PRIVACY POLICY

Last Updated March 2023

Spenga Holdings LLC and its partners and affiliates (“we” or “Spenga”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (the “Privacy Policy”).

WHAT DOES THIS PRIVACY POLICY APPLY TO?
This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website https://spenga.com/ (our “Website”), users of our mobile applications (the “App” or “Apps”), visitors to our Spenga studios (whether owned by Spenga or our franchisees), and our practices for collecting, using, maintaining, protecting, and disclosing that information. The Privacy Policy also applies to all services that we offer, including via e-mail or text message inquiry or other services that we offer through our Website (collectively, the “Services”).

This Privacy Policy applies to information that we collect:

• On this Website;
• In e-mail, text, and other electronic messages between you and this Website;
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser based interaction between you and this Website; and
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertisements include links to this Privacy Policy.

This Privacy Policy does not apply to any website, product, or service of any third-party companies, affiliates, advertisers, or service providers, even if the website links to (or is linked from) our Website

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates. Your use of our Website, Apps, or services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Privacy Policy.

WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
We collect information directly from you when you provide it to us. Additionally, we also collect information automatically as you navigate through our Website such as usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information We Collect About You and How We Collect It.

• Information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, IP address, device ID, or other personal information (“Personal Information”); and
• Information that is about you individually, but does not identify you, such as your web browser software and referring website, as well as demographic data including, but not limited to your country of residence, gender, age, and sign up location.

Information You Provide to Us. Some of the information that we collect on or through our Website provided by you may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our Services, posting material, or requesting further Services. We may also ask you for information when you enter a contest or other promotional offering sponsored by us, and when you report a problem with our Website;
• Records and copies of your correspondence (including e-mail addresses) if you contact Spenga;
• Your responses to surveys that we might ask you to complete for research purposes;
• Details of transactions you carry out through our Website and the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website;
• You search queries on the Website; and
• Certain areas of our Website, including our social media accounts contain information supplied by users and others. If you submit user content to our social media accounts, you acknowledge that the content will be publicly available. Please do not submit any information to the social media accounts, including personally identifiable information, that you do not want to make public. We are not responsible for comments, advice, reviews, information, or any other posting made by you, other users or third parties in these areas. We do not have the obligation, but we reserve the right, to review content posted in public areas, including comments to our social media pages, and to delete or edit them, for any reason, at any time.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. The technologies that we use or may use include cookies, flash cookies, and web beacons. These technologies are used to capture the following information:

• 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;
• Information about your computer and internet connection, including your IP address, operating system, and browser type; and
• If you are accessing a Service from a mobile device or through a mobile application, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience with our Services, when we work with a partner such as a third-party mobile ad platform. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings on our mobile device and/or through the settings in the applicable mobile application.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Contact us for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information that we collect automatically may only statistical data and does not include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized services, including by enabling us to:

• Estimate our audience size and usage patterns
• Store information about your preferences, allowing us to customize our Website according to your individual interests
• Speed up your searches
• Recognize you when you return to our Website.

We do not collect personal information automatically but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions for an advertisement or other targeted content, you should contact the responsible provider directly.

HOW DO WE USE YOUR INFORMATION?
We use Personal Information for the following general purposes: (i) to provide you with the services you request; (ii) to provide you with order confirmation and updates; (iii) to manage your account; (iv) to communicate with you in general; (v) to respond to your questions and comments; (vi) to measure interest in and improve our Services and our Website; (vii) to notify you about special offers and products or Services that may be of interest to you; (viii) to otherwise customize your experience with the Website; (ix) to solicit information from you, including through surveys; (x) to resolve disputes, collect fees, or troubleshoot problems; (xi) to prevent potentially prohibited or illegal activities; (xii) to enforce our Terms of Use; (xiii) to notify you about changes to our Website; (xiv) to provide you with notices about your membership, including expiration and renewal notices; and (xv) in any other way we may describe when you provide the information.

