Spira

Last Updated: 09.12.2024

(“Spira,” “we,” “us,” “our”) provides its services (described below) to you through its website located at whitecode.com.tr (the “Site”) and its mobile applications and related services (collectively, such services, including any new features and applications, and the Site, the “Service(s)”), subject to the following Terms of Service (as amended from time to time, the “Terms of Service”). We reserve the right, at our sole discretion, to change or modify portions of these Terms of Service at any time. If we do this, we will post the changes on this page and will indicate at the top of this page the date these terms were last revised. We will also notify you, either through the Services user interface, in an email notification or through other reasonable means. Any such changes will become effective no earlier than seven (7) days after they are posted, except that changes addressing new functions of the Services or changes made for legal reasons will be effective immediately. Your continued use of the Service after any such changes constitutes your acceptance of the new Terms of Service. If you do not agree to abide by these or any future Terms of Service, do not use or access (or continue to use or access) the Service. It is your responsibility to regularly check the Site to determine if there have been changes to these Terms of Service and to review such changes.

In addition, when using certain services, you shall be subject to any additional terms applicable to such services that may be posted on the Service from time to time, including, without limitation, the Privacy Policy. All such terms are hereby incorporated by reference into these Terms of Service.

ACCESS AND USE OF THE SERVICE

Services Description: The Spira Service is designed to allow users to learn and practice languages, meet other members from around the world, and other functions, from a mobile application and/or website.

Your Registration Obligations: You may be required to register with Spira in order to access and use certain features of the Service. If you choose to register for the Service, you agree to provide and maintain true, accurate, current and complete information about yourself as prompted by the Service’s registration form. Registration data and certain other information about you are governed by our Privacy Policy. If you are under 18 years old, you may use the Service, with or without registering, only with the approval of your parent or guardian.

YOUR ACCOUNT：

You need to create an account with us in order to access and use Spira. Any account that you open with us is personal to you and you are prohibited from gifting, lending, selling, transferring or otherwise permitting any other person to access or use your account.

You are responsible for:

a. safeguarding your account details, including any passwords, phone verification code used to access your account and Spira, and

b. all use of Spira under your account, including any purchases made and/or payment obligations arising under your account. You must promptly notify us by going to "Me" -> "Settings" -> "Help" from within the Spira app or by email to info@ whitecode.com.tr if you know or suspect that your password or account has been compromised. We will regard all use of your account on Spira as being by you, except where we have received a valid and properly received notification to us regarding your account or password being compromised.

We may allow you to register for and login to Spira using sign-on functionalities provided by third party platforms, such as Wechat, QQ, Gmail, Facebook or Apple etc. You agree to comply with the relevant third party platform's terms and conditions applicable to your use of such functionalities (in addition to these Terms).

Member Account, Password and Security: You are responsible for maintaining the confidentiality of your password and account, if any, and are fully responsible for any and all activities that occur under your password or account. You agree to (a) immediately notify Spira of any unauthorized use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session when accessing the Service and/or lock and password protect the device used to access the Service. Spira will not be liable for any loss or damage arising from your failure to comply with this Section.

Modifications to Service: Spira reserves the right to modify or discontinue, temporarily or permanently, the Service (or any part thereof) with or without notice. You agree that Spira shall not be liable to you or to any third party for any modification, suspension or discontinuance of the Service.

General Practices Regarding Use and Storage: You acknowledge that Spira may establish general practices and limits concerning use of the Service, including without limitation the maximum period of time that data or other Content will be retained by the Service and the maximum storage space that will be allotted on Spira's servers on your behalf. You agree that Spira has no responsibility or liability for the deletion or failure to store any data or other Content maintained or transmitted by the Service. You acknowledge that Spira reserves the right to terminate accounts that are inactive for an extended period of time. You further acknowledge that Spira reserves the right to change these general practices and limits at any time, in its sole discretion, with or without notice.

Mobile Services: The Service includes certain services that are available via a mobile device, including (i) the ability to browse the Service and the Site from a mobile device and (ii) the ability to access certain features through an application downloaded and installed on a mobile device (collectively, the “Mobile Services”). To the extent you access the Service through a mobile device, your wireless service carrier’s standard charges, data rates and other fees may apply. In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by your carrier, and not all Mobile Services may work with all carriers or devices.

