SPINNR™ PRIVACY POLICY
This privacy notice for Spinnr Inc. (“Spinnr,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:
- Download and use our mobile application (Spinnr), or any other application of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Spinnr’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Spinnr and the Services, the choices you make, and the products and features you use. Click here to learn more.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Click here to learn more.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Click here to learn more.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click here to learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here , or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what Spinnr does with any information we collect? Click here to review the notice in full.
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. AI TRAINING AND DATA USAGE CONSENT
10. COLLECTION AND USE OF CONTACT LIST INFORMATION
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
- email addresses
- usernames
- data about a person’s sex life or sexual orientation
- information revealing race or ethnic origin
- information revealing religious or philosophical beliefs
- Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services(such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Collection and Use of Contact List Information
We collect and use users’ Contact List information solely for the purpose of allowing our members to invite their contacts to events, squads, or the app in general. This information is used strictly for the functionality of sending invitations and will not be used for any other purpose.
Consent and Affirmative Action
By using our app, you provide affirmative consent for the collection and use of your Contact List information solely for the purpose of enabling invitations to events, squads, or the app. We will present a clear and prominent disclosure message within the app, explaining that your Contact List information will only be used for sending invitations and will not be used for any other purpose.
Third-Party Access
We do not share users’ Contact List information with any third parties. Your Contact List information remains securely stored within the app and is used solely for the purpose of sending invitations to events, squads, or the app.
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click
to learn more.
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
9. AI TRAINING AND DATA USAGE CONSENT
By registering for an account on the Spinnr application or website, you acknowledge and agree to the terms outlined in this section. This policy pertains to the use of your chat history, including one-on-one conversations and group “Squad” chats, for the purpose of enhancing our AI systems on Spinnr and Vengo AI.
We utilize chat data to train our AI systems, aiming to continually improve user experience on Spinnr and Vengo AI. This process involves using historical chat data to refine and develop our AI’s capabilities in understanding and responding to various conversation contexts. We prioritize your privacy and data security. To ensure this, we employ advanced data encryption techniques. Additionally, we strip all personal information from chat data before it is used for AI training. This process ensures that all data used remains anonymous and cannot be traced back to any individual user.
Your interactions through chat contribute to the enhancement of our AI systems. This, in turn, aids in providing a more tailored and efficient user experience for you and the entire Spinnr community and members of Vengo AI. By using our services, you consent to the use of your chat data as described above. We assure you that this data usage strictly adheres to enhancing user experience and maintaining the highest standards of privacy and data security.
If you do not wish your data to be used in this manner, you have the option to opt-out. Please be aware that opting out may impact the quality of personalized AI interactions you receive on our platform.
We reserve the right to modify this policy at any time. Continued use of our services after such changes implies your acceptance of the new terms.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
” below.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
” below or updating your preferences.
Opting out of marketing and promotional communications:You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
- Log in to your account settings and update your user account.
| Category | Examples | Collected |
|
A. Identifiers
|
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
|
NO
|
|
B. Personal information categories listed in the California Customer Records statute
|
Name, contact information, education, employment, employment history, and financial information
|
NO
|
|
C. Protected classification characteristics under California or federal law
|
Gender and date of birth
|
YES
|
|
D. Commercial information
|
Transaction information, purchase history, financial details, and payment information
|
NO
|
|
E. Biometric information
|
Fingerprints and voiceprints
|
NO
|
|
F. Internet or other similar network activity
|
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
|
NO
|
|
G. Geolocation data
|
Device location
|
NO
|
|
H. Audio, electronic, visual, thermal, olfactory, or similar information
|
Images and audio, video or call recordings created in connection with our business activities
|
NO
|
|
I. Professional or employment-related information
|
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
|
NO
|
|
J. Education Information
|
Student records and directory information
|
NO
|
|
K. Inferences drawn from other personal information
|
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
|
NO
|
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
4316 Sheffield Ave