Effective Date: October 31, 2025
 
SP-OIL Inc., together with its affiliates and subsidiaries (collectively, “SP-OIL,” “we,” “us,” or “our”), values your privacy and the trust you place in us. This Global Privacy Policy (“Policy”) explains the types of personal information (“Information”) we collect about our customers—both in-store and online—how we use and protect that Information, with whom we share it, and the choices available to you regarding our use of your Information. This Policy also describes how you can contact us regarding our privacy practices.

PLEASE READ THIS POLICY CAREFULLY. By submitting information to or through our Website, you consent to the collection, use, disclosure, and retention of your Information as described in this Policy. By using the Website, you also agree to our Terms of Use (https://thespoilcollective.com/en-ca/terms.html) and accept our practices regarding the handling of your Information.
To exercise any rights described in this Policy, you may contact us using the information provided in Section 19: “How to Contact Us.”
 
Contents of this Privacy Policy
 

1. How We Collect Your Information
    

   • Information You Provide
      

   • Information Collected Automatically
      

2. How We Use Your Information
    

   • General Uses
      

   • Technologies We Use
      

   • How Automated Information Is Used
      

   • Do Not Track Signals
      

3. Information We Share
    

4. Your Rights and Choices
    

5. Children’s Privacy
    

6. Storage of Information / Data Transfers
    

7. Information Security and Data Retention
    

8. User-Submitted Content
    

9. Third-Party Websites
    

10. California Privacy Rights
     

11. Nevada Residents
     

12. EU Residents
     

13. Updates to Our Privacy Policy
     

14. How to Contact Us
     

1. How We Collect Your Information
We may obtain information about you from various sources. We may collect information when you purchase goods or services from us, provide it to us at one of our stores, on our website located at www.thespoilcollective.com (the “Website”), via our social media pages, at one of our events or if you contact us by telephone, e-mail or live chat.

Our products are available for sale online, in our or our reseller’s retail stores and many department stores. Unless otherwise indicated at the time that you provide your information, any information collected in our reseller’s retail stores or department stores is not provided to us. This Policy does not address any data collection by any of our retail partners. When you visit our Website or our social media pages, we may also collect certain information about your device or usage by automated means, including using technologies such as cookies, web server logs and web beacons.

The kinds of personal information we may collect are set out in Sections 2 and 3 of this Policy.

Information You Provide
You may choose to share information with us in various ways, including when you:
 

• Participate in an offer or promotion
   

• Make a purchase on our Website or in our stores
   

• Engage with us via our social media pages
   

The types of information you may provide include, but are not limited to:
 

• Contact Information: name, postal address, email address, phone number, or mobile number
   

• Personal Details: age and date of birth, gender
   

• Payment Information: billing and delivery addresses, and other payment details
   

• Purchase History and account information (e.g., user ID)
   

• Product Preferences and Feedback
   

• Location Information
   

• Product-Related Information: including product complaints, reactions, allergies, or ethnic origin as relevant to product use
   

• User-Generated Content: such as photographs, videos, reviews, articles, survey responses, and comments
   

• Device Information: details about the device you use to access our Website or social media pages, including unique device identifiers, IP address, device type, or operating system
   

• Social Media Information: information you provide through social media networks when interacting with our pages, including your name, profile picture, likes, location, friend list, and other publicly available information

 
Information We Collect by Automated Means
When you visit our Website, interact with our online advertisements (including ads on third-party websites), or engage with our social media pages, we may collect certain information automatically using technologies such as cookies, web server logs, web beacons, and similar tools. This information may include:
 

• Your IP address
   

• Unique device identifiers or other device-specific information
   

• Geolocation data
   

• Usage and browsing activity, including pages viewed, links clicked, and time spent on our Website
   

We also use third-party services such as Adyen, Stripe, and PayPal for payment processing, analytics, and other business services. These providers may collect identifying information about your devices in connection with the services they provide to us, including for purposes such as fraud detection and service improvement.

