Last Updated: March 8, 2017
WHO WE ARE:
We are Skinny Labs Inc. ("Spin"). We have created a network for sharing bicycles through a mobile application that enables users to locate, rent, and operate bicycles 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, please do not use the Services.
“Personal Information,” as used in this Policy, is information that specifically identifies an individual, such as an individual’s name, address, 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, gender, geographic area (including location), and preferences, when any of this information is linked to Personal Information that identifies that individual.
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 and/or third parties that are providing services in connection with the Services 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 request that we remove this information from our database.
Passively Collected Informatio
“Cookies” and Clear Gif Information. We may automatically collect certain information through the use of “cookies” and/or clear gifs. 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. Clear gifs (also known as web bugs or web beacons) are small, invisible graphic images that may be used by the Services or in emails relating to the Services to collect certain information and monitor user activity on the Services and may be combined with Your IP address or other information that we have gathered with respect to a User’s use of the Services. 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 bicycles 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. Although this allows us to see and analyze Your movements around the Site, 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. Spin may combine this information with other Personal Information we maintain about You. If we do so, this Policy governs any combined information that we maintain in a personally identifiable format.
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;
◦ to contact You about our or a third party’s services, products, activities, special events or offers and for other marketing, informational, product development and promotional purposes;
◦ for the specific purpose for which the information was provided; and
◦ to conduct an aggregate analysis of the performance of the Services
Spin may use “cookies” or clear gif information for a number of reasons related to the Services, including to: (a) remember Your information so that You will not have to re-enter it during Your visit or the next time You use the Services; (b) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (c) track Your entries, submissions, and status in any promotions or other activities.
We have a policy that Spin’s employees, agents and contractors must have a legitimate business reason to obtain access to the Personal Information You may 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 service and not for any other purpose and we require them to maintain the confidentiality of the Personal Information.
Personal Information provided online may be linked together or merged with other Personal Information so that we may better understand Your needs and inform You about our products or services and those of our partners. In addition, if we receive information from third parties with whom we have business relationships, we may combine this information with the other Personal Information we maintain about You. In either case, this Policy governs this 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.
You understand that when You use the Services, information You post in Your public profile and in any other interactive areas of the Services will be available to other Users and in some cases may be publicly available and You provide that information at Your sole risk.
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.
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.
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 may attempt to notify You electronically through the contact information that You have provided to Spin so that You can take appropriate protective steps. Spin may 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
You may, of course, decline to share Your Personal Information with Spin, in which case Spin will not be able to provide to You some of the features and functionality found in the Services. If
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:
The Services may be linked to Third Party Sites operated by other companies (including facebook.com), products, or services that we do not own or operate. Some of these Third Party Sites may be co-branded with our name or logo, even though they are not operated or maintained by us. 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. Additionally, please be aware that the Services may contain links to Web sites and services that we operate but that are governed by different privacy policies. 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 their 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, including children under the age of 13. If Spin learns that Personal Information of persons under 13 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 13 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.