Privacy policy
You must validate this Privacy Policy upon setting up of Your Spool Account and accept it as
binding upon You. Terms defined in capital letters have the meaning given to them in the Terms
of Use.
We adopt this notice to comply with the The European Union’s General Data Protection
Regulation (GDPR) and the California Consumer Privacy Act (CCPA). Any terms defined in the
GDPR and CCPA have the same meaning when used in this notice.
A. Conditions for processing Your Personal Data
We collect and use Personal Data that You have spontaneously transmitted to Us, which is
necessary to subscribe to the Services and to receive emails containing information from Us
(newsletters).
You are required to provide accurate, true and correct personal details and information and to
update these data and information whenever necessary, so it remains true and complete.
We collect and process Your Personal Data in a fair and lawful manner, while respecting Your
rights. We are responsible for the processing of Your Personal Data.
Under no circumstances do We transfer or sell Your Personal Data to any Third Parties, except
to Our IT providers.
B. Information collected
We collect information pertaining to You including information that You provide in connection
with the Service, information from Third Parties, and information that is collected automatically
such as through the use of cookies and other technologies.
This information include (i) personal information including, but not limited to, full names, postal
address, email address, (ii) payment information, including, but not limited to, payment card
number, expiration date, security code and billing address, (iii) Information that Your browser
sends whenever You access the Services, (iv) third-party services that collect, monitor and
analyze data to provide analytics and other data to help us to improve Our Services, (v) third-
party services (including, but not limited to, Microsoft Outlook, Gmail, iCloud) used by You to
import data including, but not limited to, Your Contacts Personal Data (email, name, address,
phone number, calendar events, etc.), (vi) inquiries and feedbacks provided by You, including
contact information and content of the inquiries and feedbacks, (vii) Internet or other
electronic network activity information, including, but not limited to, browsing history, search
history, and information regarding an interaction with an Internet Web site, application, or
advertisement

and (viii) personal information which is capable of being associated with, or could be reasonably
linked, directly or indirectly, with a particular consumer or household.
C. Information use
We collect information, including Personal Data, for the purpose of providing the Services;
identifying and communicating with You, including newsletters and marketing materials;
responding to Your requests, including customer service inquiries; processing Your payments;
improving the Services; analyzing Your usage of the Services; and responding to valid legal
processes and valid requests from government authorities.
Pursuant to data protection laws and regulations, You have the right to access, modify, oppose
the processing of Your Personal Data, and to obtain communication of them in a structured,
readable format (unless legitimately impossible). You also have the right to place a claim with a
monitoring authority and to define directives pertaining to their digital testament.
You may exercise Your rights by sending an email to suppoort@spoolapp.co.
D. Communication
We may send You emails to the address associated to Your Account, to inform You of the
Services changes or its activities, or to communicate technical or administrative information.
Under no circumstances will You receive emails from third-party companies or partners without
Your permission.
You may opt out of receiving any, or all, of these marketing communications from Us by
following the unsubscribe link or instructions provided in any email We send or by contacting
Us. Please note that We may still send You transactional or administrative messages related to
the Services even after You have opted out of receiving marketing communications.
We may transfer Your Personal Data to technical service providers in order to provide You with
a better experience.
We may also share, transmit, disclose, grant access to, make available, and provide Personal
Data with and to Third Parties if in accordance with this Privacy Policy.
We commit not to communicate, sell or transfer Personal Data to Third Parties (aside from Our
technical service providers) without Your express consent, but may communicate them if the
law so requires, or upon judicial or government request.
You have the right to request that we disclose certain information to you about our collection
and use of your personal information over the past 12 months. Once we receive and confirm
your verifiable consumer request, we will disclose to you:

