This Privacy Notice describes how Sphere Laboratories, Inc. and its subsidiaries, including Symmetry Financial Technologies, LLC and Arcadia Financial Technologies, LLC (“we,” “us,” “our”) collects, uses and discloses information about you when you use our website (https://spherepay.co), applications, services, tools and features, or otherwise interact with us (collectively, the “Services”).  For this Privacy Notice, “you” and “your” mean you as the user of the Services.

For the purpose of applicable data protection laws, we act as the data controller. If you wish to exercise your data protection rights, you may contact us or our appointed representatives at:

EEA Representative: Adam Brogden, Office 2, 12A Lower Main Street, Lucan, Co. Dublin, K78 X5P8, Ireland, the EEA portal or contact@gdprlocal.com

UK Representative: Adam Brogden, 1st Floor Front Suite, 27–29 North Street, Brighton, England, BN1 1EB, the UK portal, or contact@gdprlocal.com.

US Representative: Data Protection Officer, 8 The Green, #22219, Dover, DE 19901, USA or privacy@spherepay.co.

Please read this Privacy Notice in full.  By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice.  If you do not understand or agree to this Privacy Notice, please do not use or access the Services.
Our U.S. Consumer Privacy Notice applies to information that we collect about U.S. individuals who seek, apply for, or obtain our financial products and services for personal, family, or household purposes.

Changes to This Privacy Notice

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

3. Collection and Use of Information

When you use or access the Services, we collect certain categories of information about you from a variety of sources. In addition to the specific uses discussed below, we may use this information to provide and improve the Services and to maintain our business relationship, as a matter of our legitimate interests, including by enhancing the safety and security of our Services, providing customer support, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting our rights and the rights of our employees, users or other individuals.

Information You Provide to Us

Some features of the Services may require you to directly provide certain information, including information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

• Basic contact details, such as name, address, phone number, and email. We use this information to create and maintain your account and provide the Services, as required to perform our contract with you, and because it is in our legitimate interest to communicate with you (including to tell you about products or services that may be of interest to you, to the extent you have consented to receiving marketing communications from us).
• Account information, such as username, password, security questions that you select and the answers you provide. We use this information to provide the Services, as required to perform our contract with you, and because it is in our legitimate interest to maintain and secure your account with us. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend that you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Financial Accounts, such as linked deposit, asset and other financial accounts and balances and assets in such accounts. We use this information to provide the Services.
• Payment information, such as bank account, credit or debit card details, and billing address. We use this information to process your payment and provide the Services, as required to perform our contract with you.
• Applicant details, such as information included in your resume, CV, references, and job history. We use applicant details to process your application for employment, and it is in our legitimate interest to evaluate your candidacy.
• User-content, such as messages, photos, and recordings, submitted by you through our services. We or others may store, display, reproduce, publish, or otherwise use such content, and may or may not attribute it to you. Others may also have access to such content and may have the ability to share it with third parties. If you choose to submit content to any public area of the Services, your content will be considered “public” and will be accessible by anyone, including us.
• Any information you choose to input into our AI-powered tools (“Input”), which we use to generate and output new information or content (“Output”) as a part of the Services. We may also use Input and Output to improve the Services, including by training or fine-tuning the AI models that power such tools.
• We may become aware of personal history, account information, contact information, and criminal history during our financial crime checks, such as anti-fraud procedures and anti-money laundering checks, including information received from public sources. We will process this data in connection with our legal obligations and for the detection and prevention of crime.
• Any other information you choose to include in communications with us, for example, when sending a message through the Services, because it is in our legitimate interest to be responsive to you.

Information Collected Automatically

We and third parties may also use cookies, pixels or other tracking technologies to automatically collect certain information about your interactions with the Services. This information is collected and used either with your consent (for example, to personalize the Services for you, and to target, deliver and measure interest-based advertising) or because it is in our legitimate interests to tailor your experience with the Services, provide you with offers or promotions, run analytics, better understand user interactions with the Services, etc. Such information includes:

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.
• Location information, such as approximate location / precise geolocation, if you choose to provide it.
• Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data, interactions with marketing emails, and ad impressions.

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies. If you so choose, you may block or delete certain of our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers.

Information Collected From Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes:

• Financial account, payment and asset data we receive from partnering financial institutions or from providers that facilitate linking your financial or third party account to the Services.
• Analytics data we receive from providers such as Google Analytics, which we use in our legitimate interests to improve our website, communications and the Services.
• Information we receive from career websites, such as LinkedIn, which we use in our legitimate interests to process your application for employment.
• Information we receive from consumer marketing databases or other data enrichment companies, which we use in our legitimate interests to better customize advertising and marketing to you.

Information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third-Party Websites and Links.

Deidentified Information

Finally, we may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been deidentified/anonymized), and we may use such deidentified/anonymized information for any purpose.

4. Disclosure of Your Information

We may disclose your information for legitimate purposes subject to this Privacy Notice, including the following categories of third parties:

• Our affiliates or others within our corporate group, as a matter of our legitimate interests to efficiently provide the Services.
• Financial institutions, exchangers and payment processors that facilitate any transaction you may request through the Service.
• Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
• Third parties for their own marketing purposes based on your consent.
• Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets or login integration, with your consent or to perform our contract with you.
• Professional advisors, such as auditors, law firms, or accounting firms, as a matter of our legitimate interests to assess, protect, enforce and defend our rights and to comply with our legal and regulatory obligations.
• Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction, as a matter of our legitimate interests to run a successful and efficient business.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or in our legitimate interests to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

5. Social Features

Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features may include features that allow you to access our pages on third-party platforms, and from there to “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Third-Party Websites and Links.

6. Third-Party Websites and Links

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

7. Children’s Privacy

Our Services are not intended for children, and we do not seek or knowingly collect any personal information about children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the information below to request that it be deleted.

8. Data Security and Retention

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products. In particular, we retain certain of your information as follows:

• your account data for as long as you keep your account open or as needed to provide you with our Services;
• if you contact us, we will keep your data for [60] months after you contact us;
• your technical usage information for [60] months;
• data on your use of our Services is retained for [60] months; and
• records relating to transactions or activity subject to U.S. sanctions review, including potential or confirmed OFAC list matches, for [120] months.

9. Data Transfers

We are based in the United States. If you are using the Services from outside the United States, please be aware that the information we collect from you may be transferred to, stored and processed in the United States or other countries outside your country of residence.

10. Privacy Rights

Depending on where you live, you may have certain rights in relation to your personal information. Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law.

• Access / Know: You may have the right to request access to the personal information we hold about you, and to obtain information about how we use it, and with whom we share or have shared it in the past.
• Deletion / Erasure: You may have the right to request that we delete personal information we hold about you.
• Correction: You may have the right to correct inaccurate personal information we hold about you.
• Portability: You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party.
• Restriction of Processing: You may have the right to require us to stop, suspend or restrict our processing of personal information we hold about you.
• Objection: You may have the right to object to our processing of your personal information.
• Opt-Out of Marketing: You may opt out of marketing at any time by using the unsubscribe / opt-out function displayed in our communications to you. Please note that if you opt out, we may still send you transactional or administrative messages, such as emails about your account.
• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent at any time.

To make a request described in this Section, please contact us at the email address listed below. You may also have the right to complain to your local data protection authority about how we process your personal data. Of course, we hope you will contact us first so we can resolve any issues.

11. How to Contact Us

Should you have any questions about our privacy practices or this Privacy Notice, please email us at support@spherepay.co or contact us at:

8 The Green #22219, Dover, DE 19901

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