Privacy Policy

Spryia (“Spryia,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit Spryia.com, create an account, purchase or use our products and services, communicate with us, or otherwise interact with the Spryia platform (collectively, the “Services”).

By using the Services, you acknowledge the practices described in this Privacy Policy. If you do not agree with this policy, please do not use the Services.

1. Information We Collect

The information we collect depends on how you interact with Spryia.

Information You Provide

We may collect:

• Account information, including your name, email address, password, organization, professional role, and account preferences.
• Transaction information, including the products or services purchased, transaction amount, billing details, and purchase history. Payment card information is generally collected and processed directly by our payment processor rather than stored by Spryia.
• Profile and directory information, including business names, provider information, services offered, locations, contact details, qualifications, licenses, certifications, and other information submitted for a directory listing or professional profile.
• Program and participant information, including information entered into transition-planning, employment-readiness, job-matching, assessment, or related tools.
• Sensitive information, if voluntarily submitted, such as disability, accommodation, support-needs, educational, employment, behavioral, or health-related information.
• AI feature content, including prompts, instructions, documents, responses, and other content submitted to or generated through AI-enabled features.
• Communications, including messages, support requests, survey responses, reviews, testimonials, and other correspondence.
• Marketing preferences, including newsletter subscriptions and communication choices.
• Job and employment information, such as résumés, employment interests, work-readiness information, skills, availability, accommodations, or job application materials.

Please do not provide personal information about another person unless you have the legal authority and all required permissions or consents to do so.

Information Collected Automatically

When you use the Services, we and our service providers may automatically collect:

• IP address;
• browser, device, and operating-system information;
• pages viewed and links selected;
• referring and exit pages;
• dates, times, and duration of visits;
• approximate location derived from an IP address;
• account and feature activity;
• cookie identifiers and similar technical information; and
• diagnostic, performance, security, and error data.

We may collect this information through cookies, pixels, software development kits, local storage, server logs, and similar technologies.

Information From Other Sources

We may receive information from:

• payment processors;
• authentication and account-management providers;
• analytics, advertising, and email-service providers;
• employers, service providers, caregivers, professionals, or organizations that use Spryia;
• publicly available sources, including professional licensing databases and business websites;
• referral partners and integration providers; and
• users who submit information about another person when legally authorized.

2. How We Use Information

We may use personal information to:

• create, administer, and secure user accounts;
• provide and personalize the Services;
• process transactions and deliver purchases;
• operate provider directories, employment tools, transition programs, and digital products;
• verify provider, professional, employer, or business information;
• support job matching, work-readiness, and transition-planning functions;
• operate AI-enabled tools and generate requested outputs;
• communicate about accounts, transactions, service changes, and support matters;
• send newsletters and promotional communications where permitted by law;
• analyze usage and improve our website, products, features, and user experience;
• detect, investigate, and prevent fraud, abuse, security incidents, and unlawful activity;
• enforce our agreements and protect our rights, users, and business;
• comply with legal, regulatory, tax, accounting, and reporting obligations; and
• carry out another purpose disclosed when the information is collected or with your consent.

Where applicable law requires a legal basis for processing, we process information based on performance of a contract, legitimate business interests, compliance with legal obligations, consent, or another legally permitted basis.

3. AI-Enabled Features

Some Spryia Services may use artificial intelligence supplied by Spryia or third-party technology providers.

Information submitted to an AI feature may be transmitted to service providers that help us process the request and generate a response. Users should not submit highly sensitive personal information, confidential records, protected health information, or information they are not legally authorized to disclose unless Spryia has expressly approved that use in writing.

AI-generated information may be incomplete, inaccurate, or inappropriate for a particular person. AI output is provided as a support tool and must not replace professional judgment, individualized assessment, medical advice, legal advice, clinical decision-making, or legally required human review.

We will describe any materially different use of AI-submitted information through the applicable feature, terms, or consent notice.

