This Privacy Policy was last updated on January 1, 2020.
This privacy policy (this “Privacy Policy”) applies to information collected by PH62 LLC (PH62 , “we” or “us”) on this website, its subdomains, and through any other online or mobile website, application, product, event, or service operated by SpringHill on behalf of itself and/or its affiliates (each, a “Site”), as well as any personal information provided to SpringHill by any means. Your privacy is important to us. As such, we provide this Privacy Policy explaining our online information practices. We encourage you to read this Privacy Policy in its entirety before using the Site or submitting any Personal Information (defined below) to us. If you choose to provide us with your Personal Information, you are telling us that you understand and accept the privacy practices detailed in this Privacy Policy and you authorize us to take actions consistent with this Privacy Policy. This Privacy Policy is also part of our Terms of Use, which govern your use of the Site. We are required by law to tell you what information we collect from you, how we use it, under what circumstances we may share it with third parties, how we protect that information and how you may opt out of the sale of that information. If you have questions about this Privacy Policy, contact us at legal@phsixtwo.com. This Privacy Policy does not apply to any products, services, websites or content that are offered by third parties, which are governed by their respective privacy policies.
I. THE INFORMATION WE COLLECT
We receive both information that is directly provided to us, such as personal information you provide when you visit the Site, and information that is passively or automatically collected from you, such as information collected from your browser or device. In this Privacy Policy, any information that could reasonably be used to identify you personally or identify your household or device is referred to as “Personal Information”.
1. Information you provide to usIn the course of using the Site or the Services, we may ask you to provide us with certain information, such as your first and last name, home or business address, other shipping or billing addresses, telephone number, e-mail address, credit card, bank account, or electronic payment information, and your purchase and/or service history.We may collect this information when you:
- Sign up for a newsletter, request to be placed on our mailing list and/or email marketing lists, or contact us via webform, email, phone or in person;
- Request information from us regarding products, Services, events, and/or special promotions;
- Contact us regarding a question, concern or inquiry, such as when you make inquiries concerning our Site, products and/or Services, including at in-person events;
- Register and create an account on our Site or through an online store that we operate;
- Order products from us and/or have them shipped to you or others;
- Post comments, review, and/or feedback on our side
- Participate in a sweepstakes, contest, or promotion sponsored or co-sponsored by us; and/or
- Otherwise interact with our Site or our representatives.
Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features or our Services, including ordering products or Services, submitting inquiries, or signing up for newsletters or marketing lists.
2. Information that is passively or automatically collected
In addition to information that you choose to submit to us, we, and our “Partners” who include third party service providers, advertisers, advertising networks and platforms, agencies, online store, fulfillment, distribution or other partners may use automated means to collect various types of Information about you, your computer, or other devices used to access the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:
- Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
- Your Device functionality (including browser (e.g., Chrome, Safari, Firefox, Internet Explorer), browser language, operating system (e.g., Microsoft Windows or Mac OS), hardware, mobile network information);
- The name of your Internet service provider (e.g., Spectrum, Verizon or AT&T) and domains used by such providers;
- Referring and exit web pages and URLs;
- The areas within our Site that you visit and your activities there, including remembering you and your preferences or the content and advertisements you have accessed, seen, forwarded and/or clicked on;
- Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
- Your Device characteristics; and
- Certain other Device data, including the time of day you visit our Site(s).
For location information, we may use this information to provide customized Services, content, promotional offers, and other information that may be of interest to you. If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your Device or through the settings in the applicable mobile application. Consult your Device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, Content, promotions, or products on our Site may be limited to disabled.
3. Use of Cookies and Other Tracking Technologies
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):
- Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.
- Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
- ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
- Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
- Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
- To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality or to allow you to make use of cart or payment functionality;
- To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
- To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
- To deliver content relevant to your interests on our Site and third-party sites based on how you interact with our advertisements and/or content.
You can get more information about Cookies and Tracking Technologies, and instructions on how to opt out of cookies and certain tracking technologies, in our “Ads and Information About You” section below and in our Cookie Policy.
