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 Canada, it is also controlled by Spin Mobility Inc.

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.

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:

• 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 (including demographic and statistical information, educational and employment information, usage information, and feedback), 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 from Suppliers, Vendors, Business Partners, and Similar Businesses (and Representatives Thereof)

• Contact and Business Information. If you are a company or other organization that we engage with, or a representative of the foregoing, we may collect your name, phone number, email address, and postal address, government identifier, and business name, industry, locations, other information related to your employer, and any other information you choose to provide us, including through third-party portals and platforms.
• Financial and Transactional Information. If we need to make payments to you or receive payments from you, we may collect financial account and related transactional information.
• Communications. If you contact us, we may receive information such as your name, email address, and phone number. We also will receive the contents of any communications you have with us. This might include requests, questions, and/or issues regarding your offers, your account, our Services, or other topics you might raise.
• Events and Programs. If you register for or attend an event or program that we host, sponsor, or attend, we may receive information such as your name, email address, phone number, and other information related to your attendance at the event or program from those who interact with or express interested in our Services. 

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. 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 disclosure from your device through your device settings. For more information, see the “Your Rights & Choices Regarding Your Information” section below. 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. Please note: precise geolocation information is considered “sensitive personal information” under certain privacy laws, and we process this information in accordance with applicable legal requirements.

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 disclose the information collected from and about you for the following business and operational purposes:

• Service Providers:  We may provide access to or disclose 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 disclose information with that affiliated company. We will disclose 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 disclose 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 disclosed 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 disclosure of your information for other purposes not listed above, we will also disclose your information consistent with your consent.

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”).  

• 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.

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.

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.

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.

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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 disclose 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.

Mobile Devices

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:

• 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 disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about the financial incentives that we offer to you, if any.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable. 

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 privacyhelp@spin.pm 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 legal@spin.pm.

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.  

‍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.

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 11 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.

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 11 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 “Last Updated” 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