4. Health, Disability, and Other Sensitive Information

Spryia may process disability-related, accommodation, support-needs, educational, behavioral, or employment information when users voluntarily provide it to access relevant features.

Spryia is not automatically a healthcare provider, health plan, or HIPAA-covered entity. Unless Spryia has entered into a written Business Associate Agreement expressly covering a particular service, users must not treat Spryia as a HIPAA-compliant medical-record system or submit protected health information that requires HIPAA safeguards.

Organizations and professionals using Spryia are responsible for determining whether they have the authority, notice, consent, and legal basis required to collect, enter, disclose, and use information about clients, patients, students, employees, job candidates, or program participants.

We do not use sensitive personal information to unlawfully discriminate against an individual.

5. How We Disclose Information

We may disclose information to the following categories of recipients:

Service Providers

We may disclose information to vendors that provide services such as:

• website and cloud hosting;
• payment processing;
• account authentication;
• email delivery;
• analytics;
• customer support;
• document storage;
• cybersecurity;
• AI processing; and
• business operations.

These providers may use information only as permitted by their agreements with us and applicable law.

Organizations and Authorized Users

If an account is created through or managed by an employer, clinic, school, provider, caregiver, job coach, agency, or other organization, authorized representatives of that organization may be able to access information associated with the account.

Directory and Public Information

Information intentionally submitted for publication in a public directory, provider profile, employer listing, job posting, review, testimonial, or similar public feature may be visible to other users and the public. Do not submit information for public display that you wish to keep private.

Business Transactions

We may disclose information in connection with a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar business transaction, subject to applicable law.

Legal and Safety Purposes

We may disclose information when reasonably necessary to:

• comply with a law, regulation, subpoena, court order, or legal process;
• respond to lawful government requests;
• investigate fraud, security incidents, or violations of our agreements;
• protect the rights, property, safety, or security of Spryia, our users, or others; or
• establish, exercise, or defend legal claims.

With Your Direction or Consent

We may disclose information when you direct us to do so, authorize an integration, request that information be sent to another party, or otherwise provide consent.

6. Sale, Sharing, and Targeted Advertising

Spryia does not sell personal information for money.

However, certain privacy laws may define the use of advertising cookies or the disclosure of identifiers to advertising and analytics partners as “selling,” “sharing,” or processing for targeted advertising—even when no money is exchanged.

If Spryia uses technologies covered by these definitions, eligible users may opt out by visiting [insert “Your Privacy Choices” link], adjusting the cookie-consent settings, or contacting us at hello@spryia.com.

Spryia does not knowingly sell or share the personal information of individuals under 16 for targeted advertising.

7. Cookies and Similar Technologies

We use cookies and similar technologies to:

• keep users signed in;
• remember settings and preferences;
• operate essential website functions;
• measure traffic and performance;
• understand how users interact with the Services;
• detect fraud and protect accounts; and
• support advertising where applicable.

Some cookies are necessary for the Services to function. Where required by law, we will request consent before using nonessential cookies.

You may manage cookies through our cookie-preference tool, if available, or through your browser settings. Blocking certain cookies may prevent parts of the Services from operating correctly.

Spryia currently [does/does not] respond to legally recognized browser-based opt-out signals, such as Global Privacy Control. This statement must be updated to reflect Spryia’s actual technical practices.

8. Email and Marketing Communications

We may send administrative messages relating to accounts, purchases, security, or the operation of the Services. These messages are not promotional, and users may not be able to opt out while maintaining an active account.

You may unsubscribe from promotional emails by selecting the unsubscribe link in the email or contacting hello@spryia.com. We may retain limited information necessary to honor your opt-out request.

9. Data Retention

We retain personal information only for as long as reasonably necessary to:

• provide the Services;
• maintain an active account;
• complete transactions;
• fulfill the purposes described in this policy;
• comply with legal, tax, accounting, and regulatory requirements;
• resolve disputes;
• enforce agreements; and
• prevent fraud or security incidents.

