We urge you to read this Policy thoroughly. By accessing our website/mobile app and using our Services, you will have represented your agreement to this policy and bound by its terms. Kindly note, this policy does not apply to third-party websites, products, or services even if they link to our Services, and y ou should consider the privacy practices of those third-parties carefully.
i) Our Site – www.spintly.com ,
ii) Our SMART ACCESS APP,
iii) SPINTLY DEVICE
iv) Customer interface channels
v) Social networking sites, and
vi) Electronic communications,
All of the above are collectively referred to as “ Services ”.
2) Information we collect
a) We may collect and retain the following information (Personal Data) from and about you if you interact with us through the Site:
i) your phone numbers;
ii) your email id and password (stored in encrypted form on cloud) which you have entered in the SMART ACCESS APP;
iii) your location, website browsing patterns (e.g., through cookies) and purchase history;
iv) Other information you actively submit to us or we can determine about you based on your interactions with our Site and Services.
b) We may also collect information that your browser sends whenever you visit our Website or use our Service which may include information such as browser type, browser version, your computer’s Internet Protocol (IP) address, internet service provider, date/time stamp, URLs of referring/exit pages, operating system, the information you search for, local and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information, the time spent on those pages usage information, and other statistics.
3) How you can choose how we should use your Personal Data
a) We get access to abovementioned information when you:
● Access the website or the SMART ACCESS APP;
● Register, subscribe, or create an account with SMART ACCESS APP;
● Open or respond to our emails;
● Contact customer service or use other customer support tools;
● Visit any page online that displays our ads or content;
● Connect or link to any Site via social networking sites;
● Post comments to online communities; and
● Provide information to our vendors.
b) As a SPINTLY user, you have the power to control how you can limit how we use the Personal Data that we collect:
i) You can manage the types of personal data you provide to us and can limit how we communicate with you.
ii) You can manage your email and notice preferences by adjusting the settings in your web browser.
iii) You can also manage your subscriptions by following subscription management instructions contained in any commercial emails that we send you.
c) Please note that even if you decide not to subscribe to, or to unsubscribe, from promotional email messages, we may still need to contact you with important transactional information related to your account with Smart Access APP and your purchases/access of SPINTLY Device.
d) You hereby consent to receive communications by SMS or calls from MRINQ TECHNOLOGIES LLP with regard to the services provided by it.
e) You may manage how your web browser or mobile device handles cookies by adjusting its privacy and security settings. Please refer to Paragraph 10 of this Policy for information of Cookies for more information.
f) You may also manage the sharing of certain personal data with us when you connect with us through social networking platforms or applications. You may adjust our permissions and manage the interactivity between us and your social networking account or your mobile device.
4) How we use your Personal Data
We process and use your Personal Data for the following purposes enumerated below. The list is not an exhaustive one. We use the information for a many other of purposes including the following:
a) To personalise your account with SMART ACCESS APP;
b) To provide you with personalized direct marketing initiatives via email and direct marketing offers;
c) Facilitate and process orders – for example, for vouchers and other goods and services;
d) Determine your eligibility for certain types of offers, products or services that may be of interest to you, and analyse advertising effectiveness;
e) Answer your questions and respond to your requests;
f) Communicate and provide additional information that may be of interest to you about us, the sellers and our business partners;
g) Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of business partners;
h) Manage our everyday business needs, such as administration of the Site, analytics, fraud prevention, and enforcement of our corporate reporting obligations or to comply with the law;
i) Comply with our legal obligations, resolve disputes, and enforce our agreements;
j) Enhance other information we have about you to help us better understand you, determine your interests and provide you with more relevant and compelling services.
k) To maintain, operate and improve the site;
5) How we disclose your Personal Data
We are not in the business of selling or renting Personal Data. We will not share your Personal Data with third parties, except in the following manner:
a) with the Owners, so they can enable access;
b) in case of a merger, acquisition or reorganization with a purchaser of our company or all or substantially all of our assets;
c) to comply with legal orders and government requests, or as needed to support auditing, compliance;
d) to combat fraud or criminal activity, and to protect our rights or those of our affiliates, business partners and users, or as part of legal proceedings affecting MRINQ ;
e) in response to a legal process, including to law enforcement agencies, regulators, and courts; or
f) With your consent or as otherwise required or permitted by law.
6) Security of Personal Data
a) We use strict security measures to ensure the security, integrity and privacy of Your Personal Data and to protect your Personal Data against unauthorized access or unauthorized alteration, disclosure or destruction.
b) We shall, however, not be responsible for any breach of security or for any actions of any third parties that receive your Personal Data.
7) User’s Rights in relation to Personal Data
a) By keeping your personal data updated you can help us to ensure that we can respect your preferences and offer you the goods and services that are most relevant to you.
b) You have a right to have your Personal Data maintained by us removed from our systems or returned. You can also at any time unsubscribe from our services, newsletters, e-mailers. Provided that, notwithstanding such request, this data may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain your Personal Data maintain a record of your transactions for financial reporting or other compliance purposes.
8) Social Site Features
9) Privacy Policies of Third Parties
a) Cookies are unique identifiers, usually made up of small bits of text or code. Cookies are usually stored on your device or in your web browser and they send certain information back to the party who served the cookie. When we say cookies we are actually referring to a broader range of technologies than just cookies, including web beacons, clear gifs, pixels and other similar technologies. When we say first-party cookies we mean cookies that are served by spintly.com. When we say third party cookies we mean cookies that are served by non-spintly.com parties.
e) Cookies in E-mails: Our emails contain cookies that track whether you open our emails and whether you click any links within them. The cookies used in our emails to monitor these behaviours are unique to each email and are not stored on your computer or mobile device.
f) Cookies and Browser settings: You may be able to avoid certain cookies by configuring your browser settings or opting-out directly with the party that operates and controls the cookie. Please check your browser settings for more information. Kindly note that in case you opt to decline cookies and flush out the cookies from your computer, it will reduce the functionality of our Service.
11) Personal Data of Children
We do not knowingly collect Personal Data from children under 18. If you are a child under the age of 18, do not submit any Personal Data to us. If you are a parent or guardian, we encourage you to instruct your children not to disclose any Personal Data without your consent.
12) Contact Us