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Sprin Inc. ("Sprin," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile application (the "App"), website (the "Site"), and related services (collectively, the "Services"). By using the Services, you consent to the practices described in this policy.
This Privacy Policy applies to information collected:
• Through the Sprin Site and App;
• In electronic communications between you and Sprin, including emails, text messages, and marketing messages;
• When you interact with our advertising on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to:
• Offline information collection by Sprin or third parties;
• Third-party websites or services not operated or controlled by Sprin.

2. NO USERS UNDER THE AGE OF 18

The Sprin Site and App are not intended for use by individuals under the age of 18. We do not knowingly collect personal information from users under 18. If we discover that we have collected personal data from someone under 18, we will delete it promptly. If you believe we might have any data from a child under 18, please contact us at support@sprin.app.

3. INFORMATION WE COLLECT

We collect various types of information:
(a) Information You Provide:
• Personal data such as name, email, phone number, address, gender, date of birth, and payment details;
• Health-related information relevant to your use of the App (e.g., pain points, therapy progress);
• Account login credentials;
• Messages and feedback submitted via forms or customer support.
(b) Information Collected Automatically:
• Device and usage data such as IP address, browser type, access times, operating system, and device identifiers;
• Analytics data through tools like Google Analytics;
• Cookies and similar technologies.

4. HOW WE USE YOUR INFORMATION

Sprin uses the information we collect about you or that you provide to us, including any personal data, for a variety of purposes, including:
• To operate, maintain, and improve our Services, including to provide you with content and features that are tailored to your interests;
• To manage your account and provide you with notices about your subscription or your account;
• To carry out our obligations and enforce our rights arising from any contracts entered intobetween you and Sprin;
• To respond to inquiries and customer service requests, including to provide technical support;
• To process your purchases and transactions, including sending notifications about your order status;
• To inform you of changes to the App, Site, or any products or services we offer or provide through them;
• To deliver promotional materials and relevant advertising to you, which may be based on your preferences or activity on the App or Site, subject to your opt-out preferences;
• To analyze user activity to improve the user experience, enhance App functionality, and optimize content delivery;
• To prevent fraudulent transactions, monitor against theft, and otherwise protect our users and our business;
• To comply with applicable laws and regulations, and to respond to lawful requests from public authorities;
• To fulfill any other purpose for which you provide the information or as otherwise specified at the point of collection;
• With your consent for any other purpose not listed here.
We may also aggregate or de-identify your personal data so that it no longer reasonably identifies you. We may use and disclose such aggregated or de-identified information for any purpose permitted by law, including research, analytics, and product development.
Sprin reserves the right to retain personal data as long as necessary to fulfill the purposes described above, comply with our legal obligations, resolve disputes, and enforce our agreements.

5. DISCLOSURE OF YOUR INFORMATION



Sprin does not sell your personal data to third parties. We may, however, disclose your information to certain trusted third parties to operate our business effectively, as outlined below:
• To our subsidiaries, affiliates, and service providers for purposes consistent with this Privacy Policy, such as cloud storage, analytics, email delivery, and customer support;
• To our professional advisors, including lawyers, auditors, and insurers, in connection with legal or insurance claims, audits, and risk management;
• In the event of a corporate transaction such as a merger, acquisition, asset sale, or bankruptcy, your personal data may be transferred to a successor entity subject to confidentiality obligations;
• To fulfill any specific purpose for which you provide the information, including sharing data with a third-party service as directed by you;
• When required by law, subpoena, or other legal process, or if we believe that disclosure is necessary to protect our rights, investigate fraud, or respond to a government request;
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sprin, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud detection and prevention and credit risk reduction.
We may also share aggregated or anonymized information that does not identify any individual user with third parties for research, analysis, or marketing purposes.
Sprin will not share your data for advertising or cross-context behavioral marketing unless we have obtained your explicit consent where required by law. We require all third parties with whom we share data to adhere to confidentiality and data protection agreements that align with applicable privacy regulations.
If you have questions or concerns about third-party access to your data, please contact us at support@sprin.app.
We do not sell your personal data.

