SpyNinjas.net Privacy Policy

Updated: August 10, 2021

Preamble

This Privacy Policy explains how Qlay Co. and Davchy IP Holdings, LLC, with offices located at P.O. Box 81274, Las Vegas, NV 89180, and their affiliates (collectively “ Spy Ninjas”, “we”, “our”, or “us”) collect, use, and share information from or about you when you use SpyNinjas.net (“Website”).

Spy Ninjas respects the privacy of our visitors and we are committed to maintaining the privacy of their personal information. This privacy policy describes how we may collect and use personal information, you provide on the Website. It also describes the rights and choices available to you regarding our use of your personal information.

We strongly urge you read this policy and make sure you fully understand and agree with it, before you access or use the Website. If you do not read, fully understand and agree to this Privacy Policy, you must immediately leave the Website and avoid or discontinue all use of the Website.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. BY USING THE SERVICES, YOU ACKNOWLEDGE YOU HAVE READ AND UNDERSTAND THE PRIVACY POLICY AND THAT WE WILL COLLECT, USE AND SHARE YOUR INFORMATION AS SET FORTH BELOW.

CONSENT

This Privacy Policy describes how we may collect and use information pertaining to visitors of the Website (each, a “Visitor” or “you”), in connection with their access to and use of the Website (including www.SpyNinjas.net and any of its subdomains, the “Website”).

Spy Ninjas takes your privacy seriously. We will not sell, lease, or exchange your personal data to, or otherwise share your personal data with, third parties in ways other than described in this Privacy Policy. This Privacy Policy only addresses activities from our servers. This Privacy Policy constitutes a binding and enforceable legal contract between Spy Ninjas and you. Please read it carefully.

You may use the website only if you fully agree to this Privacy Policy, and by accessing or using the Website, you signify and affirm your informed consent to this Privacy Policy, including to the collection and processing of your Personal Information as defined and explained below.

Types of Information We Collect and Uses

We do not collect any information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, address, email, and/or telephone number (“Personal Information”). In using the Website, we may collect information that does not directly or indirectly identify, and cannot reasonably be used to identify an individual Visitor (“Anonymous Information”). Anonymous Information may be used to create information about groups or categories of guest, which does not identify and cannot reasonably be used to identify an individual Visitor (“Aggregate Information”). More specifically, we collect the following information:

Server Logs
When accessing web pages on the Website, we may log your IP address, access URL, time of access, geographic location, browser type, and referral URL in order to provide us with internal information regarding site traffic statistics. This information is used in the aggregate, and is never linked back to any Personal Information.

Social Media
The Website also includes social media features, such as the Facebook button. These features may collect your IP address, which page you are visiting on Our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing such features.

How We Collect Your Information

We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, and Web beacons when you visit the Website.

Cookies
We and our partners, affiliates, or analytic or service providers use technologies such as cookies, beacons, tags, and scripts to analyze trends, administer the Website, and tracking users’ movements around the Website. We may receive reports based on the use of these technologies by these companies on an aggregated basis.

We use cookies for authentication, tracking user sessions, preferences, and movements around the website, anonymous and aggregated marketing analytics, performance analytics, retargeting, and tracking aggregate trends. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Website, but your ability to use some features or pages of the Website may be limited.

Behavioral Targeting
We partner with third parties to either display advertising on our Website or to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. Below are a list of specific third party targeting services we use:

Google Analytics
We use the Google Analytics service from Google, LLC (1600 Amphitheatre Parkway, Mountain View, CA, 94043; “Google”) to analyze our Website visitors. Google uses cookies. The information generated by the cookie about the use of the online product or service by users is generally transferred to a Google server in the USA and stored there. Google will use this information on our behalf to evaluate the use of our Website by users, to compile reports on the activities within the Website and to provide us with further services associated with the use of the Website and the use of the internet. Pseudonymous user profiles can be created from the processed data. We use Google Analytics only with IP anonymization enabled. The IP address transmitted by the user’s browser is not merged with other Google data and will remain Anonymous Information. For more information about Google’s use of data for analytics purposes, please see the summary page: https://support.google.com/analytics/answer/6004245, Google’s privacy policy is available at https://policies.google.com/privacy. Users can prevent cookies from being stored by adjusting the settings to their browser software accordingly. You may be able to opt out of this service by visiting the Google Analytics Opt-out Browser Add-on Here.

