1. Research Program

1.1 By participating in the Program, you agree to provide us with your Account Access Information so that we can access your Work Account(s) for the purpose of running compatibility tests with the Work Accounts to build, test, improve, and otherwise develop and administer software, products, or services that are interoperable with those Work Accounts (“Purpose”). After you provide your Account access information, we will attempt to determine whether we can use Account Access Information to access the Work Account(s) for which they were provided (each attempt, if successful, “Validate” or “Validation”).

1.2 If we are unable to Validate your Account Access Information, we may contact you (e.g., via email to confirm the Account Access Information provided and/or request accurate Account Access Information. You acknowledge and agree that participation in the Program does not grant you access to or use of any software, products, or services which may result from our research efforts.

2. Payment

2.1 As to each unique Work Account for which you provide us Account Access Information, after successful initial Validation by us of that Account Access Information, we will provide you with a one-time payment of at least US $100 and up to $500 (each a “One-time Payment”). We will determine the exact amount of the One-time Payment in our sole discretion. We will make the One-time Payment within 30 days of initial successful Validation of your Account Access Information.

2.2 In addition, we will provide you with a monthly payment of at least US $25 and up to $100 (each a “Monthly Payment”), for each month of your participation in the Program, provided that we can Validate your Account Access Information for that month. We will determine the exact amount of the Monthly Payment(s) in our sole discretion.Monthly Payments will be made on the 1st business day of each calendar month, beginning the month after your Account Access Information have been Validated.

2.3 All payments will be made to you via PayPal or other payment mechanism established when you enroll in the Program. In order to receive payment, you must have an account with PayPal or other payment mechanism and provide us with any information or permission reasonably requested by us in order to make payments hereunder. We are not obligated to make any payments to you if we cannot Validate your Account Access Information.

2.4 Further, we reserve the right to rescind any One-time Payment made to you if we cannot Validate your Account Access Information at any time during the first sixty (60) days of your participation in the Program, and we reserve the right to rescind any Monthly Payment made to you if we cannot Validate your Account Access Information within 48 hours of payment.

3. Eligibility

You must be at least 18 years old to participate in the Research Program. By agreeing to these Terms, you represent and warrant to us that: (a) you are at least 18 years old; (b) you have not previously been suspended or removed from the Research Program; and (c) your registration and participation in the Research Program is in compliance with any and all applicable laws and regulations.

4. Data

4.1 The information contained within your Work Account, excluding your Account Access Information, is referred to herein as your “Data.” By providing your Account Access Information, you hereby consent and authorize us to use your Account Access Information and Data for the Purpose described above. You acknowledge and agree that your Account Access Information or Data may be deemed to be personal information under certain jurisdictions. We use commercially reasonable efforts to secure your Account Access Information.

4.2 You warrant and represent that the Account Access Information are complete and accurate, and you agree to promptly inform us of any changes to the Account Access Information by emailing us at [email protected]. You further warrant and represent that (i) the Account Access Information and Data are yours and you have the right to provide the Account Access Information and Data to us for the purposes described in these Terms; (ii) your provision to us of the Account Access Information or Data does not violate any contractual or other obligation that you have to any third party.

4.3 You shall indemnify and defend, and hold harmless, us, our affiliates and each of our and their respective officers, directors, employees and agents, from and against any third party claim arising out of or relating to your breach of the foregoing warranties and representations.

5. Intellectual Property

5.1 We own all right, title and interest in and to any software, products, or services that we build, test, improve, or otherwise develop, in connection with the Research Program, including all improvements and modifications thereto and derivative works thereof, and intellectual property rights relating to the foregoing (collectively, the “Spindle Property”). Your participation in the Research Program does not confer upon you any right, title or interest in or to any of the Spindle Property.

