Privacy Policy

Last Updated 31 August, 2022

INTRODUCTION

This privacy policy (“Policy”) describes how Extellior (5448 Apex Peakway #370, Apex, NC 27502, USA) (“Company,” “we,” and “our”) DBA Spinjutsu processes, collects, uses and shares personal data when using this and all of our websites (including but not limited to extellior.com, spinjutsu.net and any subdomain or website we may host on servers we manage and bearing the Extellior or Spinjutsu brand, collectively, the “Site”) in addition to the Spinjutsu software application(s) (the “Applications”), together (the “Services”). Please read the following information carefully to understand our practices regarding your personal data and how we will process data.

Our privacy policy may change. You should visit this page periodically to stay aware of changes to it.

ATTENTION: European Union Residents

You may not use our website if such use would create any obligation for Company to comply with the laws or regulations of any country or governing body beyond the United States of America. No person may use our website if such use would create any ogligation for Company to comply with EU GDPR.

1. Purposes of Processing

What is personal data?

We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation, this includes any information which, either alone or in combination with other information we process about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

Why do we need your personal data?

We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Services, in the delivery and support of the Services, and to support legal recordkeeping requirements for tax (VAT) purposes. If you registered with us, you will have been asked to tick a checkbox to agree to provide this information in order to access our Services, purchase our products, or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services.

2. Collecting Your Personal Data

We collect information about you in the following ways:

Information You Give Us. This includes:

• the personal data you provide when you register to use our Services, including your‎ name, email address, phone number, billing address, username, password;
• the personal data that may be contained in any video, comment or other submission you upload or post to the Services;
• the personal data you provide in connection with promotions we run on the Services;
• the personal data you provide when you report a problem with our Services or when we provide you with customer support;
• the personal data you provide when you make a purchase or otherwise acquire Services; and
• the personal data you provide when you register for webinars;
• the personal data you provide when you correspond with us by phone, email or otherwise.

Information from Social Networking Sites. Our Sites may include interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Site, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site. For example, when visiting our Site, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the sections on cookies, Flash Technology and Pixel Tags below.

Automated Decision Making and Profiling.

We may use automated decision making and/or profiling in regard to your personal data for some services and products, for example by providing you with some relevant features suggestion or by offering you a custom promotional offer based on your email information and behavior inside our Services. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision making and/or profiling by contacting us by postal mail at Extellior, 5448 Apex Peakway #370, Apex, NC 27502, USA.

3. COOKIES

What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Disabling cookies

Most browsers are set to accept cookies by default. You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

4. FLASH TECHNOLOGY

We may also use Flash cookies (which are also known as Flash Local Shared Object (“LSOs”)) on our Services to collect and store information about your use of our Services. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash cookies stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can also control Flash LSOs by going to the Global Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Services.

5. PIXEL TAGS

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of users on our Services. Pixel tags cannot be declined, but you can limit their use by controlling the cookies that interact with them. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

6. DO NOT TRACK SIGNALS

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

7. ADVERTISING

Generally. We may use other companies to serve third-party advertisements when you visit and use the Site/Application(s)/Services. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Site/Application(s)/Services and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.

Targeted Advertising. In order to serve offers and advertisements that may interest you, we may display targeted advertisements on the Site/Application(s)/Services, or other digital properties or applications in conjunction with our content based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide personal data to advertisers when you interact with an advertisement.

Your Ad Choices. Some of the third party services providers and/or advertisers may be members of the Network European Interactive Digital Advertising Alliance (“EDAA”) Self-Regulatory Program for Online Behavioural Advertising. To learn more, visit http://www.edaa.eu/edaa-for-users which provides information regarding targeted advertising and the “opt-out” procedures of EDAA members.

Mobile. We may, from time to time, offer certain location or pinpoint based services, such as location assisted navigation instruction. If you elect to use such location-based services, we must periodically receive your location in order to provide such location-based services to you. By using the location-based services, you authorise us to: (i) locate your hardware; (ii) record, compile and display your location; and (iii) publish your location to third parties designated by you by means of location publication controls available within the applications (for example, settings, user preferences). As part of the location-based services, we may also collect and store certain information about the users who elect to use such location-based services, such as a device ID. This information will be used to provide you the location-based services. We may use third-party providers to help provide such location-based services through mobile systems and we may make information available to such providers to enable them to provide their location-based services, provided that such third party providers may use the information only in accordance with this Policy.