CONDITIONS OF USE

Your Rights and Grant of Rights in the Content: Some content that you share or upload, such as photos, may be protected by intellectual property laws. You own the intellectual property rights (things like copyrights or trademarks) for any such content that you create and share on Spira. Nothing in these Terms takes away the rights you have to your own content. You are free to share your content with anyone else, wherever you want. However, to provide our services we need you to give us some legal permissions (known as a 'license') to use this content. This is solely for the purpose of providing and improving our Products. Specifically, when you share, post, or upload content that is covered by intellectual property rights on or in connection with our Products, you grant us a non-exclusive, transferable, sub-licensable, royalty-free, and worldwide license to host, use, distribute, modify, run, copy, publicly perform or display, translate, and create derivative works of your content (consistent with your privacy and application settings). This means, for example, that if you share a photo on Spira, you give us permission to store, copy, and share it with others, (again, consistent with your settings) such as service providers that support our service or other Spira Products you use. This license will end when your content is deleted from our systems by either you or Spira. When content is deleted, it’s no longer visible to other users.

User Conduct: You are solely responsible for all information, data, text, software, music, sound, photographs, graphics, video, messages or other materials (“Content”) that you upload, post, publish or display (hereinafter, “Post”) or email or otherwise transmit or use via the Service. The following are examples of the kind of content and/or use that is illegal or prohibited by Spira. Spira reserves the right to investigate and take appropriate legal action against anyone who, in Spira's sole discretion, violates this provision, including without limitation, removing the offending Content from the Service, suspending or terminating the account of such violators and reporting you to the law enforcement authorities. You agree to not use the Service to Post, email or otherwise transmit any Content that:

i. is unlawful, harmful, threatening, abusive, harassing, tortious, excessively violent, defamatory, vulgar, obscene, sexual, pornographic, libelous, invasive of another’s privacy, hateful racially, ethnically or otherwise objectionable;

ii. infringes any intellectual property or other proprietary rights of any party;

iii. constitutes unsolicited or unauthorized advertising, promotional materials, commercial activities and/or sales, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” “contests,” “sweepstakes,” or any other form of solicitation;

iv. contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment;

v. in the sole judgment of Spira, is objectionable or which restricts or inhibits any other person from using or enjoying the Service, or which may expose Spira or its users to any harm or liability of any type;

vi. impersonate any person or entity, or falsely state or otherwise misrepresent your affiliation with a person or entity;

vii. solicit personal information from anyone under the age of 18;

viii. harvest or collect email addresses or other contact information of other users from the Service or the Site by electronic or other means for the purposes of sending unsolicited emails or other unsolicited communications;

ix. advertises/markets a product or service, an individual’s personal page, social account, or contact information, contributions/donations or any form of solicitation, or repetitive posts that either have no useful value or are against our community guidelines;

x. interfere with or disrupt the Service or servers or networks connected to the Service, or disobey any requirements, procedures, policies or regulations of networks connected to the Service;

xi. or violate any applicable local, state, national or international law, or any regulations having the force of law;

xii. further or promote any criminal activity or enterprise or provide instructional information about illegal activities;

xiii. or obtain or attempt to access or otherwise obtain any materials or information through any means not intentionally made available or provided for through the Service.

Account verification: To make your experience as authentic as possible, and to ensure that all our users are interacting with real people, we may ask you to confirm your identity by verifying your email address or mobile phone number. We do not recommend opening multiple accounts, especially as it is not possible to merge or share data between two or more accounts when you sign in to our app. We also reserve the right to refuse any new account registrations if we find that you have previously registered for an account and your original or older account was permanently suspended for violating these terms of service.

Safety: In order to maintain a safe environment and empower free expression, we remove accounts that are harmful to the community, including those that compromise the security of other accounts and our services. We utilize a combination of automated and manual systems to block and remove accounts that are used to persistently or flagrantly abuse our community standards. We want to make sure that the content people are seeing on Spira is authentic. We believe that authenticity creates a better environment for sharing, and that having people on Spira who misrepresent themselves would harm the open environment.

In certain cases, we will seek further information about an account before taking actions ranging from temporarily restricting accounts to permanently disabling them. We will evaluate accounts that misrepresent their identity by:

· providing any false personal information or creating an account for anyone other than yourself without permission;

· using a name, user ID, nickname, or self-introduction that does not abide by our name policies;

· using a profile picture that does not abide by our picture policies, including, but not limited to, company logos, political figures, or other celebrities' photos;

· providing a false date of birth, incorrect nationality, or native language;

· creating a single account that represents or is used by more than one person;

· maintaining multiple accounts as a single user;

· being compromised;

· being empty accounts with prolonged dormancy;

· using multiple Spira accounts;

· misusing Spira's reporting systems to harass others;

· concealing a Page’s purpose by misleading users about the ownership or control of that Page.

Fees: You acknowledge that Spira reserves the right to charge for any portion of the Service and to change its fees (if any) from time to time in its discretion. You agree to pay all fees when due in accordance with the terms set forth on the Site.

