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This Privacy Policy describes how Spots Development Group, LLC (referred to in this
Privacy Policy as “Spots,” “Company,” “we,” “us,” or “our”) collects information when you use
the website located at (the “Site”) and the Spots mobile application
provided by Spots on which a link to these Terms of Service is provided (the Site and mobile
application are referred to collectively in this Privacy Policy as the “Service”). It also explains
how we use and disclose the information we collect from you, and your rights in relation to
that information.

By accessing, visiting or using the Service, you expressly consent to our collection, storage,
use and disclosure of your information as described in this Privacy Policy. Please note that if
you disagree with any of the terms in this Privacy Policy, you must not use the Service. This
Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Spots
Terms of Service located at

Data Collection & Use

A. Information You Directly and Voluntarily Provide to Us.

You can access
the Service without submitting information to us, however, in order to access certain content
and functionality on the Service you will need to become a registered user of the Service, and
you will be required to provide your email address as part of the registration process. In
addition, we may collect information that you provide to us when you communicate with any
of our departments such as customer service or technical services.

B. Information Automatically Collected from You.

We may automatically
collect information about you when you use the Service. For example, when you access the
Service through a mobile device, we may be able to identify the location of your mobile
device. You may choose not to share your location details with us by adjusting your mobile
device’s location services settings. For instructions on changing the relevant settings, please
contact your service provider or device manufacturer. We may automatically collect
information from you when you use the Service using “cookies”. Cookies are small amounts
of data that are stored within your computer’s Internet browser and that are accessed and
recorded by the websites that you visit so that they can recognize the same browser
navigating online at a later time.

Information that may be collected by cookies when you use the Service may include,
without limitation:

  • the date and time of your visit to the Service;
  • the amount of time you spend using the Service;
  • the Internet Protocol (IP) address used to connect your computer to the
    Internet; and/or
  • your computer and connection information such as your browser type and
    version, operating system and platform.

C. Information You Publicly Post through the Service.

If you post information
on public areas of the Service that information may be collected and used by Spots, other
users of the Service, and the public generally. We strongly recommend that you do not post
any information through the Service that allows strangers to identify or locate you or that you
otherwise do not want to share with the public.

D. Information Provided Through Social Media Services.

We may provide
you with the option of logging in to the Service using a third party social media service, like \
Facebook Connect. By logging in to the Service through a third party social media service
you give us permission to access, store and use any information that you permit the
applicable third party social media service to share with us in accordance with the privacy
policy of that social media service and the privacy settings that are applicable to your
account. We encourage you to review, and if necessary, adjust, your privacy settings on the
applicable social media service before logging in to the Service through a social media
service. Information that we receive from third party social media service is stored and used
by Spots in accordance with this Privacy Policy.

E. How We Use the Information We Collect from You.

We and our service
providers may use the information you provide or that is collected through the Service to
operate and improve the Service, our other sites, applications, products and services, or to
contact you from time to time to provide you with important information, notices and
marketing promotions relating to the Service. If you wish to opt-out of receiving marketing
communications from us by email, please follow the instructions contained in each email you
receive from us describing how you can opt-out of receiving further marketing
communications from us by email.

2. Collection of Information by Third Parties.

A. Analytics.

We may work with analytics companies to help us understand
how the Service is being used, such as tracking the frequency and duration of use of the
Service. We may use Google Analytics, an analytics service provided by Google, Inc.
(“Google”), to collect information about your use of the Service. Google may collect
information about the content you view and your system information and geographic
information. The information generated by Google about your use of the Service will be
transmitted to and stored by Google. The information collected by Google allows us to
analyze your use of the Service. The information collected by Google and these other
analytics companies allows us to analyze your use of the Service.

We encourage you to review your device and Service settings to ensure they are
consistent with your preferences, including with respect to the collection and use of
information. You may be able to stop further collection of certain information by the Service
by updating your applicable device settings, or you may uninstall the Service. In addition, you
may choose not to share your location details by adjusting your mobile device’s location
services settings. For instructions on changing the relevant settings, please contact your
service provider or device manufacturer.

B. Third Party Links and Content.

In addition, the Service may include third-
party advertising, links to third party websites, and other content from third-party businesses.
These third-parties may use cookies and web beacons to track the actions of users online
over time and across different websites or platforms to deliver targeted electronic
advertisements to an individual user. For information about how tracking works for online
advertising purposes you can visit We do not have
access to or control over web beacons or cookies that third party websites may use. We are
not responsible for the privacy practices or the content of these third-party websites. You are
encouraged to review the privacy policies of the different websites you visit. In addition, some
third-party advertising companies may provide a mechanism to opt-out of their technology.
For more information about the opt-out process, you may visit the Network Advertising
Initiative website, available at:

C. Do Not Track Requests.

The Service does not currently incorporate
functionality that would permit you to submit a “do not track” request. If we subsequently
incorporate functionality that allows you to submit “do not track” requests, we will update this
Privacy Policy to provide additional information about how we respond to those requests.