5.2 Any ideas, suggestions, guidance or feedback provided by you to us relating to Spindle, any other Spindle Property, or the Research Program (collectively, “Feedback”) is owned by us. You hereby assign to us, and agree to assign to us, all of your right, title and interest in and to such Feedback. To the extent that the foregoing assignment is ineffective for whatever reason, you hereby grant to us an exclusive, perpetual, irrevocable, royalty-free, fully paid, worldwide license (with the right to grant and authorize sublicenses) to make, have made, use, import, offer for sale, sell, reproduce, distribute, modify, adapt, prepare derivative works of, display, perform and otherwise exploit such Feedback for any purpose without restriction and without compensation or attribution to you.

5.3 Any use of any trademarks and logos of any third parties in connection with the Research Program is only to factually identify or otherwise refer to those third parties. Except as otherwise expressly stated, Spindle is not affiliated with, sponsored by, or endorsed by any such third party. All rights in the trademarks and logos of such third parties remain solely and exclusively with their respective owners.

6. Disclaimers; Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW:

6.1 YOUR PARTICIPATION IN THE RESEARCH PROGRAM IS COMPLETELY VOLUNTARY AND SOLELY AT YOUR OWN RISK. WE MAKE NO, AND HEREBY DISCLAIM ANY AND ALL, WARRANTIES AND REPRESENTATIONS, EXPRESS, IMPLIED, OR OTHERWISE, REGARDING SPINDLE, THE RESEARCH PROGRAM, YOUR PARTICIPATION IN THE RESEARCH PROGRAM, OR ANY OTHER WEBSITE OR PROPERTY OWNED BY SPINDLE OR ITS AFFILIATES.

6.2 EXCEPT IN CONNECTION WITH OUR GROSS NEGLIGENCE OR WILLFUL MISCONDUCT, (I) IN NO EVENT SHALL WE BE LIABLE TO YOU OR ANY OTHER PARTY FOR ANY INCIDENTAL, INDIRECT, CONSEQUENTIAL, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES OF ANY KIND (INCLUDING, BUT NOT LIMITED TO, LOST REVENUES OR PROFITS) ARISING FROM OR RELATING TO THIS AGREEMENT OR THE PROGRAM REGARDLESS OF WHETHER SUCH PARTY WAS ADVISED, HAD OTHER REASON TO KNOW, OR IN FACT KNEW OF THE POSSIBILITY THEREOF; AND (II) OUR AGGREGATE LIABILITY FOR DIRECT DAMAGES UNDER THIS AGREEMENT WILL NOT EXCEED THE AMOUNTS PAID BY US TO YOU HEREUNDER DURING THE PERIOD SIX (6) MONTHS PRIOR TO THE EVENT GIVING RISE TO THE CLAIM.

7. Term; Termination

These Terms, and your participation in the Research Program, commence on the date that you first provide us with your Account Access Information and shall continue until terminated as set forth herein. Either party may terminate these Terms and your participation in the Research Program at any time upon written notice, which may be sent via email provided that (1) email notice, if being sent to us, must be sent to membersupport@spindleresearch.com, and (2) email notice, if being sent to you, must be sent to the email address provided upon registration or application for the Research Program. Upon termination of these Terms, (i) your participation in the Research Program will immediately cease, (ii) we will cease using your Account Access Information; (iii) we will have no obligation to make any future payment(s) to you; and (iv) all provisions of these terms relating to intellectual property, indemnity, disclaimers, limitations of liability, and all other provisions which by their nature should survive, will survive.

8. Governing Law

Subject to Section 14 with respect to EU and UK users, this Agreement and any action related thereto will be governed by the laws of the State of New York without regard to its conflict of laws provisions.