We may send you the Spenga Newsletter that contains information about your orders or special offers available through our Website. Please note that you will have the opportunity to choose not to receive these e-mail communications in any such e-mail we send. Please note that if you unsubscribe from our e-mail newsletters, we will continue to send you e-mails regarding your orders and administrative information.


CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
Spenga strives to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly.
• Promotional Offers from Spenga. If you do not wish to have your information used by Spenga to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to info@spenga.com. If Spenga has sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

WHO DO WE SHARE YOUR INFORMATION WITH?
Spenga and its affiliates will take reasonable precautions to protect your information. However, in order to operate the Website and deliver our services, we may occasionally need to share your Personal Information with the following parties:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Spenga’s assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Spenga about our Website users is among the assets transferred;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information; and
• With your consent.

We may also share your information in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights; to defend against legal claims; when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or this Website, our customers, or others; and as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us.

CHILDREN UNDER THE AGE OF 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any Personal Information to (or on) the Website. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@spenga.com.
California residents under 16 years of age may have additional rights regarding the collection and sale of their Personal Information. Please see Your California Privacy Rights for more information.

DOES SPENGA USE COOKIES?
Spenga may use “cookie” technology on our website. “Cookies” are small text files that a website can use to recognize repeat users, facilitate the user’s access to and use of the site and to track behavior of the web pages you visit, among other uses. Our Website may automatically collect cookies and other information, including, but not limited to, your domain name. Spenga may compile aggregate data for statistical purposes to improve the content of our Website or to better administer the web pages available on the Spenga Website.

When and if Spenga requests an e-mail address from you, you will be given the opportunity to indicate whether or not you wish to receive future e-mail solicitations from us. Regardless, from time to time, we may send you e-mails for other reasons, including, but not limited to responding to your inquiries to us.

HOW WE PROECT YOUR INFORMATION
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and other information will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy or security measures contained on the Website.

PRIVACY POLICY UPDATES
Due to the Internet’s rapidly evolving nature, Spenga may need to update this Privacy Policy from time to time. If so, Spenga will post its updated Privacy Policy on our Website located at https://spenga.com/ and we may send registered users an e-mail, so you are always aware of what personally identifiable information we may collect and how we may use this information. If any modification is unacceptable to you, you shall cease using this Website and our services. By using the services of our Website, you expressly consent to the use and disclosure of your information as described in this Privacy Policy. By using the Services of our Website, you expressly consent to the use and disclosure of your information as described in this Privacy Policy. If you do not cease using this Website and our services, you will be deemed to have accepted the change.

PRIVACY QUESTIONS
This Website is owned and operated by Spenga. This Privacy Policy is to provide you with and explain the Spenga policy regarding your Personal Information and the measures to be taken to protect and properly use it. If you have any questions about this Privacy Policy, please feel free to e-mail us at info@spenga.com or write us at:

Spenga Holdings LLC
Attn: Web Developer
13161 W 143rd Street, Suite 103
Homer Glen, Illinois 60491

If you would like to know what information Spenga retains specifically about you, or if you wish to have Spenga change your information because it is out of date or inaccurate, please contact us by e-mail at info@spenga.com. We will modify your record accordingly

YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. California Privacy laws require that we provide California residents information about how we use their personal information, whether collected online or offline, and this section is intended to satisfy that requirement.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that 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 send an e-mail to info@spenga.com or write us at:

Spenga Holdings LLC
Attn: Web Developer
13161 W 143rd Street, Suite 103
Homer Glen, Illinois 60491

Categories of Personal Information that We Collect, Disclose, and Sell
Below we identify the categories of personal information that we collect about California consumers and households, the purposes for which we use each category, and whether we disclose or sell information within each category.

Please note our data collection practices set forth below are not different than those described above; the California Consumer Privacy Act (“CCPA”) specifies particular information that we need to discuss in our Privacy Policy, and, in this section, we have reorganized

Spenga retains personal information for internal use in accordance with applicable law and for as long as it is needed to establish, exercise, or defend any legal claims.

