If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your personal information (as defined by the California Consumer Privacy Act (“CCPA”)). This Privacy Notice (“Notice”) applies to information that we collect and process about users of Spin’s websites, mobile applications, and Spin vehicles, as well as information provided when you interact with Spin, such as by emailing us (collectively, the “Services”). For more details, you can read our Privacy Policy.
This Notice provides information about our practices in the 12 months leading up to the effective date of this Policy in relation to the categories of personal information that we collect from California residents generally – including the categories of sensitive personal information (precise location information) – the purposes for which we use the information, the categories of third parties to whom we disclose the information for business purposes, and retention practices.
The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for purposes of “cross-context behavioral advertising”. We do not engage in such activity and have not in the past 12 months.
Your Rights & Choices
To learn more or to exercise your rights regarding your data, please see the “Your Rights & Choices Regarding Your Information” section of our Privacy Policy.
“Shine the Light” Disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Retention of Information
We retain your information only for as long as is necessary to provide the Services and to fulfill the transactions you have requested, and for other necessary purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and for fraud prevention and related security purposes. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain your email address as an authentication credential (where applicable) as long as you have an account with us and an additional period of time after that for our legitimate interests and for our fraud and legal compliance purposes. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information.