9. Binding Arbitration

Subject to Section 14 with respect to EU and UK users, in the event of a dispute arising under or relating to this Agreement or the Program (each, a “Dispute”), either Spindle or you may elect to finally and exclusively resolve the dispute by binding arbitration governed by the Federal Arbitration Act (“FAA”). Any election to arbitrate, at any time, shall be final and binding on the other party. IF EITHER PARTY CHOOSES ARBITRATION, NEITHER PARTY SHALL HAVE THE RIGHT TO LITIGATE SUCH CLAIM IN COURT OR TO HAVE A JURY TRIAL, EXCEPT EITHER PARTY MAY BRING ITS CLAIM IN ITS LOCAL SMALL CLAIMS COURT, IF PERMITTED BY THAT SMALL CLAIMS COURT RULES AND IF WITHIN SUCH COURT’S JURISDICTION. ARBITRATION IS DIFFERENT FROM COURT, AND DISCOVERY AND APPEAL RIGHTS MAY ALSO BE LIMITED IN ARBITRATION. All disputes will be resolved before a neutral arbitrator selected jointly by the parties, whose decision will be final, except for a limited right of appeal under the FAA. The arbitration shall be commenced and conducted by JAMS pursuant to its then current Comprehensive Arbitration Rules and Procedures and in accordance with the Expedited Procedures in those rules, or, where appropriate, pursuant to JAMS’ Streamlined Arbitration Rules and Procedures. All applicable JAMS’ rules and procedures are available at the JAMS website www.jamsadr.com. Each party will be responsible for paying any JAMS filing, administrative, and arbitrator fees in accordance with JAMS rules. Judgment on the arbitrator’s award may be entered in any court having jurisdiction. This Section 9 shall not preclude parties from seeking provisional remedies in aid of arbitration from a court of appropriate jurisdiction. The arbitration may be conducted in person, through the submission of documents, by phone, or online. If conducted in person, the arbitration shall take place in the United States county where you reside. The parties may litigate in court to compel arbitration, to stay a proceeding pending arbitration, or to confirm, modify, vacate, or enter judgment on the award entered by the arbitrator. The parties shall cooperate in good faith in the voluntary and informal exchange of all non-privileged documents and other information (including electronically stored information) relevant to the Dispute immediately after commencement of the arbitration. As set forth in Section 11 below, nothing in this Agreement will prevent us from seeking injunctive relief in any court of competent jurisdiction as necessary to protect our proprietary interests.

10. Class Action Waiver

Subject to Section 14 with respect to EU and UK users, you agree that any arbitration or proceeding shall be limited to the Dispute between us and you individually. To the full extent permitted by law, (i) no arbitration or proceeding shall be joined with any other; (ii) there is no right or authority for any Dispute to be arbitrated or resolved on a class action-basis or to utilize class action procedures; and (iii) there is no right or authority for any Dispute to be brought in a purported representative capacity on behalf of the general public or any other persons. YOU AGREE THAT YOU MAY BRING CLAIMS AGAINST US ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

11. Equitable Relief

You acknowledge and agree that in the event of a breach or threatened violation of our intellectual property rights and confidential and proprietary information by you, we will suffer irreparable harm and will therefore be entitled to injunctive relief to enforce this Agreement. We may, without waiving any other remedies under this Agreement, seek from any court having jurisdiction any interim, equitable, provisional, or injunctive relief that is necessary to protect our rights and property pending the outcome of the arbitration referenced above. Subject to Section 14 with respect to EU and UK users, you hereby irrevocably and unconditionally consent to the personal and subject matter jurisdiction of the federal and state courts in the State of New York, Borough of Manhattan for purposes of any such action by us.

12. Consent to Electronic Communications

By participating in the Research Program, you consent to receiving certain information, notices, and other communications, including via email and SMS messages, from us as further described in our Privacy Policy. Please read our Privacy Policy to learn more about our electronic communications practices. You agree that any notices, agreements, disclosures, or other communications that we send to you electronically will satisfy any legal communication requirements, including that those communications be in writing.

13. Contact Information

The Program is administered by Spindle Research LLC, a Delaware corporation with a registered address at 124 Broadkill Rd., #403, Milton, DE 19968. You may contact us by sending correspondence to that address or by emailing us at [email protected]. You can access a copy of these Terms by clicking here.

