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By continuing to browse and use the functionality of this website, I agree with the processing of my personal data (including personal data obtained through cookie files) in accordance with the Privacy Policy of this website. My consent to processing of my personal data also includes the consent on cross-border transfer of my personal data in accordance with the rules established in the Privacy Policy. By pressing the button “I agree”, I also confirm that I am at least 16 (sixteen) years of age. If I am less than 16 (sixteen) years of age, I shall not press the button “I agree”. I understand that if I press the button “I do not agree” or ignore this window and do not press any button at all, I may not be able to use all the functions of this website which are necessary for receiving the services of SPIN4SPIN Inc. operating this website.
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Privacy Policy

 

Valid from: July 22, 2021

Last modified: July 22, 2021

We, SPIN4SPIN Inc. (hereinafter referred to as the “Spin”), a company registered in accordance with the laws of the State of Delaware, the United States under the file number 5256688, having the registered address at 8 THE GREEN, STE A, Dover, Kent, DE 19901, the United States, care about privacy of our customers and their personal data. Spin takes all the measures necessary for the protection of customers’ personal data and compliance with all the laws and regulations on personal data protection. Therefore, Spin enacts this Privacy Policy (hereinafter referred to as the “Policy”) which provides for the list of personal data processed by Spin, the purposes of personal data processing, the rules on sharing of customers’ personal data with third parties, and the conditions of storing personal data. This Policy is enacted in accordance with the general US-law requirements on personal data protection and fair customer treatment, Children’s Online Privacy Protection Act and Rule enacted by the Federal Trade Commission (COPPA), California Consumer Privacy Act (CCPA), and General Data Protection Regulation (GDPR) No. 2016/679 adopted by the European Parliament and the Council on 27 April 2016.

The terms and definitions provided by GDPR shall apply to this Policy.

The Policy applies to the provision of the Services offered by Spin via the official website of Spin with the URL https://spin4spin.com/ (hereinafter referred to as the “Website”). The Policy applies to processing of personal data of Users. You can read the Policy by following the link: [URL of the Policy]. Please read the Policy carefully before starting the use of the Services. The following terms and definitions shall also apply to the Policy:

“User” means a natural person using the Services of Spin who is a data subject under GDPR. A natural person becomes the User since he opens the Website of Spin.

“Services” means services offered by Spin via the Website, including the following:

• Retail of clothes, footwear, headdresses, accessories • Resale of used clothes, footwear, headdresses, accessories under the commission agreement between Spin and the User • Other Services offered via the Website

“Account” means a set of data about the User stored in the computer system of Spin in a form of a personal web-page of the User on the Website that provides the User with additional functionality of the Website facilitating provision of the Services.

“Controller” means Spin acting as a legal entity which determines the purposes and means of the processing of personal data.

“Processor” means a natural person or a legal entity which processes personal data of Users on behalf of Spin.

“Parent” means a natural person or a legal entity that is the holder of parental responsibility over the Juvenile User (e.g., a parent or an adoptive parent).

“Juvenile User” means a User who is at least 13 (thirteen) years of age but under 16 (sixteen) years of age.

“Minor” means a User who is under 13 (thirteen) years of age.

“Third parties” means natural persons or legal entities receiving User’s personal data for purposes not related to processing of personal data, including commercial and other business purposes.

If any of the terms and definitions provided by this Policy differ from the terms and definitions provided by COPPA, CCPA, GDPR or other applicable personal data legislation, the term and definition provided in the Policy shall apply unless the term or its definition violates the applicable legislation.

1.Consent to processing of User’s personal data

There are several ways of providing Spin with the consent to processing of User’s personal data depending on the type of the personal data processed by Spin.

1.1. When the User opens the Website, the special window with the following text will appear on the User’s screen: “By continuing to browse and use the functionality of this website, I agree with the processing of my personal data in accordance with the Privacy Policy of this website. My consent to processing of my personal data also includes the consent on cross-border transfer of my personal data in accordance with the rules established in the Privacy Policy”. The window will also include the buttons “I agree” and “I do not agree”. The User shall press one of the buttons in order to continue to use the Website. If the User presses the button “I agree”, this means that the User provided Spin with the consent to processing of User’s personal data provided for in para.3.3 of the Policy. If the User presses the button “I do not agree” or ignores the appeared window and does not press any button at all, this means that the User refused to provide Spin with the consent to processing of User’s personal data provided for in para.3.3 of the Policy. If the User refuses to processing of User’s personal data provided for in para.3.3 of the Policy, the User may browse the Website and use the Services that do not need processing of personal data provided for in para.3.3 of the Policy, but Spin is entitled to refuse provision of some of the Website’s functions if provision of such Website functions is impossible without processing of User’s personal data provided for in para.3.3 of the Policy.