Google Ads
On our Website we use the marketing and remarketing services of Google. These services allow us to display advertisements in a more targeted manner in order to present advertisements of interest to users. Through remarketing ads and products are displayed to users relating to an interest established by activity on other websites within the Google network. For these purposes, a code is used by Google when our website is accessed and what are referred to as (re)marketing tags are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies may also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which apps or websites users have visited, which content they are interested in and which offers have been used. In addition, technical information about the browser and operating system, referring websites, the length of the visit as well as any additional data about the use of the online products and services are stored. The IP address of users is also recorded. All user data will only be processed as Anonymous Information. Google does not store any names or e-mail addresses. All displayed ads are therefore not displayed specifically for a person, but for the owner of the cookie. This information is collected by Google and transmitted to and stored by servers in the USA. One of the Google marketing services we use is the online advertising program Google AdWords. In the case of Google AdWords, each AdWords customer receives a different conversion cookie. Cookies can therefore not be tracked through the websites of AdWords customers. The information collected by the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they will not receive any information that personally identifies users. We may include third-party advertisements based on the Google Marketing Service called DoubleClick. DoubleClick uses cookies to enable Google and its partner websites to place ads based on users’ visits to this website or other websites on the Internet. Google services make use of Google’s Tag Manager. For more information about Google’s use of data for marketing purposes, please see the summary page: https://www.google.com/policies/technologies/ads, Google’s privacy policy is available at https://policies.google.com/privacy. If you wish to object to interest-based advertising by Google marketing services, you can do so using the settings and opt-out options provided by Google Here.

Facebook Pixel
We use Facebook and their partner networks, such as Instagram, to market ourselves using the Facebook pixel by Facebook, Inc. , Inc. (1 Hacker Way, Menlo Park, CA 94025; “Facebook”) that collects data about behaviour on our Website and to measure the effect of our advertising. This tracking is used to evaluate and measure how different campaigns and marketing strategies perform on Facebook & Instagram. By sharing this data with Facebook, we can, for example, offer personalized advertising content and adjust the frequency of advertising you see from us. Facebook stores the data we send to them for up to 2 years depending on the type of data in question. You can find Facebooks privacy policy at https://www.facebook.com/about/privacy.

TikTok Pixel
We use TikTok to market ourselves using the TikTok pixel created by TikTok, Inc. (Attn: TikTok Legal Department 10100 Venice Blvd, Suite 401, Culver City, CA 90232; ”TikTok”) that collects data about behavior on our website and to measure the effect of our advertising. This tracking is used to evaluate and measure how different campaigns and marketing strategies perform on TikTok. You can find TikToks privacy policy at https://www.tiktok.com/legal/privacy-policy.

When We Share Your Information

We may share Anonymous Information or Aggregated Information about our Visitors with our partners. This information does not identify individual users or contain Personal Information. This information contains statistics related to traffic and the geographic location of our customers. We also may share Aggregate Information with third parties who help us to analyze our user base to improve the Service.

Legal Basis for Use of Your Information

The laws of some jurisdictions, such as the European Union the UK, or Brazil, require companies to tell you about the legal basis for using, sharing, or disclosing your information. To the extent those laws apply, we may rely on the following legal bases:

Legitimate interest: where use of your information is necessary for our, or others’, legitimate interests and where the use is not outweighed by your rights and interests. Below are some examples of such interests:

providing and operating the Website
improving our Website
recognizing and better understanding our users
marketing and promoting our content and Website
conducting compliance and risk management activities
providing and managing access to our Website

Legal obligation: where use of your information is necessary to comply with laws and regulations such as those relating to anti-bribery and corruption and anti-money-laundering, complying with requests from government bodies or courts, or responding to litigation.

