California Disclosures

Effective Date: April 18, 2020

The California Consumer Privacy Act (the “CCPA”) requires us to disclose certain information related to our privacy practices. This California Privacy Notice supplements our Practyce Privacy Policy (the “Privacy Policy”) to meet our disclosure requirements under California law. To understand our privacy practices and your rights, please refer to the Privacy Policy together with this California Privacy Notice. Our Privacy Policy is located here:

This California Privacy Notice applies only to residents of California. As used in this California Privacy Notice, “Personal Information” refers to “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” The definition of Personal Information” within the Privacy Policy is the same.

Categories of Personal Information We Have Collected

We have collected the following categories of Personal Information in the preceding 12 months:


Real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address or other similar identifiers.

User comments, feedback and reviews. Social media account information such as name and email address. Participation in contests, sweepstakes or other promotions.

Personal information listed in § 1798.80 of the California Customer Records statute

Name, signature, address, telephone number, credit and debit card numbers, physical characteristics, ordering, billing and transactions information. For customer support, phone number, call audio, information about the device and browser used and the connection, and chat transcript. Employment and employment history.

Protected characteristics

Age and gender.

Commercial Information

Records and history of products or services purchased or considered.

Biometric Information

Photographs and images.

Internet or other electronic network activity information

Information from or about the computers, phones, or other devices used to access our website. Includes online environment (operating system, browser, hardware version, device settings, or device identifiers); device location, including specific geographic locations, such as through Bluetooth, WiFi signals, or GPS; connection information (name of mobile operator, internet service provider, IP address); and browsing activity, such as the pages visited, the date and time of the visit, the amount of time spend on each page, or the links clicked on.

Geolocation data

Approximate physical location (derived from an Internet Protocol address)

Audio, electronic, visual, thermal, olfactory, or similar information.

Recording of phone calls for customer service

Professional or employment-related information

Name, work history, and other information relevant to your employment application.


Inferences drawn from any of the above categories of information.

For more information about the Personal Information we have collected, please see the section in the Privacy Policy entitled What Kinds of Information Do We Collect?

How We Use Your Personal Information

We have used your Personal Information for the purposes described in our Privacy Policy. For more information about how we have used your Personal Information, please see the section in the Privacy Policy entitled How Do We Use This Information?

What Personal Information We Share

Our Privacy Policy describes the categories of third parties with whom we share Personal Information. For more information about the personal information we share, please see the section in the Privacy Policy entitled How Is This Information Shared?

Personal Information Sold

We have not sold Personal Information relating to California residents in the last twelve (12) months.

Your Rights Under The CCPA

Under the CCPA, you have the rights stated below. Please note that these rights are not absolute and may be subject to conditions or limitations within the CCPA.

Right to Access Personal Information: You have the right to request, at no charge, that we disclose to you the categories and specific pieces of Personal Information that we have collected in the prior 12 months.

Right to Know: You have the right to request that we disclose certain information about how we have handled your Personal Information in the prior 12 months including the:

  • (i) categories of Personal Information collected about you;
  • (ii) categories of sources from which we collected your Personal Information;
  • (iii) the purposes for collecting your Personal Information;
  • (iv) the categories of third parties with whom we shared Personal Information; and
  • (v) the specific pieces of Personal Information that we collected about you.

Right of Access and Portability: You have the right to obtain a list of categories and a copy of your Personal Information in a portable and readily usable format.

Right of Deletion: You have the right to request the deletion of your Personal Information we have collected from you. This right may be subject to certain conditions and limitations under applicable law.

Right to be Free from Discrimination: We will not discriminate against you for exercising your rights under the CCPA.

Submitting a Request to Exercise Your Rights

If you wish to exercise any of your privacy rights as set forth above, please contact us by email at You may be required to provide additional information to verify your identity and request before further action is taken.

If you have any questions or concerns regarding this Privacy Notice, you may contact us at the following address:

  • Spiraledge, Inc.
  • Attention: General Counsel
  • 2105 S. Bascom Avenue, Suite 160
  • Campbell, California 95008
  • By phone: 1-800-691-4065

Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information, we will let you know. We will respond to your request within 45 days of receipt or notify you if we need additional time.