Spicy Gum

Introduction

SPICYGUM LTD (hereinafter "we", "us" or "our") operates the websites https://www.spicy-gum.com/ (hereinafter "SpicyGum") and https://www.spicygum.club/ (collectively, hereinafter the "Websites") and is the controller of the information collected or provided via the Websites.

Please read this privacy policy carefully, as your access to and use of our Websites signifies that you have read and understand all terms within this privacy policy. We respect your privacy and are committed to protecting your personal data.

If you have any questions about our privacy practices, please see "Contact Information" below for information on how to contact us.

Scope

This privacy policy applies to information we collect:

on the Websites and your email communications with the Websites
through our mobile applications that provide dedicated non-browser-based interaction between you and the Websites
when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this privacy policy

The Data We Collect About You

We may collect different kinds of personal data about you, depending on whether you chose to create an account with us.

Persons who visit the Websites without logging in or registering ("unregistered users"):

Contact Information: We collect email address or any other information which you voluntarily provide to us at your direction for a specific function, for example a contest or survey.
Website activity data: We collect information about how you use our Websites, products and services and interact with our content and advertisements, including the pages you visit in our Websites, search history, and the referring web page from which you arrived at our Websites. We collect browser and operating system information, devices you use to access the Websites and your time zone setting. We also collect online identifiers. Specifically, we collect internet protocol (IP) address information and we set cookies as explained below in the section on Cookies and Automatic Data Collection Technologies

Persons who choose to create an account on SpicyGum ("registered users") and persons who choose to upgrade their account on SpicyGum to a premium account such that they have access to the content found on SpicyGum Membership ("VIP users"):

We collect from registered users the same categories of information described above for unregistered users.
Contact Information: We collect username or similar identifier, and email address.
Payment and Commercial Information: If you make a purchase, we collect payment card details and related information necessary to process your payment. We also collect details about payments to and from you and details of products and services you have purchased or received from us.
User Submitted Personal Information: We collect information you submit in order to personalize your account or for a specific function, for example date of birth, age, gender, your interests, preferences, feedback, survey responses, your preferences in receiving marketing from us and our third parties, and your communication preferences, as well as any other information which you voluntarily provide to us at your direction for a specific function.

We may use your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.

Our Websites are not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Websites are accessed ("minors"), and we prohibit minors from using the Websites. We do not knowingly collect personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us at juneliuspicygum@gmail.com to have that minor's personal information deleted.

The Sources from Which We Collect Personal Information

We collect Personal Information in the following ways:

Directly from you: We collect the categories of information listed above directly from you.
Automated technologies or interactions. As explained in the section below on Cookies and Automatic Data Collection Technologies, we set cookies and other automatic techniques to collect website activity data when you visit the Websites or other websites owned by our corporate group.

Purposes for Which We Use Your Personal Information

We use personal information for the purposes described below.

Provision of services:

We use identifiers, website activity data, and, additionally, for registered users and Premium users only, contact information, and payment and commercial information and user contributions to present our Websites and their contents to you, including any interactive features on our Websites, to provide you with information, products or services that you request from us, and to verify your eligibility and deliver prizes in connection with contests and sweepstakes.

Customer management (Registered Users and Premium Users Only):

We use identifiers and contact information, and payment and commercial information to manage a Premium users' and registered users' account, to provide customer support and notices to the registered user about his account or subscription, including expiration and renewal notices, and notices about changes to our Websites or any products or services we offer or provide through them.

Customization of content and marketing (Unregistered Users and Registered Users Only):

We use identifiers and contact information, website activity data, user submitted personal information and user contributions to analyze your use of, or interest in, our Websites' content, products, or services, in order to develop and display content and advertising tailored to your interests on our Websites.

Analytics:

We use identifiers and website activity data to determine whether users of our Websites are unique, or whether the same user is using the Websites on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns.

Functionality and security:

We may use any of the categories of data we collect to diagnose or fix technology problems, to verify your payment information, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.

