PRIVACY POLICY

This Privacy Policy was last updated on July 6, 2022.


We know that your privacy is important to you, and we work hard to earn and keep your trust.  Spoke Custom Products, LLC (d/b/a Spoke Custom) (collectively with its subsidiaries, “Company,” “we,” “us,” and “our,”), respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “ Privacy Policy”). 


This Privacy Policy addresses our use and disclosure of the information we collect from you, which includes personal information (“Personal Information”) and also non-personal information.  This Privacy Policy applies to our website available at  www.spokecustom.com as well as any websites and blogs directly owned by the Company.


This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Links to Other Websites”). 


Please read this Privacy Policy carefully to understand our practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, then please do not use our Website.  By using our Website, you agree to the terms of this Privacy Policy.  This Privacy Policy may change from time to time (see below, “Changes to this Policy”).  Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

SUMMARY OF OUR PRIVACY POLICY IN PLAIN ENGLISH

  • Data security is important to us.  We collect personal information (see below, "What We Collect") when you use our web site of services because we need it to communicate with you and provide you with our services (see below, "How We Use The Information We Gather").

  • We do not resell customer or user data to any third parties, ever.  When we do share any user information with their parties it is for the explicit purpose of delivering or improving our services.  When we share information with third parties, we require they adhere to our rules for data protection, including prohibiting them from sharing or reselling this data to any third party. (see below, "How We Share The Information We Gather")

WHAT WE COLLECT

In the course of using Company as a preferred supplier, using our Website and in responding to our surveys, you may have the opportunity to voluntarily submit Personal Information.  Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device. We strive to limit the information collected about you to what is needed for conducting our business and offering products and services that might be of interest to you.  We may collect the following Personal Information from users of the Website:

 

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. For example, when you:

    • register yourself with the Website;

    • subscribe to one of our e-newsletters;

    • communicate with us, such as request information.

  • Indirectly from you. For example, through information we collect from you in the course of providing our services to you.

  • Directly and indirectly from activity on our Website. For example, from Website usage details that are collected automatically, such as information, including non-personal information, about your visits to the Website and telling us what website you came from.  For more information on automatic information collection, please review the “How We Use Cookies” section below.

The information that you provide in each case will vary.  In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting Company to request further information.  When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers or other sensitive personal data, unless required for our services. When you send us an email message, we will retain the content of the email, your email address, and our response, in order to handle any follow-up questions you may have. We also use it to measure how effectively we address your concerns. Email messages sent to our Website may not be secure. You should not send confidential information by email. If you choose to do so, you accept the risk that a third party may intercept email messages.

HOW WE USE COOKIES

When you access the internet, the computers that host websites you visit (web servers) automatically receive some anonymous information. This "usage data" may include a record of a browser type, which pages a web browser has visited, and an IP address. Company's servers receive usage data when customers visit our Website. Company may use various kinds of software devices to collect information about the internet use related to our Website.  Some of the tools we use to automatically collect information about you may include:

(a)   Cookies.  A “cookie” is a small data file transmitted from a website to your device’s hard drive.  Cookies are usually defined in one of two ways, and we may use either (or both) of them: 

1.   session cookies, which do not stay on your device after you close your browser, and

2.  persistent cookies, which remain on your device until you delete them or they expire. 

We use the following categories of cookies on our Website.

i.   Strictly Necessary Cookies.  These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items (e.g. a shopping cart), cannot be provided.

ii.   Performance Cookies.  These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.

iii.   Functionality Cookies.  These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized.  These cookies cannot track your browsing activity on other websites.

iv.   Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign.  The cookies are usually placed by third-party advertising networks.

A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website’s functions or features.

(b)   Google Analytics.  The Website sends aggregated, non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance.  For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

 

(c)   Web Beacons.  A Web Beacon is an electronic image.  Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior.  If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails.  We may also use them to track if you click on the links and at what time and date you do so.  Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website.  This information is only collected in aggregate form and will not be linked to your Personal Information.  Please note that any image file on a webpage can act as a Web Beacon.

(d)   Embedded Web Links.  Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link.  The tracking is accomplished through a redirection system.  The redirection system allows us to understand how the link is being used by email recipients.  Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you.  This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

 

(e)   Third-party Websites and Services.  We work with a number of service providers of marketing communications technology.  These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide.  The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing.  For example, we may collect data where our banner advertisements are displayed on third-party websites.

HOW WE USE THE INFORMATION WE GATHER

We require this information to understand your needs and provide you with a better service, and in particular for internal record keeping.

In addition to the uses described above, we may use the information we collect:

  • to improve the content of our Website.

  • to notify you about updates to our Website.

  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • to contact you for marketing purposes.

  • for security, credit or fraud prevention purposes.

  • in any other way we may describe when you provide the information.

  • for any other purpose with your consent.

HOW WE SHARE THE INFORMATION WE GATHER

We do not sell or lease your Personal Information to any third party.  We may share your Personal Information by disclosing it to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract. 

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

  • Identifiers; and

  • Internet or other network activity information.