4. Information Collected by and From Social Media Services and Other Third-Party Platforms
You may also be able to engage with our Content, on or through social media services or other third-party websites, plug-ins, integrations and applications. This may involve the third-party site providing information to us. For example, when you engage with our Content on or through social media services or other third-party platforms, plug-ins, integrations or applications, you may allow us to have access to certain Personal Information in your profile. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, like photos and videos, your list of friends or connections, people you follow and/or who follow you, or your posts or “likes.” We may also provide links to allow third parties to process credit card and/or electronic payments. These third parties may retain any information used or provided in any such communications or activities and these parties are not subject to SpringHill’s Privacy Policy. We may not control or have access to your communications through these third parties. For a description on how social media services and other third- party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.
II. HOW WE USE THE INFORMATION
We, along with our Partners and Service Providers, may use your Personal Information to:
- Provide information and communicate with you about the Site, the Services, or your account with us;
- Fulfill your requests regarding the Site and Services, including, without limitation, requests for newsletters and notifications;
- Process your product purchase(s) and/or ship or fulfill your order(s);
- Respond to your inquiries, and notify you if you have won a contest;
- Communicate with you about other products, programs or services that we believe may be of interest to you;
- Provide mobile marketing messages and other communications and messages;
- Enforce the legal terms (including, without limitation, our policies and Terms of Use), and/or for the purposes for which you provided the Information;
- Provide technical support for, address problems with, and improve the Site and our products and Services, including testing and creating new products, features, and Services;
- Verify your identity and/or prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Site;
- Comply with applicable law and protect the safety, rights, property, or security of SpringHill, the Services and our Users;
- Protect the security and integrity of our Site, including understanding and resolving any technical and security issues reported on the Site;
- Customize or personalize ads, offers and content made available to you based on your visits to and/or usage of the Site or other online or mobile websites, applications, platforms or services, and analyze the performance of those ads, offers and content, as well as your interaction with them;
- Engage in analysis, research, and reports regarding how you use the Site or the Services;
- Send gifts, invitations, or emails, if you use these services, to your designated recipients;
- Improve the effectiveness of our Site, marketing endeavors, and our product and Service offerings;
- Improve the effectiveness of our Site, marketing endeavors, and our product and Service offerings;
When you provide information from your social media account, it can help enable us to do things like (1) give you exclusive content, (2) personalize your online experience with us within and outside the Site, (3) contact you through the social media service or directly by sending you the latest news, special offerings, and rewards, and (4) enable you to share your experience and content via social media services. When you provide information about yourself to us through an application, through the Site, or on social media services or other third party platforms, it may be publicly viewed by other members of these websites and we cannot prevent further use of the information by third parties.
We or a Partner may use “cookies” or similar technologies to associate certain of the Information with a unique identifier that then associates the Information with your device or browser. Sometimes, we may associate cookies with the Information, including de-identified, “hashed,” or anonymous versions of Information you have provided (such as during registration), in order to send or help our Partners send ads and offers based on your presumed interests or demographic information. Please see our Cookie Policy for more information.
We may combine any of the Information we collect, for any of the above purposes, and may sometimes enhance the Information with other information that we obtain from third party sources. Please also be aware that if you choose to submit Personal Information or content for publication (e.g., a review or comments regarding our products or Services, a posting to a blog or a discussion board, or a video), we may publish that Information and content, along with other Information about you (such as your name, screen name or location).
III. INFORMATION SHARING AND DISCLOSURE
We may disclose the Information as follows:
- To service providers or Partners that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research and analytics; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) fulfill purchases, orders and user requests; (f) handle payments; (g) host the Site, forums and online communities; (h) administer contests; (i) maintain databases; (j) send or support online or mobile advertising; and (k) otherwise support the Site.
- In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request or similar request.
- With third parties in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Site, or violations of our policies, the law or our Terms of Use, to verify or enforce compliance with the policies governing the Site.
- We may transfer some or all of your Personal Information if we, or one of our business units, undergoes a business transition, like a merger, consolidation, restructuring, acquisition by another company, or sale of all or part of our assets, or if a substantial portion of our or of a business unit’s assets is sold, consolidated, restructured, acquired, or merged in this way, including during any applicable due diligence process.