1.2. When the User uses the Services related to retail of clothes, footwear, headdresses, accessories and expresses an intent to purchase an item by adding the item to the cart, the User provides Spin with the User’s personal data provided for in para.3.1 of the Policy in order to complete the purchase. Before completing the purchase, the User puts a tick in the box next to the phrase “By putting a tick in the box, I agree with the processing of my personal data in accordance with the Privacy Policy of this website. My consent to processing of my personal data also includes the consent on cross-border transfer of my personal data in accordance with the rules established in the Privacy Policy”. If the User puts a tick in the box, this means that the User provided Spin with the consent to processing of User’s personal data provided for in para.3.1 of the Policy. If the User puts a tick in the box, this means that the User refused to provide Spin with the consent to processing of User’s personal data provided for in para.3.1 of the Policy. If the User refuses to processing of User’s personal data provided for in para.3.1 of the Policy, Spin will refuse to provide the User with the Services related to retail of clothes, footwear, headdresses, accessories because provision of such Services is impossible without processing of User’s personal data provided for in para.3.1 of the Policy.

1.3. When the User uses the Services related to resale of used clothes, footwear, headdresses, accessories under the commission agreement between Spin and the User, the User provides Spin with the User’s personal data provided for in para.3.2 of the Policy by filling out the special form available via the Website. Before submitting the filled form, the User puts a tick in the box next to the phrase “By putting a tick in the box, I agree with the processing of my personal data in accordance with the Privacy Policy of this website. My consent to processing of my personal data also includes the consent on cross-border transfer of my personal data in accordance with the rules established in the Privacy Policy”. If the User puts a tick in the box, this means that the User provided Spin with the consent to processing of User’s personal data provided for in para.3.2 of the Policy. If the User puts a tick in the box, this means that the User refused to provide Spin with the consent to processing of User’s personal data provided for in para.3.2 of the Policy. If the User refuses to processing of User’s personal data provided for in para.3.2 of the Policy, Spin will refuse to provide the User with the Services related to resale of used clothes, footwear, headdresses, accessories under the commission agreement between Spin and the User because provision of such Services is impossible without processing of User’s personal data provided for in para.3.2 of the Policy.

1.4. When the User uses other Services offered via the Website, the User provides Spin with the User’s personal data provided for in para.3.1 of the Policy. Spin may also ask the User to fill out a special form provided by the Website in which the User describes the request for the Services and provides Spin with the information which the User considers sufficient for receiving the Services. After that the User a tick in the box next to the phrase “By putting a tick in the box, I agree with the processing of my personal data in accordance with the Privacy Policy of this website. My consent to processing of my personal data also includes the consent on cross-border transfer of my personal data in accordance with the rules established in the Privacy Policy”. If the User does not put a tick in the box, Spin is entitled to refuse provision of the Services if provision of the Services is impossible without processing of User’s personal data. If Spin comes to the conclusion that the information provided by the User in the special form is insufficient to provide the User with the Services, Spin may ask the User to provide additional information necessary for the provision of the Services. If the User refuses to provide additional information, Spin is entitled to refuse provision of the Services if provision of the Services is impossible without processing of such additional information.

1.5. The other provisions of the Policy provide for the additional ways of obtaining the consent to processing of personal data from the User depending on the type of personal data processed and the ways of data processing.

2. Creation of User’s Account

2.1. For the purposes of using some of the Services, the User is entitled to create an Account. The creation of the Account is not obligatory for the User and only facilitates provision of the Services. The full list of advantages provided to Users having Accounts is published on the Website.

2.2. In order to create the Account, the User shall provide Spin with the User’s personal data provided for in paras.3.1.1-3.1.4 of the Policy. The User shall also create the password that will protect the created Account and used by the User to access the Account. The password is considered User’s personal data for the purposes of this Policy.

