Privacy Policy

Spirit Funds LLC d/b/a NetPicks — Privacy Policy

Our Commitment to You

If you have questions or comments about this Privacy Policy, please contact Customer Support by phone or email. Please visit our Contact Us page for contact information. Please reference our Privacy Policy, 17b Disclosures, SMS Terms and Terms. We are not investment advisors or broker-dealers. The content and information contained in email, text messages, social media, online communication or on our website is purely for informative purposes, and not to be treated as a recommendation to make a specific investment.

Spirit Funds LLC d/b/a NetPicks, LLC (collectively, "Netpicks," "our," "we," or "us") values and respects the privacy of its customers and visitors. While operating our business and interacting with you, we collect, use, and share personal information as disclosed in this privacy policy ("Privacy Policy").

This Privacy Policy provides you with detailed information about how Netpicks and its subsidiaries, divisions, affiliates, brands and other companies that link to this Privacy Policy collect, use, share, and protect personal information, and describes your choices and rights. This Privacy Policy also applies to personal information we receive from business partners and other third parties. We encourage you to read this Privacy Policy carefully and if you have any questions to contact us using the methods listed below.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes will be reflected in a revised policy posted on the website and we will alert you that there has been a change by updating the "Revised" date displayed on the Privacy Policy. If Netpicks determines that such changes materially affect your privacy rights, we will provide additional notice to you.

Collecting Your Information

We may collect information about you in a variety of ways but generally speaking it is done either through: (1) information that you provide to us, (2) data we receive from our trusted partners about you or (3) you visiting our websites. The types of information we may collect include, but are not limited to:

Information You Provide To Us

This is personal information you choose to provide in connection with completing an online form, providing content on the Site, or other activities in which you participate on the Site, such as your name, age, phone number, location, and survey information.

Information We Are Provided By Third Parties

This is personal information we receive from our third party partners. This includes your name, age, email address, and phone number.

Information We Collect About You

Information our servers automatically collect when you contact us or visit, use, or browse the Site, such as your IP address, your operating system, browser version, the address of a referring website, the pages you visit on the Site, the dates and times you visit the Site, device and usage information, such as language preferences, referring URLs, country, location, information about how and when you use our services and other technical information. If you access the Site from a mobile device, information about the type of mobile device you use.

In order to collect this information, the Site may use cookies, web beacons, and other tracking technology, depending on the features offered. Tracking technology is useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help us customize the Site and improve your experience. If you previously provided personally identifiable information to us, a unique identifier in the cookie may tie the information collected via the cookie to such information. Aggregate cookie and tracking information that does not directly identify you may be shared with third parties.

Also, some content on the Site may be provided by third parties that may use cookies in conjunction with other tracking technologies to collect information about you when you use the Site, which enables them to provide targeted advertising to you. We do not control these third parties' tracking technologies or how they may be used.

We may display certain advertising offers on the Site or allow service providers, advertisers, ad networks, or other third parties to advertise on the Site. Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies, web beacons, or similar tracking technology to help manage and optimize your online experience with us.

Most web browsers are set to accept cookies by default. You can usually choose to set your browser to disable or reject cookies. Be aware that disabling or rejecting cookies could affect the availability and functionality of the Site or certain portions of the Site. Also, please note that we may still use information we've collected from cookies prior to your disabling them; however, we will not collect any further information from the disabled cookies.

Using Your Information

Any information collected about you may be used to: help increase the efficiency and operation of our business; deliver and improve our products and services; manage our business; monitor and analyze usage and trends to improve our business and the user experience; generate a personal profile of you to make future engagement more personalized; perform the functions and services our clients request; send you confirmations, updates, alerts, administrative messages, and otherwise facilitate your use of the Site; request feedback and contact you about your use of our services or our clients' services; respond to your emails; compile anonymous statistical information and analyses, which we may use internally and/or provide to third parties; to support our customers and their interactions with you through our Services; market our services (and those of third parties) to you that we believe may be of interest to you; and deliver information to you that you request or that we think may be of interest to you, such as articles, news, or information about various promotions.

Sharing Your Information

We may share your information with third parties that perform services for or on our behalf for business purposes that include: (A) to match with a third party partner, (B) to perform analytics on the personal data that is provided to us, (C) when it is shared as part of a transfer of assets, (D) for security and fraud purposes, and (E) when we are required by law to share it.

