Your privacy is important to us at Spin Digital Media, LLC (“SPIN” or “We”, or “Us,” or “Our”). This Privacy Policy (the “Privacy Policy”) governs the use of your Personal Information (as defined below) in connection with any websites or mobile websites owned or operated by Us, including, without limitation, the websites currently located at www.spin.com (the “Website”), and any other interactive features, widgets, or resources offered by Us and/or our affiliates, distributors or licensees through traditional Internet websites, mobile devices or other platforms, and all other content included within the Website (collectively, the “Services”). This Privacy Policy explains what information we collect about you on our Website, how we use or share such information, how to exercise any rights you may have with respect to your personal information, and the safeguards we have in place to reduce the risk of unauthorized access and use. Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Website, including, without limitation, www.spin.com, and any related SPIN webpages or mobile sites. If you do not agree with our Terms of Use and/or the Privacy Policy, please refrain from using our Website. By accessing or using our Website you agree to Our use of your information consistent with the Terms of Use and this Privacy Policy.

 Contents

• Contact Information
• Scope of this Privacy Policy
• Information We Collect and How We Use It
• Cookies and Online Tracking Technologies
• How We Use the Information We Collect
• Sharing Your Information
• Retention of Personal Information
• Preference Management
• Your Legal Right
• Your California Privacy Rights
• Information Security
• Transfer of Information to the United States
• Children’s Privacy
• Links to Other Materials
• Changes to Our Privacy Policy

 

Contact Information

Should you have any questions about our Website or this Privacy Policy, please contact us contact@spin.com. For EU consumers, if you believe that your Personal Information has been processed in a way that does not comply with the EU General Data Protection Regulation, you have the right to lodge a complaint with the relevant supervisory authority. The supervisory authority will be the point of contact with respect to the progress and outcome of your complaint.

Scope of this Privacy Policy

This policy applies to information we collect:

• On our Website (www.spin.com) and related SPIN webpages.
• Via email, text and other electronic messages between you and the Website.

 

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by any third party (including, if applicable, our affiliates and subsidiaries).
• Any third party (including, if applicable, our affiliates and subsidiaries), through any application or content (including advertising) that may link to or be accessible from or on the Website.

 

Information We Collect and How We Use It Personal Information

We collect information that you choose to provide us or that you choose to include in your profile or account, and that personally identifies you such as your name, address, zip code, telephone number, e-mail address, and other personally identifiable information (“Personal Information”). You may be asked to provide us with Personal Information when you register with the Website and at other times to enable us to provide the Website and Services to you and to manage our relationship with you including payment processing, troubleshooting and maintenance. As authorized by you (opt-in consent) or permitted by law, your Personal Information may also be used by us to market (directly or indirectly by third parties) products and services that may be of interest to you. The decision to provide this information is optional. However, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Website or Services. The lawful bases for processing your Personal Information in this manner include SPIN’s legitimate interest, compliance with legal obligations, and the performance of any contractual relationship requested by you.

Usage Data and Site Activity

We automatically collect and analyze information in connection with the actions you take on the Website and in connection with using the Services (“Usage Data”) to improve the Website, Services and User experience. This data includes, but is not limited to, the type of browser you are using, the type of operating system you are using, your IP address, aggregate data about the number of visits to the Website, and aggregate data about the pages visited. This anonymous usage information may be associated with your username and profile, but we do not disclose this information to third parties. The lawful bases for processing your Personal Information in this manner include SPIN’s legitimate interest, compliance with legal obligations, and the performance of a contractual relationship with you.

Cookies and Online Tracking Technologies 

SPIN may use cookies (a small text file placed on your computer to identify your computer and browser) and other third party tracking technologies such as web beacons (an electronic file placed on a website that monitors usage), to collect general and personally identifiable information about visitors to the Website. The information collected is used to improve the experience of the Website and Services, such as allowing us to recognize you when you revisit the Website to provide you with customized information and/or to remember your preferences. We use cookies and other third party tracking technologies such as web beacons to collect Personal Information. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Website or Services may not work if you delete or disable cookies.

Advertising 

Notwithstanding any other provision, we partner with third parties (Third Party Providers and Advertisers, collectively known as “Advertisers” as such terms are defined below) that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you. Our partners may place or recognize a cookie on your computer, device or directly in our emails / communications, and we may share personal information with them, as permitted by law and in accordance with this Privacy Policy. Our partners may link the personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Our partners use this information to recognize you across different channels and platforms over time for advertising, analytics, attribution, and reporting purposes. For example, our partners may deliver an ad to you in your web browser based on a purchase you made in a physical retail store, or they may send a personalized marketing email to you based on the fact that you visited a particular website. To learn more about interest-based advertising in general and to opt out, please visit http://www.aboutads.info/choices. Our Privacy Policy does not cover any use of information that an ad network may collect from you. Advertisements may be shown via the Site, the Services or on third-party websites. You can visit the Network Advertising Initiative website at www.networkadvertising.org, which offers information about Internet advertising companies and how to opt out of their information collection.