For more information about their privacy practices, see:

• Adyen Privacy Policy
   

• Stripe Privacy Policy
   

• PayPal Privacy Policy
   

 
2. How We Use Your Information
We may use the information we collect, whether provided by you or collected automatically, for purposes including but not limited to:
 

• Sending promotional materials or other communications in line with your preferences
   

• Providing products and services, including processing payments and gift card transactions
   

• Creating and managing your online account, including access to your purchase history (online and in-store)
   

• Assisting with product selection and responding to your inquiries
   

• Personalizing advertisements on our Website and elsewhere based on your interests and interactions with us
   

• Administering and communicating about special events, contests, sweepstakes, surveys, and other offers
   

• Operating and improving our social networking applications
   

• Evaluating, developing, and improving our business, products, and services
   

• Managing communications, analyzing products, performing data analytics, and supporting accounting, auditing, and internal functions
   

• Protecting our systems and infrastructure from security risks
   

• Complying with applicable laws, industry standards, and internal policies
   

• Any other uses authorized or permitted by applicable law
   

We will notify you in advance if we intend to use your information in ways not described in this Policy.
 
Technologies We Use

Cookies, Web Server Logs, and Web Beacons
Our Website uses cookies—small text files stored on your device—to uniquely identify your browser, remember your preferences, and enhance your experience. Your browser settings may allow you to receive notifications about cookies or restrict or disable them. Please note that some features of our Website may not function properly without cookies. 

In addition to cookies, our web servers may log information such as your device type, operating system, browser type, language settings, IP address, and the country and time zone of your device. Logs may also capture the referring website or page that brought you to our Website.

We may also use web beacons, which are small tags on web pages that link pages to servers and cookies, helping us measure and improve how our Website is used.

Third-Party Web Analytics Services
We may use third-party analytics services, such as Google Analytics, to help us understand how visitors interact with our Website. These services use cookies, web server logs, and web beacons to collect anonymized information, such as IP addresses and browsing behavior, for analysis. This information is used to evaluate Website performance and user experience. You may opt-out of Google Analytics tracking by using Google’s Analytics opt-out browser add-on.

Targeted Advertising
We may work with third-party advertising networks that collect information, including IP addresses, cookies, web server logs, and web beacons, across our Website, emails, and advertising placed on third-party websites. This information is used to deliver ads tailored to your interests and to track the effectiveness of our marketing campaigns. Some of these ads may promote products and services from companies not affiliated with SP-OIL.

You can manage your preferences regarding targeted advertising and the sharing of your information with these third parties by adjusting your cookie settings [here] or via our “Do Not Sell My Personal Information” page.

How We Use the Information Collected by Automated Means
Information collected automatically through our Website may be used for purposes including, but not limited to:
 

• Market Research and Data Analytics: to better understand visitor behavior, preferences, and trends
   

• System Administration: to manage and improve Website functionality and performance, including identifying returning or new visitors
   

• Personalized Advertising: to tailor ads shown to you on our Website and across other platforms
   

• Compliance: to adhere to applicable laws, regulations, policies, and relevant industry standards
   

We may also use this information for other purposes, provided we notify you of such uses at or before the time of collection.
 
Do Not Track
At this time, SP-OIL does not modify its tracking practices in response to “Do Not Track” signals or similar browser settings.
“Do Not Track” is a privacy preference you can enable in your web browser to indicate that you do not wish certain information about your browsing activity to be collected across websites when you have not directly interacted with those services.
For more information, including instructions on enabling “Do Not Track,” please visit https://www.eff.org/issues/do-not-track.

3. Information We Share
We do not rent, sell, or otherwise disclose your personal information except as described below:

• Affiliated Entities: We may share information with our affiliated legal entities.
   

• Service Providers: We may share information with third-party service providers who perform services on our behalf in accordance with our instructions. These providers are authorized to use your information only as necessary to perform services for us or to comply with legal requirements. Examples include providers that process payments, fulfill orders, host our website, or provide advertising and marketing services.
   

• Legal and Safety Requirements: We may retain and disclose information about you:
   

  • When required by law or legal process
     

  • To law enforcement authorities or other government officials
     

  • When we believe disclosure is necessary to prevent physical harm or financial loss, or to investigate suspected or actual fraudulent or illegal activity
     

• Business Transfers: In the event that we sell, transfer, or reorganize all or part of our business or assets—such as in a merger, acquisition, reorganization, liquidation, or change in control—we may transfer your information to the new owner. We will use reasonable efforts to ensure the transferee uses your information in a manner consistent with this Privacy Policy. After such a transfer, you may contact the acquiring entity with inquiries regarding their processing of your information.