2.3. The User may also create the Account by connecting the User’s account in a social network to the Account. In this case Spin processes User’s personal data provided for in para.3.4 of the Policy. The following social networks may be used by the User for creation of the Account:

2.3.1. VK (Vkontakte)

2.3.2. Gmail

2.3.3. Facebook

Before creating the Account in accordance with the procedure prescribed in this paragraph of the Policy, the User shall also provide Spin with the personal data provided for in para.3.1.4. of the Policy so that Spin could verify the age of the User and receive the consent to the processing of Juvenile User’s personal data from the Parent of the Juvenile User (see Section 10 of the Policy).

2.4. Before submitting the personal data provided for in para.2.2, the User shall agree with processing of User’s personal data provided for in paras.3.1.1-3.1.4 of the Policy in accordance with para.1.4 of the Policy.

2.5. By connecting the account of the User in the social network with the Account, the User provides Spin with the consent to processing of User’s personal data provided for in para.3.4 of the Policy.

2.6. After the User submits all the personal data necessary for the creation of the Account and provides Spin with consent to the processing of User’s personal data, Spin will send the letter to the User’s email confirming creation of the Account.

2.7. The User having the Account may voluntarily provide the Account with the following personal data:

2.7.1. Personal data provided for in para.3.1.5 of the Policy.

2.7.2. The User’s sizes of clothes and footwear.

2.7.3. The User’s favorite items chosen by the User by liking the items.

2.8. By providing the personal data listed in para.2.7 of the Policy, the User provides Spin with the consent to processing of such personal data for the purposes determined in para.4.1, para.4.4, para.4.5 of the Policy.

2.9. The User having the Account may also subscribe to the advertisements, newsletters, and other information provided by Spin for communication, marketing, and advertising purposes. In doing so, the User shall open the section “My subscriptions” in the Account and put ticks in the boxes next to the phrases which offer the User to receive useful information about Spin, including the information about promotions and events organized by Spin. By putting a tick in the box, the User provides Spin with the consent to processing of User’s personal data provided for in para.3.1 of the Policy.

2.10. The User may at any time delete the Account and ask Spin to stop processing User’s personal data or/and delete User’s personal data associated with the Account. In this case, Spin is entitled to refuse provision of the Services if provision of the Services is impossible without processing of User’s personal data.

3. Personal data that Spin is entitled to process

3.1. Under this Policy, Spin processes the following personal data of Users that is necessary for the provision of the Services:

3.1.1. First and family name of the User;

3.1.2. Telephone number of the User;

3.1.3. Email of the User;

3.1.4. Date of birth of the User;

3.1.5. Home address of the User, including the country of User’s residence, the User’s city, ZIP code, street and home number, and the number of the apartment (if applicable).

3.1.6. Payment information about the User, including the User’s bank card data, User’s Apple ID or Google ID (if payment is made via Apple Pay or Google Pay).

3.2. Spin processes the following personal data of Users related to resale of used clothes, footwear, headdresses, accessories under the commission agreement between Spin and the User:

3.2.1. Personal data provided for in para.3.1 of the Policy;

3.2.2. Consignment request text that includes a description of the item which the User intends to re-sell under the commission agreement between the User and Spin and a request to conclude a commission agreement with the User.

3.3. When the User browses and uses the functionality of the Website, Spin processes the following personal data of the User (irrespective of whether the User purchases items via the Website or files the consignment requests):

3.3.1. Information about the User’s activity on the Website collected by Google and Facebook pixel tags. The information collected by pixels tags includes the following:

- operating system used by the User;

- type of the Website used by the User (mobile or desktop);

- User’s screen resolution;

- time the Website was visited;

- activities on the Website during a session (pages visited, clicks made by the User, time spent on the specific web-page).

You can read more about pixel tags by following the link: https://en.ryte.com/wiki/Tracking_Pixel.

3.3.2. Information about the User’s activity on the Website collected by Yandex.Metrica. The information collected by Yandex.Metrica includes the following:

- the number of Users that visited the Website during the specified period;

- the number of new and unique Users of the Website;

- the statistics on the Website’s popularity (the growth of Users’ number, the time spent by Users on the Website, the web-pages visited by Users etc.).

You can read more about Yandex.Metrica by following the link: https://metrica.yandex.com/about/info/features.

