Privacy Policy

This Privacy Policy describes the collection, use and disclosure of Your personal information when You use the Spinbot website, www.spinbot.com (“Service”).

Definitions

For the purposes of this Privacy Policy:

  • "Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • "Device" means any device that can access the Service such as a computer, a cell phone or a digital tablet.
  • "Do Not Track (DNT)" is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • "Service Provider" means any natural or legal person who processes personal information on our behalf.
  • "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • "You"means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personal information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

Types of Personal Information We Collect

Contact Information

If you contact us, we may ask You to provide us with certain personally identifiable information. Personally identifiable information may include:

  • Email address
  • First name and last name

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) for a variety of purposes. For example, we use Cookies to enable our servers to recognize Your web browser, tell us how and when You visit and use our Service, analyze trends, learn about our user base and operate and improve our Service. Cookies are small pieces of data – usually text files – placed on Your computer, tablet, phone or similar device when You use that device to access our Service. We may also supplement the information we collect from You with information received from third parties, including third parties that have placed their own Cookies on Your Device(s).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use the following Cookies:

  • Essential Cookies. Essential Cookies are required for providing You with features or services that You have requested.
  • Functional Cookies. Functional Cookies are used to record Your choices and settings regarding our Service, maintain Your preferences over time and recognize You when You return to our Service. These Cookies help us to personalize our content for You and remember Your preferences.
  • Analytics Cookies. Analytics Cookies allow us to understand how visitors use our Service. They do this by collecting information about the number of visitors to the Service, what pages visitors view on our Service and how long visitors are viewing pages on the Service.

How to Manage Cookies

Browser Settings

You can decide whether or not to accept Cookies through Your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent Your browser from accepting new Cookies, as well as (depending on the sophistication of Your browser software) allow You to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on Your Device. If You do this, however, You may have to manually adjust some preferences every time You visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to You, look in the “preferences” or “options” section of Your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Opting Out Of Certain Analytics

We use Amplitude and Google Analytics. Google Inc. (“Google”) uses Cookies in connection with its Google Analytics services. For information about how Google Analytics collects and processes data, please see "How Google uses data when You use our partners' sites or apps", located at www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available at https://policies.google.com/technologies/partner-sites or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

Do Not Track Signals

Your browser may offer You a “Do Not Track” option, which allows You to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because of our use of Cookies, our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” You can visit www.allaboutdnt.com.

Use of Your Personal Information

We may use personal information for the following purposes:

  • To provide and maintain our Service including to monitor the usage of our Service.
  • For the performance of a contract: the development, compliance and undertaking of any contract You have with us through the Service.
  • To respond when You contact us: To respond if You contact us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, to evaluate and improve our Service, products, and your experience, and to measure business performance.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers. For example, analytic service providers to monitor and analyze the use of our Service.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Information

We will retain Your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your personal information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. This data is used to strengthen the security or to improve the functionality of our Service, and to measure business performance.

Transfer of Your Personal Information

Your personal information is processed in the United States and in any other places where our Service Providers are located. It means that Your personal information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

When we transfer personal information about individuals based in the EEA or UK outside of those countries, we will take appropriate measures to safeguard the transfer as required by applicable law, including by using the European Commission-approved standard contractual data protection clauses or following an adequacy decision by the EU Commission. If You do not want Your personal information transferred outside of the EEA or UK, please do not submit any personal information to us or use our Services.

Disclosure of Your Personal Information

Business Transactions

If we are involved in a merger, acquisition or asset sale, Your personal information may be transferred. We will provide notice before Your personal information is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, we may be required to disclose Your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

We may disclose Your personal information in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend our rights or property
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Information

The security of Your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Your personal information, we cannot guarantee its absolute security.

Analytics

We use third-party Service Providers, Google Analytics and Amplitude, to monitor and analyze the use of our Service.

Additional Terms Applicable to EEA and UK Residents

Legal Basis for Processing Personal Information under GDPR

We may process personal information under the following conditions:

  • Consent: You have given Your consent for processing personal information for one or more specific purposes.
  • Performance of a contract: Provision of personal information is necessary for the performance of an agreement (including our Terms of Service) with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing personal information is necessary for compliance with a legal obligation to which we are subject.
  • Vital interests: Processing personal information is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing personal information is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
  • Legitimate interests: Processing personal information is necessary for the purposes of the legitimate interests pursued by us.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing.