Your Rights

Depending on where you live, you may have certain rights with respect to your information. You have the right not to be discriminated against (as provided for in applicable law) for exercising your rights under some local laws such as in California.

For example, under local laws, including in the European Union, you may be able to ask us to:

provide access to certain information we hold about you, in some cases in a portable format, if technically feasible;
update or correct your information;
delete certain information;
restrict the use of your information

We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations.

We will take reasonable steps to verify your identity. We may require further documentation before granting access to your information.

If you would like to exercise any individual right you may have please contact us at privacy@spyninjas.net. Please include “My Rights” in the subject line and provide a clear explanation of which right you are exercising and your country of residence in the body of the email.

Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

If you have any unresolved concerns, you may have the right to complain to your local data protection authority.

“Do Not Sell My Personal Information” (California Residents only)
California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include allowing third parties to receive certain information such as cookies, IP address, device identifiers or other hashed identifiers, interests, browsing behavior and/or other activity to add to a profile about your device, browser, or you. This profile enables marketing to you and delivery of interest-based advertising on the Website. Advertising, including interest-based advertising, enables us to provide relevant offers to you.

Depending on what Services you use, we may share the following categories of information for such purposes which may be considered a sale (as defined by California law):

device information and identifiers, such as IP address, and unique advertising identifiers and cookies; connection and usage information, such as browsing history or app usage; geolocation information, such as city; and inference data.

If you or your authorized agent would like to opt out of Spy Ninjas’ use of your information for such purposes (to the extent this is considered a sale), you may do so by emailing us at privacy@spyninjas.net.

Third Parties’ List – Shine the Light (California Residents only)
California residents can also request a list of all the third parties to which we have disclosed certain personal information (as defined by California’s Shine the Light law) during the preceding year for those third parties’ direct marketing purposes. California residents may contact us at P.O. Box 81274 Las Vegas, NV 89180. In the body of your request, you must include: “California Shine the Light Request”, your name, a current California address including, street address, city, state, and zip code, as well as sufficient information for us to determine if the law applies to you. You will need to attest to the fact that you are a California resident. We will not accept requests by telephone, email, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Nevada Residents
We do not engage in the following activity, however Nevada law requires us to post the following: certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

If you are a Nevada resident who has purchased goods or services from Spy Ninjas, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at P.O. Box 81274
Las Vegas, NV 89180. Please use “Nevada Do Not Sell” in the subject line. Note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

UK & EU Residents’ Rights
When you visit the Website, your data is controlled by Qlay Co., P.O. Box 81274, Las Vegas, NV 89180.

Your personal data is primarily used to maintain the functionality of the Website. It may also be used to comply with legal obligations we are subject to or to fulfill our legitimate interests, such as to personalize your experience, develop and improve our services or to detect illegal activities. Please review this Privacy Policy to identify how your information is collected and used.

You have a number of rights including the right to request access to, change, or remove your personal data, or to change your marketing preferences (including withdrawing your consent at any time) – please see this Privacy Policy to learn more about managing your marketing preferences or deleting your information.

Our Data Protection Officer can be contacted by emailing P.O. Box 81274
Las Vegas, NV 89180.

You have a right to lodge a complaint with your local Data Protection Supervisory Authority or with the UK Information Commissioner’s Office: https://ico.org.uk/for-the-public.

Brazilian Residents’ Rights
When you visit the Website, your data is controlled by Qlay Co., P.O. Box 81274, Las Vegas, NV 89180.

You have a number of rights set forth in Brazil’s data protection legislation including but not limited to the right to confirm the existence of the processing of your personal data, request access to, change, or remove your personal data, or to change your marketing preferences (including withdrawing your consent at any time) – please see this Privacy Policy to learn more about managing your marketing preferences or deleting your information.

Our Data Protection Officer can be contacted by emailing P.O. Box 81274
Las Vegas, NV 89180.

