The Spice Network  Privacy Policy

Welcome to The Spice Network. (“Spice”, “we”, “us” and/or “our”). 
Our mobile application (“App”) helps users (“Users,” “you,” or “your”) take back 
control of your time by giving you tools to set boundaries with technology so you 
can connect more deeply with yourself and others. Our website (“Site”) also allows 
you to easily access and use content, including features, resources and other 
information intended to help you change the way you live and work. Collectively, 
the services we provide through the Site and the App are defined as the 
“Service(s)”.

This Privacy Policy explains what personal data we collect through the App and the Site, how we use and share that data, and your choices concerning our data practices. This Privacy Policy forms part of our Terms and Conditions Agreement, which are available at https://www.thespicenetwork.com.

By providing us with your personal data when using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services.

This Privacy Policy also explains what personal data we collect from TSN’s enterprise customers (“Customers”) and how we use and share that data. Where we provide the Services under contract with our Customers, that Customer controls the personal data submitted to the Services. In this Privacy Policy, we refer to the data we process on behalf of Customers as “Service Data”.

Our use of Service Data is governed by our contract with the specific Customer and the Customer’s own privacy policies. We are not responsible for the privacy policies or privacy practices of Customers or other third parties. For more information, please see the Service Data section below.

TSN complies with the EU-U.S. and Swiss-U.S. Privacy Shield frameworks (“Frameworks”) as set forth by the U.S. Department of Commerce regarding the processing of personal data transferred from the EU and Switzerland to the U.S. (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway).

TSN has certified that it adheres to the Privacy Shield Principles (described below). If there is any conflict between the policies in this Privacy Policy and the EU or Swiss Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Frameworks and to view our certification page, please visit https://www.privacyshield.gov/.

INFORMATION WE COLLECT

When you interact with our Site, we collect information that alone or in combination with other information, could be used to identify you (“Personal Data”), described below.

Site Users
Personal Data You Provide Us. We collect information that visitors to the Site enter when you sign up on the Site (e.g., email and password) or send to us electronically, for example when completing any “free text” boxes in our forms (such as on our “Contact Us” page, support request or survey submission), requesting information, registering for an event, or subscribing to mailing lists.

While the type of data we collect depends on the nature of the inquiry, it typically includes name and contact details, company information, and phone number.

Automatically Collected Data. We automatically collect certain information relating to your use of our Site, described under the Automatically Collected Data section below.

Automatically Collected Data
When you use the Site or the App, the following information is created and automatically logged in our systems:

Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site, or that the App automatically sends when you use the Services. Log data includes your IP address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Services.

Cookies: Information from cookies and other technologies.

Please see the “Cookies” section below to learn more about how we use cookies and other technologies.

Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.

Usage Information: Information about how you use our Site and the App, such as the types of content that you view or engage with, the features you use, the actions you take, the other Users you interact with and the time, frequency and duration of your activities.

HOW WE USE INFORMATION
We use your Personal Data collected for the following purposes:

To authenticate Users and provide the Services. This processing is necessary to perform the contract with you.

As necessary for certain legitimate business interests, which include the following:

To respond to your inquiries and fulfil your requests for products and services;
To customize our Services for you.

For example, we use information on your use of Services features, including information that we obtain through cookies and other technologies, to better understand your needs and interests in order to personalize your experience with our Services by presenting content or functionalities tailored to your interests;

To send administrative information to you, for example, information regarding the Site or the App, and changes to our terms, conditions, and policies;

To provide, maintain and improve the content and functionality of the Services. For example, we regularly fix bugs or user experience issues that may be tied to particular user accounts. We use cookies and other technologies to analyze how Users interact with our Services. And that analysis can help us build better Services;

To conduct research, and provide aggregate and anonymized information on your use of our App to third parties (such as device manufacturers);

If you ask us to delete your data and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing;

To prevent fraud or criminal activity, misuse of our products or services, and ensure the security of our IT systems, architecture and networks; and

To (a) comply with legal obligations and legal process; (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our Terms and Conditions Agreement; (d) protect our operations or those of any of our affiliates; (e) protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain, as required or permitted by the law.

For individuals in the European Union (“EU”) and Switzerland, please see the “European Union (EU) Users” section below for information on what we mean by legitimate interests and your rights.

Marketing. We may contact you to tell you about content, services or products we believe will be of interest to you. If we do, where required by law, for example, if you are a User in the EU, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you or by updating your user settings. In addition, if at any time you do not wish to receive future marketing communications, please contact us at legal@thriveglobal.com. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.

SHARING AND DISCLOSURE OF INFORMATION
We may share or disclose your information at your direction, such as when you authorize a third-party service to access your account or when you voluntarily share information or content via the Services.

There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you unless required by the law, as set forth below:

Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions: providers of hosting, caching and other IT services, email communication and automation platforms, customer support services, analytics, marketing, advertising (for more details on the third parties that use cookies and other technologies through the Site and the App, please see the “Cookies” section below).

For example, we use Google Analytics to collect certain demographic data and to understand how our Site and the App are used, and Google Cloud, Heroku and Amazon Web Services for hosting. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.

Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.

Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of Users of the Site or the App, or the public, or (iv) protect against legal liability.

DATA RETENTION
We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.