SPRING Privacy Policy

This Privacy Policy describes the policies and procedures of Jello Labs, Inc., d/b/a Spring ("we", "our" or "us") regarding the collection, use and disclosure of the information of users of the Spring website located at www.shopspring.com (the "Site") and the services, features, products, content or applications we make available, including the mobile application called "Spring" (the "Application") (collectively with the Site, the "Services"). We receive information about you from various sources, including: (i) if you register for the Services, through your user account on the Services (your "Account"); (ii) your use of the Services generally; and (iii) from third party websites and services. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information ("Personal Information") gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners. Our business partners include fulfillment companies, our Payment Processors (defined below), and brands that make available through the Services their own products and retailers that make available through the Services the products of multiple brands.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any business partner or other third party websites, services and applications ("Third Party Services") that you elect to access through the Services. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we have no control over, do not review, and cannot take responsibility for these Third Party Services, the content therein, or the privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Information Do We Collect and How is such Information Used?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.

Account Information:

When you create an Account, you may provide information that could be Personal Information, such as your username, password and email address. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you messages about our Services. You may unsubscribe from these messages through your Account settings or by clicking on the unsubscribe link included at the bottom of marketing emails, although we, regardless, reserve the right to continue sending you non-marketing emails, such as emails about your accounts and our business dealings with you.

The Services may allow users to log in and create an Account through your Facebook or Google account (each a "Third Party Account") using your Facebook ID or Google ID. If you log in to the Services through your Third Party Account, you are allowing the Services to access your information and you are agreeing to the Third Party Accounts terms of use in your use of the Services. We may receive information from such Third Party Accounts and that information may be imported to the Services (either as a part of your profile or otherwise). We will use all information available through a Third Party Account in accordance with the Third Party Account's policies and your account privacy settings selected through the Third Party Account, so please consult such policies and settings.

You acknowledge and agree that you are solely responsible for your use of your Third Party Account and that it is your responsibility to review the terms of use and privacy policy of each Third Party Account. We will not be liable for: (i) the availability or accuracy of your Third Party Account; (ii) the content, products or services on or available on your Third Party Account or (iii) your use of your Third Party Account.

User Content:

We collect information that you include in your profile, such as your photo and birthday.

Financial Information:

If you purchase products through the Services, your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information), is collected and stored by our third party payment processing company (the "Payment Processor"), and use and storage of that information is governed by the Payment Processors applicable privacy policy. As of the Effective Date of this Privacy Policy listed below, Stripe is the Payment Processor used within the Services and its privacy policy is available at https://stripe.com/us/privacy or such other URL designated by Stripe. In order to facilitate your order transactions, we collect and store your credit card type and the last four digits of your credit card number, but no other financial information. When you order products using the Services, we may share your billing (including credit card type and last four digits of your credit card number) and purchase information with the applicable brand or retailer of your purchase and any fulfillment companies.

Shipping Information:

When you order products using the Services, we collect your shipping information. We pass this information to our Payment Processor, fulfillment company, brand, or retailer partners for purposes of customer service, fulfillment, shipping and returns. The use of your Personal Information by these parties is subject to their respective privacy policies.

Other Information:

We may collect your phone number and the unique device id number of the mobile device on which you use the Application.

If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

When you participate in one of our surveys, we may collect additional personal information.

We also collect other types of personal information that you provide to us voluntarily.

If you participate in a contest, sweepstakes or other promotion, we will collect any data you provide in connection with that promotion.

We may also obtain information from other sources and combine that with information we collect on our Services.

We may also collect personal information at other points in our Services that state that personal information is being collected.

IP Address Information and Other Information Collected Automatically:

Email Communications:

We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.

Information Collected Using Cookies:

Information Related to Advertising and the Use of Web Beacons:

To support and enhance the Services, we may serve advertisements, and also allow third parties to serve advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called "ad networks." Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms.

Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be based on your activity on Third Party Services. We do not provide Personal Information to any ad networks for use outside of the Services.

To increase the effectiveness of ad delivery, we may deliver a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad networks servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.

General Uses of Information:

We use personal information collected through our Services for purposes described in this Privacy Policy or disclosed to you in connection with our Services. For example, we may use your information to:

We may store and process personal information in the United States and other countries.

We may get information about you from other sources. We may add this to information we get from the Services.

How, and With Whom, Is My Information Shared?

The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties.

Public Information about Your Activity on the Services:

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Site or Application or otherwise through the Services.

Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

IP Address Information:

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

User Profile Information:

User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.

Financial Information:

As stated above, your financial information is collected and stored by our Payment Processor; we collect and store your credit card type and the last four digits of your credit card number only. However, we may from time to time request and receive some of your other financial information from such Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.

Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our "Agents"). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Shared with Our Brands and Retailers:

When you order products using the Services, you may be purchasing such products directly from Spring or from our brand or retailer partners, as applicable. We may share your email address, billing (including credit card type and last four digits of your credit card number), purchase, shipping and return information with the applicable brand, retailer and any fulfillment companies. After your order, the applicable brand or retailer is solely responsible for all customer order fulfillment, customer service, shipping, returns and exchanges. The brand or retailer may use the information we share with it in the manner described in its privacy policy, including to send you marketing messages. Because we do not control the privacy practices of any of our brand and retailer partners, please review its privacy policy and direct any questions regarding its use of your information to it. If you do not want to receive any marketing communications, the privacy policy of the brand or retailer may tell you how to opt out of receiving its marketing messages. Please follow the instruction provided by the brand or retailer partner in order to opt-out of or unsubscribe from such marketing communications.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy. In addition, we may share your Personal Information with our subsidiaries and affiliates.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any Personal Information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

We are using the services of our trusted service provider, Forter, in order to help us prevent online fraud. Our service provider may use and process your personal information in accordance with applicable privacy and data protection laws. You can read about the ways by which our service provider may use and process your personal information in this address.

Information We Share With Your Consent:

We may share your Personal Information to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, with your consent, or to third parties designated by you.

Is Information About Me Secure?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer, phone, and browser or other device by signing off after you have finished accessing your Account.

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We otherwise store all of our information, including your IP address information, using industry-standard techniques. While we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security and we do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.

What Information of Mine Can I Access?

If you are a registered user, you can access and edit information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights:

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Jello Labs, Inc., 584 Broadway Suite 908, New York, New York 10012.

How Can I Delete My Account?

Should you ever decide to delete your Account, you may do so by emailing info@shopspring.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public. We may retain an archived copy of your records as required by law or for legitimate business purposes.

What Choices Do I Have Regarding My Information?

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email and will change the Effective Date (below). A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to info@shopspring.com. We will make every effort to resolve your concerns.

A Note About Children

We do not intentionally gather personal information from users who are under the age of 13. If a child under 13 submits personal information to Spring and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at: info@shopspring.com.

Users Outside of the United States

If you are a non U.S. user of the Services, by using our Services, you acknowledge and agree that your personal information may be processed for the purposes identified in this Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

Contact

You may contact us at the following address: Jello Labs, Inc., 162 Fifth Avenue, 3rd floor, New York, New York 10010

Effective Date: August 15, 2016