Payment through the Service: Spira offers certain enhanced features of the Services which you can purchase in a variety of terms including, but not limited to, a three month, one year, monthly auto-recurring, yearly auto-recurring, and lifetime subscription (“Subscription”). A description of features associated with Subscriptions is available via the Services. The amounts due and payable by you for a Subscription that you purchase through the Services will be presented to you before you place your order. If you choose to purchase a Subscription via the Services, you agree (a) to pay the applicable fees and any taxes; (b) that Spira may charge your credit card for verification, pre-authorization and payment purposes if you purchase via the site, or if you purchase via the App, charge your account with the app store or distribution platform (like the Apple App Store or Google Play) where the App is made available (each, an “App Provider”); and (c) to bear any additional charges that your App Provider, bank or other financial service provider may levy on you as well as any taxes or fees that may apply to your order. You’ll receive a confirmation email after we confirm the payment for your order. Your order is not binding on Spira until accepted and confirmed by Spira. All payments made are non-refundable and non-transferable except as expressly provided in these Terms.

Renewal and Cancellation of Subscriptions: All amounts are payable and charged: (i) for one-off purchase (i.e. lifetime Subscription), at the time you place your order; and (ii) For monthly, yearly, or other auto-recurring subscriptions, at the beginning of the subscription and, because each such subscription renews automatically for an additional period equal in length to the expiring subscription term until you cancel it, at the time of each renewal until you cancel. You must cancel your monthly or yearly Subscription before it renews to avoid the billing of the fees for the next Subscription period. If you purchase your Subscription via the Site, you can cancel the renewal of your subscription at any time by contacting us by email at info@whitecode.com.tr If you purchase your Subscription via an App Provider, you can cancel the renewal of your subscription with the App Provider. You will not receive a refund for the fees you already paid for your current subscription period and you will continue to receive the Services ordered until the end of your current Subscription period.

If you have any concerns or objections regarding charges, you agree to raise them with us first and you agree not to cancel or reject any credit card or App Provider charges unless you have made a reasonable attempt at resolving the matter directly with Spira.

Spira reserves the right to not process or to cancel your order in certain circumstances, for example, if your credit card is declined, if we suspect the request or order is fraudulent, or in other circumstances Spira deems appropriate in its sole discretion. Spira also reserves the right, in its sole discretion, to take steps to verify your identity in connection with your order. Spira will either not charge you or refund the charges for orders that we do not process or cancel.

Apple-Enabled Software Applications

Spira offers Software applications that are intended to be operated in connection with products made commercially available by Apple Inc. (“Apple”), among other platforms. With respect to Software that is made available for your use in connection with an Apple-branded product (such Software, “Apple-Enabled Software”), in addition to the other terms and conditions set forth in these Terms of Service, the following terms and conditions apply:

· Spira and you acknowledge that these Terms of Service are concluded between Spira and you only, and not with Apple, and that as between Spira and Apple, Spira, not Apple, is solely responsible for the Apple-Enabled Software and the content thereof.

· You may not use the Apple-Enabled Software in any manner that is in violation of or inconsistent with the Usage Rules set forth for Apple-Enabled Software in, or otherwise be in conflict with, the App Store Terms of Service.

· Your license to use the Apple-Enabled Software is limited to a non-transferable license to use the Apple-Enabled Software on an iOS Product that you own or control, as permitted by the Usage Rules set forth in the App Store Terms of Service.

· Apple has no obligation whatsoever to provide any maintenance or support services with respect to the Apple-Enabled Software.

· Apple is not responsible for any product warranties, whether express or implied by law. In the event of any failure of the Apple-Enabled Software to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the Apple-Enabled Software to you, if any; and, to the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the Apple-Enabled Software, or any other claims, losses, liabilities, damages, costs or expenses attributable to any failure to conform to any warranty, which will be Spira's sole responsibility, to the extent it cannot be disclaimed under applicable law.

· Spira and you acknowledge that Spira, not Apple, is responsible for addressing any claims of you or any third party relating to the Apple-Enabled Software or your possession and/or use of that Apple-Enabled Software, including, but not limited to: (i) product liability claims; (ii) any claim that the Apple-Enabled Software fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection or similar legislation.

· In the event of any third party claim that the Apple-Enabled Software or the end-user’s possession and use of that Apple-Enabled Software infringes that third party’s intellectual property rights, as between Spira and Apple, Spira, not Apple, will be solely responsible for the investigation, defense, settlement and discharge of any such intellectual property infringement claim.

