, LLC, a Washington limited liability company
and the owner and operator of the website www.sphir.io (the
the social media platform accessed via the Website (the
including any content, functionality, and services offered on or through the Website or Platform (collectively, the
(the Website, Platform, and Services are collectively referred to herein as the
is entered into by and between you and Sphir, and governs the use, processing, and disclosure of your Personal Information (as
on or via the Technology. Sphir respects your privacy and as a part of Sphir’s mission to provide you effective social media services in accordance with applicable privacy laws and regulations, including without limitation California’s
Consumer Privacy Act
Ca. Civil Code sections 22575-22579) and the European Union’s
General Data Protection Regulation
Regulation (EU) 2016/679), Sphir hereby provides you this Policy to describe what information is collected, how it is secured and managed, and when and to whom it may be disclosed. Please take a few minutes to review this Policy.
You will not have consented to the handling of your Personal Information (as
as provided on or to the Technology unless you provide affirmative consent to this Policy when initially accessing the Technology. If you do not consent to the terms and conditions of this Policy, you should not use the Technology, and notify Sphir of your refusal to consent to this Policy pursuant to Section 13 of this Policy.
Through your use of the Technology, you may provide personally identifiable information to or via the Technology. Such information, referred to as Personal Information in this Policy, includes:
All Personal Information is encrypted and not viewable by Sphir unless you direct Sphir otherwise. The following items are known to Sphir (collectively,
Accessible Personal Information):
- Personal names;
- Phone numbers;
- physical addresses;
- E-Mail addresses;
- Age-related and demographic information;
- Personal identification numbers;
- Payment information (e.g. credit card numbers, bank account numbers, etc.);
- Job titles and positions;
- Device identification information;
- Geo-location data;
- Preferred language and country information;
- Communications sent via the Technology;
- Information on your interactions with the Technology, and other Technology users;
- Your Internet protocol addresses, Tech
Unless as expressly provided in this Section of the Policy, you, not Sphir, own and control how your Personal Information is managed and used. As such, Sphir cannot and does not sell your individual Personal Information to any third party, manipulate your information or newsfeeds on the Technology, or store any of your Personal Information in a manner in which Sphir can directly control.
- Platform account name you enter; and
- Platform account E-Mail address you use.
Personal Information Obligations.
You have an obligation to ensure that your Personal Information is accurate and reflects your personal characteristics. You may not impersonate any person or entity on or via the Technology.
Use of Accessible Personal Information.
Sphir may collect certain aspects of your Accessible Personal Information that you provide to the Technology for the following purposes:
To verify Technology accounts.
Encourage and Ensure Safe Interactions Between Technology Users:
Improve the safety and reliability of the Technology, including detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could hinder or harm Sphir, other Technology users, or the general public.
Resolve Disputes and Troubleshoot Problems:
Investigate or resolve any Technology-related dispute or problem;
To enforce this Policy or any other agreement associated with the Technology;
Customize, Measure, and Improve Technology User Experience:
Analytical and measuring purposes to understand how the Technology is used, through use of third-party analytics tools;
Interact with you directly concerning the Technology.
Fulfill Reporting and Legal Requirements:
When requested by applicable governmental authorities for reporting obligations and compliance requirements.
When you register a Website or Platform account, or otherwise utilize the Technology, Sphir may assign you a unique identifier and send such information to your computer or device hard drive in the form of a cookie, which is a very small bit of code. This code is uniquely yours. It is used to assist you in utilizing the Technology. If you do not wish to have any such cookies on your devices, you may turn them off at anytime bymodifying your device’s Internet browser settings. However, by disabling cookies on your device, you may be prohibited from fully utilizing the Technology.
Disclosure of Accessible Personal Information.
Currently, Sphir would only disclose your Accessible Personal Information to: (a) its officers subject to the terms of this Policy; and (b) to applicable government authorities pursuant to its obligations under applicable laws and regulations.
Security and Storage of Your Personal Information.
The security of your Personal Information is important to Sphir. Sphir will only keep your Accessible Personal Information for the purposes detailed in Section 4 of this Policy, as long as is required by law, or as is relevant for the purposes for which it is collected. Personal Information will be stored in the following formats and locations:
Sphir’s Amazon Web Services Account.
Sphir employs generally accepted industry standards to store and protect Personal Information. However, as the transmission of information over wireless and wired networks cannot be absolutely secure, even with advances in encryption and blockchain technology, Sphir does not warrant or guarantee that Personal Information will remain permanently secure despite measures to ensure such protection.
