Privacy Policy

Privacy Statement

Last updated: November 16, 2018

Thanks you for visiting and using the website. We sincerely respect your privacy and
assure you we will take every measure to protect your privacy and personal information. We are here to serve
you as highly valued members, so your peace of mind and confidence while using the Site are our highest

This privacy policy (“Privacy Policy”) applies to which is owned and operated by In
The Spread, LLC. (herein after referred to as “ITS,” “we,” “our,” or “us”), (the “Website”), however accessed
and/or used, whether via personal computers, mobile devices, tablets or other means. This Privacy Policy also
applies to interactive features or downloads that are owned or operated by ITS, are available through the
Website, or that interact with the Website and post this Privacy Policy. This Privacy Policy covers information
collected at the Website and does not cover any information collected at any other web site or offline by ITS
(unless specifically stated).

This Privacy Policy explains ITS’s information collection practices at the Website, such as the types of
information ITS collects regarding visitors to the Website and how we may use that information. Please review
this Privacy Policy carefully. In addition, please review the Website’s Terms of Use which governs your use of
the Website.

Notice to EU Individuals: this Privacy Statement and its enumerated policies are intended to comply with
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “General Data
Protection Regulation” or “GDPR”) and provide appropriate protection and care with respect to the treatment of
your user information in accordance with the GDPR.

Voluntary Registration Information

In order to fully access this Site, you must first complete the registration process, during which we will collect
personal information about you. The information will include your name, address, and email address along with
several optional fields to help us better service your needs. We do not collect personally identifiable information
about you except when you specifically provide such information to us on a voluntary basis.
By interacting with us, you consent to the use and method of disclosure as described in this Privacy Policy.

Information We Collect on the Website

Collection of Usage Information: When users come to our Website, we automatically collect “Usage
Information” which include among other things, which pages of our Website were visited, the order in which
they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information
from the URLs from which you linked to our Website. Collecting such information may involve logging the IP
address or other unique identifier (“Device Identifier”) for your computer or other device used to access the
Website (any, a “Device”), operating system and browser software used by each user of the Website. Although
such information is not Personally Identifiable Information, we may be able to determine from an IP address a
user’s Internet Service Provider and the geographic location of his or her point of connectivity. Whenever we
associate Usage Information or a Device Identifier with your Personally Identifiable Information, we will treat it
as Personally Identifiable Information.

Collection of Personally Identifiable Information

In order to access certain features and benefits on our Website, you may need to submit “Personally Identifiable
Information” (i.e., information that can be used to identify you). Personally Identifiable Information can include
information such as your name, address, telephone number and email address. You are responsible for ensuring
the accuracy of the Personally Identifiable Information you submit to ITS. Inaccurate information may affect
your ability to use the Website, the information you receive when using the Website, and our ability to contact
you. For example, your email address should be kept current because that is one of the primary manners in
which we communicate with you. We may collect Personally Identifiable Information in connection with various
functionality and services offered via the Website, including the following:

  1. Updates and Newsletters. ITS may offer you the ability to receive email updates and newsletters. In
    order to subscribe to these services, you may be required to provide us with Personally Identifiable
    Information such as your name, email address and zip code.
  2. Participation in Contests, Sweepstakes, and Other Promotions. ITS may offer you the opportunity to
    participate in a contest, sweepstakes, or other promotions on or through the Website. If you desire to
    participate in any such contest, sweepstakes, or other promotion, you will be asked to provide us with
    certain information necessary to conduct such contest, sweepstakes, or other promotion. This
    information may include, among other things, your name, age, mailing address, email address, and
    phone number.
  3. Communications with ITS. We may receive Personally Identifiable Information when you send us an
    email message or otherwise contact us.
  4. Social Media Interaction. We may receive Personally Identifiable Information when you engage with
    our Website on or through third-party social networking sites, such as Facebook, Instagram or Twitter,
    and allow us to have access to information from your profile (e.g., name, email address, photo, gender,
    birthday, location, friends, followers, the posts or the ‘likes’ you make). You can control what data you
    share through privacy settings available on some social networking sites. For more information about
    how you can customize your privacy settings and how such third-party sites treat your Personally
    Identifiable Information, please refer to their privacy policies and terms of use
  5. Referrals. You may choose to invite friends to join the Site by sending invitation emails via our invite
    feature. The Site stores the email addresses you provide so that the respondents may be added to your
    social network, confirm orders/purchases and also to send reminders of the invitations. The Site does not
    sell these email addresses or use them to send any other communication besides invitations and
    invitation reminders. Recipients of invitations may contact us to request removal of their information
    from our database.