· If you have any questions, complaints or claims with respect to the Apple-Enabled Software, they should be directed to Spira at info@whitecode.com.tr

Spira and you acknowledge and agree that Apple, and Apple’s subsidiaries, are third party beneficiaries of these Terms of Service with respect to the Apple-Enabled Software, and that, upon your acceptance of the terms and conditions of these Terms of Service, Apple will have the right (and will be deemed to have accepted the right) to enforce these Terms of Service against you with respect to the Apple-Enabled Software as a third party beneficiary thereof.

Special Notice for International Use; Export Controls: Software (defined below) available in connection with the Service and the transmission of applicable data, if any, is subject to United States export controls. No Software may be downloaded from the Service or otherwise exported or re-exported in violation of U.S. export laws. Downloading or using the Software is at your sole risk. Recognizing the global nature of the Internet, you agree to comply with all local rules and laws regarding your use of the Service, including as it concerns online conduct and acceptable Content.

Commercial Use: Unless otherwise expressly authorized herein or in the Service, you agree not to display, distribute, license, perform, publish, reproduce, duplicate, copy, create derivative works from, modify, sell, resell, exploit, transfer or transmit for any commercial purposes, any portion of the Service, use of the Service, or access to the Service. The Service is for your personal use and may not be used for direct commercial endeavors.

Intellectual Property Rights

Service Content, Software and Trademarks: You acknowledge and agree that the Service may contain content (“Service Content”) that is protected by copyright, patent, trademark, trade secret or other proprietary rights and laws. Except as expressly authorized by Spira, you agree not to modify, copy, frame, scrape, rent, lease, loan, sell, distribute or create derivative works based on the Service or the Service Content, in whole or in part, except that the foregoing does not apply to your own User Content (as defined below) that you legally upload to the Service. In connection with your use of the Service you shall not engage in or use any data mining, robots, scraping or similar data gathering or extraction methods. Any use of the Site or the Service Content other than as specifically authorized herein is strictly prohibited. The technology and software underlying the Service or distributed in connection therewith is the property of Spira, our affiliates and our partners (the “Software”). You agree not to copy, modify, create a derivative work of, reverse engineer, reverse assemble or otherwise attempt to discover any source code, sell, assign, sublicense, or otherwise transfer any right in the Software. Any rights not expressly granted herein are reserved by Spira.

The Spira name and logos are trademarks and service marks of Spira (collectively the “Spira Trademarks”). Other company, product, and service names and logos used and displayed via the Service may be trademarks or service marks of their respective owners who may or may not endorse or be affiliated with or connected to Spira. Nothing in this Terms of Service or the Service should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any of Spira Trademarks displayed on the Service, without our prior written permission in each instance. All goodwill generated from the use of Spira Trademarks will inure to our exclusive benefit.

Third Party Material: Under no circumstances will Spira be liable in any way for any Content posted by third parties or at the direction of users, including, but not limited to, for any errors or omissions in any Content, or for any loss or damage of any kind incurred as a result of the use of any Content posted, emailed or otherwise transmitted via the Service. You acknowledge that Spira does not pre-screen Content, but that Spira and its designees shall have the right (but not the obligation) in their sole discretion to refuse or remove any Content that is available via the Service. Without limiting the foregoing, Spira and its designees shall have the right to remove any Content that violates these Terms of Service or is deemed by Spira, in its sole discretion, to be otherwise objectionable. You agree that you must evaluate, and bear all risks associated with, the use of any Content, including any reliance on the accuracy, completeness, or usefulness of such Content.

User Content Posted on or through the Service: You are solely responsible for the Content and other materials you Post on or through the Service or the Site or transmit to or share with other users or recipients (collectively, “User Content”). You will not Post any Content that you did not create or that you do not own all right, title and interest in and to, including, without limitation, all copyright and rights of publicity contained therein. By Posting any User Content you hereby grant and will grant Spira and its affiliated companies a nonexclusive, worldwide, royalty free, fully paid up, transferable, sublicenseable, perpetual, irrevocable license to copy, display, transmit, perform, distribute, store, modify and otherwise use your User Content in connection with the operation of the Service or the promotion, advertising or marketing thereof, in any form, medium or technology now known or later developed.

You acknowledge and agree that any questions, comments, suggestions, ideas, feedback or other information about the Site or the Service (“Submissions”), provided by you to Spira are non-confidential and Spira shall be entitled to the unrestricted use and dissemination of these Submissions for any purpose, commercial or otherwise, without acknowledgment or compensation to you.

You acknowledge and agree that Spira may preserve Content and may also disclose Content if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal process, applicable laws or government requests; (b) enforce these Terms of Service; (c) respond to claims that any Content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Spira, its users and the public. You understand that the technical processing and transmission of the Service, including your Content, may involve (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices.

