1. Introduction

Welcome to the websites operated by Varia Global, The Matchbox, Spyll World, and The Ad Spend (collectively referred to in this Privacy Policy as “we,” “us,” “our,” or the “Companies”). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains what information we collect, how we use and share it, and how you can exercise your privacy rights when you visit or use:

1. Varia Global’s website (varia.global) and related services (the “Varia Global Services”),

2. The Matchbox’s website (thematchbox.inc) and related services (the “Matchbox Services”),

3. Spyll World’s website (spyll.world) and related services (the “Spyll World Services”), and

4. The Ad Spend’s website (theadspend.com) and related software services (the “Ad Spend Services”).

This Policy also applies to any other websites, subdomains, or applications where this Privacy Policy is referenced or made available (collectively, the “Websites”).

If you have any questions or concerns about our use of your personal information, please contact us at:

Address: 1460 Broadway, 17th Floor, New York, NY 10036
Phone: (213) 642-4577
Email: [email protected]

By accessing or using our Websites and Services, you agree to the terms of this Privacy Policy. If you do not agree with any term in this Privacy Policy, please discontinue using our Websites and Services immediately.

2. Scope

This Privacy Policy describes how we collect, use, disclose, store, and protect your information when you visit our Websites or use our Services, which span multiple industries and business models:

• Business Consulting (Varia Global)

• Marketing/Advertising Services (The Matchbox)

• Record Label and Artist Management (Spyll World)

• Software Development and Solutions (The Ad Spend)

The Policy also addresses your rights regarding your personal information under various privacy regulations, including (when applicable) the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and other relevant laws.

3. Information We Collect

We collect several types of information from and about our visitors and users, which can vary based on your interactions with us.

3.1 Personal Information You Provide to Us

• Contact Details: Such as your first name, last name, email address, phone number, mailing address, and other information you may provide in forms on our Websites or through other communication channels.

• Account Information (where applicable): If you create an account to use certain features (e.g., software accounts for The Ad Spend), we may collect your username, password, and other related credentials.

• Business Information: If you engage us for consulting, marketing, or other professional services, we may collect details about your company, business strategies, financial data, and other information needed to provide our Services effectively.

• Payment Information: Where transactions or service fees apply, we may collect payment details (e.g., credit card number, billing address). Typically, payments are processed via secure third-party processors, and we do not store full payment card details on our servers.

• Correspondence: We may retain records of any correspondence you send us, including emails, social media interactions, or direct messages.

3.2 Information We Collect Automatically

When you visit our Websites or use our Services, we may automatically collect certain information about your device and usage:

• Log Data: This may include your IP address, browser type, browser version, the pages you visit, the time and date of your visit, the time spent on those pages, and other statistics.

• Cookies and Similar Technologies: We may use cookies, web beacons, pixels, and other tracking technologies to collect and store information about your interactions with our Websites and emails. (See Section 6 for more details on cookies and tracking technologies.)

• Usage Data: We may collect data about how you interact with our Websites, Services, and software offerings, including clicks, scrolling, and feature usage.

3.3 Information from Third Parties

We may obtain information about you from third parties, such as:

• Service Providers: Vendors that help us provide our Services (e.g., analytics providers, payment processors, marketing platforms).

• Public Databases: We may combine information from publicly available sources with data we already have.

• Business Partners and Affiliates: We may receive information from our subsidiaries, affiliates, or other business partners when they share it with us in accordance with their own privacy policies.

4. How We Use Your Information

We use the personal information we collect for various purposes, which can include:

1. Service Provision:

   • Operating, maintaining, and providing you with features and functionality of our consulting, marketing, advertising, record label/artist management, and software services.

   • For The Ad Spend, this includes software functionality, user account management, and related customer support.

2. Communication:

   • Responding to your inquiries, providing customer support, sending administrative or account-related information, and keeping you informed about changes to our services or policies.

3. Marketing and Advertising:

   • Personalizing your experience on our Websites, measuring campaign effectiveness, and sending you promotional materials or advertising about our products, services, or those of our business partners.

   • Delivering targeted ads based on your interests or browsing history on our Websites or across other sites.

4. Analytics and Improvements:

   • Monitoring and analyzing usage trends to evaluate and improve our Websites, Services, software solutions, and overall user experience.

5. Security and Fraud Prevention:

   • Protecting our rights and the rights of our users, partners, or affiliates, as well as preventing fraud, abuse, or illegal activities.

   • Ensuring a secure environment across our various platforms and services.

6. Compliance:

   • Complying with legal obligations, responding to legal process, or as otherwise required by law.

5. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, our legal basis for processing your personal information may include:

• Contractual Necessity: For the performance of a contract with you or to take steps at your request before entering into a contract.

• Consent: Where you have given explicit consent to process your personal information (e.g., for direct marketing communications).

• Legitimate Interests: Where it is in our legitimate interests to process your data (e.g., for fraud prevention, marketing, or security), provided these interests are not overridden by your data protection rights.

• Legal Obligations: Where we need to comply with a legal or regulatory obligation.

6. Cookies and Other Tracking Technologies

6.1 What Are Cookies?

Cookies are small data files placed on your computer or mobile device when you visit a website. They serve various functions, from enabling essential site features to personalizing content and tracking site usage.

