Privacy Policy
This privacy policy has been compiled to better serve those who are concerned with how their personal data is being used online. Personal data is defined under law, but is generally information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal data in accordance with our website. For the purposes of data protection law, Spruzzo Digital Marketing is the data controller and may be contacted via email or written letter at the following address:
tony@spruzzodm.com
What personal data do we collect?
When ordering or registering on our site or app, emailing with us, or talking to us over the phone, as appropriate, you may be asked to enter your name, email address, payment information or other details to help you with your experience or to complete a transaction with us.
How long do we keep personal data?
We will only retain your personal data for as long as necessary to fulfill 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 the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
At any time, however, you may contact us to request that we delete all of your personal data.
Do you have to provide personal data to us?
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
When do we collect information?
We collect information (including personal data) from you when you fill out a form on our site or app, enter information on our site, communicate with us over the phone, email us, or otherwise enter into a transaction with us.
How do we use your personal data?
We may use the personal data we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To provide our services to you and fulfill your requests of us.
- To complete transactions you requested that we complete.
- To send periodic emails regarding your order or other products and services.
- To send you our newsletter, if you have requested as much.
- To run ads.
What is our legal basis for processing?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have provided consent for us to use your personal data.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
How can you control our use of your personal data?
You may decline to provide us with personal data and/or decline to enter into transactions with us. You may also contact us at any time to request: to access your personal data, to rectify your personal data, to erase your personal data, or to opt-out of future communications from us. You may contact us via email or written letter at the following address:
tony@spruzzodm.com
In addition, you also have the right to lodge a complaint with data protection supervisory authorities, the identity of which may depend on your location.
How do we protect and store personal data?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We use regular Malware Scanning.
Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user enters, submits, or accesses their personal data to maintain the safety of your personal data.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
We may transfer, store or process your personal data outside of the European Economic Area (“EEA”). The laws in some countries may not provide as much legal protection for your personal data as in the EEA.
By submitting your personal data to us, you agree to this transfer, storing or processing. Where we use service providers outside the EEA, we rely on approved data transfer mechanisms (for example, the EU Standard Contractual Clauses and the EU-US Privacy Shield) to ensure that your personal data is adequately safeguarded in the recipient country.
Unfortunately, transmission of information over the internet is not completely secure. We will do our best to protect your personal data, but we cannot guarantee its security and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.
Do we use ‘cookies’?
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies off, some features will be disabled that make your site experience more efficient and some of our services will not function properly.
However, you can still place orders .
We use cookies and other similar technologies to distinguish you from other users of our websites and apps (including when you browse third party websites). This helps us to provide you with a good experience when you use our services (for example, to remember your login details and improve our services). We also use cookies and similar technologies to show you more personalized advertising, including ads for us on other websites. You may adjust the settings on your browser to refuse cookies but some of our services may not work if you do so.
Third-party disclosure
We may share your personal data with third parties in the following situations:
- We may provide your personal data to our business partners, suppliers and subcontractors who provide services to us or where necessary to perform a service that you have requested (i.e. to process payment information that you provide to us).
- We may provide data about your visit to analytics and search engine providers to help us improve and optimize our services. We generally only share this information in a form that does not directly identify you.
- We may provide your personal data to our professional advisors (like lawyers, accountants, and financial advisors) if needed for our own professional advice
- We may provide your personal data to law enforcement or regulatory authorities if required under law.
Third-party links
We do not include or offer third-party products or services on our website.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We have not enabled Google AdSense on our site but we may do so in the future.
California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA we agree to the following:
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’ and can be easily be found on the page specified above.
Users will be notified of any privacy policy changes:
- On our Privacy Policy Page
Users are able to change their personal information:
- By emailing us
How does our site handle do not track signals?
We don’t honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. We don’t honor them because:
we are not tracking
Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioral tracking.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
- Within 1 business day
We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions.
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM we agree to the following:
- NOT use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at
- Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
Contacting Us
If there are any questions regarding this privacy policy you may contact us using the information below:
tony@spruzzodm.com