Privacy Policy
Last Updated: July 7, 2024
About this Privacy Policy and Our Commitment to Your Privacy
Sprye, Inc. (“Sprye,” “we,” ”us,” “our”) provides online products and services (collectively, the “Services”) through our mobile applications and Sprye.com (collectively, the “Site”) that may, among other things, provide you with tools to aid in your engagement in supportive care management for persons that require care assistance. We provide this privacy policy (“Privacy Policy”) to outline the information Sprye collects from users of the Site (“Users”,“you”), Sprye Partners (defined below) and how we may use and disclose this information when the Site is accessed through any device. It also describes the choices available to you regarding our use of your information and how you can manage and update this information. Some online services offered by or affiliated with Sprye may be governed by separate privacy policies. We suggest you review each of the privacy policies for the services you wish to receive.
Third-Party Advertising on Our Site
We do not allow third parties to directly advertise to Users on our Site, however information collected on the Site may be used for referrals for third party services.
How to Contact Us
Please read this Privacy Policy carefully. If you have questions or complaints regarding our Privacy Policy or privacy practices, please contact us at: Attn: Chief Privacy Officer, Sprye, LLC, 15559 Union Ave #5046 Los Gatos CA 95032 or info@isprye.com.
Information Addressed by this Privacy Policy
We want you to have a clear understanding of the information addressed by this Privacy Policy. We will collect information (“Information”) about you, a recipient of services from Sprye (“Primary Client”) and the friends and family members of the Primary Client (“FFM”) in a variety of ways, including directly from you, through automatic means, or from third parties.
Personal Information and Privacy
When you use our Service, you may be creating and maintaining a personal, private area of the application (“Individual Site”) on behalf of yourself and/or one or more persons within your Sprye team (“Sprye Team”), or visiting and posting to an Individual Site created by someone else within your Sprye Team. By their very nature, these Individual Sites contain personal information about the Primary Client, FFM and other Users on the Sprye Team. Our goal is to balance our Users’ need to find each other and communicate information and support against our Users’ desire for privacy.
Site Access
The Individual Site is accessible “By Invitation Only.” Once established, every member of a Sprye Team, including the creators of Individual Site and all Users are responsible for maintaining the confidentiality of the Individual Site in accordance with the Primary Client’s wishes.
Information You Provide Directly to Sprye
When you use the Site, you may provide certain information directly to us.
● Contact data. When you choose to register a user account, you will be required to provide, among other things, your email address, name, and phone number.
● Profile data, such as the username and password that you may set to establish an account on the Services, date of birth, biographical details, profile photograph.
● Personal status. When you create a Sprye Account, we may collect identifying information about the Primary Client, the FFM, and any person working with the Primary Client and living situation of the Primary Client. We also collect information about how the Sprye Team members can support the Primary Client.
● Communications data based on our exchanges with you, including when you contact us through the Service.
● Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
● Medical history. When you use our services and you are a Primary Client, we may collect information regarding your past and present medical history (i.e., diagnosis, medical events, medications, etc.) in order for us to better understand the Primary Client’s current situation.
● Financial data. The Sprye Team may be exposed to certain financial information from the Primary Client and the FFM. We will not use this information, except in general ways to help tailor the services to the Primary Client’s needs.
● Insurance data. The Primary Client or FFM may expose the Sprye Team to certain information regarding a Primary Client’s insurance coverage and benefits. We will not use this information, except in general ways to help tailor the services to the Primary Client’s needs
● Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Information that is Automatically Collected
We and third parties may use automated means to collect information about you, your computer or other device that you used to access the Site, and your use of the Site, such as:
● Device data, such as your computer or mobile device’s operating system type and version, browser type, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier,.
● Online activity data, both mobile and website such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Some of the automatic collection described above is facilitated by cookies and similar technologies. For more information on how we use cookies, please see our Cookie Notice.
Information We Collect from Third Parties
Sprye enters into business relationships with business partners and companies that contract with third party service providers and/or Sprye (“Contractors”). Contractors make Sprye’s products and services available to Users of the Services. Sprye’s business partners are collectively referred to in this Privacy Policy as “Sprye Partners.” When you use the Services, we may collect information about you, directly or indirectly, from or through applicable Sprye Partners. We may also collect or be provided with Information from Contractors or other third parties.
