Skinny Labs Inc., which is headquartered in the United States, is the controller of information, including personal data, collected through the Services. If you are in Canada, it is also controlled by Spin Mobility Inc.
If you are a California resident and would like to see a summary of the privacy disclosures applicable to you, please click here for our California Privacy Notice.
We obtain a variety of information from and about you as you use the Services. We need certain types of information so that we can provide the Services to you. Please note that if you choose not to provide us with certain information, or ask us to delete it, you may no longer be able to access or use the Services. For example, if you are a customer but do not provide us with your billing information for payment, you will not be able to rent a vehicle.
Information You Provide to Us
Information from Account Holders/Riders
We collect information that you choose to provide us directly through your use of our Services. For example, we collect information from you when you:
This information generally includes the following types of data (this list may vary depending on your country or region):
Information from Suppliers, Vendors, Business Partners, and Similar Businesses (and Representatives Thereof)
Information We Collect Through Automated Means
Automatically collected information may include:
We and our service providers may also collect and combine diagnostic and usage information collected on our Services with other information about your online activities over time, including the use of other devices, websites, or apps, if such services also use the same vendors.
Information We Collect from Social Media Platforms
When you “like” or “follow” us or interact with us on Facebook, Instagram, Twitter, or other social media sites, we may collect some information from you including your name, e-mail address, account handle, and any comments or content you post relevant to us, depending on your settings on those platforms. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.
Information We Collect from Others
We may obtain information from other sources, such as payment service providers (who provide us with payment confirmation or balance information), identity verification providers, analytics service providers, and security service providers (who provide us with information to secure the Services and help to prevent fraud).
We may also collect certain business contact information and related information about potential business partners (such as influencers or brand partners) from third party sources, including name, title, email address, phone number, and area of expertise.If you access a Spin vehicle through a third-party app or service (“Third-Party Provider”), we may receive certain information from that Third-Party Provider in order to provide the Services, comply with and enforce our Terms, or comply with applicable law. For example, we may receive your contact information if we need to contact you about a vehicle that you rented.
We and our service providers use the information described above to accomplish the following business and operational purposes:
We may also aggregate, de-identify, and/or anonymize any information collected through the Services in such a way that we cannot reasonably link information to you or your device. Subject to applicable law, we may use such aggregated, de-identified, or anonymous information for any purpose, including without limitation for research and marketing purposes.
We and our service providers may disclose the information collected from and about you for the following business and operational purposes:
We may disclose such aggregate or anonymous information with any third party, including researchers, universities, advertisers, promotional partners, and sponsors in accordance with applicable law. We may also disclose aggregated, de-identified data with local or federal government transportation authorities when required or necessary, at our sole discretion.
To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers use web server logs, cookies, tags, tracking pixels, and other similar tracking technologies (“Cookies”).
Cookies are typically classified as either “session cookies,” which do not stay on your device after you close your browser or “persistent cookies,” which will usually remain on your device until you delete them or they expire. Sometimes cookies are placed by us (“First-Party Cookies”) and sometimes they are placed by others (“Third-Party Cookies”). Different cookies are used to perform different functions on our Services:
There are a number of ways you can manage what cookies are set on your devices. If you do not allow certain cookies to be installed, the Services may not be accessible to you and/or the performance or features of the Services may be compromised. See “Online Analytics” below for more information.
We may use third-party web analytics services (such as those of Google Analytics, Looker, and Amplitude Analytics) on our Services to collect and analyze usage information through cookies and similar tools (such as the pages most read, time spent, search terms and other engagement data); engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here and learn more here.
Usage information of our Services is collected to compile statistical data in order to develop new and improved Services and marketing, identify popular features, and to provide you content that is of interest to you.
If you receive email from us, we may use certain analytics tools, such as tracking pixels, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, which is why we describe a variety of opt-out mechanisms above. However, we do not currently recognize or respond to browser-initiated DNT signals. Learn more about Do Not Track.
If we send you marketing communications in your jurisdiction (based on our relationship with you, your consent, or applicable law), you may instruct us not to use your contact information to contact you by SMS, email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below.
We may send you push notifications through our Apps. If you no longer wish to receive push notifications to your device, you may opt out by changing your notification settings on your device or, if applicable, through the push notification service. For mobile devices, the device manufacturer, and not Spin, controls these notification settings.
If you granted us permission to collect your precise geolocation information and you no longer wish for us and our service providers to collect such information, you may disable the location features on your device through the device’s operating system settings. Please note that if you disable such features, you may not be able to access or receive some or all of the services, content, and/or features made available via the Services.
Rights Regarding Your Information
Depending on your jurisdiction, you may have the right to make certain requests regarding your “personal information” or “personal data” and (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:
As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include verifying your name and email address. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights or would like to exercise any of them, please visit this link, email us at email@example.com and include “Consumer Privacy Rights Request” in the subject, or submit your request here.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. To exercise such an appeal right, email firstname.lastname@example.org.
Notice of Financial Incentives
We may offer opportunities to receive certain services or benefits, including money to participate in surveys, sign up for communications, or other similar incentives, which may require the provision of personal information, such as registering for an account and answering surveys or providing additional feedback or information. Such opportunities could be considered a financial incentive under applicable law (each, an “Incentive Program”). Your participation in Incentive Programs is purely voluntary. When you participate in an Incentive Program, you agree to the terms of that Incentive Program, and may revoke your participation depending on the Incentive Program.
California Notice at Collection.
If you are a California resident, you can learn more about our practices by visiting our California Privacy Notice.
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined by Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity.
If you provide your consent to receive push notifications, we may send push notifications to your mobile device to provide you with App updates, safety alerts, and other relevant information such as [information about your trips, subscription renewals, and special offers and promotions]. If you wish to stop receiving push notifications from us, you can turn off push notifications for the App either within the App or in the settings of your mobile device.
We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.
We take measures, including the implementation of physical, technical, and managerial safeguards, to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services and that any such transmission is at your own risk. You are responsible for keeping your account information—and especially your login information—confidential. We ask you not to share your login credentials with anyone.
You may also write to us at:
Spin Mobility Inc.
595 Burrard St., P.O. Box 49314, Suite 2600, Three Centre Vancouver, British Columbia V7X 1L3, Canada.
Skinny Labs Inc., dba Spin
2 Embarcadero Center
8th Floor – WeWork
San Francisco, California 94111