Compliance:

We may use any of the categories of data we collect to enforce our terms and conditions and to comply with our legal obligations.

We will use contact information and user submitted personal information in any other way we may describe when you provide the information (e.g., for a contest); or for any other purpose with your consent provided separately from this privacy policy.

Our Legal Bases Under EU Law

We have the following legal bases under EU law for processing your personal data for the purposes described under Section Purposes for Which We Use Your Personal Information:

We process personal data for the purposes of providing the services, customer management, certain customization of content (e.g., based on your selected preferences, favorites and ratings), and functionality and security because the processing is necessary for the performance of a contract, specifically it is necessary to provide the services or products you have requested, or to provide our Websites and services in a manner consistent with our terms and conditions and any other contract that you have with us.
We process personal data for the purposes of customization of advertising, marketing and analytics for our legitimate interests.
We process personal data for functionality and security because it is necessary for our legitimate interests, and in certain cases because the processing is necessary for us to comply with a legal or regulatory obligation.
We process personal information in specific circumstances where you have provided your consent to such processing.

Disclosure of Your Personal Information

Within our corporate group:

We may disclose any of the categories of personal information to members of our corporate group (including affiliates and related entities) to the extent this is necessary for our purposes listed in the sections above.

Service providers:

We disclose the categories of personal information we collect to our authorized service providers that perform certain services on our behalf. These services may include payment processing and fulfilling orders, risk and fraud detection and mitigation, customer service, marketing and advertising, customization of content, analytics, security, or hosting our Websites or supporting our Websites' functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.

Legal successors:

We may disclose all of the categories of personal information we collect to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.

To comply with the law or protect our rights or the rights of third parties:

We access, preserve and share your personal information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of our Websites or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

Cookies and Automatic Data Collection Technologies

As you navigate through and interact with our Websites, we use automatic data collection technologies to collect website activity data.

We use cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.

Your Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the personal information you provide to us.

You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Websites because such information may be required in order for you to register as a member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our Websites.
You can opt out of receiving marketing emails from us using the opt-out link provided in our emails. If you are a Registered User, we may continue to send you other types of transactional and relationship e-mail communications, such as emails about your account or orders, administrative notices, and surveys.
You may delete and deactivate your account with us at any time. If you do so, your profile will no longer be accessible by you. If you later choose to have an account with us, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.

Your Rights Related to Your Personal Information

You have certain rights regarding the personal information we collect, use or disclose and that is related to you, including the right:

to receive information on the personal information we hold about you and how such personal information is used (right to access)
to correct inaccurate personal information concerning you (right to data rectification)
to delete/erase your personal information (right to deletion, "right to be forgotten")
to receive the personal information provided by you in a structured, commonly used and machine-readable format and to transmit the personal information to another data controller (right to data portability)
to object to the use of your personal information where such use is based on our legitimate interests or on public interests (right to object)
in some cases, to restrict our use of your personal information (right to restriction of processing)
to withdraw your consent at any time where our processing is based on consent

You may, at any time, send us an e-mail at juneliuspicygum@gmail.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area or the UK, you have a right to lodge a complaint with your local data protection authority.

Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be in a position to respond to your request. Additionally, in some cases in order to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.

Retention of Personal Information

We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider a number of factors, including what personal data we are processing, the risk of harm from any unauthorised disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your personal information for the purposes set out in this Privacy Policy, we will delete your personal information from our systems.

Third-Party Links and Sites

If you click on a link to a third party site, you will be taken to websites we do not control. This policy does not apply to the privacy practices of these websites. Read the privacy policy of other websites carefully. We are not responsible for these third party practices.

Changes to Our Privacy Policy

We may modify or revise our privacy policy from time to time. If we change anything in our privacy policy, the date of change will be reflected in the "last modified date". We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our privacy policy, which will be posted at this location, so you are aware of any changes.

Contact Information

If you have any questions about this privacy policy or our information-handling practices, please contact us at juneliuspicygum@gmail.com