DATA PRIVACY AND SECURITY POLICY
The Spyrow Program
914 N. San Francisco Street, Suite M, Flagstaff, Arizona 86001
Last Updated: May 5, 2026
Introduction
This website and online platform are operated by The Spyrow Program (the "Company,"Â "we," "us," or "our"). We are committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website or purchase access to our educational oncology nutrition
video content.
Because our platform serves users nationwide, this policy is designed to comply with applicable federal privacy laws as well as state privacy laws, including the California Consumer Privacy Act
(CCPA/CPRA), and Arizona’s data breach notification requirements.
This policy may be updated periodically. We encourage you to review it regularly. By using our platform, you signify your acceptance of this Privacy Policy. If you do not agree, please do not use our website or platform.
What Information Do We Collect?
Information You Provide Directly
When you create an account, purchase a subscription, or contact us, we may collect:
• Name, email address, mailing address, and phone number
• Account login credentials (username and password)
• Payment and billing information (credit card number, billing address)
• Any communications you send to us
Information Collected Automatically
When you visit our website or use our platform, we automatically collect certain technical data,
including:
• IP address, browser type, and operating system
• Device identifiers
• Pages visited, videos accessed, and time spent on content
• Date and time of your visits• Referring URLs
This data is used to improve our platform and is evaluated statistically. It is not used to identify you personally unless combined with other information you have provided.
Health-Related Information — Important Notice
Our platform provides educational content related to oncology nutrition. We want to be clear: we do not collect, store, or process medical records, diagnoses, treatment information, or any Protected Health Information (PHI) as defined under HIPAA. Our platform is an educational service and does not constitute medical advice or create a healthcare provider relationship. We strongly encourage users to consult qualified medical professionals regarding
any health or treatment decisions.
If you voluntarily share health-related context when contacting us (for example, in a support email), that information is treated with strict confidentiality and used only to respond to your inquiry.
How Do We Use Your Information?
We use the information we collect to:
• Create and manage your account and platform access
• Process subscription payments and deliver purchased content
• Communicate with you about your account, updates, or support requests
• Improve and personalize your experience on the platform
• Send you marketing communications about new content or offerings (where you have
consented or where permitted by law)
• Comply with legal obligations and enforce our Terms of Service
Legal Basis for Processing
Where required by applicable law, we process your personal data on the following bases:
Performance of a contract — to provide you the services you have purchased.
Legitimate interests — to improve our platform and communicate relevant updates.
Legal obligation — to comply with applicable laws and regulations.
Consent — for marketing communications, where required.
Do We Share Your Information with Third Parties?
We do not sell your personal information. We may share your information with trusted third parties only in the following circumstances:
Service providers who assist in operating our platform (e.g., payment processors, email delivery services, video hosting providers, customer support tools). These providers are
contractually required to protect your data and may only use it to perform services on our behalf.
Legal compliance — if required by court order, lawful subpoena, or applicable law.
Business transfers — in connection with a merger, acquisition, or sale of assets, in which case
users will be notified.
We do not share your personal information with third parties for their own independent marketing purposes without your consent.
Your Privacy Rights
Depending on your state of residence, you may have the following rights regarding your personal data:
Access — the right to request a copy of the personal information we hold about you.
Correction — the right to request correction of inaccurate data.
Deletion — the right to request deletion of your personal data, subject to certain legal
exceptions.
Opt-out of marketing — the right to withdraw consent for marketing communications at any time.
Data portability — where applicable, the right to receive your data in a portable format.
Non-discrimination — we will not discriminate against you for exercising your privacy rights.
California Residents: Under the CCPA/CPRA, you have additional rights, including the right to know what personal information is sold or disclosed (we do not sell personal information), and the right to opt out of sale. To exercise your California privacy rights, contact us at the address
below.
To exercise any of these rights, please contact us in writing at:
The Spyrow Program
914 N. San Francisco Street, Suite M
Flagstaff, Arizona 86001
Email: [email protected]
We will respond to verifiable requests within the timeframes required by applicable law
(generally 30–45 days).
Marketing Communications
If you opt in to receive marketing communications from us, we may send you emails about new educational content, promotions, or platform updates. You may withdraw your consent and
unsubscribe at any time by:
• Clicking the "subscribe" link in any marketing email, or
• Contacting us in writing at the address above
Once we receive your request, we will promptly stop sending marketing communications. Please note that transactional messages related to your account or purchases are not considered marketing and will continue as necessary.
Cookies and Tracking Technologies
Our platform uses cookies and similar tracking technologies to enhance your experience.
Cookies are small text files stored on your device. We use them to:
• Remember your login and preferences
• Track platform usage for improvement purposes
• Support secure authentication
You may configure your browser to refuse cookies; however, doing so may limit certain platform features, including the ability to access your purchased video content.
We do not currently respond to "Do Not Track" browser signals, but we will update this policy if our practices change.
Data Retention
We retain your personal data only as long as necessary to:
• Maintain your account and provide services you have purchased
• Comply with legal, tax, and accounting obligations
• Resolve disputes and enforce our agreements
Payment card data is not retained beyond what is necessary to complete the applicable transaction. Upon request, we will delete your personal data subject to any legal retention
requirements.
How Do We Protect Your Data?
We implement commercially reasonable technical, administrative, and physical safeguards to
protect your personal information, including:
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• Encrypted transmission of data (SSL/TLS)
• Secure storage of account credentials
• Access controls limiting who within our organization may access personal data
• Regular review of our data practices
However, no method of internet transmission is completely secure. We cannot guarantee absolute security of information transmitted to or from our platform. We recommend that you never send complete payment card information by email.
In the event of a data breach affecting your personal information, we will notify you as required
by applicable law, including Arizona’s data breach notification statute (A.R.S. § 18-552) and any
other applicable state laws.
Third-Party Websites and Links
This Privacy Policy applies only to our website and platform. Our site may contain links to third-party websites that we do not control. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party site you visit before providing personal information.
Special Notice Regarding Children’s Privacy
Our platform is intended for adults aged 18 and older. We do not knowingly collect personal information from children under the age of 13, consistent with the Children’s Online Privacy Protection Act (COPPA). If you believe a child under 13 has provided us with personal information, please contact us immediately and we will delete it from our records.
Medical Disclaimer
The educational content available on our platform, including all oncology nutrition videos, is provided for informational and educational purposes only. It does not constitute medical
advice, diagnosis, or treatment. Always seek the guidance of a qualified physician, registered dietitian, or other licensed healthcare provider with questions you may have regarding a medical
condition or nutritional needs. Never disregard professional medical advice or delay seeking it because of something you have seen or heard on our platform.
Contact Us
If you have questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us at:
The Spyrow Program914 N. San Francisco Street, Suite M
Flagstaff, Arizona 86001
[email protected]
This Privacy Policy was last updated May 5, 2026.