6. CHOICES AND RIGHTS



We believe in providing you with meaningful choices about how your personal information is collected, used, and shared. Below are the tools and options we make available to help you manage your privacy:
• Cookie and Tracking Preferences: You can manage cookie settings through your browser. If you disable cookies, some features of the App or Site may not function properly. We honor browser settings where feasible and applicable law requires.
• Promotional Communications: You may opt-out of receiving promotional communications such as marketing emails, newsletters, or SMS/text messages by using the unsubscribe link in emails or replying STOP to text messages. This does not apply to service-related communications, such as confirmation emails or account notifications.
• Interest-Based Advertising: We may partner with advertising networks to deliver tailored advertising. To opt-out of interest-based advertising, visit the Digital Advertising Alliance (www.aboutads.info/choices) or Network Advertising Initiative (www.networkadvertising.org/choices/). Even if you opt-out, you may still receive non-personalized ads.
• Third-Party Data Collection: We do not control third-party tracking technologies or how they may be used. These third parties may use cookies, pixels, and other technologies to collect information about your online activities over time and across different websites and online services.
• Control Over Account Information: You can access, review, and update your personal data by logging into your Sprin account. If you wish to delete your account, please contact us at support@sprin.app. Note that we may retain certain information as required by law or for legitimate business purposes.
• Data Minimization and Storage: We only retain personal information as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations. Backup copies and archives may persist for a period before being deleted.
• Security of Your Information: Sprin employs technical and administrative measures to protect your information, but no system can be guaranteed to be 100% secure. You are responsible for maintaining the security of your login credentials.
Sprin is committed to honoring your rights and providing you with transparency and control over your personal data. For additional assistance or questions regarding your privacy rights, please contact our privacy team at support@sprin.app.

7. INFORMATIION ACCESS

You have the right to access, correct, or delete your personal data, subject to certain limitations. You may do so through the following methods:
• By logging into your Sprin account and accessing your account settings;
• By contacting us directly at support@sprin.app with your specific request.
Please note the following:
• We may ask for verification of your identity to protect your data;
• We may decline to process requests that are frivolous, unduly burdensome, jeopardize the privacy of others, or conflict with legal obligations;
• We may retain certain data where required by law or where necessary for legitimate business interests, such as fraud prevention or recordkeeping;
• Requests to delete account-related personal data will result in the deletion of your user account, and you will lose access to any purchased or stored data within the Services;
• We may provide partial access to data where full access would compromise security, privacy, or legal confidentiality obligations;
• We reserve the right to reject unverified requests or those submitted through unsecure channels.
If you believe that your privacy rights have been violated, you may file a complaint with the appropriate supervisory authority or contact us directly for resolution.
To ensure transparency and protect user trust, Sprin commits to responding to verifiable user requests within legally mandated timeframes, typically within 30 days. For complex or voluminous requests, we may extend the response period with notice.
If you have any questions about your rights or how to exercise them, please contact our Privacy Team at support@sprin.app.

8. DO NOT TRACK SIGNALS

Sprin may use automated data collection technologies, such as cookies, beacons, tags, and scripts, to analyze trends, administer the Site, track users’ movements around the Site and App, and gather demographic information about our user base. These technologies may also be used to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
Currently, we do not respond to web browser "do not track" (DNT) signals or other similar mechanisms. Some browsers offer users the ability to activate DNT settings, which send signals to websites and online services that a user does not want their activity tracked. However, because there is no industry standard for recognizing and responding to DNT signals, we do not alter our data collection and use practices when we detect such signals.
If we develop a standardized response to DNT signals in the future, we will update this Privacy Policy accordingly. Users concerned about tracking technologies may manage cookie preferences directly through their browser settings or use browser plugins to block tracking scripts.
For more information about your choices regarding these technologies, see Section 6 "Your Privacy Choices." You acknowledge and agree that by using the Services without blocking or disabling cookies or other tracking technologies, you consent to their use by Sprin.
Sprin is not responsible for third-party website responses to DNT signals. We encourage you to review the privacy policies of each website you visit to understand their data practices.

9. DATA SECURITY

Sprin takes the protection of your personal data seriously and employs a multi-layered approach to security that includes administrative, physical, and technical safeguards. These measures are designed to secure your personal information from accidental loss and from unauthorized access, use, disclosure, alteration, or destruction.
We implement industry-standard encryption (such as HTTPS/TLS) to protect data transmitted between your device and our servers. We also use secure cloud infrastructure, conduct regular security audits, monitor our systems for vulnerabilities, and limit access to your data to only those personnel who have a legitimate business need.

User Responsibilities:

You are responsible for maintaining the confidentiality of your account credentials, including your password. Do not share your password or account access with others. Sprin will never request your password via email, phone call, or unsolicited message. If you suspect that your account has been compromised, you must notify us immediately at support@sprin.app.

Data Breaches:

In the event of a security breach that affects your personal data, we will take prompt steps to investigate and mitigate the issue. Where required by applicable law, we will notify you and relevant regulatory authorities without undue delay. Notifications may include information about what happened, what information was involved, what we are doing about it, and what you can do to protect yourself.

