Privacy Policy – Update 14 September 2023

Spudo Aps, a danish company listed in The Central Business Register under business number 40156518, VAT number DK40156518, owner of the affiliate platform known as “Spudo.com” having its registered office at Ladegardsgade 4, 1 sal, 9000 Aalborg, Denmark. Hereinafter referred to as “SPUDO”

By accessing this site, you are consenting to the information collection and use practices described in this policy as well as the Acceptable Use Policy and the site’s Publisher Terms and Conditions and Advertiser Terms and Conditions. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, THE ACCEPTABLE USE POLICY OR THE TERMS AND CONDITIONS PROVIDED ON THIS SITE, PLEASE DO NOT PROVIDE ANY INFORMATION TO Spudo OR USE ANY OF THE SERVICES OR PRODUCTS OFFERED OR PROVIDED ON ANY OF THE WEBSITES REFERRED TO IN THIS PRIVACY POLICY.

Changes to Privacy Policy:

This Privacy Policy changes from time to time and changes are effective upon posting. It is your sole responsibility to periodically review this policy for updates and you are solely responsible to be aware of any changes to this and all posted policies on this website. Spudo does not provide notices of any changes in any manner other than by posting the changes at this website.

Information Collection, Use, and Dissemination practices:

This policy applies to Spudo’s collection, use, storage and disclosure of information by Spudo on its, (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various third party websites, and (c) to Spudo’s other information collection, including the purchase of customer lists from third parties, or the use of customer lists from third parties. Spudo is not responsible for the information collection or privacy practices of third party websites or applications.

§1. Collection of Information.

§1.1. User Direct Information:

Each time you provide information to take advantage of a promotional offer, enter to win a contest, enter to win a sweepstake, send us an email, or otherwise transmit information via the site, Spudo may obtain and collect personally identifiable information provided by you, including, but not limited to, your name, email address, mailing address, social security number, credit card information, and telephone number. You may also provide us with information that, when combined with personally identifiable information, provides us with a better idea of who you are, including but not limited to your gender, birthday, marital status, and education level (collectively referred to as “personal information”). If you choose to access our website, use our services or purchase our products, we may require you to provide personal information as indicated on the forms throughout the site.

§1.2. Survey Information:

Spudo collects information from you when you voluntarily complete a Spudo survey, order form, or a registration page either online by using the internet, offline by providing this information through the mail, in person or using a telephone. This information may be collected by surveys, order forms, or registration pages operated by third parties. This method of collection is collectively known as a “Survey.” In such Surveys, Spudo or a third party may ask you to provide personal identifiable information including your name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time. Spudo may also collect such information concerning you from another source and uses that information in combination with information provided from this website. Completing the Surveys is completely voluntary, and you are under no obligation to provide Survey Information to Spudo or a third party, but you may receive incentives from Spudo or a third party in exchange for providing such information.

§1.3. Third Party List Information:

Spudo may collect information from you when you provide information to a third party and Spudo subsequently purchases, licenses, or otherwise acquires the information from the third party. Such purchased information may include, but is not limited to, your name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the third party. When acquiring this information, Spudo seeks assurances from the third party that it has a right to transfer the information to Spudo and that the third party has a right to provide offers from advertisers to you included on the third party list.

§1.4. Other Methods of Collecting Personal Information:

Other occasions when Spudo obtains information from you include (1) your claiming a prize or seeking to redeem an incentive offered by Spudo or by a third party, (2) your requests for assistance through Spudo’s customer service department, and (3) when you voluntarily subscribe to a Spudo service or newsletter.

§1.5. Cookies, Web Beacons, and Other Info Collected Using Technology:

Spudo currently uses cookie and web beacon technology to associate certain Internet-related information about you with information about you in its database. Additionally, Spudo may use other new and evolving sources of information in the future. (a) Cookies: “Cookies” are a feature on your browser software. If enabled, we may write cookies that may store small amounts of data on your computer about your visit to any of the pages of this Site. Cookies assist us in tracking which of our features appeal the most to you and what content you may have viewed on past visits. When you visit this site again, cookies can enable us to customize our content according to your preferences. We may use cookies to: keep track of the number of return visits to this site; accumulate and report aggregate, statistical information on website usage; deliver specific content to you based on your interests or past viewing history; save your password for ease of access to our Site. You can disable cookies, although the Site may not function properly for you. Your browser preferences can be modified to accept or reject all cookies, or request a notification when a cookie is set. You may read more about cookies at http://cookiecentral.com. In order to use all of the features and functionality of Spudo’s websites, you need to accept cookies. (b) Web Beacons: A web beacon is a programming code that can be used to display an image on a web page, but can also be used to transfer your unique user identification to a database and associate you with previously acquired information about an individual in a database. This allows Spudo to track certain websites you visit. Web beacons are used to track online behavioral habits for marketing purposes to determine products or services you may be interested in. In addition to using web beacons on web pages, Spudo also uses web beacons in email messages sent to individuals listed in Spudo’s database. (c) IP Addresses: Spudo automatically tracks certain information based upon your behavior on the site. We may use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on the site or not), which URL you next go to (whether this URL is on the site or not), your computer browser information, and your IP address. Your Internet Protocol (“IP”) is a unique Internet “address” which is assigned to you by your Internet Service Provider (“ISP”). For local area network (“LAN”), DSL, or cable modem users, an IP address may be permanently assigned to a particular computer. IP addresses are automatically logged by Web servers, collecting information about a user’s traffic patterns. While the IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual using the Web. Your IP address can, however, reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages. (d) Computer Profiles: Spudo may also collect and accumulate other anonymous data which will help us understand and analyze the Internet experience of our visitors. For instance, Spudo may accumulate visitor data relating to referring domain names, the type of browsers used, operating system software, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords and JavaScript enablement. When you provide us with Personal Identification Information, we are able to use such visitor data to identify you. (e) Data Mining: Data Mining technology may be employed from time to time if used by a Client of Spudo. (f) New Technology: The use of technology on the Internet, including cookies and web beacons, is rapidly developing. As a result, Spudo strongly encourages individuals to revisit this policy for any updates regarding its use of new technology.