How We Use Your Personally Identifiable Information and Usage Information

Please take some time to familiarize yourself with the different ways ITS uses the information that we gather.

  1. Usage Information. We use Usage Information in aggregate form to build higher quality, more useful
    services by performing statistical analyses of the collective characteristics and behavior of our users, and
    by measuring demographics and interests regarding specific areas of our Website.
  2. Personally Identifiable Information. Except as set forth in this Privacy Policy or as specifically agreed
    to by you, ITS will not disclose any Personally Identifiable Information to third parties we collect from
    you on the Website. In addition to the other uses set forth in this Privacy Policy, we may disclose and
    otherwise use Personally Identifiable Information as described below.
  3. Updates and Newsletters. We use Personally Identifiable Information collected when you sign-up for
    our various email, newsletter or update services to send you the messages and newsletters that you
    request us to send.
  4. Participation in Contests, Sweepstakes and Other Promotions. We use the Personally Identifiable
    Information that we collect from you when you participate in a contest, sweepstakes, or other promotion
    through the Website for processing purposes and in connection with Winner’s lists.
  5. Communications with ITS. When you send us an email message or otherwise contact us, we may use
    the information provided by you to respond to your communication and/or as described in this Privacy Policy.
  6. Disclosure to our Third Parties. You may be presented with an opportunity to receive information
    and/or marketing offers directly from third parties. If you do agree (or do not decline) to have your
    Personally Identifiable Information shared, your Personally Identifiable Information will be disclosed to
    such third parties and all information you disclose will be subject to the privacy policy and practices of
    such third parties. We are not responsible for the privacy policies and practices of such third parties and,
    therefore, you should review the privacy policies and practices of such third parties prior to agreeing to
    receive such information from third parties. If you later decide that you no longer want to receive
    communication from a third party, you will need to contact that third party directly.
  7. Disclosure to ITS Operations and Maintenance Contractors. Our operations and maintenance
    contractors may have access to your Personally Identifiable Information in the course of providing
    products or services to us. These contractors may include vendors and suppliers that provide us with
    technology, services, and/or content related to the operation and maintenance of the Website. Access to
    your Personally Identifiable Information by these contractors is limited to the information reasonably
    necessary for the contractor to perform its limited function for us.
  8. Government Authorities, Legal Rights and Actions. ITS may share your Personally Identifiable
    Information with various government authorities in response to subpoenas, court orders, or other legal
    process; to establish or exercise our legal rights or to protect our property; to defend against legal claims;
    or as otherwise required by law. In such cases we reserve the right to
    raise or waive any legal objection
    or right available to us. We also may share your Personally Identifiable Information when we believe it
    is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to
    protect and defend the rights, property, or safety of ITS, the Website, our users, customers, or others;
    and in connection with our Terms of Use and other agreements. We may also use IP address or other
    Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet
    Service Providers, wireless service providers or law enforcement agencies in our discretion. Such
    disclosures may be carried out without notice to you.
  9. Disclosure to Acquirers. ITS may disclose and/or transfer your Personally Identifiable Information to
    an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all
    or substantially all of the equity, business or assets of ITS to which your Personally Identifiable
    Information relates.
  10. Administrative and Other Purposes. ITS may use your Personally Identifiable Information for
    administrative reasons, such as to contact you about Website or policy updates, or for other reasons
    disclosed by us when you submit your Personally Identifiable Information.