3.3.3. Cookie files processed in accordance with Section 7 of the Policy.

3.4. Login information about the User’s account in a social network (which includes User’s email or phone number).

3.5. If the User has an Account, Spin may process the personal data provided for in para.2.7 of the Policy. Spin may also process the following information about the User having the Account:

3.5.1. The history of purchases made by the User via the Website.

3.5.2. The information about subscriptions of the User made by the User in accordance with para.2.9 of the Policy.

3.6. Spin does not collect any personal data about the User outside the Website. The only personal data that is processed by Spin is personal data provided by the User or automatically collected by the Website in accordance with para.3.3 of the Policy.

4. The purposes of personal data processing

4.1. Personal data of the User listed in para.3.1 and para.3.4 of the Policy is used for creating the Account and for providing the User with the Services offered via the Website, including the Services related to retail of clothes, footwear, headdresses, accessories.

4.2. Personal data of the User listed in para.3.2 of the Policy is used for providing the User with the Services related to resale of used clothes, footwear, headdresses, accessories under the commission agreement between Spin and the User.

4.3. Personal data of the User listed in para.3.3 of the Policy (except for the personal data provided for in para.3.3.3 of the Policy, see Section 7 of the Policy) is used for:

4.3.1. Statistical purposes;

4.3.2. Improving the User’s experience of the Website use;

4.3.3. Improving the work of the Website;

4.3.4. Changing the functionality of the Website in order to attract more Users of the Services;

4.3.5. Providing the User with all the functionality of the Website necessary for receiving the Services;

4.3.6. Saving information about the items that the User adds to the cart and intends to purchase or marks as User’s favorite.

4.4. Spin uses the personal data of the User listed in Section 3 of the Policy for communication and advertising purposes, including direct advertising (e-mail newsletters, bulk emailing). Communication purpose includes responding to User’s messages, reviews, and comments sent or left by Users via social networks or the Website.

4.5. Spin uses User’s personal data provided for in paras.3.1.1-3.1.3 and para.3.1.5 of the Policy for delivering the items purchased by the User on the Website and for the purpose of collecting used items from the User for the purpose of resale.

4.6. Spin uses User’s personal data provided for in para.3.5 of the Policy for the purposes provided for in para.4.1, para.4.4, para.4.5 of the Policy.

5. Controllers and processors of User’s personal data

5.1. In processing User’s personal data, Spin acts as the Controller of User’s personal data and defines the categories of personal data processed, the purposes of personal data processing, the list of Processors, the ways of processing and storing personal data, and the rules of cross-border transfer of personal data.

5.2. Spin involves Google and Facebook as Processors of User’s personal data that process the information about the User’s activity on the Website in accordance with para.3.3.2 of the Policy. The code of pixel tags provided by Google and Facebook is inserted into the Website’s HTML code. The code of pixel tags contains a link to the pixel tag’s server operated by Google or Facebook (depending on the type of the pixel tag). When the User visits the Website, the User’s browser follows the link of the pixel tag inserted into the HTML code of the Website and opens the pixel tag that is represented in a form of a tiny graphic with dimensions 1х1 pixels covered in the background of the Website. This fact is registered in the pixel tag server’s log files. After that the pixel tag collects the information about the User provided for in para.3.3.2 of the Policy.

5.3. Spin involves SendPulse as the Processor of Users’ personal data for marketing purposes. Spin provides SendPulse with Users’ personal data provided for in para.3.1.3 of the Policy. SendPulse uses the Users’ personal data provided for in para.3.1.3 of the Policy for bulk email organized by Spin. The text of the bulk email is prepared by Spin and includes information about discounts and sales of Spin or other promotions of Spin, including the information provided in accordance with para.2.9 of the Policy. SendPulse uses the personal data of Users in accordance with the privacy policy of SendPulse. Spin does not control the provisions of the privacy policy of SendPulse.

5.4. Spin involves OsmiCards as the Processor of Users’ personal data for the purpose of providing Users with electronic cards of Spin’s loyalty program that Users may add to their Apple or Google Wallets. In order to participate in Spin’s loyalty program, the User shall register on OsmiCards’ website and provide OsmiCards with personal data listed in the privacy policy of OsmiCards. The User shall also agree with processing of User’s personal data provided in accordance with the Policy and the privacy policy of OsmiCards. Spin does not control the provisions of the privacy policy of OsmiCards. Due to the technical circumstances, OsmiCards may be not available in the User’s jurisdiction. Spin will periodically review the list of the countries where OsmiCards is available to Users.

