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 one of the following countries, it is also controlled by the corresponding entity listed below.
Canada – Spin Mobility Inc.
United Kingdom—Spin Mobility Limited
The contact information for each of these entities is listed in the “How to Contact Us” section.
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
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 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 share the information collected from and about you for the following business and operational purposes:
We may share or 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 share 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 and Advertising” 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.
The Services may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google Display Network, Criteo, and others) to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you to assist in the delivery of relevant advertising about the Services on other websites you visit and other services you use.
We also sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile apps.
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.
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.
Your Privacy Rights
Your local laws (such as those in the European Union, United Kingdom, Canada, California, or Nevada) may permit you to exercise certain rights with respect to the information we collect from and about you. Please see the “Additional Information for Residents of Certain Jurisdictions” section below for more information.
Your local laws may entitle you to additional information or permit you to exercise certain rights with respect to the information we collect from and about you. Please note that your rights vary depending upon your location, and that we may request you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you or to comply with a legal obligation. In some circumstances, if you still ask us to delete your information, you may no longer be able to access or use our Services.
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 in the California Consumer Privacy Act (“CCPA”)).
If you are a California resident, the CCPA allows you (or an authorized agent acting on your behalf) to make certain requests related to your personal information. Specifically, the CCPA allows you to request us to:
The CCPA further provides you with the right not to be discriminated against (as provided in applicable law) for exercising your rights.
Certain information may be exempt from such requests under California law. For example, we may retain certain information for legal compliance and to secure our Services. We may need certain information in order to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services.
We will take reasonable steps to verify your identity before responding to a request. In doing so, we may request information from you so that we can match the data you provide to us with the data we maintain. If you would like further information regarding your legal rights under California law or would like to exercise any of these rights, or if you are an authorized agent making a request on a user’s behalf, please contact us at email@example.com and include “CCPA Consumer Request” in the subject, or submit your request here.
California’s “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share 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.
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.
EUROPEAN UNION ECONOMIC AREA & BRAZILIAN RESIDENTS
Legal Bases for Use of Your Information
Some countries require that companies only process your “Personal Data” (as that term is defined in the applicable law like the EU General Data Protection Regulation) if they have a “legal basis” (or justifiable need) for processing your Personal Data. To the extent those laws apply, our legal bases for processing Personal Data are as follows:
For residents of the European Economic Area (“EEA”), the United Kingdom, Switzerland, or Brazil who have used our Services there, you may request that we:
To make such a request, please visit here.
If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
Spin currently stores or may transfer personal data to countries other than your country of residence, including the United States, which may have different data protection standards than the country in which you reside. Spin may subcontract the processing of your data to, or otherwise share your data with, Affiliated Companies, trusted service providers, and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. By providing us with your information and/or accessing and using the Services, you acknowledge any such transfer, storage, or use.
Retention of Information
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
UNITED KINGDOM RESIDENTS
If you are a resident of the U.K. or are utilizing our services within the U.K., some data pertaining to your use of e-scooters may be shared with the U.K. Department for Transport (DfT) and the DfT’s third-party research contractor for the purpose of conducting e-scooter trials within the U.K. The DfT’s stated purpose for requesting this data is that it will enable DfT to understand the effect of e-scooters in the U.K. and help to inform future decisions about e-scooter regulation in order to promote safe and sustainable travel.
Spin will only share data that the DfT requests in order to provide the Services in the U.K.
The data to be shared includes:
For more information about the DfT’s privacy standards regarding your personal information, please see the DfT’s Personal Information Charter.
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.
Opting-out of Interest-Based Advertising
If you are in Canada and you wish to obtain more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioral ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
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
United Kingdom:New Penderel House, 4th Floor283 - 288 High Holborn, LondonWC1V 7HP, United Kingdom.