External Links

For your convenience we may provide links to websites operated by companies other than ITS (“Third Party
Sites”) that we believe may be of interest to you. We do not disclose your Personally Identifiable Information to
these Third Party Sites without obtaining your consent. We do not endorse and are not responsible for the
privacy practices of these Third Party Sites. If you choose to link to one of these Third Party Sites, you should
review the privacy policy posted on the other website to understand how that Third Party Site collects and uses
your Personally Identifiable Information.

Public Discussion, Forums & User Content

When you post User Content (as defined in the Terms of Use) on the Website you do so at your own risk. ITS
cannot control the actions of other users with whom you may choose to share your content and Personally
Identifiable Information. Therefore, we cannot and do not guarantee that User Content you post on the Website
will not be viewed by unauthorized persons. Please be aware that whenever you voluntarily post public
information to websites, blogs, message boards, chat rooms or any other public forums, such information can be
accessed by the public and can in turn be used by those people to send you unsolicited communications. If you
choose to “like” content on our Website or to otherwise post information from or via our Website to third party
web sites, features or applications, that information will become public and the third party web sites may have
access to information about you and your use of our Website.


We incorporate commercially reasonable safeguards to help protect and secure your Personally Identifiable
Information. However, no data transmission over the Internet, wireless transmission or electronic storage of
information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of
any information you transmit to us, and you use our Websites and provide us with your information at your own

Accessing and Updating Your Personal Information and Preferences

We provide mechanisms for updating and correcting your personal information for many of our services. You
may modify or remove any of your personal information at any time by logging into your account and accessing
features such as edit and account. Keep in mind, however, that there will be residual information that will remain
within our databases, access logs and other records, which may or may not contain your Personally Identifiable
Information. Please note that we reserve the right to send you certain communications relating to your use of the
Website and these transactional messages may be unaffected if you choose to opt-out from marketing

Children and Children’s Privacy

You must be 18 years of age or older to subscribe to the In The Spread service. In certain jurisdictions, the age of
majority may be older than 18, in which case, you must satisfy that age in order to become a member. While
individuals under the age of 18 may utilize the service, they may do so only with the involvement, supervision,
and approval of a parent or legal guardian. is a general audience web site and we do not knowingly collect any Personally Identifiable
Information from children younger than the age of thirteen (13). We will delete any Personally Identifiable
Information collected that we later determine to be from a user younger than the age of thirteen (13)

Changes to This Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational
requirements. We will provide notice of any such changes (including when they will take effect) in accordance
with law. Your continued use of the In The Spread service after any such updates take effect will constitute
acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept
any updates to this Privacy Statement, you may cancel your use of the In The Spread service. To see when this
Privacy Statement was last updated, please see the “Last Updated” section at the top of this statement.

Jurisdictional Issues — Consent to Transfer

The Website is operated in the United States and intended for users located in the United States. If you are
located in the European Union, Canada, Mexico, Australia, Central and South America or anywhere else outside
of the United States, please be aware that information we collect, including, without limitation, Personally
Identifiable Information, will be transferred to, processed and stored in the United States. The data protection
laws in the United States may differ from those of the country in which you are located, and your Personally
Identifiable Information may be subject to access requests from governments, courts, or law enforcement in the
United States according to laws of the United States. By using the Website or providing us with any information,
you consent to this transfer, processing and storage of your information in the United States.

Cookies and Internet Advertising

We and our Service Providers use cookies and other technologies (such as web beacons), as well as advertising
identifiers, for various reasons. For example, we use these technologies to make it easy to access our services by
remembering you when you return, to provide and analyze our services. We also use cookies, as well as
advertising identifiers, to learn more about our users and their likely interests, and to deliver and tailor marketing
or advertising. We want you to be informed about our use of these technologies, so this section explains the
types of technologies we use, what they do and your choices regarding their use.

What are cookies?

