Privacy Policy

Effective Date: April 2022

Spirited (“Spirited,” “we,” “our,” or “us”) is committed to protecting your privacy and the security of your information. This Privacy Policy explains the types of personal information we collect from our website visitors, customers, and other individuals when they visit our website (www.Spirited.com) and related sites and web-based services (our “Site”) as well as through the use of Spirited’s products and services (collectively, the “Services”). This Policy also describes how we use personal information, the purpose(s) for sharing and recipients of personal information, and your rights and choices as to that information.

Spirited obtains personal information about you from different sources to provide and manage our Site and Services. “You” may be a visitor to Site, an organization that uses our Services (“Customer”) or an applicant of a Customer (“User”).

This Privacy Policy explains the following:

• Collection of Personal Information
• Use of Personal Information
• Sharing of Personal Information
• Your Rights and Choices
• Links to Other Sites
• Children’s Privacy
• Data Security
• Ownership
• Keep Yourself Safe
• Responsible Disclosure
• International Data Transfers
• Updates to This Privacy Policy
• Contact Information

1. Collection of Personal Information

Personal information is any information that relates to an identified or identifiable individual. Personal information does not include publicly available information or information that has been anonymized, de-identified, or aggregated. Personal information we collect will be apparent by the context of the page or your interactions with us, and generally includes personal information you choose to provide us and personal information we collect as your interact with our Sites and Services.

a. Personal information you provide to us

Personal information we collect will be apparent by the context through which it is provided, and may include, but is not limited to, the following:

• When you request a demo of our Services or otherwise contact us by providing your email address, name, company name, and telephone number
• When you communicate with us via email, phone, fax, text, or by any other means, and provide your personal information over the course of those communications
• When you otherwise provide us with your personal information in order to receive our Services or information relating to our Services, including as a User, Customer, or on behalf of a  Customer

b. Information that we automatically collect

Our Sites use cookies and other tracking technologies (such as web beacons, embedded scripts, tags) which collect information from you automatically, including:

• Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Sites you are visiting; and
• Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
• We use third party analytics services on our Sites to help us analyze your use of our Sites and diagnose technical issues.

c. Information collected from third-party sources

• Our service providers. We may receive personal information about you from our service providers, such as those that conduct payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. Please review the remainder of this Privacy Policy to learn more about how and why we use this information.
• Our Customers. We may receive personal information about you from our third party Customers, who have engaged us as their service provider to render Services to them. Our collection and use of this personal information is subject to any notices and agreements between you and the Customer.
• Other third parties. We may receive personal information about you from third party sources, including things that other third parties may post publicly about you or otherwise provide to us.

2. Use of Personal Information

We use the personal information we collect to provide, maintain and improve our Sites and Services, including:

• To enter into a contract for the sale of goods or services, to bill you for products or services, and to process payment transactions;
• To provide you with customer support, including to contact you in response to an inquiry that you sent and to send administrative messages, technical notices, updates, alerts and other information;
• To provide you with better products and services and improve and grow our business, including to perform research and development, understand our customer base and purchasing trends, and understand the effectiveness of our marketing; and
• To operate and maintain safe, secure and reliable Sites and Platform.

We may also use your personal information to send you promotional communications about our Services. You may opt out of receiving any, or all, of these communications from us via the unsubscribe link provided in such emails or by following further instructions provided in Your Rights and Choices.

3. Sharing of Personal Information

Spirited may share your personal information with the following trusted entities:

• Our service providers, as necessary to provide services on our behalf, such as website hosting, data analysis, marketing, email delivery, technical support, customer service, and analytics.
• Our Customers as necessary to provide, maintain, and develop our Sites and Services.
• Pursuant to a business transaction, subject to applicable law, in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the personal data collected by us in the same manner that we are able to use it, and the purchaser will assume the rights and obligations regarding personal data as described in this Privacy Policy.
• Compliance and harm prevention, including to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We also may provide information in order to investigate, prevent, or take action regarding illegal activities or wrongdoing; to protect the rights, property, or safety of Spirited, its users, and others; to enforce our agreements; or as otherwise required by law.

We may create anonymous or de-identified data from personal information by removing data components that make the data personally identifiable to you or through obfuscation or other means. We may analyze any data we aggregate or de-identify and share our analyses at our discretion. Our use of anonymized and de-identified data is not subject to this Privacy Policy.