Third Party Websites

The Service may provide, or third parties may provide, links or other access to other sites and resources on the Internet. Spira has no control over such sites and resources and Spira is not responsible for and does not endorse such sites and resources. You further acknowledge and agree that Spira shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any Content, events, goods or services available on or through any such site or resource. Any dealings you have with third parties found while using the Service are between you and the third party, and you agree that Spira is not liable for any loss or claim that you may have against any such third party.

Third Party Services

You may enable various online services to be directly integrated into your Spira experience. By directly integrating these services into the Service, we make your online experiences richer and more personalized. To take advantage of these features, we may ask you to register for or log into such services on the websites of their respective providers. By enabling third party services within the Spira Service, you are allowing us to pass your log-in information to these service providers for this purpose. For more information about the implications of activating these third party services and Spira's use, storage and disclosure of information related to you and your use of such services within Spira (including your friend lists and the like). However, please remember that the manner in which third party services use, store and disclose your information is governed solely by the policies of such third parties, and Spira shall have no liability or responsibility for the privacy practices or other actions of any third party site or service that may be enabled within your Spira Service.

In addition, Spira is not responsible for the accuracy, availability or reliability of any information, Content, goods, data, opinions, advice or statements made available in connection with third party services. As such, Spira is not liable for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such third party service. Spira enables these features merely as a convenience and the inclusion of such features does not imply an endorsement or recommendation.

Indemnity and Release

You agree to release, indemnify and hold Spira and its affiliates and their officers, employees, directors and agent harmless from any from any and all losses, damages, expenses, including reasonable attorneys’ fees, rights, claims, actions of any kind and injury (including death) arising out of or relating to your use of the Service, any User Content, your connection to the Service, your violation of these Terms of Service or your violation of any rights of another. If you are a California resident, you waive California Civil Code Section 1542, which says: “A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which if known by him must have materially affected his settlement with the debtor.” If you are a resident of another jurisdiction, you waive any comparable statute or doctrine.

Disclaimer of Warranties

YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK. THE SERVICE IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. Spira EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT.

Spira MAKES NO WARRANTY THAT (I) THE SERVICE WILL MEET YOUR REQUIREMENTS, (II) THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, (III) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE WILL BE ACCURATE OR RELIABLE, OR (IV) THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE SERVICE WILL MEET YOUR EXPECTATIONS.

Limitation of Liability

YOU EXPRESSLY UNDERSTAND AND AGREE THAT Spira SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY DAMAGES, OR DAMAGES FOR LOSS OF PROFITS INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS OF GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES (EVEN IF Spira HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, RESULTING FROM: (I) THE USE OR THE INABILITY TO USE THE SERVICE; (II) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS AND SERVICES RESULTING FROM ANY GOODS, DATA, INFORMATION OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED INTO THROUGH OR FROM THE SERVICE; (III) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (IV) STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SERVICE; OR (V) ANY OTHER MATTER RELATING TO THE SERVICE. IN NO EVENT SHALL Spira's TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES OR CAUSES OF ACTION EXCEED THE AMOUNT YOU HAVE PAID Spira IN THE LAST SIX (6) MONTHS, OR, IF GREATER, ONE HUNDRED DOLLARS ($100).

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS SET FORTH ABOVE MAY NOT APPLY TO YOU. IF YOU ARE DISSATISFIED WITH ANY PORTION OF THE SERVICE OR WITH THESE TERMS OF SERVICE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USE OF THE SERVICE.

Termination

You agree that Spira, in its sole discretion, may suspend or terminate your account (or any part thereof) or use of the Service and remove and discard any Content within the Service, for any reason, including, without limitation, for lack of use or if Spira believes that you have violated or acted inconsistently with the letter or spirit of these Terms of Service. Any suspected fraudulent, abusive or illegal activity that may be grounds for termination of your use of Service, may be referred to appropriate law enforcement authorities. Spira may also in its sole discretion and at any time discontinue providing the Service, or any part thereof, with or without notice. You agree that any termination of your access to the Service under any provision of this Terms of Service may be effected without prior notice, and acknowledge and agree that Spira may immediately deactivate or delete your account and all related information and files in your account and/or bar any further access to such files or the Service. Further, you agree that Spira shall not be liable to you or any third-party for any termination of your access to the Service.

User Disputes

You agree that you are solely responsible for your interactions with any other user in connection with the Service and Spira will have no liability or responsibility with respect thereto. Spira reserves the right, but has no obligation, to become involved in any way with disputes between you and any other user of the Service.

