Privacy Policy

SPRUNO PRIVACY POLICY

Last modified: September 9, 2022

INTRODUCTION

Spruno, Inc. (“Company”, “We” or “Us”) respects your privacy and we are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide in connection with your use of our website www.spruno.com (the “Website”), the Spruno platform, applications, mobile applications (including mobile versions of the Website) and related services, including the Spruno for Consumers App and the Spruno for Restaurants App (collectively the “Apps”) and any other software, tools, offerings, or services of any kind owned, provided or otherwise operated by Spruno (together with the Website and Apps, the “Service”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.  Capitalized terms used herein, which are not otherwise defined, have the meanings attributed to them in our Terms of Service, which can be found at www.spruno.com/terms and www.spruno.com/restaurants/terms.

To provide you with our Service and improve our Service over time, we will collect and use certain of your information as described in this policy.  This policy also explains certain choices you have about how your information is used.  Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  You can access certain features of the Service (e.g., general website features of the Service) without creating an account or providing personal information.

If you do not agree with our policies and practices, your choice is not to use our Service.  By accessing or using our Service, you agree to this privacy policy and you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this privacy policy.

If you accept or agree to this policy on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to this policy and, in such event, “you” and “your” will refer to and apply to that company or other legal entity.

This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of our Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

SCOPE AND CONSENT

This policy applies to information we collect:

• On our Website.
• On our Apps and through our Service.
• In email and other electronic messages between you and our Service.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other unrelated website operated by Company or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Service.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CHILDREN UNDER THE AGE OF 13

Our Service is not intended for children under 13 years of age.  No one under age 13 may provide any personal information to or on the Service.  We do not knowingly collect personal information from children under 13.  If you are under 13, do not use or provide any information on the Service or on or through any of its features/register on the Service, make any purchases through the Service, use any of the interactive features of the Service or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use.  If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 13, please contact us at support@spruno.com.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our Service, including information:

• by which you may be personally identified, such as name, address, e-mail address, telephone number, (“Contact Information”) or any other identifier by which you may be contacted online or offline (“Personal Information”);
• about your internet connection, the equipment you use to access our Service and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website or use our Service. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us.  The information we collect on or through our Service may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering for an Account, registering for events on our Website, subscribing to our newsletter or blog, or requesting further services or information. We may also ask you for information when you report a problem with our Website.
• Information that you provide when downloading and registering for an Account on one of the Apps, subscribing to our Service, using our Apps, posting material on the Apps and requesting further services.  
• Information about yourself that you voluntarily provide to us, such the restaurants you order from, gender, birthdate, interests, favorite foods and favorite restaurants.
• Order information when you place an order for food from a restaurant via the Service.
• Information that you post or provide to us such as feedback or recommendations or opinions related to our Service.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes, including demographic data about yourself.
• Information you provide when you enter a contest or a promotion sponsored by us.
• Information you provide when you report a problem with the Apps or our Service or when you contact customer support.
• Information you submit when you provide ratings or reviews of restaurants on the Spruno platform, including feedback, photographs or other recordings you provide.

Billing Information. To submit orders through the Service, you will be required to provide certain information in addition to your Contact Information.  Such information may include a debit or credit card number, billing address, expiration date, security code and similar information.  

Spruno also uses Plaid Technologies, Inc. (“Plaid”) to gather User’s data from financial institutions and to link your Payment Card to your Account to detect transactions and accrue Cashback.  By using our Service, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from relevant financial institutions, and you agree to your personal and financial information being transferred, stored, and processed by us and Plaid in accordance with our Privacy Policy and the Plaid’s Privacy Policy respectively.  By using our Service, you agree to be bound by Plaid’s Terms of Use.  

Posted Content. You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Service or transmitted to other users of the Service or third parties (collectively, “Posted Content”). Your Posted Content is posted on and transmitted to others at your own risk.  Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Service with whom you may choose to share your Posted Content. Therefore, we cannot and do not guarantee that your Posted Content will not be viewed by unauthorized persons.

Social Media Information. We may offer sign-in services that allow you to use third-party login credentials, such as Facebook, to register for an account on and access the Service.  We may also offer services that allow you to share information with third-party social media websites such as Facebook, Instagram, Twitter, LinkedIn, and others.  

When you link your account or engage with our Service through third-party social media sites, you understand that you may be allowing us to have ongoing access to certain information stored on those social media sites (e.g., your public profile, friend list, people you follow or who follow you, your email address, birthday, work history, education history, interests, current city, religious and political views, website, personal description, and likes, and your friends’ birthdays, education histories, personal descriptions, and likes).  We may receive certain information about you which is stored on social media sites if other users of those sites give us access to their profiles and you are one of their friends or connections depending upon your settings on those third-party social networking sites.   We may also receive other information (e.g., content viewed and information about the advertisements within the content you have been shown or may have clicked on, etc.) from your interaction with our Service.  You agree that we may share your video viewing with or obtain information about your video viewing from analytics providers, advertising partners and third-party social media sites for two years or until you withdraw consent.  The information we have access to from the third-party social media websites varies by website and is controlled by your privacy settings on that website and by your consent.  The information that may be passed to analytics providers and advertising partners is via cookies and tracking technologies.  Please see above for information including your choices in relation to these technologies.   By associating an account managed by a third-party with your account with us and authorizing us to have access to this information, you agree that we may collect, use, and store information from these websites in accordance with this Privacy Policy.

Mobile Information: We may collect additional information from you if you access our Service through a mobile device (e.g., your unique device identifier, device’s operating system, mobile carrier, location or GPS/geolocation). 