5.5. Spin involves post offices, shipping companies, and courier services as Processors of User’s personal data provided for in paras.3.1.1-3.1.3 and para.3.1.5 of the Policy for the purposes provided for in para.4.5 of the Policy.

5.6. Spin involves Facebook as Processor of User’s personal data for context and target advertising. However, Spin does not process any personal data of Users for such purpose. The list of personal data processed for context and target advertising, as well as the ways of such processing are exclusively determined by Facebook. Please read the privacy policies of Facebook in order to learn more about context and target advertising.

6.Processing of User’s payment information

6.1. There are several ways of processing Users’ payment information depending on the jurisdiction where the User resides. Spin involves various payment services that act as Processors of Users’ personal data and may process the information about bank cards or virtual wallets of Users, the information about the transactions of Users, and other payment information that relates to payments made by Users for the Services of Spin (see para.3.1.6 of the Policy). Among Processors involved in processing of User’s payment information are Cloud Payments (for CIS region), Stripe (for the USA and some other countries), Pay Pal. The payment services involved in the processing of User’s payment information process personal data in accordance with their own privacy policies.

6.2. Spin may also connect special payment services to the Website which allow Spin to directly process the payment information about the User provided for in para.3.1.6 of the Policy.

6.3. The information about the payment service used in the User’s country is available on the Website during the payment for the purchased items.

7.Processing of cookies

7.1. Cookies or cookie files are small text files located in browser directories. They are used by Spin to help Users navigate through the Website and Services efficiently and perform certain functions of the Website. You can learn more about cookies by following the link: https://en.wikipedia.org/wiki/HTTP_cookie.

7.2. In order to provide Users with the Services, Spin may process cookies files through the Website that provide Spin with the following information about the User:

7.2.1. IP address of the User;

7.2.2. Gender of the User which is determined in accordance with the gender chosen by the User on the Website;

7.2.3. The language of the Website chosen by the User;

7.2.4. The currency chosen by the User for purchasing items through the Website;

7.2.5. The composition of the User’s cart and the list of favorite items of the User;

7.2.6. Hash-files which encrypt the login information of the User’s Account;

7.2.7. The unique ID of the User used by Facebook, Google Analytics, and Yandex.Metrica for processing the personal information provided for in paras.3.3.1-3.3.2 of the Policy.

7.3. Spin starts to process cookie files when the User opens the Website and provides Spin with the consent to processing of User’s personal data in accordance with para.1.1 of the Policy.

7.4. Cookies are processed by Spin exclusively for the purposes provided for in para.4.1, para.4.3, para.4.4 of the Policy.

8. Spin and social networks

8.1. In order to promote information about Spin, its Services, and the Website, Spin created the accounts in social networks, including Facebook, and VK (Vkontakte). Besides, Spin has a channel and accounts in messenger Telegram.

8.2. In order to interact with Spin, Users may follow the accounts of Spin in social networks and join the channel of Spin in Telegram.

8.3. Users may like posts and comments of Spin and leave comments and reviews under the posts of Spin in social networks.

8.4. Users may also send messages and reviews to accounts of Spin in social networks or in messenger Telegram. The information about accounts of Spin in messenger Telegram is provided in the channel of Spin in Telegram.

8.5. Spin may process likes, comments, messages, and reviews of Users sent via social networks or messenger Telegram for the purposes provided for in paras.4.3.1-4.3.3 and para.4.4 of the Policy.

8.6. Spin may also process the profile information of the User published by the User in a social network or the messenger “Telegram” for the purposes provided for in para.8.5 of the Policy. 9. Feedback and reviews

9.1. Users may send a message or request to Spin by filling out the form provided on the Website in section “Contacts”.

9.2. In order to write a message to Spin, the User shall provide Spin with the personal data provided for in paras.3.1.1-3.1.3 of the Policy so that Spin could respond to the message.

9.3. Before submitting the message, the User shall agree with the processing of User’s personal data provided for in paras.3.1.1-3.1.3 of the Policy in accordance with para.1.4 of the Policy.

9.4. Spin may process the messages of Users sent in accordance with para.9.1 of the Policy for the purposes listed in para.4.1, para.4.3, para.4.4 of the Policy.