General

These Terms of Service constitute the entire agreement between you and Spira and govern your use of the Service, superseding any prior agreements between you and Spira with respect to the Service. You also may be subject to additional terms and conditions that may apply when you use affiliate or third-party services, third-party content or third-party software. These Terms of Service shall be governed by the laws of the State of California without regard to its conflict of law provisions. The failure of Spira to exercise or enforce any right or provision of these Terms of Service shall not constitute a waiver of such right or provision. If any provision of these Terms of Service is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties’ intentions as reflected in the provision, and the other provisions of these Terms of Service remain in full force and effect. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the Service or these Terms of Service must be filed within one (1) year after such claim or cause of action arose or be forever barred. A printed version of this agreement and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this agreement to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. You may not assign this Terms of Service without the prior written consent of Spira, but Spira may assign or transfer this Terms of Service, in whole or in part, without restriction. The section titles in these Terms of Service are for convenience only and have no legal or contractual effect. Notices to you may be made via either email or regular mail. The Service may also provide notices to you of changes to these Terms of Service or other matters by displaying notices or links to notices generally on the Service.

Spira is a global language exchange platform developed and operated by GLOBAL CONNECTION TECHNOLOGIES LIMITED (hereinafter referred to as "we" or "our"). We attach great importance to your privacy and personal information, and are always committed to protecting your privacy. In order for you to better use Spira, we have specifically laid out how and what kind of information we collect, use, and safeguard when you use our services in this Privacy Policy.

Before using our services, please read our Privacy Policy carefully. Unless you have read and accepted all the terms of this agreement, please stop using Spira immediately. Once you check or click the "Agree and continue" button, you are deemed to have fully understood and accepted this Privacy Policy.

Part One Definitions

User: hereinafter referred to as "you" or "user" refers to individuals or organizations that register, log in, use, browse, or obtain services under this policy.

Personal information: refers to all kinds of information recorded electronically or in other ways that can be used alone or in combination with other information to identify the identity of a specific person, or reflect the activities of a specific person.

Part Two Contents

This privacy policy will help you understand the following:

Information We Collect

Information Storage

Information Security

How We Use Information

Disclosure to Third Parties

Children's Information Policy

1. Information We Collect

(1) Register an account

When you register for Spira, we will collect your device's MAC address and unique device identification code to identify you as a Spira user. If you log in to Spira using QQ, WeChat, Apple ID, Facebook, Gmail, Line, or Kakao Talk, we will collect your QQ, WeChat, Line, or Kakao Talk unique identifier, avatar, and nickname, or Apple ID, Facebook, or Gmail unique identifier to synchronize your data and enable you to log in using different devices. After you register or log in with a third-party account, your third-party account will be bound to your Spira account, but you can choose to unbind the account in [Settings→Account→Binding Info].

When you create your Spira ID, we will collect the following personal information: email address, gender, age, nationality, native language, and the language you are learning. This will help us provide you with improved service and a better user experience.

We will collect your mobile phone number to verify your user information. Mobile phone numbers are sensitive information, and the purpose of collecting your mobile phone number is to meet the online real-name system requirements of relevant laws and regulations. Refusing to provide a mobile phone number may affect your Spira user experience.

(2) Providing network security and operational security

To protect your account, network, and operation and system security and prevent phishing, website fraud, and Trojan viruses during your use of Spira, our server will automatically record the information sent by your mobile phone ("log data"). The log data will include various related information (such as mobile operator, device model, operating system and version, client version, Android ID, device resolution, package name, device settings, process, and unique device identifiers, and software and hardware characteristics) as well as device location-related information (such as IP address, GPS location, and WLAN access point, Bluetooth, and base station sensor information).

(3) Camera functions

After enabling camera permission, you may use the camera to take photos or videos, upload, share, and use other features. Please note that even if you allow access to your camera, we will only obtain relevant information through the camera when you actively click on the above functions in the client.

(4) Microphone-based functions

You can use the microphone for voice chat by enabling the microphone permission. Please know that even if you allow microphone access, we will only obtain voice information through the microphone when you actively click the microphone icon in the client.

(5) Geographic location information functions

After obtaining your consent, we will record your geographic location to show you more user attributes and a better match with language partners in your region. Geographic location information is sensitive information, and refusing to provide this information will not affect the normal use of the application. You may adjust your geographic location information permissions at any time.

(6) Functions based on storage permissions

When you upload/update your account avatar or post graphic/video content, we will need to access your device storage/album in order to publish pictures and text information. If you refuse to enable the above permissions, we will not be able to provide you with the aforementioned functions. Note, this will not affect the use of other Spira functions.

(7) Calendar-based functions

When you use Spira Live to create a livestream or reserve a spot in a livestream, we will ask you for permission to read/write to your calendar so that we can send you reminders before the event starts. We will not access or change any calendar content that is not related to language exchange and live streaming.