14. Terms for UK and EU Participants

The following terms apply to Participants who are UK or EU consumers. If you are a consumer in the EU or UK:

a. Sections 4.3, 8, 9, and 10 do not apply to you, and any Disputes between us and you (including contractual and non-contractual disputes) will be governed by English law. You and we submit to the jurisdiction of the courts of England and Wales, provided that if you are located in a jurisdiction within the EU, you may also bring a claim in the courts of your home country; and

b. You consent to the transfer of your Account Access Information and Data (though that Data remains in your Work Account) to the United States.

1. Research Programs

A. Research Program Information. When you sign-up to participate in a Research Program (as defined in the Participation Terms), we use Account Access Information you provide to us and your Data (each as defined in the Participation Terms) to conduct research with respect to the associated Work Account to understand and analyze the associated data structures and frameworks. The information Spindle’s research staff access using your Account Access Information varies depending on what information is available under the Work Account under that Account Access Information. However, that information generally includes:

Identity and Address Information: Your first and last name, personal and/or business phone number, street address, zip code, and email address, your date of birth, gender, marital status, picture, Social Security Number, and other government IDs, vehicle information, and other identifiers;

Career Information: Employer name and address, job title, employment type, employee ID, employment status, date of hire, termination date and reason, performance rating and achievements, hours worked (e.g., shift information), timestamps, work location, certifications, and licenses; and

Income and Financial Information: Compensation (including, as applicable, bonuses, commission, tips, and overtime), payout type and dates, currency, fees deductions, withholdings, reimbursements, balances, filing status, bank account and routing number, and credit card number and expiration date.

In addition, when you sign-up to participate in a Research Program, we also collect identity and contact information which generally includes your name, phone number, and email address.

B. How we use Research Program Information. 

Research Program-Related Usage: We use your Research Program Information to conduct the applicable Research Program and to communicate with you about that Research Program, including to understand and analyze  the data structure and framework of the applicable Work Account and in connection with quality assurance efforts with respect to those activities.

C. How we share Research Program Information. We share Research Program Information only in the following circumstances:

Service Providers: We share Research Program Information with third parties that provide services to us, such as customer support, providers of information technology and system security, integration services (including integration builds and related support),  and other organizations that provide similar services. We do not, however, authorize any such third parties to use or disclose your Research Program Information except as necessary to perform the activities described in Section 1.B. of this Privacy Notice or as required for such third parties’ compliance with legal requirements.

Legal Requirements; Affiliates and Successors:  We may disclose Research Program Information as required for compliance with legal requirements and to affiliates and successors as set forth in Section 2.D of this Privacy Notice.

We are not in the business of selling your Research Program Information, and we use and share it only as described in this Privacy Notice. We do not use or share your Research Program Information for any kind of marketing or advertising.

D. Retention and Deletion of Research Program Information. We retain Research Program Information for no longer than necessary to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required under applicable law.  At all times, Research Program Information will only be processed as required by law or in accordance with this Privacy Notice.

Spindle deletes your Research Program Information at the end of the applicable Research Program. We will also delete your Research Program Information if you end your participation in a Research Program, which, as described in the Participation Terms, you are free to do at any time. The exceptions to this may be if Spindle needs your information to help prevent fraud or protect privacy, investigate misuse and misconduct, or is required to maintain your information in order to comply with applicable law.

2. Spindle Website

A. Your Information. Separate from Research Program Information, we collect the following:

Information you provide to us:  We collect information you provide to us when you interact with the Services or otherwise communicate with us including contact information, such as your name, postal address, email address, and phone number, information shared with us in emails, messages or requests for support; and any other information about yourself that you choose to provide.

Information we collect automatically:  Like most online services, we and third parties automatically receive standard technical information when you connect with the Services. We collect this information through browser cookies, pixels, web server logs, web beacons, and similar technologies. These features enable us to personalize your experience with the Services, understand how you use them, maintain a persistent session, and improve and further develop the Services. Information we collect automatically includes or could include: browser and device information such as unique device identifiers, mobile phone carrier, internet protocol (IP) addresses (which may identify your general geographic location), user agent string (e.g., operating system and browser type/version), and the date and time of your interactions; information about your interactions with the Services, such as which pages of our website you visited and how much time was spent on the page. Please see our Cookie Policy  for more information.