Third-Party Risks and External Factors:

While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. Data transmission over the internet and mobile networks is not completely secure. Sprin is not liable for breaches caused by external events beyond our reasonable control, including but not limited to, denial-of-service attacks, acts of third parties, or the failure of third-party providers.

No Guarantee of Data Erasure:

Please note that no method of electronic storage is 100% secure or error-free, and despite our best efforts, we cannot guarantee that your data will never be accessed, disclosed, altered, or destroyed by a breach of our safeguards. While we offer the ability to delete or deactivate your account, residual copies of your data may remain in our backup systems for a limited time where legally permissible.

Security of Health Data:

Given the sensitive nature of health and fitness data, Sprin applies additional measures when handling health-related personal information. Health data is encrypted at rest and in transit, and access is strictly controlled. However, you acknowledge that sharing sensitive health information via mobile apps involves inherent risks and agree to use the Services with discretion.

10. CALIFORNIA PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and California Civil Code Section 1798.83 (the “Shine the Light” law), including certain rights related to the disclosure, access, correction, and deletion of your personal data.
Under the Shine the Light law, California residents may request, once per calendar year, information regarding the disclosure of their personal data by Sprin to third parties for those third parties’ direct marketing purposes. If applicable, this information will include a list of the categories of personal information disclosed and the names and addresses of those third parties. This right only applies to personal data collected and shared for direct marketing purposes and does not apply to all information sharing.
To make a request under California Civil Code Section 1798.83, please send an email to support@sprin.app with "California Privacy Rights" in the subject line and include your name, email address, and mailing address.

Your Rights under the CCPA/CPRA May Include the Right To:

• Know what categories and specific pieces of personal data we collect, use, disclose, and sell (if applicable);
• Request access to your personal data;
• Request correction of inaccurate personal information;
• Request deletion of your personal data, subject to certain exceptions;
• Opt out of the sale or sharing of personal data (if applicable);
• Limit the use and disclosure of sensitive personal data;
• Not receive discriminatory treatment for exercising any of your CCPA rights.

Verification and Authorized Agent:

To help protect your privacy and maintain security, we will take reasonable steps to verify your identity before responding to your requests. If you authorize an agent to make a request on your behalf, we may require proof of authorization and still ask for verification of your identity.

Data Sales and Sharing:

Sprin does not sell personal data for monetary consideration. We may share personal data with third-party service providers for business purposes as described in this Privacy Policy. California residents may still request to opt out of such sharing practices by contacting us.

Exercising Your Rights:

To exercise any of your California privacy rights or to request more information, you may contact us at:
• Email: support@sprin.app
Sprin reserves the right to deny or limit requests if we are unable to verify your identity or if an exception under applicable law applies.

11. CHANGES TO THIS POLICY

Sprin reserves the right to revise or update this Privacy Policy at any time, in its sole discretion, to reflect changes in our practices, technologies, legal requirements, or for any other reason. Any changes will become effective immediately upon being posted on our Site or App, unless otherwise noted. Your continued use of the Services after such modifications constitutes your acceptance of the updated Privacy Policy.
We will take reasonable steps to notify users of material changes to this Privacy Policy. Such notification may occur through email, an in-app alert, or prominent notice on our website and mobile application. However, it is your responsibility to review this Privacy Policy periodically to stay informed of any updates. The “Last Updated” date at the top of this policy reflects the most recent changes.
If you do not agree to the revised terms of this Privacy Policy, you must discontinue use of the Services immediately and may request deletion of your account and data in accordance with applicable laws and our data retention policies.
Sprin is not responsible for any losses or damages that may arise from your failure to review or become aware of changes to this Privacy Policy. You agree to regularly check this Privacy Policy to remain informed of any updates, and you acknowledge that your use of the Services after any updates indicates your full understanding and agreement with the revised terms.
For any significant changes requiring your explicit consent under applicable data protection laws, we may request your affirmative acceptance before such changes apply to your data.
If you have any questions about this Privacy Policy or any updates, you may contact us at support@sprin.app or by using the contact information listed in the final section of this Privacy Policy.

12. CONTACT INFORMATION

If you have any questions, concerns, complaints, or suggestions regarding this Privacy Policy or any other aspect of Sprin’s data practices, you may contact us via email.
Email: support@sprin.app
We aim to respond to inquiries in a timely manner and are committed to addressing your concerns in accordance with applicable privacy and data protection laws.