Privacy Notice

This Privacy Notice (“Notice”) applies to personal data Spice Solutions Inc., d/b/a Optimum (collectively, “Optimum,” “we,” “us,” or “our”) collects. This Notice also covers rights and choices related to your personal data. 

Data We Collect

We collect data about you in different ways. For example, we collect data:

  • Directly from you. This includes when you sign up to get our emails or contact us. 
  • Automatically. This includes through cookies, server logs, and other tools on our website or apps. Where required by law, we base the use of such technologies upon consent.
  • From other sources. These can include our affiliates, vendors, social media or similar channels, publicly available sources, and other companies. 

The following are a few examples of our collection and use of data: 

Context Examples of Personal Data Primary Purpose and Legal Basis
Business Contact Information We collect the name and contact information of our business partners and customers, and their employees with whom we may interact. We have a legitimate interest in contacting our business partners and customers, and communicating with them about business activities such as projects, services, and billing.
Telegram Interactions When you send messages directly to Optimum via Telegram, we collect your phone number, Telegram user ID, username, display name and profile photo (if visible), email address (if provided at signup), IP address, and other information you provide during the interaction. We have a legitimate interest in communicating with our business partners and customers about business activities or services.
Email Interactions If you receive email from us, we use tools to capture when you open our message, or click on links or banners in it after receiving an email. We have a legitimate interest in understanding how you engage with our messages.
Mailing List (Email or Mail) When you sign up for our mailing lists, we collect your contact information. We have a legitimate interest in sharing information about our products and services. Where required by law we will ask for your consent before communicating with you.
Use of Our Website We use technology (e.g., a cookie or a pixel) to learn how you engage with our websites. This may include which links you click or what you type into our online forms. We may also track your IP address, the website that referred you to us, and data about your device. We have a legitimate interest in making our website operate. We also use it to understand how you interact with our websites, gather analytics, improve our websites, and learn your preferences. We may also use this data to help detect and prevent fraud. Where required by law, we base the use of such technologies upon consent.

How We Use Data

We also use data to: 

  • Identify you when you visit our sites. 
  • Complete transactions. 
  • Improve or create services and products.
  • Conduct analytics.
  • Connect with you (e.g., addressing your requests, inquiries, issues, or feedback). 
  • Market our products or services.
  • Find and prevent malicious, deceptive, fraudulent, or illegal activity.
  • Find and prevent security incidents. 
  • Enforce our policies and agreements.
  • Debug, find, and fix errors that impair our website and services.
  • Comply with legal or regulatory obligations. 
  • Establish or exercise our rights 
  • Defend against legal claims.
  • Manage our relationships.
  • For other reasons with your consent.

The sections above describe our main purposes in collecting your data, but often we have multiple purposes. For instance, if you license our products or use our services, we may collect your information to perform our contract with you. We also have a legitimate interest in maintaining that data so that we can easily address questions about the product or our services. As a result, our collection and processing of your data is based in different contexts on your consent, our need to perform a contract, our legal obligations, and/or our legitimate interest in conducting our business.

To the extent we store and use deidentified personal data, we will not try to reidentify the information, except to test our deidentification methods.

How We Share Data

In addition to the specific situations discussed elsewhere in this Notice we may share personal data in the following situations: 

  • Acquisitions. If a company acquires or enters negotiations to acquire, our company, business, or assets, we may share data with that company. 
  • Other Disclosures without Your Consent. We may share data to cooperate with law enforcement, participate in a legal process, or for legal compliance. We may share your data to establish or exercise our rights, to defend against legal claims, to investigate, prevent, or act on possible illegal activities, threats to safety of person or property, or a violation of our policies. Your data may be shared to ship products to you.
  • Service Providers. We share your data with service providers. Service providers help us to run our website, conduct surveys, provide technical support, process payments, fulfill orders, and more.
  • Professional Services. We may share personal data with our professional service providers, such as auditors or lawyers.
  • Other Disclosures with Your Consent. We may share your data with third parties when you consent or direct us to. 

Your Choices

Some jurisdictions give you a right to make the following choices:

  • Access. You may request access to your personal data or confirmation that we have data about you. In certain limited cases, you may ask to receive access to your data in a portable, machine-readable form. 
  • Correction. You can ask us to correct inaccurate or incomplete data by contacting us at the contact information below. We may keep historical data in our backup files as permitted by law.
  • Deletion. You may ask us to delete your personal data. If required by law, we will grant such a request, but note that in many cases, we must keep your personal data to comply with legal obligations, resolve disputes, enforce agreements, or for other business purposes. 
  • Objection to or Restriction of Certain Processing. In certain circumstances, you may object to the processing of your personal data, or ask that we restrict processing of your personal data. To do so, follow the instructions below. 
  • Data Portability. Where our processing of your personal data is based on your consent or on the performance of a contract with you, and is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format (such as CSV or JSON), and to request that we transmit that data directly to another controller where technically feasible. This right applies to data you have actively provided or that has been generated through your use of our services, but does not extend to data we have independently derived or inferred. To exercise this right, please contact us using the details set out below. 
  • Promotional Emails. You may provide us with your email address to allow us to send newsletters, surveys, offers, or other promotional content , as well as targeted offers from third parties. You can stop receiving such emails by following the unsubscribe instructions at the bottom of those emails. If you choose not to receive such emails, we may still send you service-related communications. 
  • Revocation Of Consent. Where we process your personal data based upon consent, you may revoke consent. Note, if you revoke consent for processing personal data, we may no longer be able to provide you some types of services.

Not all the rights above are absolute, and they do not apply in all circumstances. We may limit or deny a request because the law permits or requires us to. We will not discriminate against individuals who exercise a privacy right.

Submitting Requests

You may exercise the above rights by contacting us via the contact information below. If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.” 

We will require you to prove your identity when making most types of requests. If needed, we may verify your identity by phone or email. 

4. How We Protect and Retain Data

No method of internet transmission or electronic storage is fully secure. While we use reasonable efforts to protect personal data, we cannot guarantee its security. If we are required to inform you about a security incident, we will do so electronically, in writing, or by phone, as the law permits.

We keep your personal data for only as long as necessary to fulfil the purposes in this Notice unless a longer retention period is required or permitted by law. This includes the purposes of satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data. We also weigh the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we obtained the data and whether we can meet those purposes through other means, as well as applicable legal requirements.

Transmission Of Data To Other Countries

We may process your data in a country with less stringent privacy laws than the laws in the country that you reside. Where possible, we treat personal data using the same privacy principles that guide the law of the country in which we first receive your data. By submitting your personal data to us you agree to the transfer, storage, and processing of your data in a country other than your country of residence including, but not limited to, the United States. For more information on our attempts to apply the privacy principles applicable in one area to data when it goes to another, contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred, by contacting us using the contact information below.

Third-Party Applications/Websites

We may provide links to websites and other third-party content or services that we do not own or operate. We may also communicate with you on third party platforms.  We have no control over the privacy practices of websites or services we do not own. For details about such third parties’ privacy practices, see their privacy notices.

Changes To This Privacy Notice

We may change our Notice and privacy practices. New notices will be published on our website. If changes are material, we will notify you by email. Also, if changes are material, the Notice that was in place when you submitted personal data to us will generally govern that data unless you consent to the new Notice.

Contact Information

If you have questions, comments, or complaints on our privacy practices, or if you need to access this Notice in a different form due to a disability, please contact us. We will try to address your requests and provide you with additional privacy-related information.

[email protected]

119 Drum Hill DR # 228, Chelmsford, MA 01824

If you are not satisfied with our response and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.