Processing of Minor’s and Juvenile User’s personal data

10.1. The Website of Spin is not directed to Minors. This is confirmed by the fact that Spin sells clothes, footwear, headdresses, accessories of famous brands, and the price of such items can amount to thousands of US dollars. Furthermore, Spin does not conclude commission agreements on resale of used clothes, footwear, headdresses, accessories with Users who are less than 18 (eighteen) years of age.

10.2. Spin does not process and does not have actual knowledge that Spin is processing personal data of Minors. If Spin finds out that some data from or about a Minor was collected, Spin will immediately delete such data.

10.3. Spin does not process personal data of Juvenile Users without the consent to processing provided by the Parent of the Juvenile User.

10.4. When the User agrees to processing of personal provided for in para.3.3 of the Policy in accordance with the procedure prescribed in para.1.1 of the Policy, the User shall also confirm that he is at least 16 (sixteen) years of age. If the User is younger than 16 (sixteen) years of age, the User shall not press the button “I agree” under para.1.1 of the Policy.

10.5. When the User provides Spin with the personal data prescribed in paras.3.1, 3.2, or 3.4 of the Policy, the Website will verify the age of the User in accordance with the personal data provided under para.3.1.4 of the Policy. If the personal data provided reveals that the User is a Minor, Spin will refuse provision of the Services and immediately delete all the information about the Minor that has already been provided. If the personal data provided reveals that the User is a Juvenile User, Spin will ask the Juvenile User to provide the telephone number or the email of the Juvenile User’s Parent that shall be different from the telephone number or the email of the Juvenile User. Spin will send a code to the telephone number or email of the Parent that the Parent shall type in on the Website or the special URL which the Parent shall click and follow. By typing in the code or clicking the special URL the Parent provides Spin with the consent to processing of Juvenile User’s personal data provided for in paras.3.1, 3.2, 3.4, and 3.5 of the Policy.

11. User’s data subject rights

11.1. Each User of Spin is provided with the following rights guaranteed by the US and the EU legislation:

11.1.1. The right of access: the User is entitled to receive from Spin the information about personal data that is processed by Spin, the purposes of personal data processing, the categories of personal data recipients, the period of personal data storage, and about the transfer of personal data to other jurisdictions.

11.1.2. Right to lodge a complaint with a supervisory authority: the User is entitled to file a complaint against Spin with a state authority of User’s country or with a state authority of Spin’s residence which supervises the compliance with personal data legislation.

11.1.3. Right to rectification: the User is entitled to rectification of inaccurate data about the User.

11.1.4. Right to erasure: the User is entitled to erasure the personal data about the User.

11.1.5. Right to restriction of processing: the User from the EU is entitled to restrict processing of personal data under the grounds provided for in Art.18 GDPR.

11.1.6. Right to data portability: the User is entitled to receive personal data about the User in a structured, commonly used and machine-readable format and transmit such data to another controller.

11.1.7. Right to object: the User is entitled to object to personal data processing on grounds relating to particular situation (for example, if Spin processes personal data for marketing purposes).

11.1.8. Right not to be subject to a decision based solely on automated processing, including profiling.

11.1.9. Right to file a request or complaint with Spin acting as the Controller of User’s personal data.

11.1.10. Right to withdraw User’s consent to personal data processing.

11.1.11. Right to prohibit sale or resale of User’s personal data.

11.2. If the User is intending to use one of the rights provided for in para.11.1 of the Policy, the User shall send a mail or an email to Spin by using Spin’s contact details provided for in Section 17 of the Policy. The User may also exercise the rights provided for in para.11.1.4 and para.11.1.10 of the Policy by filling out the special form provided on the Website.

11.3. If the User requests Spin to erasure User’s personal data, objects to processing of User’s personal data, or withdraws consent to personal data processing, Spin is entitled to refuse provision of the Services if provision of the Services is impossible without processing of User’s personal data.

12. Protection of User’s personal data against unauthorized access

12.1. Spin takes all the reasonable measures to protect User’s personal data from unauthorized access by third parties, including the following:

12.1.1. The User’s session goes through the secure SSL connection during the Website browsing.

12.1.2. The User’s personal data stored on Spin’s servers is protected by authentication (login, password, port).

12.1.3. The User Account’s password is stored in an encrypted way.

12.2. Spin’s employees and other natural persons involved in the processing of User’s personal data are duly instructed and follow the internal regulations of Spin providing for the secure use of User’s personal data.

