Last Updated: June 7, 2018
WHO WE ARE
We are Skinny Labs Inc. ("Spin"). We have created a network for sharing vehicles through a mobile application that enables users to locate, rent, and operate vehicles from the available locations (“App”) and we maintain a corporate Web site at https://spin.pm (“Site”) as well as all related applications, widgets, software, tools and other services provided by us and on which a link to this policy is displayed (collectively, together with the Site and App, our “Services”)
WHAT THIS IS
By using the Services (whether or not You are a Member), You expressly consent to the information handling practices described in this Policy. If You do not want information about You to be used in the manner set forth in this Policy, the Services may not be fully available to You.
“Personal Information,” as used in this Policy, is information that specifically identifies an individual, such as an individual’s name, telephone number, or e-mail address. Personal Information also includes information about an individual’s activities, such as information about his or her activity on our Services, demographic information, such as date of birth, geographic area (including location), and preferences, when any of this information is linked to Personal Information that identifies that individual. For purposes of this policy, Spin only collects Personal Information which is reasonably necessary to achieve our personal mobility transportation services. Spin does not collect Personal Information related to race, gender, national origin, age, or sexual determination except for survey data collected on an opt- in basis. In the event of such survey, User is under no requirement to provide any of the requested information.
ANONYMOUS AGGREGATED DATA
Anonymous data is information (originally personally identifiable or non-personally identifiable) that subsequently is used in aggregate form. Although anonymous data may be based in part on personal data, it does not identify You personally. We may collect anonymous data whether or not You are a Member. We may use anonymous data for a number of purposes, including analysis of the usage of the Services, and interests and behavior.
INFORMATION SPIN COLLECTS
Collection of Voluntarily-Provided Information
User Provided Information. When You register and set up an account, use or visit the Services, or contact us by e-mail or other means for any reason, You may provide Personal Information to Spin. Personal Information may also be collected if You provide such information in connection with creating a profile or group, leaving comments, posting content, sending an email or message to another User or participating in any features of the Services. In addition, from time to time we may collect other Personal Information You provide in connection with Your participation in promotional offers and other activities on the Services. If You use the Services with Your mobile device, we may have access to Your phone number, Unique Device Identifier or other device information that uniquely identifies individual smartphones or mobile devices.
Payment Information. If You purchase services or products from the Services, we will collect the billing and financial information necessary to process Your charges, which may include Your postal and email addresses. We may also receive the billing and payment information that You provide when Your purchase is processed by another party.
Invitation Service. Spin may offer an invitation service to tell a friend about the Services. If You choose to use our invitation service to tell a friend about the Services, we may ask You for information needed to send the invitation, such as Your friend’s email address or phone number. We may also offer You the opportunity to invite Your friend via third party services such as Facebook or Twitter. We will automatically send Your friend a one-time email or text message inviting him or her to try the Service. By providing email addresses or phone numbers of non-Users, You represent that You have the right to do so and that such information may also be provided to the third party service that You have designated to contact the non-User. We store and use this information to send this invitation, to register a friend if Your invitation is accepted, and to track the success of our invitation service. Your friend may contact us at email@example.com to request that we remove this information from our database.
Passively Collected Information
“Cookies” Information. We may automatically collect certain information through the use of “cookies.” Cookies are small data files that are stored on a User’s hard drive at the request of a Web site to enable such Web site to recognize Users who have previously visited them and retain certain information such as customer preferences and history. If we combine cookies with or link them to any Personal Information, we would treat this information as Personal Information. If You wish to block, erase, or be warned of cookies, please refer to Your browser instructions or help screen to learn about these functions. However, if a browser is set not to accept cookies or if a User rejects a cookie, some portions of the Services may not function properly. For example, You may not be able to sign in and may not be able to access certain features of the Services.
Location Information. Spin may offer features designed to help You use the Services, such as to locate vehicles available through the network, including in whole or in part based on Your location. You will be given the opportunity to opt-in to location-based services, normally through an opt-in screen on the App. If You choose to enable location-based services, we may collect Your location based on information provided by You or Your mobile device, including, if available, GPS, IP address or cell tower information. If You, as a Member, do not opt-in to location-based services, You may not have access to the features necessary to use the Services.
We use analytics tools to track how You get to our Site and to understand how You use the Site after You arrive. Our systems do not provide a way for that information to be tied to any Personal Information You choose to give us.
Information from Other Sources. We may receive information about You, including Personal Information, from third parties and third party Web sites (e.g., Facebook, Twitter, etc.) (“Third Party Sites”), in accordance with the policies and terms of such Third Party Sites. However, Spin will not make any Personal Information available to any Third Party advertiser or other private entity.