Children’s Privacy

Information about the practices of Spy Ninjas and the Website directed to children under the age of 13 in the United States or 16 in the European Union or where we have actual knowledge a child is under such ages can be found in this Section. If you are a parent or guardian and believe your child under 13 in the United States or under 16 in the European Union has provided us with personal information without consent, please contact us at P.O. Box 81274 Las Vegas, NV 89180.

This section outlines Spy Ninjas’ information practices in the United States with respect to personal information (as defined by the Children’s Online Privacy Act (“COPPA”)) collected online from services directed to children under the age of 13 or from children who we have actual knowledge are under the age of 13 (“child” or “children”). For more information about COPPA see FTC – Children’s Privacy.

Please see the other sections of this Privacy Policy for our information practices regarding online services (or portions of such services) that are directed to parents, users over the age of 13, or general audiences.

If we knowingly collect personal information on a child-directed service or from a user we have actual knowledge is a child, we will retain that information only so long as reasonably necessary to 1) fulfill the request or allow the child to participate in the activity, 2) ensure the security of our Visitors and our Website, and/or 3) as required by law. If we learn we have collected personal information from a child in a manner inconsistent with COPPA’s requirements, we will either delete that personal information or seek parental consent.

Collection and Use of Personal Information from Children
If the Website seeks to collect personal information from a child that is not subject to an exception under COPPA, we will first ask for a parent or guardian’s consent to that collection as required by law.

Our Website directed to children may collect the following information from children for the following purposes:

Persistent Identifiers: Our Website may automatically collect persistent identifiers for internal operations, including to provide and improve our Website, conduct analytics, personalize content, maintain the security and integrity of the Website, and to ensure legal or regulatory compliance. Specifically, we may collect Internet protocol or IP address, pages and content visited, the type and version of operating system or web browser, device ID. We, or our third party service providers, may collect this information using HTTP cookies, flash cookies, HTML5 and Flash local storage, web beacons/GIFs, embedded scripts, and ETags/cache browsers (“Cookies”). For further discussion of third party service providers and Cookies, please see this Privacy Policy.

Disclosure of Personal Information from Children
We may share or disclose personal information collected from children in the following circumstances:

With our service providers in order for them to perform service on our behalf;
As permitted or required by law, including in response to a court order or a subpoena.
To protect the safety of a child, to prevent a crime, or to facilitate a public safety investigation;
To take precautions against liability; or
To protect the security or integrity of our Website.

Parental Controls
Parents or guardians may contact P.O. Box 81274 Las Vegas, NV 89180 to review personal information provided by their child, have such information deleted, and/or refuse to allow further collection or use of such information. You may send mail inquiries to: Qlay Co., P.O. Box 81274, Las Vegas, NV 89180.

How We Protect Your Information

We maintain organizational, technical, and physical safeguards to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use. Despite all reasonable practices, no security method is infallible. Therefore, we cannot, and do not, guarantee the absolute security of your information, and your transmission of data and provision of information is done so at your own risk.

Our affiliates and service providers that store or process your information on our behalf are each committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

How Long We Keep Your Information

We will keep your information only for as long as it is necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention is required or permitted by law. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law.

Updates To Our Privacy Policy

We reserve the right to amend this Privacy Policy at any time to reflect changes to our practices or the law. We will make the revised Privacy Policy accessible through the Website. Please check the Website periodically for updates.

The date at the top of the Privacy Policy tells you when it was last updated. If we make material changes to the way we collect or use your information, you will be provided with appropriate notice, including by, but not limited to, posting the updated Privacy Policy on the Website, and providing notice in accordance with legal requirements. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted. By continuing to use the Website following any changes to this Privacy Policy, you acknowledge you have read and understand the updated Privacy Policy, and you understand that we will collect, use, and share information as stated therein.

Contact Us

If you have any questions or complaints about this Privacy Policy, please contact Us at privacy@spyninjas.net. You may also contact us by mail at: Qlay Co., P.O. Box 81274, Las Vegas, NV 89180.