 
4. Your Rights and Choices
You have certain choices regarding the information we collect about you, including how we use it and how we communicate with you. To update your preferences, please contact us as outlined below.

Email Opt-Out
You may opt out of receiving marketing emails from us at any time by clicking the unsubscribe link included in our emails or by contacting us directly using the details in Section 19 of this Policy.

Social Media Application Opt-Out
To remove or disable our social media applications from your account, please follow the instructions provided by the specific social network.

Access and Correction of Your Information
You have the right to request access to or correction of any personal information we hold about you. We will respond promptly and in accordance with applicable laws. To submit a request, please use the contact information provided in Section 19 of this Policy.

5. Children’s Privacy
Our Website is not directed to children under the age of sixteen, and we do not knowingly collect information from children under sixteen. If we discover that we have inadvertently collected information from a child under sixteen, we will promptly delete it from our records.
 
6. Storage of Information / Data Transfers
SP-OIL is headquartered in Canada and operates an online business. As a result, your information may be transferred to, stored in, or processed in other countries, including Canada, the United States, Australia, Germany, France, Hong Kong, the United Kingdom, and other jurisdictions that may not provide the same level of privacy or data protection as your country of residence.

Regardless of where your information is stored or processed, we are committed to protecting it in accordance with this Privacy Policy and applicable laws.
 
7. Information Security and Data Retention
We implement a combination of physical, technical, organizational, and administrative measures to protect your information from unauthorized access, use, or loss. For example, we use encryption and other technologies to safeguard sensitive data, such as your name and address, during transmission.

While we strive to maintain high standards of security, no system can guarantee complete protection, and we cannot ensure that your information will remain secure under all circumstances, including during transmission to us.

We will retain your information for as long as it is necessary to fulfill the purposes outlined in this Policy and for any additional period required or permitted by applicable law.
 
8. User Submitted Content
Users may have the ability to submit reviews, content, or other materials they create through our Website or third-party social media platforms. SP-OIL reserves the right, at its sole discretion, to remove, edit, or moderate any user-submitted content on the Website or through third-party platforms.

Any opinions expressed in user-submitted content are solely those of the individuals who submitted them and do not necessarily reflect the views, policies, or positions of SP-OIL. By submitting content, you assume all risks associated with such submissions, including any third party’s reliance on its accuracy, quality, or reliability, or the disclosure of information that could make you or others personally identifiable.

You agree that SP-OIL has no responsibility or liability for any user-submitted content. Furthermore, you acknowledge that your content is not sponsored or endorsed by SP-OIL, and you will not imply or represent that it is.
 
9. Third-Party Websites
Our Website may include links to third-party websites, each of which may have its own privacy policies and terms and conditions that are not governed by this Policy. SP-OIL is not responsible for the privacy practices, content, or policies of any third-party websites.
Third-party websites may collect, use, and share information differently than we do. We encourage you to review the privacy policies of any website you visit. Any links, references to products, services, or publications from third parties do not constitute an endorsement or approval by SP-OIL.
 
10. California Privacy Rights

California “Shine the Light” Law
If you are a California resident, you have the right once per year to request information about whether we have shared your personal information with third parties for their direct marketing purposes. To make such a request, please contact us using the details provided in Section 19 below. Please indicate in your correspondence that you are making a “California Shine the Light” request.
California Consumer Privacy Act (“CCPA”).

If you reside in California, you have the following rights under the CCPA:
 

• Opt-Out of Sale: You may opt out of the sale of your personal information.
   

• Request Deletion: You may request the deletion of your personal information.
   

• Request Disclosure: You may request, no more than twice in a 12-month period, the following information regarding personal information we have collected:
   

  • Categories of personal information collected about you in the preceding 12 months
     

  • Categories of sources from which the personal information was collected
     

  • Categories of personal information sold in the preceding 12 months
     

  • Business or commercial purpose for collecting or selling your personal information
     

  • Categories of third parties with whom we shared your personal information
     

  • Specific pieces of personal information collected about you
     

You have the right not to be discriminated against for exercising any of these rights.

Information Collected
Over the preceding 12 months, we have collected certain categories of personal information from California residents for the purposes described below. For details on sources of this information and third parties with whom it may be shared, please refer to Sections 1 (“How We Collect Your Information”) and 8 (“Information We Share”) of this Policy.
 

