Here at North Spur we consider the protection of your information to be a paramount responsibility that guides our
day-to-day behaviors. In this Privacy Policy, we want to transparently convey to you our responsibilities vis-a-vis the
information you generate when you use our websites ( or
the websites of any of our affiliates) (“Sites”) or any applications generated or provide by North Spur (“Apps”; and,
together with the Sites, collectively the “Service”).

We will take reasonable steps to protect your privacy consistent with the guidelines set forth in this policy and with
applicable laws. To be clear about the terminology we are using, when we say “personal information” in this Privacy
Policy, we mean information that allows someone to identify or contact you, including, for example, your name, address,
telephone number, e-mail address, username, unique device identifier or other device identifier (“UDID”), as well as any
other non- public information about you that is associated with or linked to any of the foregoing information. When we
use the phrase “anonymous information” in this Privacy Policy, we mean information that is not associated with or linked
to your personal information. Anonymous information does not enable identification of or contact with individual

1. Information We Collect and Receive
  • Information You Provide: We collect personal information from you when you choose to share it
    with us. This may include when you visit one of our Sites or Apps, create an account or profile with us, sign up
    for newsletters or our email list, sign up to receive email or text message updates from us, participate in a
    survey or promotion, refer a friend to use our Service, post a rating or review, post comments or other content
    on our Sites or Apps, sign up to be a volunteer or host an event, apply for a job or internship, participate in
    any interactive forums or features that we offer through our Service, or otherwise contact or request
    information from us.The personal information we collect may include, but may not be limited to:

    • Contact information, such as your name, address, email address, telephone or mobile number;
    • Date of birth;
    • Screen or user name for our Sites or Apps;
    • Photograph, such as when you choose to create a profile avatar or engage in one of our social media
    • Demographic information;
  • Communications: When you communicate with us by sending us an email, we will collect and store
    any information that is contained in your communications with us.We collect the following types of anonymous
  • Log data: When you use the Service, our system may automatically record information including
    information that your browser sends whenever you visit a website or your mobile app sends when you are using it.
    This log data may include your Internet Protocol (IP) address, the address of the web page you visited before
    arriving at the Service, your browser type and settings, the date and time of your request, information about
    your browser configuration and plug-ins, language preferences, and cookie data.
  • Device information: In addition to log data, we may also collect information about the device
    on which you are accessing the Service, including what type of device it is, what operating system you are
    using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this
    information often depends on what type of device you are using, and its settings.
  • Geo-location information: Wifi and IP addresses received from your browser or device may be
    used to determine approximate location.
  • Usage data: This is information about how you use the various capabilities and features of
    the Service. We use this information to better understand opportunities to improve the quality of the
    service we provide to you.
  • Information from partners or other third parties: North Spur may receive information from
    partners or others to help make our own information better or more useful. For example, North Spur mobile
    applications use Google Analytics to upload information about which features you use, but that information
    will never be connected to your identity, your devices, or your documents.
2. Cookie Policy

North Spur uses cookies or similar technologies to record log data and otherwise to make your interactions with the
Service easy and optimally effective. We use both session-based and persistent cookies.

Cookies are small text files sent by us to your computer or other device and from your computer or other device to us,
each time you visit our website. They are unique to your North Spur account or your browser or app. Session-based
cookies last only while your browser or app is open and disappear from your device when you close your browser software
or app or turn off your device. Persistent cookies remain on your device after you close your browser or app or turn off
your device — and last until you or your browser delete them or until they expire.

Some cookies are associated with your North Spur account and personal information in order to remember that you are
logged in. Other cookies are not tied to your North Spur account but are unique and allow us to do site analytics and
customization, among other things. If you access the Service through a browser, you can manage your cookie settings
there, but if you disable cookies you may not be able to use the Service effectively, or at all.

North Spur sets and accesses our own cookies on the Service. In addition, we use third party vendors who set and access
their own cookies to assist us with various activities (e.g., we use Google Analytics to help us monitor our website
traffic). The use of these cookies by third parties is not covered by our Privacy Policy; the information generated by
the cookies about your use of the Service (including your IP address) will be transmitted to and stored by Google under
its own privacy policy: We do not have access or control
over these cookies. For example, Google Analytics collects only the IP address assigned to you on the date you visit the
Service, rather than your name or other personal information. We do not combine the information generated through the
use of Google Analytics with your personal information. Although Google Analytics plants a persistent cookie on your web
browser to identify you as a unique user the next time you visit the Service, the cookie cannot be used by anyone but
Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Service is
restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You may refuse the use of cookies by
selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use
the full functionality of the Service.