8. Using Your Personal Data

We may use your personal data as follows:

• to operate, maintain, and improve our Site, products, and services;
• to deliver, manage and support products and services you obtain from us;
• to manage your account, including to communicate with you regarding your account, if you have an account on our Site;
• to operate and administer any promotions you participate in on our Site;
• to respond to your comments and questions and to provide customer service;
• to send information including technical notices, updates, security alerts, and support and administrative messages;
• with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
• to process payments you make via our Site;
• as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others;
• for analysis and study services; and
• as described in the “Sharing of your Personal Data” section below.

9. Sharing Your Personal Data

We may share your personal data with third-parties as follows:

• Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
• Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
• Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These services include:

PayKickStart: A payment portal provider where we sell products and services. After you make a transaction via PayKickStart, the system may automatically use your information in order to create accounts for you in our membership system and other platforms that we use to deliver the products or services your purchased, to add you onto our email list so you stay updated about the products and services you have purchased, to automatically provision software licenses, etc.

PayPal: An electronic payment provider;

Provely: A service provider that provides social proof of customer purchases by displaying their first name, last initial, and estimated location, at a high level;

Stripe: An electronic payment provider;

MailChimp: An email platform upon we keep our “email list” of people who have purchased various products and services, so that we can send you important updates and information about the products you have purchased, related industry news and information, and information about marketing promotions we may run;

AWeber: An email platform upon we keep our “email list” of people who have purchased various products and services, so that we can send you important updates and information about the products you have purchased, related industry news and information, and information about marketing promotions we may run;

SendFox: An email platform upon we keep our “email list” of people who have purchased various products and services, so that we can send you important updates and information about the products you have purchased, related industry news and information, and information about marketing promotions we may run;

Azure: A hosting and computational processing platform that handles software license control requests and changes;

Groove.cm: AKA Groove, GrooveDigital, GrooveFunnels, GroovePay - A multi-function digital marketing platform that processes payments and transactions, sends email, hosts members-only content, runs webinars, hosts websites, et al.;

Amazon Web Services SES: An email sending platform used to send you transactional emails in response to interactions that you may have with us on our support, membership or other web platforms or systems.

Hosting Providers: We use the following hosting providers to deliver products and services, and your information may be stored on their platforms, depending on the particular products or services we may have provided.

We chose our vendors carefully and encourage you to read more about their commitments to protecting the privacy of your information:

• SiteGround: https://www.siteground.com/term/307.htm?scid=4&lang=en
• Google Cloud: https://cloud.google.com/security/gdpr/
• Amazon Web Services: https://aws.amazon.com/compliance/gdpr-center/

10. ANONYMOUS DATA

When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.

We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyses usage patterns in order to make improvements to our Services.

11. Third Party Sites

Our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.

12. User Generated Content

You may share personal data with us when you submit user generated content to our Site. Please note that any information you post or disclose on our Site will become public information, and will be available to other users of our Site and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Site. Such personal data and other information will not be private or confidential once it is published on our Site.

If you provide feedback to us, we may use and disclose such feedback on our Site. You give us consent to post your first and last name along with your likeness and feedback on our Site.

13. INTERNATIONAL DATA TRANSFER

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By accepting this Policy, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

14. Security

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.

15. Retention

We will only retain your personal data for 36 months after you stopped using our Services unless a longer retention period is required or permitted by law (for example for regulatory or tax/VAT purposes).

We retain information to support our obligations under US tax legislation and audit requirements. This means that your personal information, as may be contained in invoices and sales records, will be kept by us in accordance with the requirements of the US Internal Revenue Service.

16. Our Policy on Children

Our Site is/are not directed to children under 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as possible.

17. Sensitive Personal Data

Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through Services or otherwise to us.

If you send or disclose any sensitive personal data to us when you submit user generated content to our Services, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Services.

18. Your Rights

• Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Site or our services may be ineffective upon opt-out, and we may be unable to either deliver or support any product or service.
• You may access the information we hold about you at any time via your profile/account or by contacting us directly.
• You can also contact us to update or correct any inaccuracies in your personal data.
• Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
• Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us at Extellior, 5448 Apex Peakway #370, Apex, NC 27502, USA. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for legal recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

19. Complaints

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: Extellior Complaints, 5448 Apex Peakway #370, Apex, NC 27502, USA. We will generally reply to your complaint within 30 days of receipt, but may take up to two additional months as may be permitted under law. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority

20. Contact Information

We welcome your comments or questions about this Policy. You may contact us in writing at:

Extellior
5448 Apex Peakway #370
Apex, NC 27502, USA.