This End User License Agreement (the “Agreement”) for the SpinDeals (together with any updates, the “Application”) is a legal agreement between user (“You” or “Your”), and SpinDeals App. By accessing, downloading, copying, or otherwise using the Application, You acknowledge that you have read this Agreement, understand it, and agree to be bound by its terms and conditions. If you do not agree to the terms and conditions of this Agreement, do not access, download, copy or use the Application. SpinDeals App will not and does not grant you access to the Application unless You agree to the terms of this Agreement

We know that in this digital age, your privacy is important. This Privacy Policy reflects our commitment to protect personal data and the choices we offer you regarding how your data is used. We welcome you to read more about how we keep your information safe, as well as how you can exercise your rights. In addition, our Privacy policy covers our treatment of data that may be personal to you.

• ‍We will review, update, and amend these policies from time to time consistent with our business needs and technology. We encourage you to check back periodically for new updates or changes. Your continued use of the service makes up your acceptance of any change to this Privacy Policy. We are the data controller of your information. We handle and process all data on behalf of our customers
• You may likewise decide not to give us “discretionary” Personal Data; however please remember that without it, we will most likely be unable to provide you with the full scope of our administrations or with the best client experience when utilizing our Services.
• This Privacy Policy (“Privacy Policy”) describes how SpinDeals App. will gather, use, and maintain your Personal Information on the spindealsapp.com. It will also explain your legal rights with respect to that information.
• By using the SpinDeals App website and mobile application or services, you confirm that you have read and understand this Privacy Policy, and our Terms (together referred to herein as the “Agreement”). The Agreement governs the use of spindealsapp.com. SpinDeals App will collect, use, and maintain information consistent with the Agreement.
• The app does use third party services that may collect information used to identify you.
• Link to privacy policy of third-party service providers used by the app.
  Apple Store.

We recommend that you read this Policy in full to ensure you are fully informed.

 

What private data do we collect from the people who visit our website and mobile application?

When enlisting on our site or buying Services, as suitable, you could be approached to type in your name, email, postage information, payment information, or different subtleties to assist you with your experience.

When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:

• Account Data: To use certain features (like Paid or unpaid Services), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, and date of birth, and assign you a unique identifying number (“Account Data”).
• Personal Data: Personal Data is information that can be used to identify you specifically, including your name, username, or demographic information like your age, gender, or hometown. You consent to give us this information by providing it to us voluntarily on our website or any mobile application. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website and mobile application.
• Profile Data: You can also choose to provide profile information like a photo, social media profiles, or other data. Your Profile Data will be publicly viewable by others.
• Financial Data: Financial data is related to your payment methods, such as credit card or bank transfer details. We collect financial data to allow you to purchase, or services from our website and any related mobile apps. We store limited financial data. Most financial data is transferred to our payment processor, Stripe and Google Pay, and you should review these processors’ Privacy Policy to determine how they use, disclose, and protect your financial data. 
  • Stripe Privacy Policy can be found here https://stripe.com/gb/privacy
• Contact information. An Authorized User is required to provide some contact information (e.g., an email address) when making an account on the Services.

Data About Your Accounts on Other Services: 

• We may obtain certain information through your social media or other online accounts if they are connected to your Spindealsapp.com account. If you login to via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service, we may collect your name, profile picture, account ID number, login email address, location, the physical location of your access devices, gender, birthday, and list of friends or contacts.
• Social Networking Data: We may access personal information from social networking sites, and apps, including Facebook, and Google, which may include your name, your social network username, location, email address, age, gender, profile picture, and any other public information. If you do not want us to access this information, please go to the specific social networking site and change your privacy settings.
• Mobile Device Data: If you use our website via a mobile device or app, we may collect information about your mobile device, including device ID, model and manufacturer, and location information.
• Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.