6.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the operation of our Websites and Services.

• Functional Cookies: Remember your preferences and personalize your browsing experience.

• Performance/Analytics Cookies: Collect information on how you use our Websites, such as the pages visited most frequently, to help improve functionality.

• Advertising Cookies: Deliver relevant ads, track ad performance, and enable advertising networks to show you ads based on your interests.

6.3 Cookie Management

Most web browsers allow control and management of cookies through browser settings. You can reject or remove cookies, but note that doing so may affect the functionality of our Websites and limit certain features.

6.4 Other Tracking Technologies

We may also use web beacons (pixel tags) and other technologies to track user actions, deliver cookies, and measure marketing campaign performance.

7. How We Share Your Information

We do not sell or rent your personal information. However, we may share your personal information in the following circumstances:

1. Within Our Companies:

   • We may share personal information among Varia Global, The Matchbox, Spyll World, and The Ad Spend to facilitate our Services, for administrative purposes, and as otherwise described in this Privacy Policy.

2. Service Providers:

   • We may disclose personal information to third-party service providers performing services on our behalf (e.g., payment processing, data analysis, hosting, marketing, software development, or IT support).

3. Business Transfers:

   • If we undergo a merger, acquisition, reorganization, or other corporate transaction, your personal information may be transferred to the acquiring or successor entity.

4. Legal Compliance and Protection:

   • We may disclose personal information if required by law, court order, or other legal process, or if we believe such disclosure is necessary to protect our rights, property, or safety—or those of our users, employees, or affiliates.

5. Consent:

   • We may share your information with third parties if you have given us explicit consent to do so.

8. International Data Transfers

Because our Companies operate in various jurisdictions, your personal information may be transferred to and processed in countries other than your own. We take steps to ensure data is treated securely and in accordance with this Privacy Policy, including using recognized legal adequacy mechanisms (such as the European Commission’s Standard Contractual Clauses, where applicable).

9. Data Retention

We retain personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or for legitimate business needs (e.g., compliance with legal obligations, dispute resolution, or enforcement of agreements). We may retain anonymized or aggregated information indefinitely.

10. Security Measures

We have implemented reasonable administrative, technical, and physical safeguards to protect personal information against unauthorized access, alteration, disclosure, or destruction. While we strive to protect your data, no method of transmission or storage is completely secure. If you suspect a data breach or have concerns about the security of your information, please contact us immediately at the email or phone number provided in this Policy.

11. Your Privacy Rights

11.1 GDPR (EEA & UK Residents)

Under the GDPR, you have certain rights regarding your personal data, including:

• Access: Request information about the data we hold about you.

• Rectification: Request correction of inaccurate or incomplete data.

• Erasure (Right to be Forgotten): Request deletion of personal data when no longer necessary or if you withdraw consent (where applicable).

• Restriction of Processing: Request limiting the processing of your data in certain circumstances.

• Data Portability: Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.

• Objection: Object to processing of personal data based on legitimate interests, including direct marketing.

• Withdraw Consent: If processing is based on consent, you can withdraw your consent at any time.

To exercise these rights, please contact us at [email protected]. We may request information to confirm your identity before processing your request.

11.2 CCPA (California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights:

• Right to Know: You can request details about the categories and specific pieces of personal information we have collected, used, disclosed, or sold about you in the past 12 months.

• Right to Delete: You can request the deletion of your personal information, subject to legal exemptions.

• Right to Opt-Out of Sale: We do not sell personal information. If this changes in the future, we will provide a method for you to opt out.

• Right to Non-Discrimination: We will not discriminate against you for exercising any CCPA rights.

To exercise these rights, please contact us at [email protected] or call (213) 642-4577.

11.3 Other State or Country-Specific Rights

Depending on your jurisdiction, you may have additional privacy rights under local laws. We will address any valid request in accordance with applicable legal requirements.

12. Children’s Privacy

Our Websites and Services are not intended for individuals under the age of 13. We do not knowingly collect personal information from children under 13 without verifiable parental consent. If you believe a child under 13 has provided us with personal information, please contact us at [email protected], and we will take steps to delete such information promptly.

13. Third-Party Websites and Services

Our Websites may contain links to third-party websites or services that we do not operate or control. This Privacy Policy does not apply to the practices of those third parties. We encourage you to review the privacy policies of any third-party website or service you visit.

14. Do Not Track (DNT) Signals

Currently, our Websites do not respond to “Do Not Track” (DNT) signals. To learn more about Do Not Track, please visit allaboutdnt.org.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices or legal obligations. If we make material changes, we will update the Effective Date at the top of this page and may provide additional notice (e.g., posting a prominent notice on our Websites or sending you an email). We encourage you to review this Policy periodically to stay informed about how we are protecting your personal information.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Address:
Varia Global, The Matchbox, Spyll World, & The Ad Spend
1460 Broadway, 17th Floor
New York, NY 10036

Phone: (213) 642-4577
Email: [email protected]

We will do our best to respond to your inquiry as quickly as possible. If you are not satisfied with our response, you may have the right to lodge a complaint with the data protection authority in your jurisdiction (if applicable).

17. Your Acceptance of These Terms

By using our Websites or Services, or by otherwise providing us with personal information, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please discontinue use of our Websites and Services immediately.