D. Payment Processors.

If you make a purchase through the Service, you may
be able to pay using a third party payment service, such as Stripe, PayPal, Apple Pay or
other third party payment services. All information collected by these third party payment
services for purposes of processing your payments is not available to us, unless you have
otherwise provided this information to us in connection with your use of the Service.
Information collected from you by these third party payment services is governed by the
applicable third party payment service’s privacy policy. You should review the applicable
privacy policy prior to submitting any information to the applicable third party payment

3. Social Media Services.

The Service may use social networking or “share
functionality” or may contain links to third party social media sites that are not owned or
controlled by Spots. Your use of these features may result in the collection or sharing of
information about you by these sites, depending on the feature. Spots has no control over,
and assumes no responsibility for, any share functionality or the content, privacy policies, or
practices of any third-party site. You are subject to the policies of those third parties when
and where applicable. We encourage you to review the privacy policies and settings on the
social media sites with which you interact to make sure you understand the information that
may be collected, used, and shared by those sites.

4. Children Under Age 13.

The Service is not intended for children under age 13. We do not knowingly collect or distribute
personal information from or about children under the age of 13.

5. How We Share Your Information.

We do not sell or rent personal information we
collect through the Service to any third parties for their own marketing purposes. In the event
we want to sell or rent your personal information to third parties for their own marketing
purposes in the future, we will notify you and you will have an opportunity to affirmatively opt-
in to receiving these third party marketing communications. We may share the information
you provide or that we collect in some circumstances as follows:

A. Service Providers.

We may share your information with our service providers
who work on our behalf. For example, these service providers may handle payment or credit
card processing, data management, feature administration, email distribution, market
research, information analysis, and promotions management. These service providers will
only have access to the information needed to perform these limited functions on our behalf.

B. Response to Subpoenas or Court Orders or to Protect Rights and to
Comply with Our Policies.

To the extent permitted by law, we will disclose your information
to government authorities or third parties if: (i) required to do so by law, or if requested in
response to a subpoena or court order; (ii) we believe in our sole discretion that disclosure is
reasonably necessary to protect against fraud, to protect the property or other rights of us or
other users, third parties or the public at large; or (iii) we believe that you have abused the
Service by using it to attack other systems or to gain unauthorized access to any other
system, to engage in spamming or otherwise to violate applicable laws or in violation of our
Terms of Service. You should be aware that, following disclosure to any third party, your
information may be accessible by others to the extent permitted or required by applicable law.

C. Business Transfers; Bankruptcy.

In the event of a merger, acquisition,
bankruptcy or other sale of all or a portion of our assets, any user information owned or
controlled by us may be one of the assets transferred to third parties. We reserve the right, as
part of this type of transaction, to transfer or assign your information and other information we
have collected from users of the Service to third parties. Other than to the extent ordered by
a bankruptcy or other court, the use and disclosure of all transferred user information will be
subject to this Privacy Policy. However, any information you submit or that is collected after
this type of transfer may be subject to a new privacy policy adopted by the successor entity.

D. Analytics Companies.

We may share your information with analytics
companies as described above in Section 2(A) for purposes of analyzing your use of the

6. Managing Your Information.

If you’d like us to delete or update information that you
have provided through the Service, please contact us at Please note that
some or all of the information you provided may be required in order for the Service to
function properly or may be retained in backup storage.

7. Use of Information Outside Your Country of Residence.

The Service is directed
to users located in the United States. If you are located outside of the United States and you
choose to use the Service or provide your information to us, your information may be
transferred to, processed and maintained on servers or databases located in the United
States. Your use of the Service represents your consent and agreement to these practices.
If you do not want your information transferred to or processed or maintained in the United
States, you should not use the Service.

8. Security.

We provide industry-standard physical, electronic, and procedural
safeguards to protect information we process and maintain. Please be aware that, although
we endeavor to provide reasonable security for information we process and maintain, no
security system can prevent all potential security breaches. As a result, we cannot guarantee
or warrant the security of any information you transmit on or through the Service and you do
so at your own risk.

9. Updates to this Privacy Policy.

We will notify you of material changes to this Privacy
Policy at least thirty (30) days before the effective date of the changes. If you do not agree to
the changes, you should discontinue your use of the Service prior to the time the modified
privacy policy takes effect. If you continue using the Service after the modified privacy policy
takes effect, you will be bound by the modified privacy policy.

10. Contact Information.

If you have questions about this Privacy Policy, you may
contact us at We will do our best to
respond to you in a timely and professional manner to answer your questions and resolve your concerns.