Privacy Policy

1. Introduction

Welcome to eWish, a service provided by Spearmint LLC ("Company," "we," "us," or "our"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our automated birthday and anniversary email service accessible at ewish.app (the "Service").

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use our Service.

2. Information We Collect

2.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us when you:

• Register for an account or use our Service
• Upload contact lists or member information
• Customize email templates
• Contact us for support
• Subscribe to our newsletters or communications
• Participate in surveys or feedback forms

This information may include:

• Name and contact information (email address, phone number)
• Organization or company information
• Member/contact information you upload (names, email addresses, birth dates, anniversary dates)
• Account credentials and authentication information
• Payment information (processed by third-party payment processors)
• Communications and correspondence with us

2.2 Information Automatically Collected

When you access our Service, we automatically collect certain information about your device and usage patterns:

• IP address and geolocation data
• Browser type and version
• Operating system and device information
• Log files and usage statistics
• Cookies and similar tracking technologies
• Pages visited and time spent on our Service
• Referral sources and click-through data

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Authentication services (Google OAuth)
• Payment processors
• Analytics providers
• Email delivery services
• Customer support tools

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Service Provision

• Deliver automated birthday and anniversary emails
• Maintain and manage your account
• Process transactions and billing
• Provide customer support
• Customize and improve user experience

3.2 Communication

• Send service-related notifications
• Provide updates about our Service
• Respond to inquiries and support requests
• Send marketing communications (with your consent)

3.3 Legal and Security

• Comply with legal obligations
• Protect against fraud and abuse
• Enforce our Terms of Service
• Ensure platform security and integrity

3.4 Analytics and Improvement

• Analyze usage patterns and trends
• Improve our Service functionality
• Develop new features and services
• Conduct research and analytics

4. Information Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to third parties except in the following circumstances:

4.1 Service Providers

We may share information with third-party service providers who perform services on our behalf, including:

• Email delivery services
• Payment processors
• Cloud hosting providers
• Analytics providers
• Customer support tools
• Authentication services

4.2 Legal Requirements

We may disclose your information when required by law or in good faith belief that such disclosure is necessary to:

• Comply with legal process or government requests
• Enforce our Terms of Service
• Protect the rights, property, or safety of Spearmint LLC, our users, or others
• Investigate potential violations of our policies

4.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

4.4 Consent

We may share information with your explicit consent or at your direction.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

5.1 Technical Safeguards

• SSL/TLS encryption for data transmission
• Encryption of sensitive data at rest
• Regular security assessments and updates
• Secure authentication mechanisms
• Network security monitoring

5.2 Administrative Safeguards

• Access controls and authorization procedures
• Employee training on data protection
• Regular security policy reviews
• Incident response procedures

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

6.1 Account Information

We retain account information while your account is active and for a reasonable period thereafter to comply with legal obligations and resolve disputes.

6.2 Contact Data

Member and contact information is retained while your account is active and for up to 30 days after account deletion, unless longer retention is required by law.

6.3 Usage Data

Usage logs and analytics data are typically retained for 12 months unless longer retention is required for legal or security purposes.

6.4 Deletion

When information is no longer needed, we securely delete or anonymize it in accordance with our data retention policies.

7. Your Rights and Choices

You have the following rights regarding your personal information:

7.1 Access and Portability

• Request access to your personal information
• Obtain a copy of your data in a portable format
• View and download your account information

7.2 Correction and Update

• Correct inaccurate information
• Update your account details
• Modify contact information

7.3 Deletion

• Request deletion of your account
• Remove specific information
• Exercise your "right to be forgotten"

7.4 Communication Preferences

• Opt out of marketing communications
• Manage email preferences
• Unsubscribe from newsletters

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and analyze usage patterns:

8.1 Types of Cookies

• Essential Cookies: Necessary for Service functionality
• Analytics Cookies: Help us understand usage patterns
• Preference Cookies: Remember your settings and preferences
• Marketing Cookies: Deliver relevant advertisements (with consent)

8.2 Managing Cookies

You can control cookies through your browser settings or by using our cookie preference center. Note that disabling certain cookies may affect Service functionality.

8.3 Third-Party Tracking

We may allow third-party analytics providers to collect information about your online activities over time and across different websites.

9. Third-Party Services

Our Service integrates with various third-party services. We are not responsible for the privacy practices of these external services:

9.1 Key Third-Party Services

• Google OAuth: For authentication and account creation
• Payment Processors: For billing and subscription management
• Email Delivery: For sending automated emails
• Analytics: For usage tracking and optimization

9.2 External Links

Our Service may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites.

We encourage you to review the privacy policies of any third-party services you use in connection with our Service.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own, including the United States where Spearmint LLC is located.

10.1 Transfer Safeguards

When transferring data internationally, we implement appropriate safeguards including:

• Standard contractual clauses
• Adequacy decisions
• Certification schemes
• Other legally recognized transfer mechanisms

10.2 Data Processing Locations

Your data may be processed in:

• United States (primary)
• European Union (if using EU-based services)
• Other jurisdictions where our service providers operate

11. Children's Privacy

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

11.1 Age Verification

By using our Service, you represent that you are at least 13 years old or have obtained parental consent.

11.2 Parental Rights

If you are a parent or guardian and believe your child has provided personal information to us, please contact us immediately. We will delete such information from our systems.

11.3 School and Educational Use

If our Service is used in an educational context, we comply with applicable laws including COPPA and FERPA.

12. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

12.1 Right to Know

You have the right to request disclosure of:

• Categories of personal information collected
• Sources of personal information
• Business purposes for collection
• Categories of third parties with whom information is shared
• Specific pieces of personal information collected

12.2 Right to Delete

You have the right to request deletion of personal information, subject to certain exceptions.

12.3 Right to Opt-Out

You have the right to opt-out of the sale of personal information. We do not sell personal information.

12.4 Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

13. GDPR Compliance

If you are located in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR):

13.1 Legal Basis for Processing

We process your personal information based on:

• Contract: To provide our Service
• Legitimate Interest: To improve our Service and prevent fraud
• Consent: For marketing communications
• Legal Obligation: To comply with applicable laws

13.2 Your GDPR Rights

• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object
• Right to withdraw consent

13.3 Data Protection Officer

For GDPR-related inquiries, contact our Data Protection Officer at: [email protected]

13.4 Supervisory Authority

You have the right to lodge a complaint with your local supervisory authority if you believe we have violated your privacy rights.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

14.1 Notification of Changes

We will notify you of material changes by:

• Posting a notice on our website
• Sending an email to registered users
• Updating the "Last Updated" date
• Providing in-app notifications

14.2 Effective Date

Changes become effective immediately upon posting unless otherwise specified. Your continued use of the Service constitutes acceptance of the updated policy.

14.3 Previous Versions

We maintain records of previous versions of this Privacy Policy. Contact us if you need access to a previous version.

15. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

15.1 Privacy Inquiries

For privacy-related questions, please include:

• Your name and contact information
• Nature of your inquiry or request
• Account information (if applicable)
• Specific privacy concern or question
• Preferred method of response

15.2 Data Subject Requests

For requests related to your personal data (access, deletion, correction), please provide:

• Verification of your identity
• Specific request details
• Account information
• Preferred delivery method for response

15.3 Security Concerns

If you discover a security vulnerability or have concerns about data security, please contact us immediately at [email protected] with "Security" in the subject line.