Last updated May 03, 2023
SUMMARY OF KEY POINTS
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Due Spaghetti and the Services, the choices you make and the products and features you use.
Do we process any sensitive personal information? No, we do not process sensitive personal information.
Do we receive any information from third parties? No, we do not receive any information from third parties.
How do we process your information? We process your information to provide, improve and administer our Services, communicate with you, for security and fraud protections, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid and legal reason to do so.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information.
What are my rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do I exercise my rights? You may exercise your privacy rights by contacting us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.
WHAT INFORMATION WE COLLECT
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
- Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include: names, email addresses, billing addresses, debit/credit card numbers.
- Sensitive Information. We do not process sensitive information.
Information automatically collected
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identify (such as your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes: log and usage data, device data, and location data. You can opt out of allowing us to collect location data by refusing access to the information or by disabling your location setting in your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
HOW WE PROCESS YOUR INFORMATION
We process your personal information for a variety of reasons, depending on how you interact with our services, including:
- To deliver and facilitate delivery of services to the user.
- To respond to user inquiries and/or offer support to users.
- To fulfill and manage your orders.
- To enable user-to-user communications.
- To request feedback.
- To send you marketing and promotional communications.
- To deliver targeted advertising to you.
- To protect our Services.
- To identify usage trends.
- To determine the effectiveness of our marketing and promotional campaigns.
- To save or protect an individual’s vital interest, such as to prevent harm.
We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide you with services to enter into or to fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
For Residents of the EU or UK
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information.
The following are those legal bases:
- Consent: We may process your information if you have given us consent to use your personal information for a specific purpose. You may withdraw your consent at any time by emailing [email protected].
- Performance of a Contract: We may process your information if we believe it is necessary to fulfill our contractual obligations to you, including providing our Services at your request.
- Legitimate Interest: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.
- Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
For Residents of Canada
We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You may withdraw your consent at any time by emailing [email protected].
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
- For investigations and fraud detection and prevention.
- For business transactions provided certain conditions are met.
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
- For identifying injured, ill or deceased persons and communicating with next of kin.
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
- If it is reasonable to expect collection and use with consent would compromise the avaiability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
- If it was produced by an individual in the course of their employment, business or profession and the collection is consistent with the purposes for which the information was produced.
- If the collection is solely for journalistic, artistic, or literary purposes.
- If the information is publicly available and is specified by the regulations.
WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION
We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work.
Third parties with whom we may share personal information include: ad networks, affiliate marketing programs, data analytics services, payment processors, sales and marketing tools, website hosting service providers.
We may also need to share your personal information in the following situations: business transfers, when using Google Maps Platform APIs, and other users of our Site and Services.
Our Services may link to third-party websites, online services or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services or applications. We do not make any guarantee regarding such third party websites, services or applications. The inclusion of a link toward a third-party website, service or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third-parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
COOKIES AND OTHER TRACKING TECHNOLOGIES
HOW LONG WE KEEP YOUR INFORMATION
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting of other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW WE KEEP YOUR INFORMATION SAFE
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee the hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, setal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
INFORMATION FROM MINORS
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn tha personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].
YOUR PRIVACY RIGHTS
In some regions (such as the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at [email protected]. We will consider and act upon any request in accordance with applicable data and protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority of UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time by contacting us at [email protected]. Please note that withdrawing consent will not affect the lawfulness of processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications ant any time by clicking the unsubscribe link in the emails we send, or by contacting us as [email protected]. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.
If you have questions or comments about your privacy rights, you may email us at [email protected].
PRIVACY RIGHTS FOR RESIDENTS OF CALIFORNIA
California Civil Code Section 1798.83, known as the “Shine The Light law, permits our users who are California residents to request and obtain from us, one a year and free of charge, information about categories or personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties which which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make a request, please contact us at [email protected].
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us at [email protected] and include the email associated with you account and a statement that you reside in California. We will ensure the data is not publicly displayed on Services, but please be aware that the data may not b e completely or comprehensively removed from all of our systems (e.g. backups, etc.)
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as: 1) every individual who is in the State of California for other than a temporary or transitory purpose and 2) every individual who is domiciled in the State of California who is outside the State of California for temporary or transitory purposes. All other individuals are defined as “non-residents.” We must adhere to certain rights and obligations regarding the personal information of residents of the State of California.
What categories of personal information do we collect?
Examples include: your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. We will use and retain this personal information as needed to provide Services or for as long as the user has an account with us.
B. Personal information as described in California Customer Records statute
Examples include: name, contact information, education, employment, employment history, and financial information.
C. Protected classification characteristics under California or federal law
Examples include: gender and date of birth.
D. Commercial Information
Examples include: transaction information, purchase history, financial details, and payment information.
E. Biometric Information
Examples include: fingerprints and voiceprints.
F. Internet or other electronic network activity information
Examples include: browsing history, search history, online behavior, interest data, and interactions with the Website, application, or advertisement.
G. Geolocation data
Examples include: device location.
H. Audio, electronic, visual, thermal, olfactory, or other similar information
Examples include: images and audio, video or call recordings created in connection with our business activities.
I. Professional or employment-related information
Examples include: your current or past employment history or other information related thereto.
J. Education information
Examples include: Student records and directory information.
K. Inferences drawn from personal information
Examples include: inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
L. Sensitive personal information
Examples include: government identifiers (such as social security numbers); an account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or email in the context of receiving help through our customer support channels, participation in customer surveys or contests, and facilitation in the delivery of our Services and to respond to your inquiries.
How we use and share your personal information
Due Spaghetti may collect and share you personal information through targeting cookies/marketing cookies, social media cookies, and click redirects to affiliate links. More information about our data collection and sharing practices can be found in this privacy notice. You may contact us at [email protected].
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
What information we may disclose for a business purpose
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” your personal information.
Due Spaghetti has not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
Due Spaghetti has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
- Category A: Identifiers, such as contact details like your real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address and account name.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
You can call for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request an delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
- Whether we collect and use your personal information;
- The categories of personal information that we collect;
- The purposes for which the collected personal information is used;
- Whether we sell or share personal information to third parties;
- The categories of personal information that we sold, shared, or disclosed for a business purpose;
- The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- The specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer’s sensitive personal information.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. Wwe may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an op-ot request, we will actu upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, contact is at [email protected]. If you have a complaint about how we handle your data, we would like to hear from you.
PRIVACY RIGHTS FOR RESIDENTS OF VIRGINIA
Under the Virginia Consumer Data Protection Act (CDPA):
- “Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
- “Personal data” means any information that is linked to or could reasonably be linked to an identified or identifiable individual. “Personal data” does not include de-identified data or publicly available information.
- “Sale of personal data” means the exchange of personal data for monetary consideration.
Your rights with respect to your personal data:
- Right to be informed whether or not we are processing your personal data.
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us.
- Right to opt-out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
To exercise any of these rights, please contact [email protected]. To process any of these requests, we will need information to verify your identity. In order to do so, you must provide any requested information, such as your contact information. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
If you have questions or comments about this privacy notice, you may email us at [email protected] or write to us at:
4720 Garfield Avenue
Minneapolis, MN 55419
TO REVIEW, UPDATE OR DELETE DATA COLLECTED
Based on the applicable laws of your country, you have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update or delete your personal information, contact us at [email protected].