Service Providers and Partners: We may receive information about you from our service providers such as analytics services, and our partners such as ad campaign information (e.g., the ads you click on).

Geolocation Information: We collect or receive information from your device or browser including geographic location, typically your log-in location for the Services, such as a city or country. We do not “track” your precise geolocation information, but we need to use your general location in order to provide the Services. We will not collect your geolocation information when you are not logging in or using the Services. For information about how to turn off geolocation services please seen our Cookie Policy.

B. Data Commingling. 

Except with respect to Your Information that is information we collect automatically in connection with your participation in a Research Program, we do not commingle your Website Information with your Research Program Information. Our use, sharing and disclosure practices for Your Information are set forth in this Section 2 of the Privacy Notice.

C. How We Use Your Information.

We use Your Information to provide the Services and to operate our business, including:

Service-Related Usage:  We use Your Data to provide and support the Services, such as communicating with you and other Participants, providing support services, and maintaining our systems.

Analyzing and Improving the Services: We may run calculations, aggregate, normalize, clean, and make derivative works of Your Information in order to (i) understand and analyze usage trends and preferences, (ii) monitor and analyze the effectiveness of the Services, (iii) improve the Services and develop new products, services, features, and functionality; and (iv) test the Services and our infrastructure to make sure the Services are working correctly.

Marketing:  If you enter your contact information on the Spindle Website and opt-in to receive electronic marketing communications from us, we may provide you with promotional materials that could be useful, relevant, valuable, or otherwise of interest to you. We will not send you marketing emails if you have not signed up for this, and you can unsubscribe from receiving such emails at any time by clicking on the “unsubscribe” link at the bottom of all our marketing emails.

Advertising:  Spindle, its business partners and advertising/marketing companies use Your Information, subject to your consent where required, to tailor, analyze, manage, report and optimize advertising you see on the Services, and on other sites and apps that you access and/or use through your devices.

D. How We Share Your Information.

We share, transfer, or disclose Your Information if you consent to us doing so, as well as in the following circumstances:

Service Providers:  We also share information with third parties who provide services to us, such as customer services, website management, information technology and IT security, auditing, payment processing, data analytics, advertising, and other similar service providers (e.g., our affiliates other entities with which we are building technology integrations). We do not authorize these individuals or entities to use or disclose Your Information except for as necessary to engage in the activities described in Section 2.C. of this Privacy Notice or to comply with legal requirements.

Marketing and Advertising: Spindle shares some of Your Information, including Tracking Data, with marketing firms and advertisers/remarketing providers for the purpose of Marketing and Advertising. You may set your mobile device to limit ad tracking, in which case we will not be able to see your ADID or IDFA.  Please see our Cookie Policy for more information.

Compliance with Legal Requirements:  We may disclose Your Information if required or permitted to do so to:

Comply with applicable laws and legal processes;

Respond to requests from law enforcement authorities, public and government agencies or officials, or other persons or entities with appropriate legal authority or justification to receive such information, including persons or entities outside your country of residence; and

Protect our rights, privacy, safety, or property, and / or that of our affiliates, you, or others.

Affiliates and Successors:  We may share some or all of Your Data with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us. Further, as we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, Your Data may be part of the transferred assets.

Aggregated, De-Identified Information: We may use Your Data to create aggregate or statistical information that does not directly identify a specific person, and we may share that information with third parties. For example, we may share anonymous and aggregated reports and information on user demographics and industry patterns with third parties.

E. Retention and Deletion of Your Information. We retain Your Information for no longer than necessary to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required under applicable law. At all times, Your Information will only be processed as required by law or in accordance with this Privacy Notice. \

F. Links to Other Websites, Devices, Apps and Features. The Services may contain links to third-party websites (“External Sites”). We have no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for their content, use or privacy practices. We strongly suggest that you review the applicable privacy policies and terms of service when visiting any External Sites.