Cookies are small data files that are commonly stored on your device when you browse and use websites
and online services. They are widely used to make websites work, or to work more efficiently, as well as
to provide reporting information and assist with service or advertising personalization.
Cookies are not the only types of technology that enable this functionality; we also use other, similar
types of technologies. See below for more information and examples.

What are advertising identifiers?

Advertising identifiers are similar to cookies and are found on many mobile devices and tablets (for
example, the “Identifier for Advertisers” (or IDFA) on Apple iOS devices and the “Google Advertising
ID” on Android devices), and certain streaming media devices. Like cookies, advertising identifiers are
used to make online advertising more relevant.

Why does In The Spread use cookies and advertising identifiers?

  • Essential cookies: These cookies are strictly necessary to provide our website or online service.
    For example, we and our Service Providers may use these cookies to authenticate and identify
    our members when they use our websites and applications so we can provide our service to
    them. They also help us to enforce our Terms of Use, prevent fraud and maintain the security of
    our service.
  • Performance and functionality cookies:These cookies are not essential, but help us to
    personalize and enhance your online experience with In The Spread. For example, they help us
    to remember your preferences and prevent you from needing to re-enter information you
    previously provided (for example, during member sign up). We also use these cookies to collect
    information (such as popular pages, conversion rates, viewing patterns, click-through and other
    information) about our visitors’ use of the In The Spread service so that we can enhance and
    personalize our website and service and conduct market research. Deletion of these types of
    cookies may result in limited functionality of our service.
  • Advertising cookies and advertising identifiers: These cookies and advertising identifiers use
    information about your use of this and other websites and apps, your response to ads and emails,
    and to deliver ads that are more relevant to you. These types of ads are called “interest-based
    advertising.” Many of the advertising cookies associated with our service belong to our Service

How can I exercise choice regarding cookies and advertising identifiers?

To opt out of interest-based ads from In The Spread in connection with an advertising identifier on a
mobile device, tablet, or streaming media devices, please configure the appropriate setting on your
device (usually found under “privacy” or “ads” in your device’s settings). You may still see In The
Spread ads on your device, but they will not be tailored to your likely interests.
In The Spread supports the following self-regulatory programs, which provide additional privacy choices
for interest-based advertising:

  • In the US: Digital Advertising Alliance (DAA)
  • In Europe: European Interactive Digital Advertising Alliance (EDAA)
  • In Canada: Ad Choices: Digital Advertising Alliance of Canada (DAAC) / Choix de Pub: l’Alliance de la publicité numérique du Canada (DAAC)

At this time, we do not respond to Web browser “do not track” signals.

How Does In The Spread use Web Beacons and other Technologies?

Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. We and
our Service Providers may use them for similar purposes as cookies, such as to understand and enhance
the use of our service, improve site performance, monitor visitor traffic and actions on our site, and
understand interactions with our marketing (including email and online ads on third party sites). Because
web beacons often work in conjunction with cookies, in many cases, declining cookies will impair the
effectiveness of web beacons associated with those cookies.

We use other technologies that are similar to cookies, such as browser storage and plugins (e.g.,
HTML5, IndexedDB, and WebSQL). Like cookies, some of these technologies may store small amounts
of data on your device. We may use these and various other technologies for similar purposes as cookies,
such as to enforce our terms, prevent fraud, and analyze the use of our service. There are a number of
ways to exercise choice regarding these technologies. For example, many popular browsers provide the
ability to clear browser storage, commonly in the settings or preferences area; see your browser’s help
function or support area to learn more. Other technologies, such as Silverlight storage, may be cleared
from within the application.


By consenting to the Terms and Conditions of the Site and thereby this Privacy Policy as well, you consent to
the simple fact that no data transmission over the Internet is completely secure. For that, we cannot guarantee or
warrant the security of any information you provide to us and you transmit such information to us at your own

Contacting ITS

If you have any questions or comments about this Privacy Policy or our Website, please contact us:
Address: 1825 West Avenue #8 Miami Beach, FL 33139

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