Data About Your Accounts on Other Services: 

• We may obtain certain information through your social media or other online accounts if they are connected to your SpinDeals App account. If you login to via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service, we may collect your name, profile picture, account ID number, login email address, location, the physical location of your access devices, gender, birthday, and list of friends or contacts.
• Social Networking Data: We may access personal information from social networking sites, and apps, including Facebook and Google, which may include your name, your social network username, location, email address, age, gender, profile picture, and any other public information. If you do not want us to access this information, please go to the specific social networking site and change your privacy settings.
• Mobile Device Data: If you use our website via a mobile device or app, we may collect information about your mobile device, including device ID, model and manufacturer, and location information.
• Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
• If you access or use our Services or to buy services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.

When do we acquire information?

We get data from you when you get enlisted on our site, respond to an audit, give us reactions on our App or enter information on our App. Below are the examples:

• To register on our website and mobile application to get updated about services or to find a deal.
• To create your account on the App (e.g., your name and email address)
• To process your orders via our online services (e.g., your name, email, and payment details) 
• To deal with our relationship with you, including notifying you about changes to our terms or security arrangement. Requesting that you leave an auditor to take an overview. 
• To manage and ensure our business and this site (counting investigating, information examination, testing, framework upkeep, backing, announcing, and facilitating information).
• To send you our email newsletter and other automated email correspondences. 
• To make proposals and suggestions to you about App or administrations that might hold any importance with you.

Automatically collected information about your use of our Services or tools,

This information is registered automatically with the visit by own configuration or manual of each tool on the website and mobile application

• When you visit, connect with, or utilize our service, we may gather, record, or create specific specialized data about you. We do so either autonomously or with the assistance of third gathering Service Providers, including using “cookies” and other following innovations. 

 

• Such data comprises of availability, specialized and collected utilization data, for example, IP locations and general areas, gadget data (like sort, working framework, cell phone id, program form, region and language settings, Browser Information, Geographic location, Time of Visit, Referring site, applications or service, search engine utilized), date and time stamps of use, the and pixels introduced or used on such gadget and the recorded movement (meetings, clicks and further cooperation’s) of Visitors and Users regarding our Service. for purposes including examination, service-, tasks, and business quality control and enhancements, and record-keeping purposes.

This is to improve the website and mobile application, services, and security, among which we include security inspection by the administration of the website and mobile application and third parties.

How do we handle social signals? 

In Short: Yes, if you choose to register or log in to our website and mobile application using a social media account, we may access certain information about you. 

Our Sites offers you the ability to register and log in using your third-party social media account details (like your Facebook or Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture, as well as other information you choose to make public. 

We will use the information we receive only for the purposes described in this privacy policy or that are otherwise made clear to you on the Sites. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their sites and apps.

Do we use Google Maps?

 In Short: Yes, we use Google Maps to provide better service and we may collect your location temporarily to show you nearby shops/ restaurants and other places that may be of your interest. This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link. 

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. Using our implementation of the Google Maps APIs, you agree to allow us to access information about you, including personally identifiable information (such as usernames) and non-personally identifiable information (such as location). We will be collecting the following information: You agree to allow us to obtain or cache your location. You may revoke your consent at any time. We use data about location in conjunction with data from other data providers. 

The Maps APIs that we use to store and access cookies and other information on your devices. If you are a user currently in the European Union, please look at our EU User Consent Policy.

Do Not Track

Currently, various browsers — such as Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user’s browser DNT preference setting. SpinDeals App does not currently commit to responding to browsers’ DNT signals with respect to the Company’s Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. SpinDeals App takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

How do we use your details?