Employment

We, or our third-party vendor, collect information you submit as part of a job application. This may include your work experience and previous employment, your education history, your resume, the URL to your personal or professional websites, and, whether you need a visa to work in the United States. If you apply for a job, you can choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status.

Do Not Track Disclosure 

Additionally, although some Internet browsers have a ‘do not track’ feature that lets you tell websites that you do not want to have your online activities tracked, we are currently not set up to respond to such signals.

Sharing Your Information

SPIN does not sell, trade, or disclose your Personal Information to third parties except as set forth in this Privacy Policy and as follows:

• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• To SPIN corporate affiliated entities.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, change in control, or other sale, transfer, or other action with respect to of some or all of SPIN assets, whether as a going concern or as part of bankruptcy, dissolution, liquidation or similar proceeding, in which Personal Information held by SPIN about the Website users is among the assets affected.
• If we were previously authorized or are otherwise permitted by law to share your Personal Information with our affiliates and Advertising Partners to provide you with information that may be relevant to you, including for their own marketing purposes.
• To fulfill the purpose for which you provide it.
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our  Terms of Use  and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SPIN, our customers, or others.
• For any other purpose disclosed by us when you provide the information.
• We may disclose aggregated, non-personally identifiable information about the Website users without restriction.

 

Retention of Personal Information We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax and/or accounting obligations. We do so in accordance with our data retention policies and applicable law.

Preference Management  Third Party/Affiliate Sharing

Send an email to contact@spin.com at any time and ask to be removed.

E-Mail Marketing

Send an email to contact@spin.com at any time and ask to be removed.  We may continue to send you certain transactional email communications (e.g. emails regarding account notifications, customer support questions and similar information) regarding your use of the Site and Services.

Your Legal Rights

• You have the right to:
• Request a copy of the Personal Information we hold about you;
• Request that inaccurate information about you be corrected or deleted;
• Object to having your Personal Information processed;
• Request that we delete any and all Personal Information we hold about you;
• Request that we restrict processing your Personal Information;
• Request that you not be subject to automated decision making including profiling; or
• Receive your Personal Information in a structured, prevailing, and machine-readable form and/or have your Personal Information transferred to another controller, where technically feasible.To exercise these rights or for any other questions related to this Privacy Policy, you may contact us by emailing gdpr@spin.com.

 

SPIN email subscribers and subscribers of paid content may access and correct their contact information on file by accessing their account online. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

Under California law, a California resident with whom SPIN has an established relationship has the right to request certain information with respect to any Personal Information SPIN may have shared with third parties for their direct marketing purposes. Alternatively, SPIN may provide a cost-free means to opt out of such sharing.

SPIN has opted to provide you with a cost-free means to opt out of such sharing. If you do not want SPIN to disclose your Personal Information to other companies for their marketing purposes, please see the Preference Management section within this Privacy Policy.

Information Security

SPIN has implemented certain procedural, technical and physical security measures to help protect against the risk of loss, misuse, and alteration of sensitive information that you provide. We require third parties with whom we share Personal Information to do the same. Nevertheless, such security measures may not prevent all loss, misuse, or alteration of information on the Site, and SPIN is not responsible for any damages or liabilities relating to any such security failures. By using the Site, you understand that there is a risk that data and communications, including email and other electronic communications, may be accessed by unauthorized third parties. The foregoing does not affect any liability that cannot be excluded or limited under applicable law.

Transfer of Information to the United States

The Site is operated in the United States. If you are located outside the United States, please be aware that information we collect, including Personal Information, may be transferred to, processed, and stored in the United States. By using the Site or providing us with any information, you consent to the transfer, processing, and storage of your information in the United States. You are also consenting to the application of United States federal and relevant state law in all matters concerning the Site and this Privacy Policy.

Children’s Privacy 

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at contact@spin.com.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information. If you are under the age of 18 and have subscribed to any of the paid content available on our site, you must have your parent’s permission and we will assume you have done so. We do not otherwise knowingly collect Personal Information from anyone under the age of 18. By using the Website, you represent and warrant that you are at least 18 years old. If we become aware that a customer is under the age of 18 and has registered or otherwise provided Personal Information, we will cancel the corresponding registration and delete such information from our records.

Links to Other Materials

Website may be linked to and from our Website that are not under the control of SPIN. SPIN shall have no responsibility or liability for the content or privacy practices of any such linked Website or any link or linking program at any time. If you click on a link on our Website and link to a third party’s website, then this Privacy Policy will not apply to your Personal Information collected on that third party’s website and you must read the privacy policy on that website to see how your information will be handled. Social media widgets or tools may appear on our Website. Your use of these widgets or tools will be governed by the terms of use and privacy policy of the applicable social media provider (e.g. Facebook®).

Changes to Our Privacy Policy

We may update this Privacy Policy to reflect changes in our privacy practices. If we make changes to this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the Revision Date shown in the revised Privacy Policy. Your continued use of our Site or Services constitutes your consent to the revised Privacy Policy.

When you use our website, we share information that we collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our identity partners/service providers, including LiveRamp Inc. LiveRamp returns an online identification code that we may store in our first-party cookie for our use in online and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. To opt out of this use, please click here.

Update History

November 2020: updated Privacy Policy published.