G. Do Not Track. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, the Services do not respond to “Do Not Track” settings or other related mechanisms.

3. General

A. Children’s Privacy. We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of the Services is directed to children under the age of 16. If you learn that your child has provided us with personal information without your consent, you may alert us at the contact information listed below. If we learn that we have collected any personal information from children under 16, we will promptly take steps to delete such information and terminate the child’s account.

B. How We Protect Information. We use physical, organizational, and technical safeguards that are designed to protect the integrity and security of Research Program Information and Your Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security measures are perfect or impenetrable. We thus cannot guarantee the security of our databases, Research Program Information, or Your Information, nor can we guarantee that your Research Program Information or Your Information will not be intercepted while being transmitted over the internet to and from us.

C. Updates to This Privacy Notice. We may update this Privacy Notice from time to time to reflect changes in our privacy practices. We will indicate at the top of this Privacy Notice when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. If we make material changes we will let you know.

D. Notice to California Residents. If you are a resident of California, you have additional rights under the California Consumer Privacy Act (the “CCPA”). For more information about your rights under the CCPA, please visit our CCPA Privacy Notice.

E. Notice to EU and UK Residents. If you are a resident of the European Union or the United Kingdom, you have additional rights under the General Data Protection Regulation and the United Kingdom General Data Protection Regulation (respectively the “GDPR” and the “UKGDPR“). For more information about your rights thereunder, please visit our GDPR Privacy Notice.

D. Notice to Nevada Residents. If you are located in or a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

G. How to Contact Us. If you have any questions or comments about this Privacy Notice, our privacy practices, or if you would like to exercise your rights and choices, please contact us at [email protected].

1. About this Cookie Policy

This Cookie Policy explains what cookies are and how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to control the cookie preferences. For further information on how we use, store, and keep your personal data secure, see our Privacy Policy.

You can at any time change or withdraw your consent from the Cookie Declaration on our website. Learn more about who we are, how you can contact us, and how we process personal data in our Privacy Notice. Your consent applies to the following domains: spindleresearch.com.

2. What are cookies?

Cookies are small text files that are used to store small pieces of information. They are stored on your device when the website is loaded on your browser. These cookies help us make the website function properly, make it more secure, provide better user experience, and understand how the website performs and to analyze what works and where it needs improvement.

3. How do we use cookies?

As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.

The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.

4. What types of cookies do we use?

Essential: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your account and add products to your basket, and checkout securely.

Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit, etc. These data help us understand and analyze how well the website performs and where it needs improvement.

Marketing: Our website displays advertisements. These cookies are used to personalize the advertisements that we show to you so that they are meaningful to you. These cookies also help us keep track of the efficiency of these ad campaigns.
The information stored in these cookies may also be used by third-party ad providers to show you ads on other websites on the browser as well.

Functional: These are the cookies that help certain non-essential functionalities on our website. These functionalities include embedding content like videos or sharing content of the website on social media platforms.

Preferences: These cookies help us store your settings and browsing preferences like language preferences so that you have a better and efficient experience on future visits to the website.

The below list details the cookies used in our website.

5. How can I control the cookie preferences?

Should you decide to change your preferences later through your browsing session, you can click on the following link:

This will display the consent notice again enabling you to change your preferences or withdraw your consent entirely.

In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. To find out more about how to manage and delete cookies, visit wikipedia.org, www.allaboutcookies.org.

1. Additional Rights

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), you may have additional rights with respect to your personal data under the EU General Data Protection Regulation (“EU GDPR”), and the EU GDPR as saved into United Kingdom law by the United Kingdom’s European Union (Withdrawal) Act 2018 (“UK GDPR”) (together, the “GDPR”), as set forth in this GDPR Notice (the “GDPR Notice”). This GPDR Notice applies to your personal data (as defined in the GDPR) included in the Employment Data and/or Your Data.