• Category of Information

• Description 

• Purpose(s)

• Identifiers

• Name, alias, postal address, online identifier, IP address, email address, or similar identifiers

• Provide products and services, send communications, process payments, manage accounts, tailor ads, operate social applications, conduct data analytics, manage communications, improve products and services, protect systems, comply with legal requirements

• California Customer Records

• Name, signature, physical characteristics or description, address, telephone number

• Same as above

• Protected Classification Characteristics

• Race, color, national origin, gender

• Comply with applicable laws and policies

• Commercial Information

• Records of products/services purchased, obtained, or considered

• Marketing, analytics, product improvement

 
Internet or Network Activity

• Browsing history, search history, interactions with website, apps, or ads

• Tailor ads, improve services, analytics

• Geolocation Data

• Location Information

• Personalization, analytics

• Visual Information

• Physical characteristics

• Security, fraud prevention, analytics

 
Sale of Personal Information
SP-OIL does not sell personal information. However, under the CCPA, the use of third-party cookies for targeted advertising purposes may be considered a “sale.” While we do not sell personal information, as explained in Section 5.3 (“Targeted Advertising”), we do use third-party cookies to deliver tailored advertising. If you wish to prevent your information from being shared with these third parties, you can manage your cookie preferences [here] or visit our “Do Not Sell My Personal Information” page.

SP-OIL does not knowingly sell the personal information of minors under the age of 16.

Exercising Your Rights
To exercise your rights under the CCPA, you must submit a verifiable consumer request by contacting us as described in the “How to Contact Us” section and providing the requested information. You may submit a verifiable request on behalf of your minor child or designate an authorized agent to make a request on your behalf by providing signed written permission.

When submitting a verifiable consumer request, you will be asked to provide certain information to help us verify your identity. The specific information required may vary depending on the type of request, the nature and sensitivity of the personal information involved, and the potential risk of harm from unauthorized access or deletion. In some cases, we may also require a written declaration confirming your identity. If we cannot verify your identity, we will be unable to fulfill your request and will inform you accordingly.
 
Third-Party Collection
California law requires operators of websites and online services to disclose whether third parties may collect information about users’ online activities over time and across different websites when using the operator’s site or service. Third parties that provide content or services on our Website—such as social features, analytics services, or advertising network partners—may collect information about your browsing or usage activity both on our Website and on other websites that use the same third-party content or services.

11. Nevada Residents
Under Nevada law, SP-OIL does not sell your personal information. However, if you are a Nevada resident, you may submit a request to opt out of any sale of personal information we have collected about you. To do so, please contact us using the instructions in Section 19 (“How to Contact Us”) of this Policy.

12. EU Residents
For purposes of the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679), the personal data you provide through the Website is controlled by SP-OIL, and we serve as the “data controller.”

The Website is hosted on servers located in the United States or Canada. If you access the Website from the European Union, we will only transfer your personal information outside the EU with appropriate safeguards in place. We process your personal information to pursue our legitimate business interests in operating the Website, as described in “How We Use the Information”. For details on with whom we share your personal information, see Section “Information We Share”.

We will retain your personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws or regulations. Copies of information that you have updated, modified, or deleted may remain in our systems if retention is required by law.

You have the right to access your personal information, correct any inaccuracies, request the erasure of your personal information, and request restrictions on the processing of your data under certain circumstances. To exercise these rights, please contact us in writing using the details in Section 19, allowing reasonable time for us to collect the data. You also have the right to lodge a complaint with a relevant supervisory authority.
 
13. Updates to Our Privacy Policy
We may update this Privacy Policy from time to time, without prior notice, to reflect changes in our information practices or legal requirements. Any updates will be posted on this page, so you can always review the most current information about the data we collect and how we use it. We encourage you to check this page regularly, as the Policy may change periodically.
 
14. How to Contact Us
If you have questions about the information you have provided, wish to make general inquiries, or would like to contact us regarding this Privacy Policy or how SP-OIL processes your personal information, you may reach us through our Website or by postal mail as follows:  www.thespoilcollective.com/contact

You may also use the contact information above if you believe that we have not adhered to this Policy or have violated our privacy obligations under applicable law. Please include as much detail as possible to help us thoroughly investigate your concern. We take all complaints seriously and will make every effort to respond promptly.

If necessary, or if required, we may reach out to you regarding any matter involving your information via phone or email.