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy, including:

  • to all Company offices world-wide.

  • to contractors, service providers, and other third parties we use to support our business, such as our third party payment card processor, our shipping vendors for the processing of customer orders, or our web developer for improvements to our Website.

  • to operators of analytics tools for the creation of personalized digital content or for email marketing activities.

Except as described in this Privacy Policy, we will not share your Personal Information with third parties without your notice and consent, unless it is under one of the following circumstances: 

 

  • Sale of Business or Merger.  There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries.  Under these circumstances, the Company may share Personal Information to a buyer or other successor.  In such circumstances, the Company will ensure your Personal Information is used in accordance with this Privacy Policy.

  • Legal Reasons.

    • We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;

    • To respond to duly authorized information requests from law enforcement or other governmental authorities;

    • To enforce our agreements, policies, or the Terms of Use;

    • To investigate and prevent security threats, fraud, or other malicious activity; or

    • To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.

    • To otherwise respond to law enforcement as required to comply with applicable laws.

CHANGES TO THIS POLICY

If our information practices change at some time in the future, we will post the policy changes to our Website to notify you of these changes, and the date of the change will be reported in the last revised block above. If you are concerned about how your information is used, you should visit our Website periodically and review our policies.

NOTE CONCERNING MINORS

The Website, and the content available on the Website, is neither intended for, nor directed to, minors under the age of 18. Additionally, you must be at least 18 years old to have our permission to use our Website.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

 

DATA STORAGE AND RETENTION

We store your Personal Information on our servers and the servers of third party service providers. We retain your Personal Information for the duration of the business relationship, for a period thereafter to allow you to recover your account information, to analyze your data for our business operations, for archiving purposes, and for as long as reasonably necessary to carry out Company’s intended business purpose for such information. For more information on where or how long your data is stored, please contact us at support@spokecustom.com.

LOCATION OF OUR SERVICES

We do not warrant or represent that this Privacy Policy or the Website’s use of your Personal Information complies with the laws of every jurisdiction.  Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Privacy Policy.

 

YOUR RIGHTS UNDER STATE LAW

 

California.

  • Shine the Light law.  California Civil Code Section § 1798.83 permits users of our Website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please email or write to us at the contact information provided above.

  • Do Not Track Signals.  Other than as disclosed in this Privacy Policy, the Website does not track users over time and across third-party websites to provide targeted advertising.  Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

  • WE DO NOT SELL YOUR PERSONAL INFORMATION. If we ever decide to sell Personal Information, we will update you via this Privacy Policy and include a link entitled “Do Not Sell or Share My Personal Information” to provide you with an opportunity to opt out of sales of your Personal Information.

 

Your Consumer Rights.

If you are a California, Colorado, or Virginia consumer, as defined by the California Consumer Privacy Act of 2018 (the “CCPA”), the Colorado Privacy Act (“CPA”) or the Virginia Consumer Data Protection Act (“VCDPA”), respectively,, you may be afforded additional rights with respect to your “Personal Information” as that term is explicitly defined under the CCPA, CPA, and VCDPA.  Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.

 

A.   Access.  You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

B.   Correction. You can correct what personal data our Website database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.

C.   Prohibit Data Sharing.  When applicable, you may prohibit the sharing of your Personal Information. In your request, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information.  When such prohibitions are not possible to provide our services to you, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy.

D.   Portability.  Upon request and when possible, we can provide you with copies of your Personal Information.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy

E.   Deletion.  You 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.  Where applicable, we will ensure such changes are shared with trusted third parties.

 

F.   Non-Discrimination. If a California data subject exercises his or her rights under California law, including the CCPA, we shall not discriminate against that California resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.

G.   Exercising your rights. If you are a California, Colorado, or Virginia resident who chooses to exercise the rights listed above, you can:

 

  1. Submit a request via email at support@spokecustom.com; or

  2. Call us at 1.855.837.5014 to submit your request.

 

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.  If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.   

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et. 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.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

​SECURITY

We have implemented reasonable administrative, technical, and physical safeguards designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure, such as firewalls and an information security policy which governs the use of electronic information by our employees.  However, we can never promise 100% security.  The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.  If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.

LINKS TO OTHER WEBSITES

Our Website may contain links to other websites of interest. However, once you have used these links to leave our Website, you should note that we do not have any control over that other website. We are not responsible for the content of such websites or the protection and privacy of any information which you provide while visiting such sites. Third-party websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

YOUR CHOICES AND SELECTING YOUR PRIVACY PREFERENCES

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We may send you email newsletters and marketing emails regarding our products and services.  You may opt out of email newsletters and marketing emails at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

CONTROLLING YOUR PERSONAL INFORMATION

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing.

If you believe that any information we are holding on you is incorrect or incomplete, please contact us directly for assistance. We will work with you to make any corrections deemed necessary. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

HOW TO CONTACT US

We value your opinions and welcome your feedback.  To contact us about this Privacy Policy or your Personal Information, please contact us by email at support@spokecustom.com.