We may utilize the data we procure from you when you enlist, make a buy, respond to an examination or promoting correspondence, peruse the site, or utilize specific other site includes in the following ways:

• Create your account; and
• Deliver any services purchased by you to you; and
• Correspond with you; and
• Assist law enforcement as necessary; and
• Prevent fraudulent activity on our website or mobile app; and
• Analyze trends to improve our website and mobile application and offerings.
• To fulfill or meet the reason you provided the information (e.g., to help provide our Site services to you).
• To personalize and develop our site and the services we provide you and improve our offerings.
• To provide certain features or functionality of the services on the site.
• For marketing and promotions.
• To create, maintain, customize, and secure your account with us.
• To provide you with support, to communicate with you and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your experience and to deliver content and services relevant to your interests.
• To help maintain the safety, security, and integrity of our site, services, databases, and other technology assets and business.
• For testing, research, analysis, and App development, including to develop and improve our site and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To prevent illegal activity, fraud, and abuse.
• Where we must play out the agreement we are going to go into or have gone into with you
• To help our site that will be ready to serve you better.
• To allow us to brought administration you up in furnishing a response to your client assistance demands.
• To procure rankings and audits of items
• To send messages after a certain time routinely, with respect to your administrations or items and different items.
• To catch up after correspondence with (live talk, email, or telephone requests)
• To furnish you with the data, items, and administrations that you demand from the site.

When we share personal information

Once your personal information is collected, as detailed above, we may share it with third parties for various reasons, among them email delivery, data hosting, analytics, payment processing and content streaming. These services may collect browsing data that includes IP addresses, referring pages, and users’ movements as they navigate the Website and mobile application. Other third parties help us with our marketing efforts including sending and analyzing our marketing efforts by measuring whether recipients have opened an email and clicked on any content within it.

When we share your personal information with a third party, we require that third party to protect the information consistent with this Statement and limit its use of the information to performing the services they provide to us. For example, when we share personal information with payment processors or presenters of web seminars, its use is limited to providing that service.

Do we use ‘cookies?

Yes. Cookies are small documents a site or its provider exchanges to your computer’s hard drive through your browser (if you allow) that permit the site’s or service provider’s systems to identify your internet browser and capture please remember certain information. For example, we use cookies to help us keep in mind and process the things in your shopping cart software. Also, they are used to help us understand your requirements based on prior or current site activity, which permits us to offer you improved upon services. We also use cookies to help us put together aggregate data about site traffic and site conversation so that people may offer better site experience and tools in the foreseeable future.

We use cookies to:

• • Understand and save user’s tastes for future views or visits of our site.
  • Keep an eye on advertisements.
  • Compile aggregate data about site traffic and site connections to provide better site activities and tools in the foreseeable future.
  • We also use third-party advertisements on SpinDeals App to support our site. Some of these advertisers may use technology such as cookies and web beacons when they advertise on our site, which will also send these advertisers (such as Google through the Google AdSense program) information including your IP address, your ISP, the browser you used to visit our site, and in some cases, whether you have Flash installed. This is generally used for geotargeting purposes (Serving Online Booking ads to Travelers) or showing certain ads based on specific sites visited (such as showing marketing ads to someone who frequents marketing sites or blogs).

• We might also use third-party services that monitor these details on our behalf.

You can choose that your personal computer warns you whenever a cookie has been directed, or you can select to turn off all cookies carefully. You can perform that through your web browser settings. Since the internet browser is just a little different, check out your browser’s Help Menu to learn the way in which to change your cookies.

If you change cookies off, many of the features that produce your site experience better might not exactly function properly. It will not impact the user’s experience, which builds your site experience better and might not function properly.

Facebook Pixel _fpb,datr,dpr,fr,wd

Collects anonymous statistics regarding usage of the spindealsapp.com website and mobile application. These are third-party cookies. While spindealsapp.com ‘s use of Facebook causes these cookies to be used, spindealsapp.com itself does not control the data within the cookies themselves. The names of the cookies listed are provided as examples. spindealsapp.com does not directly control the names of the cookies involved, and the actual names may differ. These cookies enable us to: Determine the effectiveness of certain marketing campaigns Collect additional anonymous statistics (see below) You can learn more about Facebook’s Tracking Pixel here

General Use 

• Understand client’s desires for future perspectives or visits of our site. 
• Collect and Compile total data about site traffic their sources e.g. (Gadgets, Country, page sessions) and site associations to give better site exercises and apparatuses within a reasonable timeframe. 
• You have the choice to accept or reject cookies for the website and mobile application and at whatever point a cookie has been coordinated, or you can choose to deliberately kill all cookies. You can play out that through your internet browser settings if you are using chrome, you can go the setting of the chrome and select the domain and change the setting of the cookies to your desire. 
• On the off chance that you change cookies off, some of the features that produce your site experience better may not actually work appropriately. It won’t affect the client’s experience that delivers your site experience better and may not actually work appropriately.

