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.
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.
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.
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.