or stories to our Service, if you submit a story about your experience with Spencil;
• process your requests, purchases, transactions, and payments;
• create, maintain, customize, and secure your account with us;
• provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• personalize your Service experience; and
• communicate with you regarding administrative, informational, and operational purposes, such as to send you emails relating to account management, customer service, or system maintenance.

Marketing. We and our partners may use your personal information for direct marketing and interest-based advertising purposes.

• Direct Marketing. We may use information (including your email) to provide online advertising on the Service and to facilitate transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you. This may be information about our products and services or third-party products and services.
• Interest-Based Advertising. We also contract with our business partners, third-party advertising companies, and social media companies to display ads on our Service and other sites and services. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. You can learn more about your choices for limiting interest-based advertising, in the “Advertising Choices” section below.

Research and Development. We may use your personal information for testing, research, analysis, and product development, including to develop and improve our Service, products, and services and to create new products and services. We may anonymize and aggregate data collected through the Service by removing information that makes the data personally identifiable to you, which we may use or share for any purpose, including for marketing purposes and to analyze and improve the Service.

Compliance and Protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

Other Uses. In addition to the uses otherwise described in this Privacy Policy, we may also use your personal information as described to you at the time when we collect it.

How Spencil may disclose your personal information

We may share your personal information with the categories listed below and as otherwise described in this Privacy Policy or at the time of collection:

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Service, such as furniture and goods suppliers, hosting providers, database services, web analytics, billing, fraud protection, marketing, PR agencies, and other third party vendors or suppliers who help us provide the Service or operate our business. For example, if you purchase something through our Service, we will share your information with the supplier and their shipping and fulfillment partners. We will also share your information with our credit card processors.

Designers and/or Clients. We share personal information between Designers and Clients who connect via the Service.

Related Companies. We may share your personal information with our current or future affiliates and/or subsidiaries.

Business Partners. We may share any personal information we receive with any entities with whom we have partnered with to provide you the Service. For example, if you are referred to our Service by a business partner, we may let them know about your interactions with the Service.

Other Users and the Public. The content you post to the Service may be displayed on the Service and may be seen by the Clients or Designers (as applicable) with whom you work, as well as others. All visitors of the Service, whether registered or not, may be able to see some information about you, such as your full name and picture if you are a Designer. Clients may also be able to see each Designer’s location, user rating, the number of Projects such Designer has conducted, specialties, design firm name and photos of the Designer’s work. If you are a Client, Designers will be able to see your name, location and personal information, gender, and the other information you share, such as about your design needs. We are not responsible for privacy practices of the other Users who will view and use any posted information.

Social Networking and Other Websites. The Service may allow you to share information with social networking websites, such as Facebook. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.

Marketing Partners. We may allow access to other data collected by the Service to enable the delivery of online advertising on this website, or otherwise facilitate transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you. Our marketing partners may collect information about your activity on the Service and other online services to help us advertise our products and services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; protect yours’, ours’ or others’ rights, property, or safety; or for the fraud prevention and safety purposes described above.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, including any related negotiations, your information may be sold, disclosed, or transferred as part of such a transaction (or potential transaction). If another company acquires our company or our assets, that company will possess the information collected by it and us and will assume the rights and obligations regarding your information collected by us as described in this policy.

Professional Advisors. We may share personal information with our professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

Consent. We may also otherwise disclose your information with your permission.

Security of your information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Service or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service.

Your choices

You can make the following choices with respect to your personal information.

Opt-Out of Marketing Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at support@Spencil.co. You may continue to receive service-related and other non-marketing emails.

Third Party Platforms. If you choose to connect to the Service using a third party platform like Facebook, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

We use Google Analytics to help us understand user activity and patters on the Site. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available here.

Advertising Choices. Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices, and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at optout.aboutads.info. Mobile app users may opt out of receiving interest-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices. You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Some of the third party advertising companies we work with offer their own opt-out options that you can use to limit their use of your information for interest-based advertising, such as Google (info and opt-out) and Facebook (info and opt-out). Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to Provide Information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.

Other sites and services

The Service may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

International transfers of personal information

Spencil is based in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.

Notice to California residents

This section applies to visitors, users, and others who reside in California (“consumers” or “you”). We have prepared this supplemental section to comply with the California Consumer Privacy Act of 2018 (CCPA). As used in this section, “personal information” and any other terms defined in the CCPA have the meaning given in the CCPA.

Personal Information That We Collect, Use, and Disclose. We describe:

• the categories of personal information we may have collected about you in the preceding 12 months in the section above called “Personal information Spencil collects”
• the sources from which we collect this information in the section above called “How Spencil collects your personal information”;
• the business and commercial purposes for which we collect this information in the section above called “How Spencil uses your personal information”;
• the categories of third parties to whom we disclose this information in the section above called “How Spencil may disclose your personal information”.

Spencil must also disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under the CCPA. Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. In the preceding twelve months, we have disclosed the following categories of personal information in the manner described:

Category	Personal Information is Disclosed for a Business Purpose	Personal Information is Disclosed for Valuable Consideration
A. Individual Identifiers & Demographic Information	Yes	Yes
B. Geolocation Data	Yes	No
C. Commercial Information	Yes	Yes
D. Professional or Employment-Related Information	Yes	No
E. Internet or Network Activity	Yes	Yes
F. Sensory Data	Yes	No
G. Inferences Drawn from Personal Information	Yes	Yes

Your California Privacy Rights. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to your personal information. You have the right to request that Spencil disclose certain information to you about our collection and use of your personal information over the past 12 months:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (we also call this a data portability request).

Deletion. You have the right to request that Spencil delete any of your personal information that we collected from you and retained, subject to certain exceptions.

Opt-Out of the “Sale” of Personal Information. If we “sell” your personal information, you can opt-out. Like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as a “sale” of your personal information to the companies that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form or legally prohibited increases in the price or decreases in the quality of our Service

Please note, these rights are not absolute and in some cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

Exercising Your California Privacy Rights. You may request to exercise the California privacy rights described above as follows:

• Right to access, data portability, and deletion rights. Please submit a request to us and provide the information required to verify your request by:
  • Emailing us at support@Spencil.co , or
  • writing to us at Spencil Design, LLC, Attn: CCPA Request, 1100 Ludlow St., Philadelphia, PA 19107.
• Right to opt-out of the “sale” of your personal information. You can request to opt-out of the “sale” of your personal information by visiting the following link: Do Not Sell My Personal Information

Only you or your authorized agent may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We reserve the right to confirm your California residency and will need to confirm your identity to process your requests. Please note, making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Other California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, if any. To make such a request, please write or email us by using the details in the section below titled “contact information.” You must include the words “Shine the Light” in your subject line or correspondence.

Changes to our Privacy Policy

Spencil reserves the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Site and update the “Last Updated” date above. Your continued use of the Service following the posting of changes constitutes your acceptance of such changes.

Contact information

If you have any questions or comments about this notice, the ways in which Spencil collects and uses your information described in this Privacy Policy, or your choices and rights regarding such use, please do not hesitate to contact us at:

Spencil Design, LLC
1100 Ludlow Street,
Philadelphia, PA 19107