3.How We Use Your Information

We use your information for the following:

  • Providing the Service: We use information you provide to authenticate you, provide the Service, storage and
    other services.
  • Compliance and investigations: We reserve the right to use data in connection with investigations of suspected
    inappropriate use, fraud, or any other activity that threatens to impede North Spur and/or its users’ ability to
    use the Service efficiently and effectively.
  • Communicating with you: We will occasionally send you tailored communications based on information you include
    in your profile, or your use of the Service. You can manage the frequency and/or opt out of receiving these
    communications by changing your settings on the Service and/or clicking the “Unsubscribe” link at the bottom of
    each email. We also will send you service and administrative emails, for which you may not opt out.

We may also use your personal information to create anonymous information records by excluding information that makes
the information personally identifiable to you.

Generally, we use anonymous information in statistical analysis to help us analyze patterns in the use of our Service.
We may, through our use of cookies, keep you logged into our website, collect your click-stream data, tailor web content
to you and personalize your experience on the website. We may also use your anonymous information to improve our
internal operations, and notify visitors of updates to our Service.

4. Sharing and Disclosure

As noted previously, North Spur culture emphasizes respect for your privacy. Consistent with that cultural value, we do
not sell or rent your personal information to any third party except in the event of a change in control as described
below. We limit our sharing of the information we collect and receive from you to the following circumstances:

  • Account Support: To provide you with customer support, our staff may need to share among themselves information
    you previously have provided to us.
  • Legal Compliance and Public Protection: We will share your information when we believe disclosure is reasonably
    necessary to comply with a law, regulation or legal request; or to protect the safety, rights and/or property of the
    public or any person.
  • Integrity of North Spur Service: We will share your information as appropriate to detect, prevent, and/or
    address fraud, security or technical issues, or otherwise to protect North Spur and its user community.
  • Third Parties and Agents: We may employ third party companies or individuals to help us provide the Service and
    they may process personal information on our behalf. For example, we may share data with a security consultant
    to help us get better at preventing unauthorized access or with an email vendor to send messages on our behalf.
    We also may share data with hosting providers, payment processors, marketing vendors, and other vendors and
    consultants who work on our behalf and under contractual promises of confidentiality.
  • Change in Control: North Spur may share your personal information in connection with or during negotiation of
    any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer,
    divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency,
    bankruptcy, or receivership, personal information may also be transferred as a business asset. If another
    company acquires our company, business, or assets, that company will possess the personal information collected
    by us and will assume the rights and obligations regarding your personal information as described in this
    Privacy Policy.
    Affiliates. North Spur may share your personal information to any subsidiaries, joint ventures, or other
    companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to
    honor this Privacy Policy.
  • Partners. We may also share your personal information with our authorized partners for the purpose of further
    supporting your use of the Service, and for co-marketing activities. All such authorized partners are required by
    North Spur to provide you with a means of opting out of some or all of their communications with you.
  • Aggregated and Non-Identifiable: North Spur may share aggregated or non-personally identifiable information with
    our partners or others in our sole discretion, including for business or research purposes.
  • Communicating With You: We will occasionally send you tailored communications based on information you include
    in your profile, or your use of the Service. We also will send you service and administrative emails. You have
    an ability to opt out of certain of these communications.

Service Visitors from Outside the United States: North Spur and its servers are located in the United States and are
subject to the applicable state and federal laws of the United States. If you choose to access or use the Service, you
consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.

5. Changes to Privacy Policy

We may change this Privacy Policy from time to time. We will prominently post any changes we deem to be material, and/or
otherwise ensure that you are aware of them. If you continue to use the Service after any changes are in effect, you
will be deemed to agree to the revised policy.

6. Third Party Websites

This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the
Service. If you disclose information to others, or authorize us to do the same under this Privacy Policy, the use and
disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the
privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.
The Service may contain content or links to other websites that are not owned or controlled by us. We have no control
over, do not review and are not responsible for the privacy policies of or content displayed on such other websites.
When you click on such a link, you will leave our Sites and go to another site. During this process, another entity may
collect personal information or anonymous information from you. The Service may also contain links to other websites
controlled by us but which operates under different privacy policies. Please review the privacy policy of any new site
you visit.

7. Children

North Spur does not knowingly collect or maintain personally identifiable information from persons under 18 years of
age, and no part of the Service is directed at persons under 18. If you are under 18 years of age, then please do not
use the Service. If North Spur learns that personally identifiable information of persons less than 18 years of age has
been collected without verifiable parental consent, then North Spur will take the appropriate steps to delete this
information. To make such a request, please contact us at

8.Questions or Concerns

Any questions or concerns regarding the use or disclosure of your information should be directed to North Spur by
sending an email to We will investigate and attempt to
resolve complaints and disputes regarding use and disclosure of your information in accordance with this Privacy Policy.