Privacy Policy

In this Privacy Policy, we describe how Skinny Labs Inc., along with its subsidiaries listed in below, and its parents or other subsidiaries (“Spin,” “we,” “us,” or “our”) collects, uses, and discloses your information. We also describe the rights and choices you have regarding our use of your information.  

This Privacy Policy applies to information that we collect and process about users of websites that link to this Privacy Policy (“Sites”), Spin mobile applications (each an “App”), and Spin vehicles, as well as information provided when you interact with Spin, such as by emailing us (collectively, the “Services”).

Your use of the Services is also subject to our Terms of Use.

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.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

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:

• Register your account;
• Use the Services, such as renting a vehicle;
• Apply for or participate in a Spin program or request a discount;
• Communicate with us (including through functions of our Sites and Apps, on third-party social media sites, and by mail or email);
• Participate in sweepstakes, contests, promotions, surveys, or research; and
• Request customer support or technical assistance.

This information generally includes the following types of data (this list may vary depending on your country or region):

• Contact and registration information: your name, email address, and phone number.
• Identifiers for verification: driver’s license, passport, or other government-issued identification and date of birth.
• Transactional information: billing and payment information, as well as details about your rentals.
• Spin Access eligibility information (if available in your jurisdiction): documentation that you submit as proof of enrollment in a low-income program (when you provide this information in connection with your application for Spin Access). Please note that this type of documentation is deleted from our systems after your eligibility for Spin Access is determined.
• Research, survey, or sweepstakes information: information you provide if you participate in a survey, contest or sweepstakes and to facilitate the award of a prize.
• User generated content, including audio or visual information: submissions or posts such as reviews, ratings, pictures, and other content such as videos, questions, and comments.
• Inquiries and feedback: comments and questions you submit through customer service interactions with us.

Information We Collect Through Automated Means

When you use our Services, including our App and/or our vehicles, we collect certain information automatically. We and our service providers (which are third-party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information. You can learn more about our use of cookies and similar tools in the “Cookies and Similar Technologies” section below.

Automatically collected information may include:  

• Device information and related identifiers: When you use our Services, we and our service providers collect and analyze information such as your IP address, browser characteristics, device IDs, Spin identifiers, characteristics, systems, mobile device’s service provider, platform type, advertising identifiers, operating system, and the state or country from which you accessed the Services.

• Usage information: When you use our Services, we and our service providers collect and analyze information about your vehicle and also your device usage activity such vehicle ID, as referring and exit pages and URLs, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services and upload or post content, error logs, language preferences, and other similar information.

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.  

• Location Information: Spin offers features designed to help you use the Services, such as locating available vehicles and pinpointing your pickup and drop off points, including, in whole or in part, based on your location. When you use the Services, we and our service providers collect general location information (i.e., city and state) from your computer or mobile device based on its IP address. We will ask your permission before collecting your precise location information. If you choose to enable location-based services, we may collect your location based on information provided by you or your device, including, if available, GPS and the start and end points of your trip.  During your ride, we also collect information from the vehicle you use, including location points along your trip and the duration and length of your ride. If you do not opt-in to location-based services, you may not have access to the features necessary to use the Services. You can disable precise location sharing through your device settings. For more information, see the “Your Rights & Choices Regarding Your Information” section below.

Please note that the Services use Google Map functionality, and by using Google Maps, you are responsible to access and review Google’s terms of service and Google’s privacy policy that are applicable to the Google Map functionality.

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:

• Administer your user account, including to process your account registration, verify your information and eligibility to use the Services, and confirm your eligibility for programs and discounts;
• Provide, manage, and improve the Services, including to allow you to locate, reserve, use, and park vehicles;
• To enable you to locate vehicles near your location and fulfill your rentals;
• Engage in transactions with you, including contacting you about your account, billing you for the Services, and processing payments;
• Provide you with updates and information about your use of the Services and upon your request;
• Respond to your requests for information and provide you with more effective and efficient customer service;
• Conduct internal business operations in support of our Services, such as auditing, security, resolving road incidents such as crashes, preventing fraud, invoicing and accounting, sales and marketing, analytics, and research and development;
• Contact you by email, text message or push notification regarding our products, services, surveys, promotions, special events, and other subjects that we think may be of interest to you;
• Personalize the Services and communications to you based on your selected preferences;
• Comply with laws, regulations, and other legal process (such as a subpoena or warrant);
• Establish, exercise, or defend our legal rights; and
• Take steps that we reasonably believe to be necessary to protect the safety, security, and rights of Spin, its employees, service providers, and others.

Please note that we may combine the information we collect through the Services with information that we collect automatically or receive from other sources and use such combined information for the purposes set out in this Privacy Policy.