Our Use of Information To Provide You with the Site and Services
Sprye, and Sprye Partners, may use and store your Information to perform activities associated with providing you with the Site and related services such as: (i) registering you to use the Site and otherwise logging you into the Site, including the authentication of your identity, where applicable, and otherwise enabling your access to the Site; (ii) resolving disputes and/or troubleshooting problems including logging into your account to troubleshoot problems or otherwise help you navigate the Site; (iii) verifying your compliance with your obligations in our Terms of Service or other Sprye policies; (iv) improving the quality of the Site, (v) fulfilling any request you make; (vi) communicating with you; (vii) connecting you with and providing you with information about services, providers of services, resources or programs to which you may have access; (viii) providing you with Site content, including, without limitation, generating recommendations (such as recommended Site activities or services), providing support services, and processing your preferences and requests; (ix) analyzing, customizing, and personalizing the Site, including through the delivery of tailored content and communications; (x) to facilitate communication between you, FFM and the Primary Client; and (xi) otherwise as directed by you or provided for herein. Except where prohibited by law, and only to the extent permitted by Sprye’s agreements with applicable Sprye Partners, we may also use your Information in connection with any other services we make available to you.
To Communicate with You and Your Friends (including Marketing)
If you choose to tell a friend about our Service or share an Individual Site through our Site, we will ask you for your friend’s name and email address or phone number. We will automatically send your friend a one-time email or text message inviting him or her to visit the Site. We retain this information to identify the User as part of the Sprye Team when they sign in. You represent that you will obtain the consent of your friend to allow us to send the email or text message inviting him or her to visit the Site.
Sprye, Sprye Partners, and any third-party vendors acting on Sprye’s behalf, may also use your Information to communicate with you (including, without limitation, via email and/or mobile push notifications) about the Site and/or our products and services (and related features and functionality) or those of any Sprye Partner that is providing services to you. Our communications to you will include, without limitation, contacting you by SMS text message or at the email address(es) that you use to register for our Site to communicate with you regarding the Site and actions that you take in connection with the Site.
To Conduct Research and Development
We may use your Information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.
To Create and Use of Combined Data, De-Identified Data, and Aggregated Data
As permitted by law and by Sprye’s agreements with applicable Sprye Partners, Sprye, and any third-party vendors acting on Sprye’s behalf, may aggregate and/or de-identify your Information, including any Personally Identifiable Information (“PII”) and/or combine your Information with other information maintained or available to Sprye and use or disclose such information as follows:
We may use aggregated or combined data to communicate with you about the Site and/or our products and services and disclose such aggregated or combined data to Sprye Partners in connection with providing the Site.
We may also create de-identified data sets and use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any business purpose, which may include, without limitation, improving our products and services, conducting analytics such as evaluating our Site and developing additional benefits, programs, and services, and disclosing to Sprye Partners for analytics purposes.
For Compliance and Protection
We may use your Information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations 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 or our 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.
Disclosure of Information
We may share your Information in the following circumstances:
· Disclosures to Service Providers and Sprye Partners
With the limited exceptions discussed in this Privacy Policy, we do not share or sell your Information with third parties, unless you tell us to. We provide necessary information for Partners to deliver services.
With Third Parties That Provide Requested Benefits: As stated above, we primarily share your information, including your Information, with third parties for the purpose of providing certain services that you request. Specifically, at your direction, we will submit your information to the appropriate third parties for purposes of filling your third-party service requests. For example, if you are interested in transportation services, we may share your information with third parties that work with Sprye to provide such transportation services. In some cases you may not qualify to receive a third party service available to others based on their terms and conditions or coverage area. The third party’s use of your Information will be governed by the third party’s own terms of service and privacy policy, not Sprye’s; Sprye does not have control over your information once it is submitted to a third party for receipt of services. While we work with reputable third-party service providers, we cannot represent how any of them will use your Information in connection with their services, and recommend that you review their terms of use and privacy policies before requesting their services.
To Perform Services on Our Behalf: We may hire vendor companies to provide limited services on our behalf, such as payment processing, sending postal and electronic mail, providing technical support, and to assist us in providing the products and services that you request from us. We provide those service providers with the information necessary to perform the requested service.
· Additional Disclosures with Your Consent
With your consent, we may share your Information with third parties or allow them to collect information from the Site in some ways not specifically described in this Privacy Policy.
· Safety, Security and Compliance with Law
Your Information and the contents of your communications through the Site may be disclosed to third parties as required by law, such as to comply with a subpoena or similar legal process, or when we reasonably believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, report improper or unlawful activity, or respond to a government request.
· Subsidiaries and Affiliated Companies
Except where prohibited by law or precluded by contract, we may share your Information with any subsidiaries or other affiliated companies under the control of, or under common control with, Sprye for the purposes set out in this Privacy Policy.
· Sale, Merger or Similar Transaction
We may share your Information in connection with any proposed or actual merger, reorganization, a sale of some or all our assets, a financing or acquisition of all or a portion of our business by another company, or to a receiver, trustee or successor in interest in bankruptcy, in which case such company may continue to process your Information as set forth in this Privacy Policy (except where prohibited by law) or otherwise with your consent.
