PRIVACY POLICY

This Privacy Notice for Spiral Ad, Inc., doing business as Spiral ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://spiral.ad, or any website of ours that links to this Privacy Notice
• Use our AI-powered Meta Ads creative generation platform
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@spiral.ad

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We collect information from third parties including Meta's advertising platforms through official APIs, and other service providers as necessary to deliver our Services.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We protect your personal information using industry-standard security measures and follow best practices for data protection. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information when you create an account, use our Services, or contact us.

The personal information that we collect depends on the context of your interactions with us and the Services. The personal information we collect may include the following:

• Company names
• Email addresses
• Names and job titles
• Usernames and passwords
• Contact or authentication data
• Billing addresses
• Phone numbers

Meta Ads Account Integration. When you connect your Meta Ads account to our Services, we collect:

• OAuth access tokens and refresh tokens
• Meta Ads account information and settings
• Campaign performance data and metrics
• Ad creative data and performance history
• Audience and targeting information
• Spend and billing information from your Meta Ads account

AI-Generated Creative Content. We store all AI-generated creatives and variations created through our Services on our servers. You retain ownership of these Generated Creatives as outlined in our Terms of Use.

Payment Data. We collect billing information necessary to generate invoices and process payments, including company details and contact information for accounting purposes. Payment processing is handled by Stripe. You may find their privacy notice at https://stripe.com/privacy.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports, and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service, including analyzing your Meta Ads data to generate optimized creative content.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
• For marketing and advertising purposes. We may process your information to deliver targeted advertisements, analyze the effectiveness of our marketing campaigns, and improve our promotional efforts.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To improve our AI models and algorithms. We may process aggregated and anonymized data from your Meta Ads performance and Generated Creatives to improve our AI's ability to create better-performing ad variations for all users. We never share your specific Meta Ads data with other users.
• To analyze user behavior and optimize Services. We may use analytics tools like Mixpanel to understand how users interact with our Services, which features are most used, and how we can improve the user experience.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

We process your personal information based on the following legal grounds:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Analyze how our Services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share your information with the following third‑party service providers. We update this list within ten (10) days of adding or removing a provider.
• Third‑Party Service Providers (Sub‑Processors). We may share your information with the following third‑party service providers. We update this list within ten (10) days of adding or removing a provider.
  • AI / ML platforms – OpenAI, Anthropic, Google Vertex AI (accessed via LangChain)
    Purpose: generate and analyse ad copy, headlines, creatives, and chat responses.
  • Cloud hosting & storage – Supabase (PostgreSQL and object storage) plus our primary cloud infrastructure provider
    Purpose: securely store user accounts, workspaces, encrypted Meta tokens, and generated creatives.
  • Content delivery & security – Cloudflare
    Purpose: provide global content delivery, DDoS protection, and web‑application firewall services.
  • Payment processing – Stripe
    Purpose: handle billing, subscriptions, and invoicing.
  • Email delivery – Resend
    Purpose: send transactional emails (e.g., password resets, account notices) and, with consent, marketing newsletters.
  • Product analytics – Mixpanel
    Purpose: aggregate event analytics to understand feature usage and improve the user experience.
• Meta Platforms Integration. We access and process data from Meta's advertising platforms through official APIs to provide our core Services. This data remains under your control and ownership.
• Legal Requirements. We may disclose user information only when we are legally required to do so. Each request is reviewed by the company’s founders (and outside counsel when necessary) to confirm its validity and scope. If we believe a request is unlawful or over‑broad, we will challenge or seek to narrow it. We disclose only the minimum data needed to comply and record the request, our response, and the legal basis in an internal log.
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation in which we are involved.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

In Short: We use cookies and other tracking technologies to collect and store your information for website performance, analytics, and marketing purposes.

We use cookies and similar tracking technologies (like web beacons and pixels) to access or store information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Essential Cookies: We use necessary cookies to:

• Keep you logged in to your account
• Remember your preferences and settings
• Ensure website security and prevent fraud
• Enable core functionality of our Services

Analytics Cookies: We use Mixpanel and other analytics services to collect information about how you use our Services, including:

• Pages visited and features used
• Time spent on different sections of our Services
• User interactions and navigation patterns
• Device and browser information
• General location information (country/city level)

Marketing Cookies: We also permit third parties and service providers to use online tracking technologies on our Services for marketing purposes, including to:

• Help manage and display advertisements
• Tailor advertisements to your interests
• Send abandoned cart reminders (depending on your communication preferences)
• Track the effectiveness of our marketing campaigns
• Retarget visitors with relevant ads on other websites

The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

Your Cookie Choices: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. However, if you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States and European Union. If you are accessing our Services from outside these regions, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States, European Union, and other countries.

We will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Specific retention periods:

• Account Information: Retained for as long as your account is active
• Meta Ads Data: Retained for as long as your account is active and for up to 12 months after account termination for billing verification purposes
• Generated Creatives: Retained permanently unless you request deletion
• Support Communications: Retained for 3 years after the last communication
• Billing Information: Retained for 7 years as required by law

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Our security measures include:

• Industry-standard security practices including encrypted connections and secure data storage
• Access controls for our systems and databases
• Secure handling of Meta Ads API tokens and credentials

In the unlikely event of a security incident, we will notify affected users promptly.

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. The Services are intended for business users only. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@spiral.ad.

In Short: You can access, update, or delete your personal information, opt out of marketing communications, and request account termination at any time.

You have the following rights regarding your personal information:

• Access and update your account information
• Delete your account and associated data
• Opt out of marketing emails (unsubscribe links provided)
• Request data portability where applicable under local laws

To exercise these rights:

• Log into your account settings, or
• Contact us at support@spiral.ad

Account Termination: If you request account deletion, we'll deactivate your account and delete your information from active databases. We may retain some information to prevent fraud, troubleshoot problems, or comply with legal requirements.

In Short: Residents of certain US states have additional privacy rights including the right to know what personal information we collect, request deletion, and opt out of data sales or targeted advertising.

If you are a resident of California, Virginia, Colorado, or other states with privacy laws, you may have additional rights including:

• Right to know what personal information we process
• Right to request deletion of your personal information
• Right to correct inaccuracies in your data
• Right to opt out of targeted advertising or data sales

To exercise these rights, contact us at support@spiral.ad. We do not sell personal information to third parties.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at support@spiral.ad, or contact us by post at:

You can request access to, correct, or delete your personal information by contacting us at support@spiral.ad.