(8) Other circumstances

According to relevant laws, regulations, and national standards, in the following situations, we will collect and use your personal information without asking for your authorization:

When it is directly related to national security, national defense security, and other national interests; directly related to major public interests such as public safety, public health, and public knowledge;

When it is directly related to criminal investigation, prosecution, trial and execution of judgments;

In order to protect your or other individuals’ life, property, reputation, and other major legal rights, but it is difficult to obtain the consent of the person;

When the personal information collected is disclosed to the public by yourself;

In order to collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

When it is necessary for signing and fulfilling the contract according to your requirements;

When it is necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and disposing of product or service failures;

When it is necessary to carry out statistical or academic research in public interest, and when it provides the results of academic research or description to the outside, the personal information contained in the results is de-identified;

Other circumstances stipulated by laws and regulations.

2. Information storage

(1) Method and period of information storage

We will store your information in a secure way, including local storage (for example, data caching within the app), database, and server logs.

Under normal circumstances, we will only store your personal information for the time necessary to achieve the purpose of the service or under the conditions stipulated by laws and regulations. You can choose to delete your data history and other personal information provided and generated when you use our services. When you delete any of your personal information, we will immediately delete the corresponding data accordingly.

(2) Managing and retaining your information

Legal obligations and issues: We keep your information for legal reasons such as when we have a legal obligation to retain data, to enforce and prevent violations of our Terms, or if necessary to protect rights, property, and users.

Operational retention needs: We do not retain your messages when providing our services (except in the limited circumstances set out above), and so once your messages are delivered they are deleted from our servers. However, if a message cannot be delivered immediately, we keep it in an encrypted form on our servers for up to 30 days as we try to deliver it, after which it is deleted. Your public information will be retained until you delete your account and withdraw from the agreement, including your profile information and the moments you posted. All of these data will be deleted or anonymized.

(3) Data transmission in other countries

Spira is a global language exchange platform. Data is transferred to third countries outside your home country. Data transfer is approved by law and is handled appropriately and safely. Such data is available for your review on request.

(4) Retention and usage period of personal information

Spira will obtain user consent for the retention period of personal information at the time of their member or service subscription for the following purposes.

Mobile phone number: Up to 1 year from the time of request for registration/modification/deletion

According to relevant statutes, including the Act on Consumer Protection, in Electronic Commerce, Etc., the Framework Act on Electronic Documents and Transactions, and the Protection of Communications Secrets Act, require Spira to store the information for a certain period of time under the following circumstances. Spira stores personal information during the set period under the provisions of the statutes and in no case will it ever store this information for any other purposes.

Act on Consumer Protection, in Electronic Commerce, Etc.

Records on the contract or subscription withdrawal, etc.: Stored for 5 years

Records on the payment and supply of goods, etc.: Stored for 5 years

Records on consumer complaints or dispute settlement: Stored for 5 years

Protection of Communications Secrets Act

Personal information that fully serves its purpose of collection and uses, by means such as membership cancellation, service termination, and/or expiration of the retention period of personal information approved by the user, is destroyed to an irreversible state.

Information required to be retained under the statutes is also destroyed to an irreversible state without delay after the expiration of the relevant period.

Please note that Spira separately stores and manages or deletes the personal information of members who have not used its service for at least one year in accordance with the Personal Information Validity Period Plan.

3. Information Security

(1) Data protection

We have taken extensive technical and organizational measures to secure your data against potential risks, such as unauthorized login or access, unauthorized perusal, amendment, or distribution, and against loss, deletion, or misuse.

In order to protect your personal data against unauthorized access by third parties when being transmitted, we secure data transmissions, if necessary, using SSL and TLS encryption. This is a standard encryption procedure for online and mobile services.

(2) Regarding video and audio chats

We will not monitor, record, or broadcast video or audio chat sessions at any time. However, we cannot prevent your chat partners from broadcasting live or recorded chat sessions without your or our permission through third-party websites or services. We recommend that you exercise caution in disclosing any information, personal or otherwise, during a video or chat session.

(3) Security incident handling measures

In the event of personal information leakage, damage, loss, or other security incidents, we will activate emergency plans to prevent the expansion of security incidents. After a security incident occurs, we will promptly inform you of the basic situation of the security incident, as well as the handling and remedial measures we are about to or have taken, in the form of push notifications, emails, etc. If it is difficult to notify users one by one, we will issue a warning through announcements and other methods.

(4) How you can manage your information

You can access and modify your mobile phone number information, account password, and third-party account information through [Me→Settings→Account];

You can visit and unfollow related users through [Me→Following];

You can access and delete friends and related conversation information through [Talks→Message];

When you find that there are errors in our processing of information about you, you have the right to request us to make corrections. In the process of providing services, you may need to activate some device permissions, such as notifications, photo album, camera, and microphone. You can choose to turn off some or all of the permissions in the [Settings] of your device at any time to stop Spira from collecting your personal information.