THE WAY SPIN USES AND DISCLOSES INFORMATION
In general, we use Personal Information we collect to process Your requests or transactions, to provide You with information or services You request, to inform You about other information, events, promotions, products or services we think will be of interest to You, to facilitate Your use of, and our administration and operation of, the Services, and for the purpose for which the information was provided. For example, we may use the information we collect:
to send You a welcoming email and to contact You about Your use of the Services, to provide other services, products or information You request and to complete any transactions in connection therewith;
to enable Your use of the Services, including to determine your service eligibility and credit- worthiness, access Your driving safety records, and obtain insurance;
to respond to Your emails, submissions, comments, requests or complaints;
to request feedback and to enable us to develop, customize and improve the Services;
for the specific purpose for which the information was provided; and
to conduct an aggregate analysis of the performance of the Services
Spin’s employees, agents and contractors must have a legitimate business reason to obtain access to the Personal Information You provide to register as a member of the Site and/or to use the Services. We may share Your Personal Information with companies that provide services to us, including outside contractors or agents who help us manage our information activities (for example, for payment processing, insurance, services to search driving records, data storage, customer service, email delivery, and to assist us in our marketing efforts), but we limit the Personal Information that is provided to these service providers to that which is reasonably necessary to provide us with a specific business service and not for any other purpose and we require them to maintain the confidentiality of the Personal Information.
We may disclose Personal Information in the good faith belief that we are lawfully authorized or required to do so, or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of the Services, our Users, our employees or the public, including without limitation to protect Spin or our Users from fraudulent, abusive, inappropriate or unlawful use of the Services.
We may disclose Personal Information in connection with the reorganization, reincorporation, acquisition, debt financing, merger, sale of Spin’s relevant assets or business or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets. In any such case, we will notify You of our intention to transfer Personal Information and will provide You an opportunity to affirmatively disallow the transfer of such information. Spin agrees not to undertake any form or partnership, data sharing agreement or other data sharing arrangement if the other entity or entities does not provide for the same or similar standards set forth herein.
We use all of the information that You provide or that we collect and/or aggregate to understand and analyze the usage trends, interests, and preferences of our Users, to improve the way the Services work and look and to create new features and functionality.
Notwithstanding the above, Spin shall comply with all applicable state, city and municipal law and requirements with respect to Personal Information, including the California Online Privacy Protection Act (CalOPPA) and municipal permit agreements.
HOW SPIN PROTECTS INFORMATION
Spin uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Your Personal Information. We cannot, however, ensure or warrant the security of any information You transmit to Spin, and You do so at Your own risk and this is not a guarantee that such information will not be accessed, disclosed, altered, or destroyed by breach of any of Spin’s physical, technical, or managerial safeguards.
If Spin learns of a security systems breach, then we will notify You electronically through the contact information that You have provided to Spin so that You can take appropriate protective steps. Spin will also post a notice on the App and/or the Site if a security breach occurs. Depending on where You live, You may have a legal right to receive notice of a security breach in writing.
CHOICES YOU HAVE REGARDING THE USE OF YOUR PERSONAL INFORMATION
Please be aware that if You “opt out” of receiving commercial email from us, it may take up to ten business days for us to process Your “opt out” and You may receive commercial email from us during that period.
To protect Your privacy and security, we take reasonable steps to verify Your identity before granting You account access or making corrections to Your information but You are solely responsible for maintaining the secrecy of Your unique password and account information at all times.
LINKS TO OTHER WEBSITES
If You choose to visit or use any third party products or services, please be aware that this Policy will not apply to Your activities or any information You disclose while using third party products or services or otherwise interacting with third parties. We are not responsible for the privacy practices of these Third Party Sites and third party services. We encourage You to carefully review the privacy policies applicable to any Web site or service You visit other than the Services before providing any Personal Information on them.
THIRD PARTY CONNECTED SERVICES
We may permit Users with accounts on certain Third Party Sites (including social networking, search, sharing, and other services delivered by third parties) to bypass standard registration processes on our Services. If You connect to our Services through an authorized Third Party Site, You may be able to use Your third party login information to log into our Services, and You may be able to publish Your comments and any other activity on our Services to the Third Party Site. We are not responsible for the sharing, posting, commenting, or other content and information-gathering practices on any Third Party Site. Please review the Third Party Site’s terms of service and privacy policies carefully before using their services and connecting to our Services.
By using any Third Party Site to log in to our Services, or otherwise connecting to any Third Party Site, You permit us to access and use all information related to Your account on the Third Party Site that may be accessible to us through the Third Party Site pursuant to this Policy. To limit or control the information that is available to us through such Third Party Site, or to disconnect the Third Party Site from our Services, You should check (and, if applicable, modify) the applicable settings on the Third Party Site.
OUR COMMITMENT TO CHILDREN’S PRIVACY
Protecting the privacy of young children is especially important. For that reason, our Services are not directed to persons under 18 years-of-age and Spin does not knowingly collect or maintain Personal Information from persons under 18 years-of-age. If Spin learns that Personal Information of persons under 18 years-of-age has been collected in the Services without verifiable parental consent, then Spin will take the appropriate steps to delete this information. If You are a parent or guardian and discover that Your child under the age of 18 has obtained a Spin account, then You may alert Spin at firstname.lastname@example.org and request that Spin delete that child’s Personal Information from its systems.
Our Services are hosted in the United States and generally are intended for United States visitors. If You visit from the European Union or other regions with laws governing data collection and use that may differ from United States law, please be aware that You are transferring Personal Information to the United States. The United States does not have the same data protection laws as the European Union and other jurisdictions. By providing Personal Information to us, You consent to the transfer of it to the United States and the use of it in accordance with this Policy and applicable law.
Spin CONTACT INFORMATION
Please contact Spin with any questions or comments about this Policy, Your Personal Information, our Third-Party disclosure practices, or Your consent choices by email at email@example.com.