12.3. All Processors processing User’s personal data are acting on the basis of the contract concluded with the Controller which complies with applicable personal data legislation. Spin carefully chooses Processors of User’s personal data which privacy policies and security measures provide for the safe processing of personal data.

13.User’s personal data and Third parties

13.1. Spin has never shared and has no intention to share User’s personal data with Third parties or other persons or legal entities that are not Processors of User’s personal data.

13.2. Spin does not sell and will never sell User’s personal data to Third parties. No personal data of Users has been sold within the last 12 (twelve) months. In accordance with Section 1798.130(a)(5) CCPA, Spin will update the information on the issue provided for in this paragraph of the Policy every 12 (twelve) months.

13.3. Within the last 12 (twelve) months, Spin has processed only personal data provided for in the Policy and only for the purposes provided for in Section 4 of the Policy.

13.4. Despite the provisions of para.13.1 and para.13.2 of the Policy, the User has the right to prohibit sale or resale of User’s personal data in accordance with para.11.1.11 and para.11.2 of the Policy. The mail or email of the User who wants to prohibit sale or resale of personal data shall contain the title (if the request is sent by mail) or the subject matter (if the request is sent by email) “DO NOT SELL OR RESELL MY PERSONAL DATA!”.

14.Storage of User’s personal data

14.1. Spin stores personal data of the User as long as the User uses the Website and the Services offered via the Website.

14.2. After the Uses stops using the Services of Spin (e.g., deletes the Account), Spin stores personal data of the User as long as such personal data is necessary for reaching the purposes provided for in paras.4.3.1-4.3.4 of the Policy.

14.3. The User may at any time request Spin to delete personal data of the User in accordance with para.11.1.4 of the Policy. If provision of the Services is impossible without processing of User’s personal data, Spin is entitled to refuse provision of the Services after deleting User’s personal data.

15.International transfer of User’s personal data

15.1. The general rule is that the User’s personal data is stored in the jurisdiction where the User resides. For example, if the User resides in the US, his personal data is stored in the US, and if the User resides in the EU, his personal data is stored in the EU. Spin takes all the reasonable measures to comply with this rule.

15.2. Due to technical reasons, it may be the case that Spin may transfer User’s personal data to the server which is located in the jurisdiction different from the jurisdiction of User’s residence. Particularly, some of Users’ personal data may be stored in the USA or in the Russian Federation even if the User does not reside in these countries. By providing Spin with the consent to processing of User’s personal data in accordance with Section 1 of the Policy, the User explicitly agrees to international transfer of User’s personal data to third countries that are not countries of User’s residence, including Russia and the USA.

15.3. While Spin and Spin’s Processors take all the reasonable measures for the protection of User’s personal data against unauthorized access, Spin shall inform the User about the possible risks of storing User’s personal data outside the European Union in accordance with Art.49(1)(a) GDPR. Such possible risks include:

15.3.1. Efforts of hacking attacks. Spin and Spin’s Processors take all the reasonable measures to prevent such attacks.

15.3.2. Existence of personal data rules and regulations that are different from GDPR. Spin and Spin’s Processors provide Users with all the rights and guarantees provided for in GDPR.

15.3.3. Restriction of Processor’s business activity in a third country by the state body of such third country. Processors of Spin take all the necessary measures to secure User’s personal data and safely transfer User’s personal data to a server in another country in case of such situations.

16.Enactment and updating of the Policy

16.1. This Policy is enacted and enters into force on July 22, 2021.

16.2. Spin reserves the right to amend the Policy at any time and provide the Policy with any changes that Spin considers appropriate. The amended version of the Policy enters into force since its publication on the Website. By continuing to use the Website and the Services, the User agrees with the processing of User’s personal data in accordance with the amended version of the Policy.

16.3. If necessary, Spin may organize bulk email informing the Users about the amendments in the Policy. However, it is the User’s responsibility to check the Website of Spin for the amendments of the Policy.

17.Contacting Spin

The User may contact Spin, including for the purposes of exercising the rights provided in Section 11 of the Policy, by using the following contact details of Spin:

SPIN4SPIN Inc.

File number: 5256688

Registered address: 8 THE GREEN, STE A, Dover, Kent, DE 19901, the United States

Email: office@spin4spin.com

Telegram: @spinoffice

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