You can submit an account cancellation application on the Spira app by yourself with the cancellation method: [Me→Settings→Account→Delete Account]. After you delete your account, we will delete your corresponding personal information immediately. The processing of your information is generally completed within 1 business day.

4. Information Usage

We strictly abide by laws and regulations and agreements with users, and use the collected information as described in this privacy policy to provide you with better services.

We use your personal information to analyze user demographics.

We may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies.

We do not treat log data as personal information or use it in association with other personal information, though we may aggregate, analyze, and evaluate such information for purposes such as understanding or improving the services.

The user's public information includes name, age, profile picture, current city, and time zone. We will never show your exact location or email address. You can choose not to share any information with other users in your profile settings.

Device information: We will receive and record information about the device you use according to the specific permissions granted by you during the software installation and use (such as IMSI identification code, device model, operating system and version, client version, device resolution, package name, device settings, process and unique device identifiers, and software and hardware feature information) as well as information about the location of the device (such as IP address, GPS location and WLAN access point that can provide relevant information, Bluetooth, and base station sensor information).

Please note that separate device information and log information are information that cannot identify a specific natural person. If we combine this type of non-personal information with other information to identify specific natural persons, or combine it with personal information, this type of non-personal information will be treated as personal information during the combined use. Unless your authorization is obtained, or laws and regulations provide otherwise, we will anonymize and de-identify this type of personal information.

5. Disclosure to Third Parties

(1) Principle

If you are approved for our services, your account will be governed by Spira's respective privacy policies. Personal information will only be used by Spira to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

The accessed third-party service is operated by the relevant third party and is subject to the third party's own terms of service and information protection statement (not this "Spira Privacy Policy").

We will only share your information for legitimate, necessary, and specific purposes. For third-party service providers with whom we share information, we will require them to fulfill relevant confidentiality obligations and take corresponding security measures.

At the same time, we collect and use this analytical information in an aggregated form, so we cannot reasonably manipulate it to identify any specific individual user.

(2) Accessed third-party SDK directory:

The following personal information is stored and used until the user cancels membership or reaches the term of the entrusted agreement.

To personalize ads, we may share anonymized and personal information, such as interest and age as well as device types with Admob by Google, Facebook Audience Network, TopOn, and Pangle.

To control target group-related advertising, we record information about activities on our apps and websites (e.g. advertising banners clicked, screens viewed, and pages visited, etc.). This is recorded and we may use this to provide our customers’ users with advertising targeted to their interests.

For the purpose mentioned above, cookies may be stored on your device. Cookies are small text files that are stored on your device's hard drive. They enable recognition of your device but do not permit you to be personally identified.

If you do not want cookies to be installed, you can opt-out using your browser settings. On mobile devices, you can opt-out of sharing advertising identifiers in your device's settings.

We will push personalized advertisements to you based on your device information, IP address, and location data. In using the above information, we will anonymize it to ensure that the related information cannot be directly associated with your real identity. If you opt out of personalized advertisement services, you can turn off the receipt of personalized advertising recommendations in the app by going to "Settings - Privacy - Personalized Ads." After turning it off, the relevance of the ads you see will decrease, and you will only be presented with generic ads that are not related to your preferences.

• You can edit, hide, and delete personal data in the Me→ Settings→Privacy within the Spira app. Also, you can request the deletion of your account or ask for certain profile information to be changed via Spira’s customer support (info@whitecode.com.tr).

6. Children's Information Policy

Children under 12 are not allowed to use Spira. If you are based in the European Economic Area (EEA), you may only use Spira if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of Spira has been provided to us. If you are a parent and you learn that your child is using Spira and you don’t want them to, please contact (info@whitecode.com.tr).

If the user is under the age of 14, the child’s legal representative has the right to view and update the child’s personal information, and to revoke his/her consent to the collection and use of the child’s personal information.

We suggest that any minors participating in online activities should obtain the consent of their parents or other guardians (hereinafter referred to as "guardians") in advance. We will protect the relevant information of minors in accordance with the relevant national laws and regulations.

7. Contact Us

Spira is an international team located in Hong Kong, China and Shenzhen, China. We are firmly committed to protecting users' personal information under national data protection standards. If you have any questions or concerns about our privacy policy or data processing, please contact us.

Company Name: WHITE CODE TEKNOLOJI LIMITED SIRKETI

Company Address: İdealtepe Mah. Dik Sok. No13 İç Kapı no2 Maltepe/İstanbul

Contact email: info@whitecode.com.tr