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:

• Service Providers:  We may provide access to or share your information with select third parties who perform services on our behalf, such as payment processing, identity verification, insurance, services to search public records, sales, marketing and email delivery, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, and legal services.
• Affiliated Companies: If you utilize a component of the Services provided in whole or in part by an affiliated company, we may share information with that affiliated company. We will share information with affiliated companies to deliver the Services to you, to ensure a consistent level of service across the Services, to enhance the Services, to improve your customer experience with the Services, and for the other purposes outlined in this Privacy Policy.
• City, State, Provincial, National or Federal Regulatory Agencies (or Municipalities): We may share certain information (such as aggregated trip data or scooter-level location data) with local, state, provincial, national or federal regulatory agencies, including but not limited to transportation agencies, when required by law or by such agency in order to operate in a specific jurisdiction.
• Third Party Partners to Provide Co-Branded or Jointly Offered Products and Services. Some of our Services may from time-to-time partner with another brand, retailer or other third party to offer services, products, events and promotions on a co-branded or cross-promotional basis, including if we offer access to Spin vehicles through a Third-Party Provider. The information you choose to provide in connection with such Services may be collected directly by, or shared with the third party, as well as with any participating sponsors or advertisers of such Services. We will seek your consent beforehand where required by applicable law. These third parties will use your information in accordance with their own privacy policies.
• Protection of Spin and Others & Legal Compliance: We may access, retain and disclose the information we collect and maintain about you if required or permitted to do so by law or in a good faith belief that such access, retention, or disclosure is reasonably necessary to: (i) comply with law or legal process (e.g., a subpoena or court order); (ii) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (iii) respond to your requests for customer service; and/or (iv) protect the rights, property or personal safety of Spin, its agents and affiliates, its users, and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
• Business Transfers:  We may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.
• Your Consent:  If you have consented to our sharing of your information for other purposes not listed above, we will also share your information consistent with your consent.

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”).  

• A web server log is a file where website activity is stored.
• A cookie is a small text file that is placed on your computer or mobile device when you visit a website, and it enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
• Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or email that are designed to: (i) collect usage information like ad impressions or clicks and email open rates; (ii) measure popularity of the Services and associated advertising; and (iii) access user 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:

• Essential Cookies: Some cookies are essential to the Services and enable you to use the features of the Services and access secure areas of the Services. Without these cookies, we cannot enable appropriate content based on the type of device you are using (for example, essential cookies store user log-in information so that you don’t have to re-enter it for each page you visit on our website).
• Functional Cookies: These cookies allow us to remember choices you make on our Services (such as your preferred language or the region you are in).
• Personalization Cookies: We also use cookies to change the way our Services behave or look in order to personalize your experience from information we infer from your behavior on our Services or information we may already know about you because, for example, you are a registered user. These cookies may be used to tailor the Services or the content, look, and feel delivered to you on subsequent sessions to our Services. For example, if you personalize webpages, or use specific parts of the Services, a cookie helps our webpage server recall your specific information.
• Analytics Cookies: We use our own cookies and/or third-party cookies to see how you use our Services in order to enhance their performance and develop them according to the preferences of our customers and visitors. For example, cookies may be used to: maintain a consistent look and feel across our Services, track and provide trend analysis on how our users interact with our Services, track errors, and measure the effectiveness of our content.
• Advertising Cookies: These cookies record your visit to our Services, the pages you have visited, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a website. We or our service providers may use this information to make advertisements more relevant to you.

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.

Online Analytics

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.

Online Advertising

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.

We neither have access to, nor does this Privacy Policy govern, the cookies or other tracking technologies that may be placed on the device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices (or, if you’re located in the EEA or the United Kingdom, here, or here if you are located in Canada) to opt out of receiving tailored advertising from companies that participate in those programs. To opt-out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. Please note that these opt-outs apply per device, so you will have to opt-out for each device through which you access our Services.

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.

The Services may contain links to third-party websites, third-party plug-ins (e.g., Facebook, Instagram, and Twitter). If you choose to use these websites, plug-ins, or services, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. If you choose to use these services, we are not responsible for the content or practices of such third-party websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

Marketing Communications

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.

You can opt-out by emailing us at support@spin.pm or by following the unsubscribe instructions located at the bottom of promotional email messages. Removing your name from the email list may take a reasonable amount of time, as permitted by applicable law. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt-out of certain transactional or operational emails, such as those necessary to fulfill our contract with you.

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.

CALIFORNIA RESIDENTS

Additional Information

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”)).

Throughout our Privacy Policy, we discuss in detail the personal information we collect from and about our users, the categories of sources from which we collect such information, our business or commercial purposes for collecting such information, the categories of information we share with others, and the categories of third parties with whom we share such information. You can learn more by visiting our California Privacy Notice.