- We may share your Personal Information with our parent, subsidiaries, and affiliates. As part of this sharing of information with our parent, subsidiaries, and affiliates, this means that once you provide us with information, these entities may use your information, including for marketing purposes, pursuant to the terms of this Policy.
- We may share the Information with unaffiliated Partners and third parties (e.g., our third party service providers, advertisers, advertising networks and platforms, agencies, other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations) that wish to market products or services to you.
Please note that the Site covered by this Privacy Policy may offer content (e.g., contests, sweepstakes, promotions, games, applications, or social network integrations) that is sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain information from their visitors. We have no control over these third parties’ use of this information, which is subject to their own privacy policies.
IV. ADS AND INFORMATION ABOUT YOU
You may see certain ads on our Site because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Site(s), such as the pages you have viewed. This collection and ad targeting takes place both on our Site(s) and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts.
We may also use Tracking Technologies, such as our own cookies, to provide you with personalized online display advertising tailored to your interests. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site. To learn more about how to opt out of Google’s use of the Google analytics cookies, visit, here. To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here. If you would like more information about behavioral advertising practices, go to the Digital Advertising Alliance’s WebChoices tool at www.aboutads.info. To learn about your choices in connection with these practices on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/choices and http://www.aboutads.info/choices. You may also click on the informational icon contained within each interest-based ad. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please see our Cookie Policy for additional information on your opt- out choices.
Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the particular website you are viewing (e.g., contextually based ads). Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.
V. OTHER IMPORTANT INFORMATION ABOUT YOUR PRIVACY
1. How We Respond to Do Not Track Signals
Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed these signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services, but at this time there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. As a result, the Site currently does not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
2. Linked Sites
For your convenience, the Site may contain links to or integrations with other services (such as Facebook, Twitter, or LinkedIn), and other media services and platforms. SpringHill is not responsible for the privacy practices, advertising, products, services, or the content of such other sites, and their information practices may be different than ours. Users should be aware when they leave our Site and should review these other services’ privacy notices if they are asked to give any personal information. None of the links on our Site to other services should be deemed to imply that SpringHill endorses or has any affiliation with the third- party link. This Privacy Policy applies solely to information collected by SpringHill, and not by any other sites or third parties.
3. Visitors to the Site Outside of the United States
Our Site is not intended for visitors outside of the United States. If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. Our Services are governed by and operated in accordance with U.S. law. The data protection laws in the U.S. may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the U.S. If you are located outside of the US, you use this Site and the Services at your own risk. By using the Site or providing us with any information, you consent to your Personal Information being collected, processed, used, stored, and transferred in the U.S. as set forth in this Privacy Policy.
4. Children’s Privacy
SpringHill recognizes the importance of children’s safety and privacy. The Site is not designed to attract children and is not intended for use by children under the age of 13. We do not request, or knowingly collect, any Personal Information from children under the age of 13. Minors under the age of 16 (but older than 12) may use the Site only under the supervision of a parent or guardian who agrees to be bound by the Site’s Terms of Use. If you are the parent or guardian of a child under 13 who has provided her or his information to us, please contact us at legal@springhillcompany.com to request the deletion of that information.
5. Data Security
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information, including physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the Personal Information we collect. These safeguards vary based on the sensitivity of the Personal Information that we collect and store. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic information can be guaranteed 100% secure. As a result, although we take appropriate measures to safeguard against unauthorized disclosures of Information, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk.
6. How to Contact Us/Opting Out of Marketing Communications
If you have any questions or concerns about the online Privacy Policy for this Service or its implementation, or if you would like to opt out from our sharing of your personal Information with unaffiliated third parties for the third parties’ direct marketing purposes you may contact us at legal@springhillcompany.com and request that we opt you out of such sharing. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.
If you receive our e-mails and prefer not to receive marketing information from the Site, follow the “unsubscribe” instructions provided on any marketing e-mail you receive from the Site.
6. How to Contact Us/Opting Out of Marketing Communications
If you have any questions or concerns about the online Privacy Policy for this Service or its implementation, or if you would like to opt out from our sharing of your personal Information with unaffiliated third parties for the third parties’ direct marketing purposes you may contact us at legal@springhillcompany.com and request that we opt you out of such sharing. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.