Spindle Research LLC is the controller of your personal data for the purposes of the GDPR.

3. Lawful Basis(es) for Processing Your Personal Data

We will only process (as defined in the GDPR) your personal data if we have a lawful basis for doing so. Under the GDPR, the lawful bases we rely on for processing this information are:

A. Your Consent. In some cases, we process personal data based on the consent you expressly grant to us at the time we collect such data. When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection. You can remove your consent at any time by contacting us via email at [email protected] with the subject line “GDPR Request.”

B. We Have a Contractual Obligation. We may process your personal data as a matter of “contractual necessity,” meaning that we need to process the data to conduct the research as contemplated in our Participation Terms. When we process data due to contractual necessity, failure to provide such personal data will result in your inability to participate in the Research Program that requires such data.

C. We Have a Legitimate Interest.  We process your personal data when we believe it furthers the legitimate interests of us or third parties. Our legitimate interests are:

Information Security

Operation and Improvement of our Services:

Audience Measurement and Marketing

Direct Marketing, where we otherwise are not required to seek consent

General Business Development and Management

Protection or Enforcement of Right

D. We Have a Legal Obligation. We may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

4. Your Data Protection Rights

You have certain rights with respect to your personal data, including those set forth below. For more information about these rights, or to submit a request, please email us at [email protected] with the subject line “GDPR Request.” You are not required to pay any charge for exercising your rights.

Where we are acting as a data controller of your personal data, there may be circumstances where we are not able to fully comply with your request, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary to verify your identity and the nature of your request.

Right of access: You can request more information about the personal data we hold about you and request a copy of such personal data.

Right to rectification: If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.

Right to erasure: You can request that we erase some or all of your personal data from our systems.

Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data.

Right to object to processing: You have the right to object to the processing of your personal data in certain circumstances.

Right to data portability: You can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

Right to withdraw consent: If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time.

Objecting to Legitimate Interest/Direct Marketing: You may object to personal data processed pursuant to our legitimate interest. In such case, we will no longer process your personal data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your personal data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to [email protected] with the subject line “GDPR Request.” In such case, your personal data will no longer be used for that purpose.

Where we are acting as a data controller for your personal data, we will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please note that all of these rights are subject to applicable exemptions and restrictions, and are not absolute rights.

5. How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us at [email protected] with the subject line “GDPR Request.”

You also have the right to lodge a complaint about the processing of your personal data with a supervisory authority of the European state where you work or live or where any alleged infringement of data protection laws occurred. A list of most of the supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm, and the UK authority details can be found at https://ico.org.uk/make-a-complaint/.

6. Transfers of personal data

We are based in the United States. As such you transfer your personal data directly to us in the United States.  We may transfer your personal data outside the EEA and/or the UK. The United States and recipient countries may not provide the same protections as the data protection laws where you are based. We will ensure that relevant safeguards are in place to afford adequate protection for your personal data, including through the use of the EU Commission-approved or UK Secretary of State-approved (as applicable) standard contractual clauses. For more information about how we transfer personal data internationally, please contact us at [email protected].

7. Data Protection Representatives

We have appointed VeraSafe Ireland Ltd., at Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland, as our EU data representative, and VeraSafe United Kingdom Ltd. at 37 Albert Embankment, London SE1 7TL, United Kingdom, as our UK data representative. You can contact our EU and UK representatives at https://verasafe.com/public-resources/contact-data-protection-representative.

1. Information We Collect

A. Categories of Information

Within the twelve (12) months preceding the latest update of the Privacy Notice, we have or might have collected or otherwise obtained the following Categories of Personal Information from or about consumers, their households or devices:

Contact Information. Contact information, such as your name, postal address, email address, and phone number.

Identity Information. Identity information, such as your name, address, phone number, email address, date of birth, gender, marital status, picture, Social Security Number, other government IDs, and vehicle information and identification.

