Privacy
PRIVACY POLICY
Last Updated: September30, 2021
SocialSpinner.net take data
protection and security seriously. This Privacy Policy describes how we collect
and process your personal data when you access content we own or operate on the
website located at www.SocialSpinner.net
(the “Website”) and/or when you use any of our APIs or third party applications
relying on such APIs, and any of our products or services (referred to
collectively hereinafter as our “Services”).
Please read this Privacy Policy carefully and its entirety. If you have any questions about this Privacy Policy, please contact us at contact@socialspinner.net.
ACCEPTANCE OF PRIVACY POLICE
By accessing and using the SocialSpinner Site or our Services, you agree that you have read, understood and accept all of the terms and conditions contained in this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of the SocialSpinner Site and our Services.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to alter, amend or modify this Privacy Policy from time to time, in our sole discretion. We will provide you with notice of such changes by sending an e-mail, providing notice on the homepage of the Website and/or by posting the amended Privacy Policy via our Website and updating the “Last Updated” date at the top of this Privacy Policy. The amended Privacy Policy will be deemed effective immediately upon posting on the Website. Your continued use of the SocialSpinner Site and/or our Services constitutes your agreement to be bound by any such changes to this Privacy Policy. If you do not agree with this Privacy Policy or any amendment to it, you should discontinue access and use of the SocialSpinner Site and our Services.
DATA WE COLLECT
When you visit the SocialSpinner Site, you may provide us with two types of
information: personal information that you voluntarily disclose or that is
collected on an individual basis; and information collected automatically when
you use the SocialSpinner Site or our Services
including, without limitation, information that we obtain from our partners
(collectively, the “Information”).
We collect and process this Information for the purpose of providing Services and information about our Services to you and/or to comply with legal requirements. You may be asked to provide personal information anytime you are in contact with us. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you choose not to share certain information with us.
Personal Information
Personal information is data that can be used to identify you directly or indirectly, or to contact you. This Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you. Personal information means any information that is unique to you, such as your:
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full legal name, date of birth, age, nationality, gender, signature, utility
bills, phone number, email address and home address;
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passport or other photo identification cards such as a driver’s license or
national identification card, other photographs like selfies;
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user ID, security questions, authentication data, transaction information,
financial information, cryptocurrency or wallet addresses; and
• • other personal information you choose to provide.
With your
permission, we may also access other personal information on your device, such
as your phone book, calendar or messages, in order to provide Services to you.
If authorized by you, we may also access profile and other information from
services like Facebook, Google, Twitter.
We may also
collect and obtain information about you in order to comply with our legal
obligations, such as anti-money laundering laws. We may obtain information
about you from third party sources as required or permitted by applicable law,
such as public databases, credit bureaus, ID verification partners, channel
partners, joint marketing partners, and social media platforms. For example, we
obtain information about you from public databases and ID verification partners
for purposes of verifying your identity when you sign up for our Services or
use our Services. Our ID verification partners use a combination of government
records and publicly available information about you to verify your identity.
Such information includes your name, address, job role, public employment
profile, credit history, status on any sanction lists maintained by public
authorities, and other relevant data. Pursuant to European Economic Area (“EEA”)
data protection law, our lawful basis for processing such data is compliance
with our legal obligations. In some cases, we may process additional data about
you to ensure our Services are not being used fraudulently or for other illicit
activities.
By using our Services or providing us with your personal information, you also consent for us to collect, hold, use and disclose your personal information in accordance with this Privacy Policy. In addition to providing the foregoing information, if you choose to correspond further with us through e-mail or through the “contact” section of the Coinpayments Site or through events and public social networking platforms, we may retain, use and disclose the content of your messages together with your user ID or e-mail address and our responses.
Information that is Collected Automatically
When you use the SocialSpinner Site or our Services, we automatically collect information from your devices. We collect the following information:
• Server Log Information: We collect server log information
when you use the SocialSpinner Site, which may include (but is not limited to) your login
details, the date and time of visits, the pages viewed, your IP address, time
spent at the SocialSpinner Site and the websites you visit just before and just after
our Website.
• Device
Information: We
collect information about the computer or mobile device you use to access the SocialSpinner Site, including the hardware model,
geo location/tracking details, browser fingerprint, operating system and
version, the web browser and version you use, and other device identifiers.
• Telemetry
Information. If you
use any of our open source software, we may collect bandwidth download and
upload speeds, the amount of free and used storage space on your device and
other statistics about your device.
• Usage
Information. If you
use the SocialSpinner Site, we will collect metadata about the files you upload
for storage and information about the transactions you make on the SocialSpinner Site or with our Services, such as
the name of recipients, your name, digital asset amounts, click-stream data,
instances in which you have used your private key to authenticate
communications and/or the timestamp of transactions.