Your Rights

You have the right to:

  • Request access to Your personal information. The right to access the personal information we have on You.
  • Request correction of the personal information that we hold about You. You have the right to have any incomplete or inaccurate information we hold about You corrected.
  • Object to processing of Your personal information. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about Your particular situation, which makes You want to object to our processing of Your personal information on this ground. You also have the right to object where we are processing Your personal information for direct marketing purposes.
  • Request erasure of Your personal information. You have the right to ask us to delete or remove personal information when there is no good reason for us to continue processing it.
  • Request the transfer of Your personal information. We will provide to You, or to a third-party You have chosen, Your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for us to use or where we used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your personal information. If You withdraw Your consent, we may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and objection by contacting us. Please note that we may ask You to verify Your identity before responding to such requests. We will respond to You within 30 days of receiving Your request. If more time is required, we will notify You in advance. You can submit your request by emailing us at [email protected].

You have the right to complain to a Data Protection Authority about our collection and use of Your personal information. For more information, if You are in the European Economic Area (EEA) or the UK, please contact Your local data protection authority in the EEA or the UK, as applicable.

Additional Terms Applicable to California Residents

Categories of Personal Information Collected

The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

  • Contact Information and Identifiers.
    • Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
    • Internet or other similar network activity, including Usage Data.
      • Interaction with our Service.

    Sources of Personal Information

    We obtain the categories of personal information listed above from the following categories of sources:

    • Directly from You. For example, when You contact us.
    • Indirectly from You. For example, from observing Your activity on our Service.
    • Automatically from You. For example, through Cookies we or our Service Providers set on Your Device as You navigate through our Service.

    Use of Personal Information for Business Purposes or Commercial Purposes

    We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

    • To operate our Service and provide You with our Service.
    • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
    • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, we will use that personal information to respond to Your inquiry.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
    • For internal administrative and auditing purposes.
    • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

    For more details on how we use this information, please refer to the "Use of Your Personal Information" section

    If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

    Disclosure of Personal Information for Business Purposes or Commercial Purposes

    We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

    • Contact Information and Identifiers.
    • Internet or other similar network activity, including Usage Data.

    Sale of Personal Information

    As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. In some circumstances, You have the right to opt out of the sale of Your personal information. Please note, however, that we do not sell Your personal information and have not done so over the last 12 months.

    Share of Personal Information

    We may share Your personal information identified in the above categories with the following categories of third parties:

    • Service Providers
    • Our affiliates
    • Our business partners
    • Third party vendors to whom You or Your agents authorize us to disclose Your personal information in connection with products or services we provide to You

    Your Rights

    The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

    • The right to notice. You have the right to be notified which categories of personal information are being collected and the purposes for which the personal information is being used.
    • The right to request. Under CCPA, You have the right to request that we disclose information to You about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm Your request, we will disclose to You:
      • The categories of personal information we collected about You
      • The categories of sources for the personal information we collected about You
      • Our business or commercial purpose for collecting or selling that personal information
      • The categories of third parties with whom we share that personal information
      • The specific pieces of personal information we collected about You
      • If we sold Your personal information or disclosed Your personal information for a business purpose, we will disclose to You:
        • The categories of personal information categories sold
        • The categories of personal information categories disclosed
      • The right to say no to the sale of personal information (opt-out). You have the right to direct us to not sell Your personal information. Please note that we do not sell Your personal information and have not done so over the last 12 months.
      • The right to delete personal information. You have the right to request the deletion of Your personal information, subject to certain exceptions. Once we receive and confirm Your request, we will delete (and direct our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for us or our Service Providers to:
        • Complete the transaction for which we collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
        • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
        • Debug products to identify and repair errors that impair existing intended functionality.
        • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
        • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
        • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
        • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
        • Comply with a legal obligation.
        • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
      • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
        • Denying goods or services to You
        • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
        • Providing a different level or quality of goods or services to You
        • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

    Exercising Your CCPA Information Protection Rights

    In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact us:

    Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

    Your request to us must:

    • Provide sufficient information that allows us to reasonably verify You are the person about whom we collected personal information or an authorized representative
    • Describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

    We cannot respond to Your request or provide You with the required information if we cannot:

    • Verify Your identity or authority to make the request
    • And confirm that the personal information relates to You
    • We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

    Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.

    For data portability requests, we will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

    "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

    Our Service does not respond to Do Not Track signals.

    However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

    Your California Privacy Rights (California's Shine the Light law)

    Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties' direct marketing purposes.

    If You'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact us using the contact information provided below.

    California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

    California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

    To request removal of such personal information, and if You are a California resident, You can contact us using the contact information provided below, and include the email address associated with Your account.

    Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

    Links to Other Websites

    Our Service may contain links to other websites that are not operated by us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

    We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

    Changes to this Privacy Policy

    We may update this Privacy Policy from time to time.

    You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

    Contact Us

    If you have any questions about this Privacy Policy, You can contact us:

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