Your Choices Regarding Our Communications with You
In accordance with applicable law, we will offer you the opportunity to opt out of certain communications, such as, for example, communications that deal with any of our products or services you are not using but that we think might be of interest to you. Where applicable, you can opt out by emailing us at info@isprye.com. However, even if you opt out of such communications, you may continue to receive other transactional, relationship, and/or administrative communications from or through Sprye that are important or related to your Sprye account or the products and services you are using (such as, for example, a notice that there has been a change in one of your services or a change to this Privacy Policy). Please also note that you, not Sprye, have control over certain settings for how communications such as emails and push notifications are displayed on your devices, and the settings you select will affect how Sprye’s communications are displayed.
We Do Not Control the Privacy Policies of Third Parties
Our Site may contain links that enable you to visit or use other third-party websites, resources or programs. However, we do not have control over the other websites, resources, or programs that you choose to visit, so this Privacy Policy does not apply to information collected or that you provide while visiting such other websites, resources, or programs. You should refer to the privacy policies, if any, applicable to the other websites, resources, or programs.
Data Security and Integrity
The security of your Information is important to us. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We also maintain procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.
Managing and Updating Information
To access, review, update and/or delete certain Information, you may contact us at info@iSprye.com, and you may update and/or delete certain Information by logging into the Site and updating your account. We will respond to your request within a reasonable and lawful timeframe under the circumstances of your request. Please remember, however, if we have already disclosed some of this Information to third parties, we cannot access that Information any longer and cannot force the deletion or modification of any such Information by the parties to whom we have made those disclosures. Additionally, if you modify certain Information on our Site that we received from a third party, we reserve the right, but are not obligated, to share the updated information back to that third party. As a result, you will need to provide updated information to those third parties if you want to be sure they have your updates.
Certain Information is necessary in order for us to provide the Site and our related Services; therefore, if you delete such necessary Information you will not be able to use the Site or receive our Services. If you wish to have your account deactivated, you may contact us at info@iSprye.com. After we receive your request, within a reasonable timeframe under the circumstances of your request, we will deactivate your account; provided, however, that: 1) Sprye (and our third-party vendors acting on our behalf), our Sprye Partners, and any other applicable third parties may continue to use and share for any purpose de-identified data and aggregated or combined data developed using your Information that has been de-identified and 2) Sprye may continue to use Information in your deactivated account for compliance with applicable laws and regulations. Also, please note that even though you may deactivate your account or request the deletion of your Information, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, develop the Services, or troubleshoot problems) to retain this information, in which case we will comply with your deletion request only after we have fulfilled such requirements. We may also keep a copy of your Information to protect our legal rights, such as in connection with your use of the Site or your agreement to our Terms of Service, as permitted or required by applicable law.
California Do-Not-Track Disclosure Requirements (for California Users)
We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes. However, we do not recognize or respond to browser initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions. Your California Privacy Rights (for California Users) California law permits customers of Sprye who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us:
Sprye, LLC
15559 Union Ave #5046
Los Gatos CA 95032
email: info@iSprye.com
We will provide a list of the categories of Information, if any, disclosed to third parties during the immediately preceding calendar year for third-party direct marketing purposes, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or postal address specified above. You should put “California Privacy Rights” in the subject line and in your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.
Children; Special California Notice
The Site and Services are not directed to children under the age of 18, and children under the age of 18 years of age are not eligible to use them. Protecting the privacy of children is very important to us. Through the Site and Services, we do not collect Information from people we actually know are under 18 years of age, and no part of the Site or Services is designed to attract people under 18 years of age. If we later learn that an individual has provided us with their information through the Site or Services and they are under 18 years of age, we will take steps to remove that User’s Information from our databases and to prevent the User from utilizing the Site or Services.
If you are a California resident under the age of 18 and are a registered User of our Site, you may request that we remove from our Site any content you post to our Site that can be accessed by any other User (whether registered or not). Please note that any content that is removed from our Site may still remain on our servers and in our systems. To request removal of content under this provision, please send an email to info@iSprye.com and provide us with a description of the content and the location of the content on our Site, and any other information we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Site by you.
Retention of Personal Data
Personal data will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Policy, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of our Site and Services. Information may persist in copies made for backup and business continuity purposes for additional time.
Modifications to this Privacy Policy
From time to time, we may update this Privacy Policy to reflect changes to our information security and privacy practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on the Site, and all changes will be effective upon such posting or upon any later date specified by us in writing. We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this Privacy Policy was last revised by referring to the “Effective Date” legend at the top of this Privacy Policy. By continuing to use the Site or any services following the effective date of any updated Privacy Policy, you are agreeing to be bound by the terms and conditions of such updated Privacy Policy.