Coppa (children online privacy protection action)

With regards to the assortment of private information from children under age 13 years, the Children’s Online Privacy Protection Act (COPPA) puts parents in charge. The Federal Trade Commission, United States’ consumer safety firm, enforces the COPPA Guideline, which spells out what providers of websites and online services should do to safeguard children privatizes and security online. For more Details Click Here or below link

https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule 

GDPR-Customer data processing appendix:

Customer Data” means any personal data that processes on behalf of Customer via the service, as more particularly described in this DPA.

“Data Protection Laws” signifies all information protection laws and guidelines appropriate to a gathering’s handling of Customer Data under the agreement, including, where pertinent, EU Data Protection Law and Non-EU Data Protection Laws.

GDPR-EU data protection law  

“EU Data Protection Law” signifies all data protection laws and guidelines appropriate to Europe, including (I) Regulation 2016/679 of the European Parliament and of the Council on the insurance of ordinary people concerning the preparing of individual information and on the free development of such information (General Data Protection Regulation) (“GDPR”); (ii) Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector; (iii) applicable national implementations of (i) and (ii); and (iii) in respect of the United Kingdom (“UK”) any applicable national legislation that replaces or converts in domestic law the GDPR or any other law relating to data and privacy as a consequence of the UK leaving the European Union).

“Europe” signifies, for the motivations behind this DPA, the European Union, the European Economic Area as well as their part states, Switzerland, and the United Kingdom. 

“Non-EU Data Protection Laws” means the California Consumer Privacy Act (“CCPA”); the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”); and the Brazilian General Data Protection Law (“LGPD”), Federal Law no. 13,709/2018.

• Parties’ roles: If EU Data Protection Law or the LGPD applies to either party’s processing of Customer Data, the parties acknowledge and agree that concerning the processing of Customer Data, Customer is the controller and is a processor acting on behalf of Customer, as further described in Annex A (Details of Data Processing) of this DPA.
• Purpose limitation: SpinDeals App shall process Customer Data only following Customer’s documented lawful instructions as outlined in this DPA, as necessary to comply with applicable law, or as otherwise agreed in writing (“Permitted Purposes”). The parties agree that the agreement sets out the Customer’s complete and final instructions to SpinDeals App concerning the processing of Customer Data, and processing outside the scope of these instructions (if any) shall require a prior written agreement between the parties.
• Customer compliance: Customer represents and warrants that (i) it has complied, and will continue to comply, with all applicable laws, including Data Protection Laws, in respect of its processing of Customer Data and any processing instructions it issues to SpinDeals App; and (ii) it has provided, and will continue to provide, all notice and has obtained, and will continue to obtain, all consents and rights necessary under Data Protection Laws for SpinDeals App   to process Customer Data for the purposes described in the agreement. Customer shall have sole responsibility for the accuracy, quality, and legality of Customer Data and how Customer acquired Customer data. Without prejudice to the generality of the foregoing, Customer agrees that it shall be responsible for complying with all laws (including Data Protection Laws) applicable to any emails or other content created, sent, or managed through the service, including those relating to obtaining consents (where required) to send emails, the content of the emails and its email deployment practices.
• The lawfulness of Customer’s instructions: Customer will ensure that United Kingdom processing of the Customer Data by Customer’s instructions will not cause SpinDeals App to violate any applicable law, regulation, or rule, including, without limitation, Data Protection Laws. SpinDeals App shall promptly notify Customer in writing unless prohibited from doing so under EU Data Protection Laws if it becomes aware or believes that any data processing instruction from Customer violates the GDPR or any UK implementation of the GDPR.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You may have the following rights: –

1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data by contacting us on [email protected]. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
   1. If you want us to establish the data’s accuracy.
   2. Where our use of the data is unlawful, but you do not want us to erase it.
   3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
   4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you.

