European General Data Protection Regulation (GDPR): GDPR and Your Rights

European General Data Protection Regulation (GDPR): GDPR and Your Rights

If you are located in the European Union (“EU”), including those that fall under the scope of the European General Data Protection Regulation (which is sometimes referred to as the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

  •   Request access to your personal data

  •   Request correction or deletion of your personal data

  •   Object to our use and processing of your personal data

  •   Request that we limit, or cease, our use and processing of your personal data

  •   Request portability of your personal data.

  • EU individuals also have the right to make a complaint to a government supervisory authority.

    While we have summarized the rights that you may have under data protection law, some of the rights are complex, and not all of the details have been included in this summary. Accordingly, you should read the relevant laws and guidance from the regulatory authorities in your jurisdiction for a full explanation of your rights.

    We do want to note for that Spearmint Ventures, LLC (“Spearmint”) processes personal information of individuals in the EU as identified below:

    Collection and Disclosure

    During the previous twelve months, we may have:
    A. Collected the following categories of personal information about you, whether via the website (“Site”) or direct customer interaction:

    •   Identifiers. By way of example, a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

    •   Identifiers (Online). By way of example, cookies, pixel tags, beacons, and similar technology, a device identifier, other forms of persistent or probabilistic identifiers and Internet Protocol address.

    •   Personal Information. By way of example, a name, signature, Social Security number, physical characteristics or description, address, telephone number,

passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

  •   Commercial Information. By way of example, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  •   Internet or other similar network activity. By way of example, browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

  •   Geolocation data. By way of example, physical location or movements reported by your device.

  •   Profile Inferences. By way of example, inferences from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

B. Collected personal information about you for the following business or commercial purposes:

  •   To audit related to a current interaction with you and concurrent transactions (such as counting ad impressions and verifying position and quality of ad impressions)

  •   To provide products and perform services you have purchased from or contracted from us such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing or assist with providing financing, providing advertising or marketing services, providing analytic services, or providing similar services

  •   To detect security incidents, fight spam, protect against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity

  •   To further develop and improve our Site and present its contents to you including, but not limited to, debugging errors that impair the Site’s functionality and personalize user experience

  •   To monitor and analyze trends and better understand how users interact with our content, which helps us improve our content, and other research

  •   To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention

  •   To permit short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

  •   To communicate with you from time to time in response to your requests for information or as may be relevant to your account with us

  •   To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections

  •   To comply with and enforce applicable legal requirements, relevant industry standards, and our policies

  •   To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred

  •   As described to you when collecting your personal information or as otherwise set forth in our Privacy Policy

C. Obtained the categories of personal information identified above from the following categories of sources:

  •   Directly from our customers, their agents, or other visitors to the Site from information they provide related to our products or services for which they engage Spearmint including through the Site or via telephone or written correspondence

  •   Directly from our customers or visitors to the Site through information we ask from them including through contact forms, e-mail marketing campaigns, and our social media features

  •   Directly and indirectly from our customers or visitors to the Site when using our products or services or visiting our Site such as usage details collected automatically in the course of their interaction with our platform or Site

  •   From third parties that interact with Spearmint in connection with the products or services we provide

D. Shared

your personal information with the following categories of third parties:

  •   Our vendors (e.g., our credit card processing company)

  •   Third parties to whom you or your agents authorized us to disclose our personal

    information in connection with the products and services Spearmint provides

  •   Third party advertising affiliates, to the extent that they collected such personal information

  •  Social media networks, to the extent that they collected such personal information

We do not sell personal information as the term is traditionally understood. For instance, we do not exchange for money personal information to data brokers or third parties for their marketing purposes independent of us. We have, however, provided our vendors with the following categories of personal information:

  •   Identifiers (online) associated with a device used to interact with our digital properties or advertisements (such as a device identifier, cookies, beacons, pixel tags, mobile ad identifiers and similar technology)

  •   Internet and other electronic network activity information associated with a device used to interact with our digital properties or advertisements

    Relatedly, we have disclosed for a business purpose the following categories of personal information about you:

  •   Identifiers

  •   Identifiers (Online)

  •   Personal Information

  •   Commercial Information

  •   Internet and Other Electronic Network Activity Information

  •   Geolocation Data

  •   Profile Inferences

    We do not sell the personal information of consumers under the age of 16 if we have actual knowledge of the individual’s age.

    Except as otherwise indicated above, in the last 12 months, Spearmint has not sold any personal information.