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SPREE FINANCE PRIVACY POLICY
Effective Date: August 21st, 2025
Engaged Labs, Inc., a Wyoming Corporation and a technology service provider to the Spree Finance site and Dashboard (“EL”, “we,” “us,” or “our”), respects your privacy and is committed to protecting the limited data we collect in connection with the Spree Dashboard and related services (the “Services”).
This Privacy Policy (the “Policy”) describes in detail the categories of information we collect, the purposes for which we process that information, the lawful bases relied upon, and the limited circumstances in which we disclose information to third parties.
Key Principle: EL does not collect or retain traditional personally identifying information (“PII”) such as Social Security numbers, government-issued identification, or bank account details. We only collect and process a narrow category of identifiers and commercial usage data necessary to provide incentive delivery, partner campaigns, and personalization within the Spree ecosystem.
By signing into the Dashboard with a connected account and wallet, you expressly acknowledge and consent to the practices described herein. If you do not agree to this Policy, you should not use the Services.
1. Information We Collect
When you connect an account or wallet to the Dashboard, Engaged Labs may collect the following information:
1.1 Identifiers
- Email address associated with your connected account.
- Linked blockchain wallet address.
- Account handle or username.
1.2 Commercial and Behavioral Data
-Purchase history with Spree Network-enabled merchants.
- Redemption activity for rewards and incentives.
- Engagement metrics (e.g., clicks, interactions, frequency of use).
1.3 Incentive Participation Data
- Promotions and campaigns for which you qualify.
- Rewards delivered to your account.
- Redemption outcomes (e.g., whether an incentive was used).
- EL does not knowingly collect sensitive personal information (such as biometric data, health data, or financial account numbers).
2. PURPOSES OF PROCESSING
EL processes the limited categories of information above solely for the following purposes:
2.1 Incentive Delivery and Rewards Management – to fulfill and administer loyalty, rewards, and incentive programs
2.2 Partner Campaign Deployment – to enable white-label or partner campaigns tied to your connected account.
2.3 Personalization and User Experience – to tailor Dashboard features and improve engagement.
2.4 Compliance and Legal Obligations – to the extent necessary to comply with applicable laws, regulations, or valid legal processes.
We do not process information for generalized advertising, profiling outside the Services, or resale.
3. LEGAL BASIS FOR PROCESSING
Depending on your jurisdiction, EL relies on one or more of the following lawful bases:
3.1 Consent – By signing in to the Dashboard with your connected account, you affirmatively consent to data collection and processing.
3.2 Performance of Contract – Processing is necessary to provide the Services and administer incentive programs
3.3 Legal Obligation – Processing may be required to comply with applicable law.
3.4 Legitimate Interests – To improve user experience, ensure platform security, and maintain operational functionality, provided such interests are not overridden by your rights.
4. SHARING OF INFORMATION
EL may share limited account data only in the following circumstances:
4.1 Authorized Merchants and Partners – strictly as necessary to deliver rewards, campaigns, and incentives.
4.2 Service Providers – with vendors who provide infrastructure, data hosting, analytics, or technical support, bound by confidentiality and data processing agreements.
4.3 Legal and Regulatory Requirements – when disclosure is compelled by law, regulation, subpoena, or court order.
4.4 Business Transactions – in connection with mergers, acquisitions, financings, or sale of assets, provided protections remain in place.
EL does not sell or license user data to unaffiliated third parties.
5. DATA RETENTION
We retain information only for so long as reasonably necessary to:
- administer ongoing programs;
- satisfy contractual or legal obligations; or
- fulfill the limited purposes described above.
In general, identifiers and commercial usage data will be retained for up to 24 months following your last activity on the Services, unless a longer period is required by law or for contractual obligations. After the applicable retention period, EL will either anonymize the data (so it is no longer associated with you) or securely delete it. EL reviews retention periods on a recurring basis to ensure alignment with legal and operational requirements. When retention is no longer required, EL will anonymize or securely delete such data.
6. SECURITY MEASURES
EL maintains organizational, administrative, and technical safeguards intended to protect the limited data we process. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
7. INTERNATIONAL DATA TRANSFERS
Where data is transferred outside of the United States, the European Economic Area (“EEA”), or the United Kingdom, such transfers will be carried out in compliance with applicable data protection laws, including through the use of Standard Contractual Clauses or other recognized safeguards.
8. YOUR RIGHTS
Depending on your jurisdiction, you may have the following rights:
8.1 Access – to request confirmation of what information we hold.
8.2 Correction – to request updates or corrections.
8.3 Deletion – to request erasure, subject to legal or contractual retention obligations.
8.4 Restriction – to request that processing be limited under certain conditions.
8.5 Portability – to request transfer of your information to another provider, where applicable.
8.6 Objection / Withdrawal of Consent – to object to processing or withdraw previously given consent.
To exercise these rights, contact us at corp@spree.finance.
9. CHILDREN'S DATA
The Services are not intended for use by individuals under 18 years of age. We do not knowingly collect data from minors.
10. CHANGES TO THIS POLICY
We may update this Policy periodically to reflect changes in our practices or for other operational, legal, or regulatory reasons. Updates will be posted to the Dashboard with an updated “Effective Date.”
11. CONTACT INFORMATION
To exercise these rights, contact us at corp@spree.finance. EL may request reasonable verification to confirm that the request is made by the account holder (e.g., by confirming access to the connected email or blockchain wallet). We will respond within the timeframes required by applicable law (typically 30–45 days). If we deny a request, we will explain the reason and provide information on how you can appeal or lodge a complaint with the relevant authority.
Engaged Labs, Inc.
30 N Gould St., Sheridan, WY, 82801, U.S.A.
Email: corp@spree.finance
12. JURISDICTION-SPECIFIC DISCLOSURES
12.1 California (CCPA/CPRA)
California residents may request additional information on categories of data collected and disclosed, and may exercise rights to opt out of any “sale” or “sharing” of data (though Spree does not engage in such practices).
12.2 European Union / UK (GDPR / UK GDPR)
Where applicable, Engaged Labs acts as “data controller” and relies on the lawful bases described above. You may lodge complaints with your local supervisory authority.
12.3 Other Jurisdictions
Local data protection rights may apply. We will honor them to the extent required under applicable law. Residents of U.S. states with applicable privacy laws (such as Virginia, Colorado, or Connecticut) may also have similar rights, which EL will honor to the extent required.
By using the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy between you and Engaged Labs, Inc..
Last Updated: August 21st, 2025