Third-Party Websites and Applications.
The Technology may contain links to third-party websites and applications that are not owned or controlled by Sphir. Sphir has no control over, and assumes no responsibility for, any share functionality, content, privacy policies, or practices of any third-party website or application. When using any such third-party website or application, you are subject to the terms and policies, including without limitation personal information security and storage policies, of such third-party website or application. By affirmatively consenting to this Policy, or by otherwise using the Technology, you expressly relieve Sphir from any and all liability arising from any share functionality or your use of any third-party website accessed from the Technology. Sphir encourages you to investigate and ask questions before you disclose your personally identifiable information to any third-party website, application, or service provider.
Sphir is committed to protecting the privacy of children who use the Technology. Sphir encourages parents and guardians to talk to their children about safe and responsible use of their information and content on the Internet. To ensure the Technology’ compliance with the
Children’s Online Privacy Protection Act
15 U.S.C. § 91 et seq.) and GDPR, neither the Website, Platform, nor any Service: (a) is made available to any person under 16 years of age; (b) publishes information or content from any person under 16 years of age; and (c) is targeted to any child under 16 years of age. Any person under 16 years of age who wishes to access or use the Technology must obtain their parent or guardian’s prior consent prior to any such use.
Privacy Disclosure Reporting.
Pursuant to the CCPA and GDPR, you may be entitled to request a report concerning the collection, use, and storage of your Personal Information
Privacy Disclosure Reporting.
Pursuant to the CCPA and GDPR, you may be entitled to request a report concerning the collection, use, and storage of your Personal Information (Privacy Report) that:
If you would like a copy of your Privacy Report, you may do so by contacting Sphir
(Attn: Privacy Rights Report Request)
pursuant to Section 13 of this Policy.
- (a) confirms whether your Personal Information has been processed, and if so, the purpose for such processing;
- (b) the categories and types of Personal Information collected and processed;
- (c) the providers and recipients of such Personal Information; and
- (d) the envisaged period for which your Personal Information will be stored, or, if not possible, the criteria used to determine that period.
User Modifications to Consent and Use of Personal Information.
Should you wish to remove your disclosure of Personal Information to the Technology, or Sphir’s use of your Accessible Personal Information as provided under this Policy, you may do so by: (a) notifying Sphir concerning your Accessible Personal Information via the contact information provided in Section 13 of this Policy titled
Attn: Personal Information Consent Modification;
and (b) updating your Platform account functionality to revoke the submission of other Personal Information to the Technology.
Right to be Forgotten.
Technology users also have the right to have their Personal Information erased from the Technology and Sphir’s systems. Should you wish to elect to have your Personal Information erased from any of such systems, you may do so by: (a) notifying Sphir concerning your Accessible Personal Information via the contact information provided in Section 13 of this Policy titled
Attn: Right to be Forgotten;
and (b) updating your Platform account functionality to revoke the submission of other Personal Information to the Technology
You have the right to obtain a portable version of all of your Personal Information submitted to the Technology by downloading a file of the same from your Platform account. Should you have any further questions about this process, you may contact Sphir titled
Attn: Data Prtability
pursuant to Section 13 of this Policy.
Reporting of Privacy Complaint.
Regardless of the encryption of your Personal Information on the Technology, as a part of Sphir’s efforts to ensure your Personal Information is kept as confidential as possible, and used, processed, and transferred only in accordance with this Policy, Sphir will reasonably attempt to notify you of any breach or unauthorized disclosure of your Personal Information to any third party. Conversely, should you become aware of any violation or breach of your Personal Information by Sphir or any other party, you may lodge a complaint to the following supervisory authorities:
Federal Trade Commission
How to File:
Via Phone or Online
EU Member State Data Protection Authority
Where you Reside (links to EU Member state data protection authorities can be found here
How to File:
Varies by EU Member State DPA — Please refer to your specific DPA here
Periodically, Sphir may update this Policy. Sphir may post notifications of updates to this Policy on or via the Technology, or via e-mail to you and other Technology users. Changes made to this Policy will take effect immediately. If you do not agree to changes to this Policy, you must discontinue your use of the Technology, and notify Sphir of the same pursuant to Section 13 of this Policy. Your access or use of the Technology after such Policy changes will not be permitted unless you provide affirmative consent to such Policy changes via the Technology.
If you have any questions regarding this Policy, please contact Sphir at:
1900 West Nickerson Street, Box 226
Seattle, Washington 98119