Match With a Third Party Partner

Netpicks shall only provide web form submitted answers with a third party partner if you provide your express consent.

Analytics

We may allow selected service providers or processors to use tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Transfer of Assets

If we reorganize or otherwise transfer some or all of the Site or our assets to another organization (such as in the course of a merger, dissolution, or liquidation), your information may be shared with the transferee; however, we will ask the transferee to honor commitments we made in this Privacy Policy.

Security and Fraud

We allow third parties to receive personal information from our users to provide both security and fraud protection to Netpicks. We do not control these third parties or how it is used.

Required By Law

We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process or as we deem necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of Netpicks or others, as we deem appropriate.

Netpicks does not sell your data in exchange for monetary consideration. In order to support tailored advertisements, offers, or content that you may find interesting when you browse the internet, Netpicks may share certain personal information with our trusted third-party partners that support online advertising, data co-operatives, mobile advertising, data analytics, social media engagement, data brokers advertising networks or any other activity that may be considered cross-behavioral advertising. This transfer could be defined as cross-context behavioral advertising or targeted advertising. You may opt-out of such activity by contacting us by either phone, email or direct mail. Please visit our Contact Us page for additional contact information.

Policy for Children

We do not use the Site to solicit information from or market to children under the age of 18. By using the Site, you represent that you are at least 18 years of age. We encourage parents and legal guardians to monitor their children's internet usage and to instruct their children never to provide personal information through the Site or any other website without parental consent. If you believe a child has provided personal information to us via the Site, please contact us and we will use reasonable efforts to locate and delete the information.

Do Not Track Signals

Do Not Track ("DNT") is a privacy preference that users can set to have their Internet browser automatically send a signal to our online and mobile resources to request we not track browsing activity across different sites. There is, however, currently no universal standard for sending and receiving DNT signals. As such, we cannot promise that we respond to all DNT signals, but do recognize and respond when required by applicable privacy laws, such as when HTTP header fields or Java objects are used.

Submitting Information From Outside The United States

We control and operate the online and mobile resources from within the United States of America (the "U.S."). Information collected through the Website and Services may be stored and processed in the United States or any other country in which our vendors or we maintain facilities. Although we do not actively block or monitor visitors from other countries, the Website is directed only at visitors from the U.S. As such, this Privacy Policy is consistent with U.S. law and practice and is not adapted to other laws (including European data security and privacy laws). Netpicks will apply the applicable laws of the U.S., including as embodied in this Privacy Policy in place of data protections under your home country's law. That is, you freely and unambiguously acknowledge that this Privacy Policy, not your home country's laws, controls how we will collect, store, process, and transfer your personal information. Similarly, the English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt.

Links to Other Websites and Third Party Practices

This Site may contain links to third party websites. It is our intent to provide links only to other quality websites. However, we have no control over these linked websites or, for that matter, any third parties. Any information collected by websites, other than the Site, is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites that may be linked to or from the Site. We encourage you to read the provisions of privacy policies on other websites before providing them with your personal information.

Exercise Your Privacy Rights

Netpicks takes privacy seriously. Where applicable, data subjects have certain rights which they can request for Netpicks to fulfill. These requests can be made by either the data subject or an authorized agent. These rights include:

1. The Right to Know. You have the right to request that Netpicks disclose the personal data that Netpicks has collected about you;
2. The Right to Amend. You have the right to correct any information that Netpicks stores about you;
3. The Right to Delete. You have the right to request that Netpicks delete information that it maintains about you, subject to certain exceptions; and
4. Right to Opt-Out of Targeted Advertising. You have the right to request that Netpicks opt you out of targeted advertising.

In order to exercise any of the rights detailed above, please contact Customer Support by phone or email, visit our Contact Us page for contact information. We will use your email as proof of verification unless otherwise prohibited. Exercising your rights under this section will not result in any discrimination by Netpicks. We will treat you the same as any other user. If you disagree or dispute a decision that has been made on the scope or application of the rights described in this clause, you may appeal this decision by contacting our Customer Support by phone or email.

Retention Period

Netpicks shall only store personal information for as long as it is required. This is determined by considering the purposes for which it was obtained in accordance with applicable laws. Our retention period is based on (1) the nature of our relationship with the data subject and (2) any legal obligations we are bound to fulfill.

Contact Us

If you have questions or comments about this Privacy Policy, please contact Customer Support by phone or email. Please visit our Contact Us page for contact information.