§1.6. No Information Collected from Children:

Spudo will never knowingly collect any personal information about children under the age of 18. If Spudo obtains actual knowledge that it has collected personal information about a child under the age of 18, that information will be immediately deleted from its database. Because it does not collect such information, Spudo has no such information to use or to disclose to third parties. Spudo has designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).

§2. Use of Individual Information.

The following section describes how Spudo uses personal information. The uses described in these sections may change at any time. Spudo may also broaden its use of your personal information. Spudo may also use your personal information to provide commercial promotional offers to individuals or entities through, among other things, email advertising, telephone marketing, direct mail marketing, banner advertising and package stuffers.

§2.1. Discretion to Use Information:

The personal information collected on this site and by third parties will be used to operate the site and to provide the services or products or carry out the transactions you have requested or authorized. Spudo may change or broaden its use of your personal information at any time. Spudo may use your personal information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, and other possible uses. Spudo MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY LEGALLY PERMISSIBLE PURPOSE IN ITS SOLE DISCRETION

§2.2. Email:

Spudo uses your personal information to provide promotional offers by email to you. Spudo may maintain separate email lists for different purposes. If you wish to end your email subscription from a particular list, you only need to press the unsubscribe button on the mail message. Such an unsubscribe request will permanently delete your email from all lists used by Spudo. Because Spudo only sends emails when you have agreed to receive emails from Spudo or you have agreed to receive emails from third parties, statutes requiring certain formatting for unsolicited email are not applicable to email messages sent by Spudo. Email messages sent by Spudo, will contain an advertiser’s name in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to Spudo. The “Subject:” line of a Spudo email messages will usually contain a line provided from the advertiser to Spudo.

§2.3. Profiling and Target Advertising:

Spudo uses your information to make and improve profiles of you and to track your online browsing habits and determine which areas of Spudo’s websites are most frequently visited. This information helps Spudo to better understand your interests so that it can target advertising and promotions to you. Spudo may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.

§2.4. Storage of Personal Information:

Spudo stores your information in a database on Spudo’s servers. Our servers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Spudo’s control. Notwithstanding such measures, Spudo cannot guarantee that its security measures will prevent Spudo computers from being illegally accessed, and your information from being stolen or altered.

§3. Use of Personal Information.

§3.1. Sale or Transfer to Third Parties:

Spudo MAY SELL OR TRANSFER YOUR PERSONAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN Spudo’S SOLE DISCRETION. Spudo uses your personal information in the following 3 ways: Customer Service; Marketing; and Complying with the law.

§3.2. Customer Service:

Spudo will use your personal information to respond to you, to process, validate and verify requests and/or purchase orders, to fulfill any of your requests and to tailor your experience on our websites.

§3.3. Marketing:

Spudo will use your personal information for any marketing and survey purpose on behalf of Spudo and its affiliates and subsidiaries to send information to you about additional goods or services that may be of interest to you. In addition, Spudo will disclose your personal information to third party agents and independent contractors to help us conduct our marketing and survey efforts and to share with other companies in connection with marketing efforts including but not limited to direct marketing. You may have no relationship with these other companies.

§3.4. Complying with Legal Process:

Spudo will use or disclose your personal information in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise our legal rights or defend against legal claims or in the event you violate or breach an agreement with Spudo. Spudo will use and disclose your personal information if we believe you will harm the property or rights of Spudo, its owners, or those of Spudo’s other customers. Finally, we will use or disclose your personal information if we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Spudo’s acceptable use policy, or as otherwise required by law when responding to subpoenas, court orders and other legal processes.

§3.5. Order Fulfillment:

Spudo will transfer your personal information to third parties when necessary to provide a product or service that you order from such third party while using Spudo’s websites or when responding to offers provided by Spudo.

§3.6. Data Summary:

Spudo may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

§3.7. Other Access to Personal Information:

You have access to your personal information collected. You may correct, amend, or delete such information. You may do this by contacting ??

Spudo may also give advertising clients and email services providers’ access to your email address to verify the origin of the personal information collected.

§4. Privacy Practices of Third Parties.

§4.1. Advertiser cookies and web beacons:

Advertising agencies, advertising networks, and other companies who place advertisements on the websites and on the internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. Spudo does not control the use of such technology and Spudo has no responsibility for the use of such technology to gather information about you.

§4.2. Links:

The websites and email messages sometimes contain hypertext links to the websites of third parties. Spudo is not responsible for the privacy practices or the content of such other websites. Linked websites may contain links to websites maintained by third parties. Such links are provided for your convenience and reference only. Spudo does not operate or control in any respect any information, software, products or services available on such third party websites. The inclusion of a link to a website does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.

§5. Unsubscribe Procedures.

If you wish to discontinue receiving email messages from Spudo, you may:

(a) Unsubscribe from one email list. To unsubscribe from a particular list, follow the instructions in each promotional email message sent by Spudo.

(b) Unsubscribe from all of Spudo email lists.