The CCPA sets forth certain obligations for businesses that “sell” personal information. Although we do not believe we engage in the sale of personal information (and have not in the past twelve months) as we currently understand such term to be defined under applicable law and relevant regulatory guidance, we do share information as described in this Privacy Policy, including with certain analytics and advertising partners who perform services like analyzing our Services and showing you ads for Spin. You can choose to limit the information shared with our analytics and advertising partners by selecting the “Cookie Settings” link at the bottom of our Sites or following the steps described in the “Cookies and Similar Technologies” section of this Privacy Policy.

Privacy Rights

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:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. This information is also set forth in this Privacy Policy.
• Provide access to and/or a copy of certain personal information that we hold about you.
• Delete certain personal information that we hold about you.
• Provide you with information about the financial incentives that we offer to you, if any exists.

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 privacyhelp@spin.pm 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.

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NEVADA RESIDENTS

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:

• To perform our obligations pursuant to a contract (or pending contract) with you. For example, we will process your Personal Data to comply with our Terms of Use to enter into a contract with you, and to honor our commitments in any contracts that we have with you.
• For our legitimate interests or the legitimate interests of others. For example, we will process your Personal Data to: operate our business and our Services; identify and fix any issues with our Services; secure the Services; learn more about how our customers use the Services; perform internal analytics; improve the Services and users’ experiences; conduct marketing; provide you with certain information about new products, special offers or other information that we think you may find interesting using the email address which you have provided in accordance with applicable law; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud; engage in a business change (e.g., sale, merger); and to know the customer to whom we are providing Services.
• To comply with our legal obligations.
• With your consent.

Privacy Rights

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:

• provide access to and/or a copy of certain information we hold about you
• delete certain information that we are holding about you
• prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
• update or rectify information that is out of date or incorrect
• oppose, cancel, or restrict the way that we process and disclose certain of your information
• transfer your information to a third-party provider of services
• revoke your consent for the processing of your information

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.

Data Transfers

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.

If you live in the EEA or the United Kingdom and have used the Services there, please note that we take appropriate measures with applicable third party processors to ensure that such companies protect your information adequately in accordance with this Privacy Policy such as, as applicable, entering into Standard Contractual Clauses or other steps in accordance with EU and other data protection laws. For more information, please contact us as detailed in the “How to Contact Us” section below.

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:

• Pseudonymized Data: Length, duration, and start and end point of trips. The DfT has indicated that neither DfT nor its research contractor will attribute pseudonymized data to any individual person or any personally identifiable data.
• Personal Data: Month, day of the week, and time band for a trip (e.g. a Wednesday in March, between 7-12am); the duration and distance of a trip; and the area (the ONS Lower Super Output Area that corresponds to a trip’s start point). Personal data may be attributed to a user’s contact details for the DfT’s sole purpose of conducting follow-up research.
• Voluntary Demographic Survey: At the end of your trip, you may be asked to participate in a voluntary demographic survey, administered and managed independently by the U.K. DfT.  DfT receives your responses to this optional survey and such data will be controlled solely by DfT. Spin does not receive, have access to, or have any control over your answers and data from this survey.

For more information about the DfT’s privacy standards regarding your personal information, please see the DfT’s Personal Information Charter.

CANADIAN RESIDENTS

Data Transfers

Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf, as outlined in Section 3 of this Privacy Policy. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S. or other foreign jurisdictions. When your data is transferred to our service providers in the US or in other foreign jurisdictions, it may be subject to applicable U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities.

For more information on transfers of your data outside of Canada, including to our third-party service providers, please contact us as set out below in Section 12 of this Privacy Policy.

Your Choices

Push Notifications

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.

• Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.
• To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
• You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

Retention

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.

Your Rights

Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody or control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out in Section 12 of this Privacy Policy. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

The Services are intended for general audiences and not for children under the age of 18 or the age of majority in the applicable region or province where you are located. We do not knowingly collect, maintain, or use personal information (as defined by the United States Children’s Online Privacy Protection Act) from such persons. If you believe that we might have any such information from a child, please contact us as described at the end of this Privacy Policy. If we discover that personally identifiable information of a child has been submitted without legally valid parental consent, we will take reasonable steps to delete it as soon as possible.

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.

We reserve the right to amend this Privacy Policy at any time. We will make the revised Privacy Policy accessible through the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” at the beginning of this Privacy Policy. If we make a material change to this Privacy Policy, we will provide you with notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

If you wish to contact us regarding our information practices or in relation to this Privacy Policy, please email us and our Privacy Counsel at privacyhelp@spin.pm from any region.

You may also write to us at: 

Canada: 

Spin Mobility Inc.

595 Burrard St., P.O. Box 49314, Suite 2600, Three Centre Vancouver, British Columbia V7X 1L3, Canada.

United States:

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.