•
Information Collected by Cookies and Other Tracking Technologies: We and our service providers use
various technologies to collect information when you interact with the SocialSpinner Site, including cookies, web beacons
and other unique device identifiers. Cookies are small data files that are
stored on your device when you visit a website, which enable us to collect
information about your device, IP address, web browsers used to access the SocialSpinnerSite, pages or features viewed, time
spent on pages, mobile app performance and links clicked. Web beacons are
graphic images that are placed on a website or in an email that is used to
monitor the behaviour of the user visiting the website or sending the email.
They are often used in combination with cookies.
HOW YOUR
PERSONAL INFORMATION IS USED
The primary
purpose for collecting your Information is to provide you with the best
possible user experience and Services and to safeguard the security and
stability of our systems. In general, we use Information to create, develop,
operate, deliver, and improve our Services, content and marketing, to comply
with our legal obligations, for anti-fraud purposes and for loss prevention. We
may use your Information in the following ways:
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to provide, maintain,
deliver or improve the SocialSpinnerSite or our Services;
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for quality control and
staff training to ensure we can provide you with the best user experience and
accurate information;
• • to monitor and analyze trends, usage and activities in connection with the SocialSpinnerSite, to determine the usefulness or popularity of certain content and to better understand the online activity of users of the SocialSpinnerSite;
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to fulfil our legal or
regulatory requirements;
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to enforce the terms and
conditions of our User Agreement and other agreements we may have with you or
third parties;
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to ensure network and
information security including processing your Information in order to enhance
security, monitor and verify identity or service access, combat spam or other
malware or security risks and to comply with applicable security laws and
regulations;
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to provide you with the
information or products or services that you have requested;
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to provide you with
customer service including, without limitation, answering your inquiry or
responding to a communication from you;
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for research and
development purposes including developing new products or services;
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to send you technical
notices, support or administrative notifications;
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to facilitate marketing
and to communicate with you about news, products, services, events and other
information we think will be of interest to you;
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to detect, investigate
and prevent fraudulent transactions or unauthorized or illegal activities;
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to protect our
interests, rights and property and that of others;
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to facilitate corporate acquisitions, mergers, or transactions;
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to link, connect or
combine Information we collect from or about you with other Information; and
• • to carry out any other purpose or reason for which the Information was collected.
SHARING OF
INFORMATION
We will never
sell or rent your personal information. We will only share your Information in
the following circumstances:
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with your consent or at your instruction;
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in connection with
offers, products or Services provided on the SocialSpinnerSite;
• • with our current or future parent companies, affiliates, subsidiaries and with other companies under common control or ownership with us or our offices internationally;
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with third parties or
service providers that we have partnered with or perform work for us;
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certain information you
may choose to share may be displayed publicly, such as your username and any
content you post when you use interactive areas of the SocialSpinnerSite or our social media platforms
like our online forums;
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in connection with a
merger or sale of our assets, or if we do a financing or are involved in an
acquisition or any other situation where Information may be disclosed or
transferred as one of our business assets;
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in order to prevent
fraud or other illegal or unauthorized activities;
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if we believe disclosure
is in accordance with, or required by, any applicable law, regulation or legal
process;
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with law enforcement
officials, courts, or other third parties when we are compelled to do so by a
subpoena, court order, or similar legal procedure, or when we believe in good
faith that the disclosure of Information is necessary to prevent physical harm
or financial loss, to report suspected illegal activity or to investigate
violations of our User Agreement or any other applicable policies;
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if we believe your actions are inconsistent with our User Agreement, our other agreements
or policies, or to protect our legitimate interests, rights, property and
safety or that of others; and
• • with third parties where aggregate Information is disclosed which cannot be reasonably be used to identify you.
The data
sharing may include transfers to companies or organizations in countries
without an adequate standard of data protection. In these cases, we transfer
personal data in accordance with applicable provisions on the international
transfer of personal data, such as, where applicable, the respective provisions
of the European Union General Data Protection Regulation (“GDPR”).
SOCIAL
SHARING FEATURES
The SocialSpinnerSite may offer social sharing
features, links to social media and other integrated tools. Your use of such
features enables the sharing of information with your contacts or the public,
depending on the settings you use with the entity that provides the social
sharing feature or social media. Please visit the privacy policies of the
entities that provide these features to obtain more information about the
purpose and scope of data collection and the processing of such data by such
entities.
HYPERLINKS
AND THIRD-PARTY SITES
The SocialSpinnerSite may contain links to other third-party websites that may collect personal information about you, including through cookies or other technologies. If you link to another website, you will leave the SocialSpinnerSite and this Privacy Policy will not apply to your use of and activity on those other websites. You should consult these other websites’ privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.
