PRIVACY POLICY

EFFECTIVE DATE: Date as in Term of Use In this Privacy Policy (“Policy”), we describe how Spintly, Inc., (also referred to as “Spintly”) (hereinafter referred to as “Company”) collects, uses, and discloses information that we obtain about visitors to our website https://www.spintly.com (the “Site”), users of our mobile application (“Application”) and the services available through our Site (collectively, the “Services”). By visiting the Site, using or downloading the mobile application (“the Application”), or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy is subject to this Policy and our Terms of Service https://www.spintly.com/terms-of-service, including its applicable limitations on damages and the resolution of disputes. The Company Terms of Service are incorporated by reference into this Policy. The Information We Collect About You We collect information about you directly from you and third parties, and automatically through your use of our Site or Services. Information We Collect Directly From You The information we collect from you depends on how you use our Site or Services.

• On the Site. Our Site contains multiple pages that enable you to contact Spintly. If you choose to do so, we may collect your name, company, email address, and phone number.
• Account Creation. To use the Application and web portal you must create an account.  To create an account, you must provide your name, phone number, email address, and password.
• Using the Spintly Application. Each time you use the Application to unlock locks, we collect certain information. This includes the registered name of the user unlocking the lock, the location of the lock which was unlocked, and the time that the user unlocked the lock.

Information We Collect From Others

• From non-affiliated entities. We use non-affiliated companies to obtain marketing lead information. This may have included your contact information (Name, email address, or phone number).
• From our Referral Program. Visitors of our Site have the option to refer businesses and individuals to do business with Spintly.  If a visitor referred you, that visitor provided us with your name, email address, phone number, and business name. That visitor may have also provided us with a description of your business.
• From Employers. If your employer has begun implementation of Spintly at your place of employment, your employer may have provided us with your name, mobile phone number, and email address to set up your account.

Information We Collect Automatically We automatically collect information about your use of our Site and Apps through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information Site:

• your operating system; device type; browser information; demographics; geolocation
• web pages you view on the Site; links you click on the Site; your IP address
• the city and state associated with your IP address if you fill out a contact form on the Site
• activities and behaviour within the Site
• activities from traffic sources (e.g., how you found us) such as Google, Facebook, Bing and other offline sources

App:

• device name and model;
• operating system, type and version;
• CPU and Memory utilization;
• Mobile Network, WIFI, and Bluetooth state;
• Charging state, Battery level;
• Screen size;
• language and Locale information;
• activities within the App and the length of time that you are logged into our App;
• location information. With your permission, we will collect location information from your mobile device to enable authorized users within Bluetooth range to enter designated areas. You may turn off this feature through the location settings on your mobile device.

How We Use Your Information We use your information, including your personal information, for the following purposes:

• To provide our Services to you.
• To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services.
• To send you email marketing about our products and services.
• To send you news and newsletters.
• To send you email marketing about products and services of our affiliated entities.
• To send you email marketing about products and services of other entities that we think may be of interest to you.
• To assist us in advertising on third-party websites, mobile apps, and other online services, and to evaluate the success of our advertising campaigns through third party channels (including our online targeted advertising and offline promotional campaigns).
• To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site and App are more (or less) used by users, and we will use this information.
• For research and analytics purposes.
• To administer our customer loyalty program.
• To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
• Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

How We Share Your Information We may share your information, including personal information, as follows:

• With Admin Users. When using the Application, you may be granted access to a lock that is tied to a certain location. When you are granted access to a lock, your name, phone number, and email address become available to any Admins of that lock. Our application also creates an “audit trail” for Admin Users to review. Audit trails are reports of Unlocking and Locking events: who unlocked which locks at what time.
• With Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf.
• Note about Bug Reports: We use a service provider to help our Application users identify and resolve technical issues with the Application. To do so, users may voluntarily enable our service provider to record a user’s usage of the Application for a limited amount of time.  Depending on how the user uses the Application during the recording session, personal information that the user has voluntarily made viewable on the Application’s interface may be visible to the service provider. This disclosure is incidental, and the service provider is not authorized to use this information for any purpose other than to help diagnose technical issues.
• With Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries.

We also disclose information in the following circumstances:

• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, a court order, or other legal processes, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Our Use of Cookies and Other Tracking Mechanisms We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf). Cookies.  Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Site and Services.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity. We also use persistent cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Site and Services.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function. Flash Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, delete any specific Flash LSO. Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and app users, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. Third-Party Analytics We use automated devices and applications, such as Google Analytics, Facebook Advertising, and Bing Analytics, to evaluate usage of our Site, to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Sites and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout. Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt out of targeted advertising by following the instructions in the Third Party Ad Network section. Third-Party Ad Networks We use third parties such as network advertisers to serve advertisemenon our Site, App, and on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you. Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at  www.networkadvertising.org. Third-Party Links Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by ththird-partyolicies of those third party websites. We are not responsible for the inthird-partyractices of such third party websites. Security of My Personal Information We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. Access To My Personalthe  Information You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Application for a period of time. What Choices Do I Have Regarding Use of My Personal Information? We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us. Children Under 13 Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems. Contact Us If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at [email protected]. Changes to this Policy This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and Application. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and Application. IMPORTANT ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS This document provides specific information for California residents, as required under applicable California privacy laws.  California privacy laws require that we provide California residents information about how we use their personal information, whether collected online or offline, and this document is intended to satisfy that requirement. California Privacy Rights under California’s Shine-the-Light Law Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us with certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use.  Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing to [email protected]. The request shall attest to the fact that the requester is a California resident, and provide a current California address.