Career Information. Career information, such as employer name and address, job title, employment type, employee ID, employment status, date of hire, termination date and reason, performance rating and achievements, hours worked, certifications, and licenses.

Income and Financial Information. Income and financial information, such as compensation, payout dates, deductions, withholdings, reimbursements, balances, filing status, bank account and routing number, and credit card number and expiration date.

Account Information. Information associated with your Spindle account, such as your name, email, username and password.

Work Account Credentials and Associated Research Program Information. Login credentials and other account information for the Work Accounts you choose to furnish us with, such as your username, email address, password, and phone number; and Research Program Information gathered from those Work Accounts under those credentials to conduct the Research Program.

Browser Information. Browser and device information, such as unique device identifiers, mobile phone carrier, internet protocol (IP) addresses (which may identify your general geographic location), user agent string (e.g., operating system and browser type/version), and the date and time of your interactions.

Interaction Data. Information about your interactions with the Services, such as which pages of our website you visited and how much time was spent on the page.

Geolocation information. Geolocation information.

Please note that under the CCPA, Personal Information does not include: (i) publicly available information from government records; de-identified or aggregated Personal Information; or information not covered by the CCPA.

B. Categories of Sources

We collect the Categories of Personal Information listed above from the following Categories of Sources:

Directly from consumers like you (e.g., through participating in Research Programs, or creating accounts with us, completing surveys, or engaging in other direct communication and interactions);

Indirectly from consumers like you, when you use our Services (e.g., through browser cookies, pixels, web server logs, web beacons, and similar technologies); and

Third–party web analytics services.

C. Use of Personal Information

We use the Personal Information we collect for the commercial or business purposes laid out in the “How We Use Research Program Information” and “How We Use Your Information” sections of our Privacy Notice.

D. Categories of Third Party Recipients

We share or might share your Personal Information for Business Purposes with the following Categories of Third Party Recipients:

Service Providers. Third-party service providers who provide services to us, such as customer services, website management, information technology and IT security, auditing, payment processing, data analytics, advertising, and other similar service providers; and

Affiliates and Successors. Affiliates and Successors, such as our parent companies, subsidiaries, joint ventures, or other companies under common control with us. Further, as we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, Research Program Information and Your Information may be part of the transferred assets.

2. Your Rights and Choices

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes these rights and explains how to exercise them.

A. Right to Know About Personal Information

You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request):

The categories of Research Program Information and Your Information that we have collected in the preceding 12 months;

The categories of sources from which we have collected Research Program Information and Your Information in the preceding 12 months,

The commercial or business reason(s) for having collected, used, disclosed, or sold Research Program Information and Your Information in the preceding 12 months; and

The categories of third parties to whom we have disclosed or sold Research Program Information and Your Information in the preceding 12 months.

You may exercise this right up to two times in any 12-month period. In addition, you may have the right to know about the specific pieces of Research Program Information and Your Information that we have collected about you or shared with third parties in the preceding 12 months.

B. Right to Request Deletion

You may also have the right to request deletion of Research Program Information or Your Information. We will honor such request, but might not be able to fulfill your request if we (or our service providers) are required to retain Research Program Information or Your Information. Examples of such exceptions are:

Completing a transaction or performing a contract we have with you;

Detecting and addressing data security incidents, and repairing or upkeep of our IT systems;

Protecting against fraud or other illegal activity;

Complying with applicable law or a legal obligation, or to exercise rights under the law (e.g. the right to free speech); or

Using Research Program Information and Your Information internally to improve our services.

3. Exercising Your Privacy Rights

In order to process the above-mentioned requests, we will ask you to provide certain information about yourself to verify your identity in accordance with requirements under CCPA. This may include your first and last name, email address, address, telephone number, or other information necessary to verify your identity. Spindle will not discriminate against you based on your exercise of any of these rights.

If you are a California resident and you or your authorized representative would like to exercise your privacy rights, please contact us at [email protected] with the subject line “CCPA Request.”