If you receive our e-mails and prefer not to receive marketing information from the Site, follow the “unsubscribe” instructions provided on any marketing e-mail you receive from the Site.
7. California Residents – Your California Privacy Rights
SpringHill collects certain types of personal information about you as a visitor, user, or consumer. Under California law, if you are a resident of California, you have the right to request certain information that we collect about you, including:
(1) The categories of Personal Information we have collected from you;
(2) The categories of sources from which we collected the Personal Information;
(3) The business purpose we have for collecting or selling that Personal Information;
(4) The categories of third parties with whom we share such Personal Information;
(5) The specific pieces of Personal Information we have collected about you.
In addition, if we sold or disclosed your personal information for a business purpose, you may request that we provide you with:
(1) The categories of Personal Information that we sold about you, and the categories of third parties to whom the personal information was sold, by category or categories of Personal Information for each category of third parties to whom the information was sold; or if we have not sold consumers’ Personal Information; and
(2) The categories of Personal Information that we have disclosed about you for a business purpose, and the categories of third parties to whom the personal information was disclosed, by category or categories of Personal Information for each category of third parties to whom the information was disclosed; or if we have not disclosed consumers’ Personal Information for a business purpose.
As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information or “Do Not Sell.” You also 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:
- 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;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- 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;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
To exercise the access, data portability, Do Not Sell, and deletion rights described in this section, please submit a verifiable consumer request to us by clicking here, or mailing or writing us with your request at the contact information below. Please include “California Privacy Rights” as the subject line. Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You must include your full name, email address, and attest to the fact that you are a California resident by including a California postal address in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in California in order to obtain the information, and you are only entitled to make this request twice a year. We will respond to your request within 45 days or let you know if we need additional time. If you have an account with SpringHill, we may require you to log into that account to make this request.
Email Address:
legal@springhillcompany.com
Postal Address:
The SpringHill Company LLC
1575 N. Gower Street, Suite 150
Los Angeles, CA 90028
We may be unable to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.Please note that certain of your Personal Information may remain in our database even after a deletion request in order to maintain the integrity and historical record of our database and systems.
8. Nevada Residents – Your Nevada Privacy Rights
If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from the springhill company Site, you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).
As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing to legal@springhillcompany.com with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out.
We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond.
9. Your Data Protection Rights Under the General Data Protection Regulation (GDPR)
If you are a resident of or located within the European Economic Area (“EEA”), you have certain additional data protection rights. These rights include:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Information.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where SpringHill relied on your consent to process your personal information.
Legal Basis for Processing Personal Information Under GDPR
SpringHill’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.
SpringHill may process your Personal Information because:
- We need to perform a contract with you;
- You have given us permission to do so;
- The processing is in our legitimate interests and it is not overridden by your rights; or
- To comply with the law.
Retention of Information
SpringHill will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
SpringHill will also retain Usage Data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.
Transfer of Information
Your information, including Personal Information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We may transfer your information to third party processors or service providers in accordance with a written contract that specifies the specific purposes for which the processor may use the information (usually, to fulfill a service they provide to us). SpringHill will take all the steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information, including data processing agreements (“DPAs”) incorporating Standard Contractual Clauses, where necessary.
Disclosure of Personal Information
Disclosure for Law Enforcement – Under certain circumstances, SpringHill may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
SpringHill may disclose your Personal Information in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of SpringHill
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Information
Please note that we may ask you to verify your identity before responding to any data subject access requests.
Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first.
We can be contacted at legal@springhillcompany.com, or:
The SpringHill Company LLC
1575 N. Gower Street, Suite 150
Los Angeles, CA 90028
For more information, please contact your local data protection authority in the EEA.
VI. UPDATES TO THIS PRIVACY POLICY
From time to time, we may update this Privacy Policy. In such event, we will post the policy changes in our Privacy Policy on the Site, and they will become effective on the date posted. We encourage you to periodically check back and review this policy so that you always will know what information we collect, how we use it, and with whom we share it.
DATA ACCESS REQUEST / DATA REMOVAL REQUEST