Right to Opt-Out of Sale/Sharing. California residents have the right to opt-out of our “Sale” of their personal information. California defines the term “Sale” broadly, and includes, our selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating (collectively a “Sale”) California residents’ personal information to another business or third party for monetary or other valuable consideration. Please note that while some of our sharing of personal information may be a “Sale” as defined by CCPA, we do not sell personal information for monetary compensation. California residents may exercise their right to opt-out the Sale of their personal information by completing our CCPA rights request form at https://spenga.com/do-not-sell-my-information or by emailing us at webmaster@spenga.com.

Right to Opt-In. We do not sell or share personal information about residents who we know are younger than 16 years old.

Right to Limit Processing of Sensitive Information.  California residents have the right to request that we limit the processing of Sensitive Personal Information about you we have collected, subject to certain exemptions. “Sensitive Personal Information” includes:

• Government identifiers, such as Social Security Numbers and drivers’ license numbers.
• Account log-in information, including payment information in combination with any required security or access code, password, or credentials allowing access to an account.
• Precise geolocation information.
• Racial or ethnic origin, religious or philosophical beliefs, or union membership.
• Content of postal mail, email, and text messages, unless the business is the intended recipient of the subject communications.
• Genetic data.
• Biometric information that uniquely identifies a consumer or information concerning a consumer’s health, sex life, or sexual orientation. 

However, we may still process all or part of your Sensitive Personal Information as reasonably necessary to perform certain business services, including but not limited to:

• Complete the transaction for which the information was collected, provide a good/service requested by you (or reasonably anticipated within the context of an ongoing business relationship with you), or otherwise perform a contract with you.
• Maintain and service your account and verify your information.
• Process payments, provide financing, or provide similar services.
• Show non-personalized advertisements during your visit(s) to our website.
• Verify or maintain the quality or safety of our services or products and to improve, upgrade, or enhance the services or products.
• Detect security incidents or otherwise protect against malicious, deceptive, fraudulent, or illegal activity, up to and including pursuing prosecution of those responsible for the illegal activity.

Notice at Collection. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

Verifiable Requests to Delete, Requests to Correct, and Requests to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months:

Right to Deletion: California residents have the right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary for any of a list of exempt purposes, including but not limited to: completing a transaction requested by you, fulfilling the terms of a written warranty or product recall, detecting and protecting against security incidents, debugging information to identify and repair errors impacting functionality, exercising other rights provided for by law, complying with the California Electronic Communications Privacy Act, engaging in public or peer-reviewed research, complying with a legal obligation, or otherwise internally using your personal information in a lawful manner that is compatible with the context in which you provided the information.

Right to Correct Inaccurate Information: California residents have the right to request that we correct any inaccurate personal information about you that we have collected.

Right to Know – Right to a Copy: California residents have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.

Right to Know – Right to Information: California residents have the right to request that we provide them certain information about how we have handled their personal information, including the:

• Categories of personal information collected;
• Categories or sources of personal information;
• Business and/or commercial purposes for collecting or selling their personal information;
• Categories of third parties/with whom we have disclosed or shared their personal information;
• Categories of personal information we have disclosed or shared with a third party for a business purpose;
• Categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

Submitting Requests. Requests to exercise the Right to Deletion, Right to a Copy, and/or the Right to Information may be submitted by California residents on our CCPA rights request form at https://spenga.com/do-not-sell-my-information, as well as by emailing us at webmaster@spenga.com or calling us at 800-249-7621. We will respond to verifiable requests received from California consumers as required by law.

We require correct and accurate responses on the form to confirm your identity as the requester and to identify the types of data associated with you that we have retained in our records. Please provide correct and accurate identifying information in the required fields when completing this form. Supplying incorrect or falsified identification data in any of these fields may result in denial, delay, or erroneous processing of your request.

Right to Non-Discrimination, and Incentives. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information.

Discrimination: Businesses may not discriminate against residents who exercise their rights under CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices or rates or impose penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Disclosure of Incentives: If businesses offer any financial incentives for the collection, sale or deletion of California residents’ personal information, residents have the right to be notified of any financial incentives offers and their material terms, the right not be included in such offers without prior informed opt-in consent, and the right to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. We do not offer any financial incentives at this time.