 The categories of personal information we collected about you.
 The categories of sources for the personal information we collected about you.
 Our business or commercial purpose for collecting or selling that personal information.
 The categories of third parties with whom we share that personal information.
 The specific pieces of personal information we collected about you (also called a data
portability request).
 If we disclosed your personal information for a business purpose, two separate lists
disclosing:
 sales, identifying the personal information categories that each category of recipient
purchased; and
 disclosures for a business purpose, identifying the personal information categories that
each category of recipient obtained
You have the right to request that we delete any of your personal information that we collected
from you and retained, subject to certain exceptions. Once we receive and confirm your
verifiable consumer request, we will delete (and direct our service providers to delete) your
personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our
service providers to:
1. Complete the transaction for which we collected the personal information, provide a
good or service that you requested, take actions reasonably anticipated within the
context of our ongoing business relationship with you, or otherwise perform our
contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech
rights, or exercise another right provided for by law.
5. Engage in public or peer-reviewed scientific, historical, or statistical research in the
public interest that adheres to all other applicable ethics and privacy laws, when the
information's deletion may likely render impossible or seriously impair the research's
achievement, if you previously provided informed consent.
6. Enable solely internal uses that are reasonably aligned with consumer expectations
based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the
context in which you provided it.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we
require more time (up to 90 days), we will inform you of the reason and extension period in
writing. If you have an account with us, we will deliver our written response to that account. If
you do not have an account with us, we will deliver our written response by mail or

electronically, at your option. Any disclosures we provide will only cover the 12-month period
preceding the verifiable consumer request's receipt. The response we provide will also explain
the reasons we cannot comply with a request, if applicable. For data portability requests, we
will select a format to provide your personal information that is readily useable and should
allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is
excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee,
we will tell you why we made that decision and provide you with a cost estimate before
completing your request.
E. Third Parties
You are responsible for ensuring that You have the necessary rights to use the Personal Data of
Third Party, including the right to upload them through the Services and process them by
means of Your Account.
You represent and warrant that You provided all required information to Third Parties, whose
Personal Data are processed.
You undertake to provide means for requests to be made electronically or by mail and to
respond to all requests of Third Parties regarding their rights (right of access, right to
rectification, right to erasure, right to restriction of processing, right to data portability, etc.).
If We receive requests from Third Parties pertaining to their Personal Data, We shall forward
them to You as soon as possible, who remain exclusively responsible.
F. Data retention and deletion
Your Personal Data are hosted by Amazon Web Services that is fully-secured and not accessible
outside our servers.
Our Amazon Web Services are located inside the Amazon European datacenter.
You may request that Your Account be closed at any time.
Due to services retention configuration, personal data deletion, associated to your account, will
be effective within a period of minimum 7 days for backups and 14 days for logs.
Account deletion will be effective within 1 week from Your deletion request.
We keep Your Personal Data as long as Your Account remains active and shall delete them
within a maximum five years from the deletion of Your Account (in case of legal action), unless

we are legally required under applicable law to Personal Data for a longer period. We will
inform You of the time required to delete all personal data associated to your account.
G. Cookies
A cookie is a file that can be recorded on the hard drive of Your terminals when You access to
the Services. We may deposit cookies on Your terminals to collect information in order to
improve the Services.
You must accept the deposit of cookies on Your terminal using the strip provided for this when
You access to the Services.
We do not keep tracking cookies or cookies containing IP addresses for more than thirteen (13)
months after their initial deposit on Your terminal(s).
You may at any time delete cookies from Your browser and set it up to block their storage on
Your terminals. Kairn invites You to refer to the help file of Your browser software to establish
the appropriate set-up. Rejecting the use of cookies may prevent optimal use of the Services.
Traffic data are generated when Your terminal is connected to the internet and to the Services.
These data may be used for improving Our Service. We never use personal names in traffic data
analyses.
H. Children’s privacy
Our Services are intended for a general audience and not directed to Users under thirteen (13)
years of age (“Children”). We do not intend to collect personal information as defined by the
U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If
You are a parent or guardian and believe We have, please contact Us here and We will remove
such data to the extent required by COPPA.
For more information on COPPA, click here or visit www.FTC.gov and look for parental guidance
on child online safety and privacy.
I. Non-Discrimination
We will not discriminate against you for exercising any of your GDPR and CCPA rights. Unless
permitted by the GDPR and CCPA, we will not:
 Deny you goods or services.
 Charge you different prices or rates for goods or services, including through granting
discounts or other benefits, or imposing penalties.
 Provide you a different level or quality of goods or services.

 Suggest that you may receive a different price or rate for goods or services or a different
level or quality of goods or services.
J. Modifications to this Privacy Policy
This Privacy Policy may be modified or updated at any time without notice, except for any
stipulations requiring Your consent
K. Contact Us
If You have any questions regarding this Privacy Policy, please contact Us at
support@spoolapp.co

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