Information Related to the Referral Program.  Spruno allows users to invite friends and family to sign up for our Service.  Sometimes we offer a promotional value for every friend or family member who signs up and places an order through your referral link.  To help you do this, we may request you to grant us access to your mobile device address book.  You can then direct us to send referral emails to contacts you select in your address book.  By sending a referral, you also consent to Spruno sending your public profile image to the contacts you select to receive a referral link.  By choosing to invite a friend you represent that you have received the friend’s consent to provide his or her name and email address with us.  Spruno may use that information to send an email inviting him or her to visit the site and will store that information to track the success of the referral program and may send marketing emails.  You can also send an SMS with a referral link to your contacts.  If you use this option, you understand that Spruno does not control the timing, content or recipients of these SMS messages.  

Users may not send, publish or share any false, misleading or deceptive communications in connection with participation in the referral program.  Such actions may violate various federal, state, and/or international laws, including, but not limited to, the regulations and policies promulgated by the Federal Trade Commission.  Users may not send any referral emails, SMS messages, or other communications to children under the age of 13.

If you are referred to Spruno through one of our referral programs, or if someone attempts to refer you, we may share your name, whether you have already signed up for Spruno, whether you are a new customer, and whether you have placed a qualifying order with Spruno with the person(s) who referred you.

Information We Collect Through Automatic Data Collection Technologies.  When you visit the Website, we may use cookies and other tracking technologies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our Website, for when you later return to the Website.  As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• Geo-location information to provide certain location-based services that you request.

When you download, access, and use any of the Apps, it may use technology to automatically collect:

• Usage details.  When you access and use any of the Apps, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
• Device information.  We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
• Stored Information and Files.  The App may also access metadata and other information associated with other files stored on your device.  This may include, for example, photographs, audio and video clips, personal contacts and address book information.  
• Geolocation information.  The Apps collect real-time information about the location of your device.  Collection of such geolocation information occurs only when the Service is running on your mobile device.  You may control the collection of geolocation information through the user settings on your device.  You may decline to allow us to collect such geolocation information, in which case Spruno may not be able to provide certain services to you.  

Spruno uses Google Maps and the Google Maps API as part of our online ordering system.  By using our order system, you are also bound to the Google Maps API’s Terms of Service found here: https://developers.google.com/maps/terms-20180207#3-privacy-and-personal-information.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Service and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Service according to your individual interests.
• Recognize you when you return to our Service.

For more information, see How We Use Cookies and Tracking Technologies below.

HOW WE USE AND RETAIN YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you with the Apps and their contents, to create and update your Account, and to operate the Service, including processing your food orders and recommending nearby restaurants to you.
• To process and facilitate payment for food orders.
• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To administer our rewards, referral and promotional programs.
• To provide you with notices about your account or registration.
• To personalize your experience by providing content on the Website.
• To improve the Website and our Apps and Service.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Website, our Apps and our Service.
• In any other way we may describe when you provide the information.
• To fulfill any other purpose for which you provide it.
• For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please unsubscribe directly from any email received from Spruno.  For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We use aggregate information about our users and the Restaurants serving our users on our platform and non-personal information to analyze Website and user behavior and prepare aggregated reports.  

We use information from the Website to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Service.

When you access the website on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy.  For example, we may use this information to provide you with location-based services, such as advertising, search results and other personalized content.  

We retain information as long as it is necessary and relevant for our operations.  We will retain your personal information for as long as your account is active or as needed to provide you the Service and to maintain a record of your transactions for financial reporting purposes.  We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To restaurants, for the purpose of completing your orders, which requires us to share your name, phone number, email address, meal order and, if you are ordering for delivery, your physical address.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your 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.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of service, which can be found at www.spruno.com/terms and www.spruno.com/restaurants/terms.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by unsubscribing directly from any email you receive. You can also always opt-out by sending us an email stating your request to support@spruno.com.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to support@spruno.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. Registered users of the service cannot opt out of receiving transactional emails related to their account.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

ACCESSING AND CORRECTING YOUR INFORMATION

You can review and change your personal information by logging into the Spruno App and visiting your account profile page.

You may also send us an email at support@spruno.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Service, or take other actions permitted by law.  Likewise, if your account or membership is terminated or suspended, we may maintain some information to prevent re-registration.

If you delete your Posted Content from the Service, copies of your Posted Content may remain viewable in cached and archived pages or might have been copied or stored by other users of the Service. Proper access and use of information provided on the Service, including Posted Content, is governed by our terms of service, which can be found at www.spruno.com/terms and www.spruno.com/restaurants/terms.

HOW WE USE COOKIES AND TRACKING TECHNOLOGIES

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):

• We offer certain features that are available only through the use of tracking technologies.
• We use both session and persistent tracking technologies.  Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser).  You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Website.  Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
• With your prior consent as obtained through your use of this Website.
• We encode and protect the tracking technologies that we set, so that only we can interpret the information stored in them.
• We may target and track any videos you view on the Website.  You consent to our tracking of your video viewing through the Website or third-party social media for up to one year or as permitted by applicable law or until consent is withdrawn.

The following table sets out details of the individual tracking technologies we use and the purposes for which we use them. We provide the chart below as a courtesy for all users but we are not obligated to maintain or update it. We are not responsible for third-party sites and their privacy practices as it relates to opt-outs from tracking activities. The following third-parties that collect information from you on our Website have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Service are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

NOTICE TO CALIFORNIA RESIDENTS

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@spruno.com.  For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code.  In the body of your request, please provide enough information for us to determine if this applies to you.  You need to attest to the fact that you are a California resident and provide a current California address for our response.  Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

How We Respond to Do Not Track Signals for California Residents

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings.  We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.  We continue to review new technologies and may adopt a standard once one is created.

DATA SECURITY

We store and process your information on our services located in the United States.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls.

It is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third parties.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

support@spruno.com