4. Your Rights and Choices

You may have rights and choices regarding our use and disclosure of your personal information. Unless instructed otherwise, you can exercise these rights and choices by emailing us at support@Spirited.com or mailing us a letter to 226 W Ojai Ave, Ste 101-419, Ojai, CA 93023.

a. Opting out of receiving electronic communications from us. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or by emailing us at support@Spirited.com. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with our Services.

b. Your California privacy rights. California residents have the right to request information from Spirited regarding third parties to whom we have disclosed certain categories of personal information during the preceding year for those third parties’ direct marketing purposes under California’s “Shine the Light” law. We do not currently disclose this type of personal information to third parties for their own purposes. However, if you are a California resident and would like to inquire further, please email us at support@Spirited.com with “California Privacy Rights” as the subject line or write to us at 226 W Ojai Ave, Ste 101-419, Ojai, CA 93023

You must include your full name, email address and postal address in your request so that we can verify your California residence and respond.
In addition, California residents are entitled to certain consumer privacy rights related to their personal information under the California Consumer Privacy Act (“CCPA”). As a platform that collects personal information in order to provide our Sites and Services to Customers, the CCPA may apply to the personal information we hold about you on behalf of our Customers. If you are a User and California resident, please direct any CCPA-related requests directly to the relevant Customer (e.g., your property manager).

c. Your Nevada privacy rights. Nevada residents have the right to request to opt out of any “sale” of their personal information under Nevada SB 220. We do not currently sell personal information under Nevada law. However, you may still request to opt out of the future sale of your personal information. If you are a Nevada resident and would like to make such a request, please email us at support@Spirited.com with “Nevada Privacy Rights” as the subject line or write to us at 226 W Ojai Ave, Ste 101-419, Ojai, CA 93023. You must include your full name, email address and postal address in your request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.

5. Links to Other Sites

Our Sites may contain links or otherwise provide access to other third-party sites, which may include websites, mobile applications, or other web-based services. Please note that we have no control over and are not responsible for third-party sites, their content, or any products or services available through the third-party sites. Our Privacy Policy does not apply to third-party sites. We encourage you to read the privacy policies of any third-party sites with which you choose to interact.

6. Children’s Privacy

We do not knowingly collect personal information from individuals under the age of 13 years without parental consent. No personal information should be submitted to our Sites by individuals under the age of 13. If we learn we have collected or received personal information from a child under the age of 13 without parental consent, we will delete that personal information as permitted by law. If you believe we may have any collected personal information from a child under the age of 13 without parental consent, please submit a written request via email to info@spirited.asia

7. Data Security

Spirited uses bank-level security standards to help protect your information against unauthorized access, destruction, alteration, misuse, or loss. Spirited uses HTTPS to ensure that your data is transmitted securely.

To protect your privacy, we limit the amount of sensitive data we store on our servers. For example, we do not store the contents of credit reports or background checks, or credit card numbers. When we do store financial information, we encrypt and protect that data on secure servers.

We designed and built all our systems with multiple levels of security, and we manage them according to industry best practices. Our hosting provider maintains world-class facilities that are certified to the highest levels of physical and virtual security. Reputable third-party security firms perform regular internal and external security audits of our systems, something we consider an essential investment.

Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.

8. Ownership

When you use Spirited, you own and control your information. We limit access to your information whenever possible. Landlords must verify their identities before viewing credit reports and background checks, or receiving payments.

All Spirited employees receive thorough training before accessing customer data, and we comply with the Fair Credit Reporting Act (FCRA) and the Gramm–Leach–Bliley Act (GLBA). We share information securely with trusted third parties only when needed—to provide services, prevent fraud, and meet legal requirements.

9. Keep Yourself Safe

Even though we review every financial transaction for fraud, we recommend only sending payments to people you know. The same goes for sharing your information. If you have any questions or concerns about safety or security, please contact us at info@spirited.asia.

10. Responsible Disclosure

We take security seriously and we appreciate your help in notifying us of vulnerabilities in a responsible manner. If you are a security researcher and have found a potential security vulnerability in our systems, please send details to info@spirited.asia.

11. International Data Transfers

Our Site is operated in the U.S. and intended for users located in the U.S. We may transfer, store and use the information we collect and maintain about you, including Personal Information outside of your state, province, country or other governmental jurisdiction. The data protection laws in the jurisdiction in which we process Personal Information may differ from those of your jurisdiction, and in certain circumstances, your personal information may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions. By using the Site or providing us with any information, you consent to the transfer and processing of your information, including personal information, in the U.S. and elsewhere as set forth in this Privacy Policy.

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. The date this Privacy Policy was last updated is identified at the top of this page. Any changes are effective when we post the revised Privacy Policy on the Sites. If we make material changes to this Privacy Policy that expand our rights to collect new personal data or to use differently any personal data that we have previously collected about you, we will notify you and provide you with the disclosure by posting it on our Sites and/or via email. We encourage you to review this Privacy Policy often to stay informed of how we may process your personal data.

13. Contact Us

If you would like to submit a privacy rights request as detailed above, or if you have any questions or concerns about this Privacy Policy or our privacy practices, please email us at support@Spirited.com or write to us or call us using the information below:

Spirited:
226 W Ojai Ave
Ste 101-419
Ojai, CA 93023