MARKETING
AND ONLINE COMMUNICATION
We require
your consent to send you marketing communications (for example: email
marketing, exclusive offers, etc).
If you are a
current customer residing in the EEA, we will only contact you by electronic
means (email or SMS) with information about our Services that are similar to
those which were the subject of a previous sale or negotiations of a sale to
you. If you are a new customer and located in the EEA, we will contact you if
you are located in the European Union by electronic means for marketing
purposes only if you have consented to such communication.
If you do not want us to use your personal information for direct marketing purposes or to pass your personal information on to third parties for marketing purposes, if GDPR applies, you can withdraw your consent by contact us at contact@socialspinner.net. Direct marketing includes any communications to you that are only based on advertising or promoting products and services.
PROTECTION
OF PERSONAL INFORMATION
We take
reasonable administrative, physical and electronic measures designed to
safeguard and protect your personal information from unauthorized access or
disclosure. This includes utilizing Secure Sockets Layer (SSL) software, which
encrypts the personal information you input, and storing your personal
information in encrypted form behind a firewall designed to block access from
outside our network. However, no security or encryption method can be
guaranteed to protect information from hackers or human error, no computer
security system is entirely fool-proof and the Internet is not a secure method
of transmitting information. As a result, we do not assume any responsibility
for the data you submit to or receive from us through the Internet or for any
unauthorized access or use of that information and we cannot and do not
guarantee that personal information communicated by you to us or sent to you by
us will be received or that it will not be altered before or after its
transmission to us.
We cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your Information will not occur. Please recognize that you play a vital role in protecting your own Information. When registering on the SocialSpinnerSite or accessing or using our Services, you should choose a password of sufficient length and complexity, not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.
Furthermore,
we cannot ensure or warrant the security or confidentiality of Information you
transmit to us or receive from us by Internet or wireless connection, including
email, phone, or SMS, since we have no way of protecting that Information once
it leaves and until it reaches us. If you have reason to believe that your data
is no longer secure, please contact us at contact@socialspinner.net.
RETENTION
PERIOD OF DATA
Information we
collect may be stored or processed on computers located in any country where we
do business. We will only retain your personal information for as long as
necessary to fulfil the purposes for which we collected it, including for the
purposes of satisfying any legal, accounting, or reporting obligations or to
resolve disputes. This is a case-by-case determination that depends on things
such as the nature of the data, why it is collected and processed, and relevant
legal or operational retention needs. For example, we may retain certain
information for accounting and security purposes even after our business
relationship with you has ceased.
RIGHTS YOU
HAVE WITH RESPECT TO YOUR PERSONAL INFORMATION
You have
certain individual rights regarding the personal information that we collect
and process about you through the SocialSpinnerSite.
Most web
browsers are set to accept cookies as a default. You may wish to opt out by
turning off cookies (please refer to the help menu on your browser); however,
switching off cookies may restrict your use of the SocialSpinnerSite.
You may also
opt out of receiving promotional communications from us at any time by
following the instructions in those communications. If you opt out, we may
still send you non-promotional communications, such as technical notices,
support or administrative notifications or information about your account (if
you have one).
You have the
right to:
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access or receive certain data about the personal information we process about
you;
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have your personal information rectified;
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object to the processing of your personal information or ask us to restrict
processing or delete your personal information;
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withdraw your consent to our processing of your personal information; and
• • not be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
If the GDPR applies and we process your personal information to perform a contract with you or based on your consent, you also have the right to receive a copy of your personal information in a structured, commonly used and machine-readable format for the purpose of transferring such information to a third party. This information will be provided subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. Please note, however, that your rights are subject to exceptions or derogations. Specifically, we may need to further process and retain your Information to perform a contract with you or your company or organization, to protect our legitimate interests (such as the establishment, exercise or defense of legal claims) or to comply with legal requirements. To the extent permitted by law, namely to protect the rights and freedoms of others or to protect our own legitimate interests, we may therefore refuse to satisfy your request or we may satisfy your request only restrictedly.
Lastly, you
have a right to lodge a complaint with a competent supervisory authority.
CHILDREN’S
PERSONAL INFORMATION
We do not
knowingly collect personal information from any person under the age of 18. If
a user submitting personal information is suspected of being younger than 18
years of age, we will require the user to close his or her account and will not
allow the user to continue to use our Services. We will also take steps to
delete the Information as soon as possible. Please notify us if you or anyone
you know is under the age of 18 and are using our Services so we can take
action to prevent access to our Services.
COMPLAINTS
You have the
right to complain about our processing of your personal information to the
relevant data protection authority. You can complain in the European Union
member state where you reside or work, or in the place where the alleged breach
of data protection law has taken place.
HOW TO
CONTACT US
If you have questions or concerns regarding this Privacy Policy or if you have complaint, please contact us at contact@socialspinner.net