U.S. State Privacy Notice Supplement

U.S. State Privacy Notice

Last Updated: July 8, 2024

This U.S. State Privacy Notice (“State Privacy Supplement”) supplements the information contained in the Privacy Notice, located on our Website (the “Site”) of Spheros Corp. (“Spheros,” “company,” “we,” “us,” or “our”), and applies solely to consumers as defined under state specific privacy laws that are applicable to Spheros. In the event of any conflict between this notice and our Privacy Notice, this privacy notice shall govern. We adopt this notice to comply with applicable U.S. State Privacy Laws.

This State Privacy Supplement is designed to provide you with notice of our practices over the prior twelve (12) months, as required under some U.S. State Privacy Laws.

Information We Collect

The information we collect is identified in the “Information We Collect” section of our Privacy Notice. The information we collect includes Personal Data, which is information that identifies, relates to, describes, references, is capable of being associated with, or reasonably could be linked, directly or indirectly, with a specific individual, consumer, or personal device (“Personal Data”); and for limited purposes we also collect Sensitive Personal Data.

Not included in the definition of Personal Data is information that is publicly available or information that has been de-identified or aggregated.

Use and Disclosure of Personal Data

We may use or disclose your Personal Data as described in the “How We Use Your Information” and “How and Why We Disclose Your Information” sections of our Privacy Notice.

The table below describes the categories of Personal Data we collect as well as examples of the type of data that fit within such categories, the purpose for which such data is processed, and the categories of recipients for each category of data and whether any disclosures are considered a sale or share as defined by certain U.S. State Privacy Laws.

Sensitive Data

Sensitive Data is provided by consumers in connection with their Sphere Accounts and is not sold or shared as defined by applicable U.S. State Privacy Laws. Information in Sphere Accounts is only shared with Connections with express consent of the account holder.

Rights and Choices

Consumers may be provided with certain rights regarding their Personal Information under their state privacy law. For requests received directly from a consumer, this section describes your rights and explains how to exercise those rights.

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your authenticated consumer request, you may request we disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we disclose that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).

Access to Specific Information and Data Portability Rights

You have the right to request that we delete your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your authenticated consumer request, we will delete your Personal Data from our records, unless an exception applies.

Deletion Request Rights

You have the right to request correction of inaccurate or incomplete Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your authenticated consumer request, we will provide a response that may include self-service tools that enable you to update your Personal Data, unless an exception applies.

Rectification Request Rights

You have the right to opt out of the following uses of your Personal Data: (a) targeted advertising; (b) the sale of Personal Data; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects.

You will be able to opt-out of the sale and share of your personal information as well as opt-out of the sale and share of your cookies for marketing purposes, including targeted advertising by filling out this form.

However, note that if you provide your information to a third party for their own use, or if said third party otherwise collects your information as part of your interactions with them, then their use of your information will be subject to the limits of their privacy statement or notice, rather than ours.

Opt-out Rights

Request Submissions

To exercise consumer privacy rights under state law, please submit an authenticated consumer request by completing the online form.

Authenticated Requests

An authenticated request may be submitted by a consumer resident of a U.S. State with an applicable Data Privacy Law. These requests must:

Detail sufficient information that allows us to reasonably authenticate you are the person about whom we collected Personal Data; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot authenticate your identity or authority to make the request and confirm the Personal Data relates to you. We will only use personal information provided in an authenticated consumer request to verify the requestor's identity or authority to make the request.

Spheros shall confirm receipt of a consumer’s request within ten (10) days of receipt. We will respond to the request within forty-five (45) days of receipt of the request.

Timeframe for Responding to Requests and Format

After receiving a response to an authenticated request, consumers may make an appeal to us by contacting privacy@spheros.io with the subject “Appeal” and state the reasons for their appeal. Consumers must send an appeal request within twenty (20) days of receipt of Spheros’ response to their authenticated request.

Appeal Process

Unless permitted by law, we will not discriminate against you for exercising the rights by:

Denying goods or services to you;
Charging different prices or rates for goods or services, including through the use of discounts, benefits, or other penalties;
Providing a different level or quality of goods or services; and
Suggesting a different price or quality of goods or services will apply if rights are exercised.

Please note that certain information is required to effectively use our Services. For example, if you exercise the right to delete your information, then your account will be deactivated, which prevents the use of our goods and services. This in no way prevents you from creating a new account in the future.

No Discrimination

We do not charge a fee to process or respond to your authenticated consumer request unless it is excessive, repetitive, or manifestly unfounded.

Fee

We do not offer any financial incentives or price or service difference in an attempt to influence a consumer’s decision whether or not to exercise a right afforded to the consumer under their state consumer privacy laws.

No Financial Incentive

Changes to Privacy Notice

From time to time, we may change this State Privacy Notice Supplement and will notify you of changes by posting the changed or modified State Privacy Notice Supplement on our Site. If the changes are material, we will provide you with additional notice (such as sending you an email notification or posting a banner notice on our web page). Any changes will be effective immediately upon the posting of the revised State Privacy Notice Supplement unless otherwise specified. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

Spheros Contact Information

If you have any questions about the Privacy Notice, this State Privacy Notice Supplement, or our privacy practices, please contact us at:

Our postal address:

377 Valley Rd # 1206
Clifton, NJ 07013

Other ways to reach us:

Email: privay@spheros.io