This Privacy Policy (effective from 29th November 2018 i.e. “Effective Date”) describes our practices regarding use, maintenance, and disclosure of Personal Information that we collect through SPINTLY and the SMART ACCESS APP. You can be assured that any Personal Information that you disclose to us will be treated only in the manner described in this policy.

Whenever this Policy mentions “ MRINQ ” or “we” or “us” or “our”, it refers to the MRINQ TECHNOLOGIES LLP which is responsible for your information under this Privacy Policy. SMART ACCESS APP and all other features, tools, services and content provided by MRINQ TECHNOLOGIES LLP in connection with the SPINTLY DEVICE.

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.

By using the Site, you agree to the terms of this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not provide us with your personal information or interact with the Site/app.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our TERMS OF SERVICE FOR OWNERS AND AUTHORISED USERS.

1) Scope of the Privacy Policy

a) This Privacy Policy applies to information that we collect through

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 ”.

b) Our privacy and security practices in connection with the access and use of our Services are governed by the TERMS OF USE FOR OWNERS AND AUTHORISED USERS, which are binding contracts between the OWNER or AUTHORISED USER (respectively, collectively referred to as “You”) and us.

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.

c) When the App crashes, we use Crashlytics to collect information related to the state of the App when it crashed. To identify each phone, we use the advertising ID. The privacy policy related to Crashlytics is given at the below location.

https://www.gstatic.com/policies/privacy/pdf/20190122/f3294e95/google_privacy_policy_en.pdf

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

The Site may contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and otherwise submit your own original content. Prior to posting in these areas, please read our TERMS OF USE FOR OWNERS AND AUTHORISED USERS carefully. All the information you post may be accessible to anyone with Internet access, and any information you include in your posting may be read, collected, and used by others.

9) Privacy Policies of Third Parties

a) We employ third parties to perform certain tasks to facilitate our Services and to assist us in analyzing its usage. We may transfer certain Personal Data to these third parties, but this transfer will be subject to your explicit consent and the TERMS OF USE FOR OWNERS AND AUTHORISED USERS. These third parties have access to your Personal Data albeit only to perform specific tasks on our behalf and are contractually and otherwise obligated not to disclose or use your information for any other purpose.

b) This Privacy Policy only addresses the collection, processing and use (including disclosure) of information by us through your interaction with the Site. Other websites that may be accessible through links from the Site may have their own privacy policies and personal information collection, processing, use, and disclosure practices. Our business partners may also have their own privacy policies. We encourage you to familiarize yourself with the privacy policies provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.

10) Cookies

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.

b) We use cookies to ensure that you have the best possible experience while using our Service. Cookies are used in order to better understand how applications and websites work and to optimize online and mobile experiences. Cookies do this by allowing the party serving the cookie to analyse a website’s or mobile app’s performance, to identify certain users anonymously and remember their preferences, to better understand whether a computer or device (and probably its user) has visited a website previously and to serve personalised advertisements.

c) Consent : By using our website or SMART ACCESS APP, using any services provided through the Site, or receiving our emails, you consent to the use of cookies in accordance with this clause as “Cookies Policy”.

d) Intent : This Privacy Policy sets out how we, and third parties we authorize, use cookies when you interact with our Site or the services offered via the Site. Our Privacy Policy explains what we do (and don't do) with the information, including any personal data we may collect about you. Please read them both.

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

If you have questions regarding this Privacy Policy or about our privacy practices, please contact us by email at info@spintly.com

13) Modifications in Privacy Policy

We will routinely update this Privacy Policy to improve our practices and to reflect new or different privacy practices, such as when we add new services, functionality or features. You can determine when this version of the Privacy Policy was adopted by referring to the “Effective Date” above.