Retention periods vary depending on the type of information, the purpose for which it was collected, legal requirements, and whether continued retention is reasonably necessary.

When information is no longer required, we may delete, deidentify, or aggregate it, subject to technical and legal limitations. Information may remain temporarily in encrypted backups until those backups are overwritten under our normal retention process.

10. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

No online service, database, or transmission method is completely secure. We cannot guarantee absolute security. Users are responsible for maintaining the confidentiality of their login credentials and promptly notifying us of suspected unauthorized account access.

11. Children’s Privacy

Spryia’s general Services are not intended for independent use by children under 13, and children under 13 may not create their own accounts.

A parent, legal guardian, school, clinic, provider, or other authorized organization may use certain Spryia features on behalf of a minor only when legally permitted and after obtaining any required parental consent or other authorization.

We do not knowingly collect personal information directly from a child under 13 without legally valid parental consent. If we learn that personal information was collected directly from a child under 13 without the required consent, we will take reasonable steps to delete it.

Parents or legal guardians who believe a child has provided personal information improperly may contact hello@spryia.com.

Spryia must implement a separate parental notice and verifiable parental-consent process before offering any service directed to children under 13 that collects personal information from them.

12. Your Privacy Rights

Depending on where you live, you may have the right to:

• confirm whether we process your personal information;
• request access to personal information;
• request correction of inaccurate information;
• request deletion of information;
• obtain a portable copy of certain information;
• opt out of the sale or sharing of information;
• opt out of targeted advertising or certain profiling;
• restrict or limit certain uses of sensitive information;
• withdraw consent where processing is based on consent; and
• appeal a decision regarding a privacy request.

These rights are not absolute and may be subject to legal exceptions. We may need to verify your identity before completing a request. Authorized agents may submit requests where permitted by law, but we may require proof of authorization and identity verification.

We will not unlawfully discriminate against you for exercising a privacy right.

To submit a request, contact:

Email: hello@spryia.com

Privacy request form: [insert link, if available]

Privacy choices: [insert link, if applicable]

We will respond within the period required by applicable law.

13. California Privacy Notice

If California privacy law applies to Spryia and your information, California residents may have rights concerning access, correction, deletion, portability, and opting out of the sale or sharing of personal information.

During the preceding 12 months, Spryia may have collected the categories of personal information described in Section 1, used them for the purposes described in Section 2, and disclosed them to the categories of recipients described in Section 5.

Spryia does not sell personal information for money. If our use of advertising or analytics technology qualifies as selling or sharing under California law, eligible users may opt out through [insert privacy-choices mechanism].

We do not use or disclose sensitive personal information for purposes requiring a separate right to limit under California law, except as otherwise disclosed at collection.

This section should be reassessed when Spryia meets the legal thresholds that make the California Consumer Privacy Act applicable.

14. Third-Party Websites and Services

The Services may contain links to websites, applications, employers, providers, payment services, or other third-party resources that Spryia does not control.

This Privacy Policy does not govern those third parties. Spryia is not responsible for their privacy, security, accuracy, or business practices. Review the privacy policies of third-party services before providing information to them.

A listing in the Spryia directory does not, by itself, mean that Spryia controls or endorses the listed organization’s privacy practices.

15. International Users and Data Transfers

Spryia is operated from the United States. If you access the Services from another country, your information may be processed in the United States or another jurisdiction where our service providers operate.

Where required, we will use legally recognized safeguards for international transfers of personal information.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our Services, technology, business practices, or legal obligations.

We will post the updated policy with a revised “Last Updated” date. If a change materially affects how we use personal information, we will provide additional notice or obtain consent when required by law.

Continued use of the Services after the effective date of an updated policy constitutes acknowledgment of the revised policy to the extent permitted by law.

17. Contact Us

Questions, concerns, and privacy requests may be directed to:

Spryia

Email: hello@spryia.com

Website: https://spryia.com

Mailing Address: [Insert complete business mailing address]

Privacy Request Form: [Insert link, if available]