How do we protect your details?

• We have implemented industry-accepted administrative, physical, and technology-based security measures to protect against loss, misuse, unauthorized access, and alteration of personal information in our systems. We ensure that any employee, contractor, corporation, organization, or vendor who has access to personal information in our systems is subject to legal and professional obligations to safeguard that personal information.
• We do not use vulnerability scanning and/or scanning to PCI specifications.
• We use regular Malware Scanning.
• Your individual information is comprised behind secured systems and is merely accessible by a restricted number of folks who’ve special access privileges to such systems and must keep the information confidential carefully. Furthermore, all very sensitive/credit information you resource is encrypted via Secure Socket Layer (SSL) technology.
• We implement several security measures whenever a user gets into, submits, or accesses their information to keep up the protection of your individual information.
• While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or form of electronic storage is 100 percent secure. Therefore, we cannot guarantee its absolute security.
• SpinDeals App prohibits unauthorized access or use of personal information stored on our servers. Such access is a violation of law, and we will fully investigate and press charges against any party that has illegally accessed information within our systems.

Can-spam act

The CAN-SPAM Act is a regulation that sets the guidelines for commercial email, establishes requirements for commercial announcements, offers recipients to have emails ceased from being delivered to them, and spells out hard fines for violations.

We accumulate your email to be able to:

• Send information, react to questions, and/or other demands or questions
• To maintain compliance with CANSPAM, we consent to the next:
• Not use untrue or misleading subject matter or email addresses.
• Identify the concept as an advertisement in some realistic way.
• Include the physical address of our site headquarters or business
• Honor opt-out/unsubscribe demands quickly.
• Allow users to unsubscribe utilizing the link at the bottom of every email.

If anytime you want to unsubscribe from receiving future email, you can email us at by using contact form at our website and mobile application spindealsapp.com and we’ll immediately remove you from ALL communication.

Limitation of liability

• Some jurisdictions do not allow the limitation or exclusion of liability for incidental or consequential damages so some of the above limitations may not apply to you.
• We make no legal representation that the website and mobile application or services are appropriate or available for use in locations outside Republic of Cyprus. You may access the website and mobile application from outside Republic of Cyprus.at your own risk and initiative and must bear all responsibility for compliance with any applicable foreign laws.

Indemnification

• Upon visiting this website and mobile application you agree release, indemnify, defend and hold harmless SpinDeals App and any of its contractors, agents, employees, officers, directors, shareholders, affiliates and assigns from all liabilities, claims, damages, costs and expenses, including reasonable attorneys’ fees and expenses, of third parties relating to or arising out of your use of the website and mobile application content; your use of the services; your violation of any provision of these terms; any unauthorized information or data you supplied to us. You will have sole responsibility to defend us against any claim, but you must receive our prior written consent regarding any related settlement.

Governing Law and Jurisdiction

• This website and mobile application originate from Republic of Cyprus. The laws of Republic of Cyprus. without regard to its conflict of law principles will govern these terms to the contrary. You, hereby agree that all disputes arising out of or in connection with these terms shall be submitted to the exclusive jurisdiction of the Republic of Cyprus. By using this website and mobile application, you consent to the jurisdiction and venue of such courts in connection with any action, suit, proceeding, or claim arising under or by reason of these terms. You hereby waive any right to trial by jury arising out of these terms.

Changes to this privacy notice

We reserve the right to alter this privacy notice at any time. Such alterations will be posted on our website and mobile application. You can also obtain an up-to-date copy of our privacy notice by contacting us.

Contacting us

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact us or email us at [email protected]

SpinDeals App 

Republic of Cyprus 

 

This document was last updated on October 7, 2021