This Privacy Policy is, effective May 15th2018, must be read in its entirety as an integral part of the SpinRamp Terms of Service in effect at the time.The Customer and their associated Service Users may be further subject to the privacy policies and terms of use of any third party providers that share Service User data with SpinRamp, and whose terms the Customer has agreed to.
1 The SpinRamp Service, Users and Customer Dataset
1.1 SpinRamp is publishing this Privacy Policy to inform Customers of SpinRamp policies and procedures regarding the collection, use and disclosure of information received from or aggregated by the SpinRamp Service.
1.2 By using the SpinRamp Service Customers are consenting to Processing of the Customer Dataset as set forth in this Privacy Policy now and as further amended, from time to time, by SpinRamp, at its sole discretion.
1.3 The SpinRamp Service is hosted in the United States. If the Customer chooses to use the SpinRamp Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then the Customer must take note that the Customer Dataset may be transferred to SpinRamp and Processed under U.S. privacy standards.
1.4 Also, SpinRamp may transfer Customer Dataset from the U.S. to other countries or regions in connection with the Processing of data, fulfilling Customer requests, and operating the SpinRamp Service. By using the SpinRamp Service and providing information to SpinRamp, the Customer consents to such transfer to, and Processing in the SpinRamp Service in the U.S, or elsewhere.
1.5 Also by using the SpinRamp Service the Customer agree to fully disclose and obtain consent of Influencers and Respondents on collection and use of their data per this Privacy Policy and to further indemnify and hold Spinramp harmless from any liability due to Processing of information of all Service Users including Respondents, Influencers and/or Customer Audience that may be part of Customer Dataset.
2 Customer Dataset Collection and Use
SpinRamp’s primary goals in collecting the Customer Dataset is to provide the Customer with the products and services made available through the SpinRamp Service, to communicate with the Customer, receive payments from the Customer and to manage Customer’s Service Users. SpinRamp may also use the Customer Dataset to operate, maintain, and enhance the SpinRamp Service and its features, and to provide customer support to other Operators.
3 Registration Information
3.1 The Customer provides SpinRamp with information when the Customer registers for an account, uses the SpinRamp Service, makes a purchase on the SpinRamp Service, or sends SpinRamp customer-service related requests. If the Customer desires to have access to certain restricted sections of the SpinRamp Service the Customer will be required to become a registered user, and/or make payments and to submit certain personally identifiable information to SpinRamp or affiliated subscription service and payment gateway providers.
3.2 This happens in a number of instances, such as when the Customer signs up for the SpinRamp Service, or if the Customer desires to receive marketing materials and information. Information that SpinRamp may collect in such instances may include Customer IP address, full user name, password, email address, city, time zone, credit card and other billing information, preferences, telephone number, and other information that the Customer decides to provide SpinRamp with. SpinRamp may link such information with other information the Customer provides about them self.
4 Use of Third Party Platform User Data
If the Customer logs in to the SpinRamp Service, or use the SpinRamp Service with Gmail, Social Media Platforms or other supported 3rd Party Authentication and 3rdParty Services as part of Customer’s operation of the SpinRamp Service, SpinRamp will access certain information obtained from those platforms regarding Customer and related Service User’s account. In particular SpinRamp may store Service User’s name and email address as well as information on the particular page or profile the Service User connected with, including post content and engagement data.
5 Customer Contact Information
5.1 In addition, SpinRamp may use Customer Dataset to market to the Customer, and provide the Customer with information about SpinRamp products and services, including but not limited to the SpinRamp Service. If the Customer decides at any time that the Customer no longer wishes to receive such information or communications from SpinRamp, the Customer should un-follow SpinRamp, or follow the unsubscribe instructions provided in any of the communications.
5.2 The Customer may also opt out from receiving commercial email from SpinRamp by sending a request to SpinRamp by email at Support@SpinRamp.com. If the Customer opts out of receiving commercial email from SpinRamp or otherwise modifies the nature or frequency of promotional communications the Customer receives from SpinRamp, it may take up to thirty (30) business days for SpinRamp to process the Customer’s request, and the Customer may continue receiving promotional communications from SpinRamp during that period.
5.3 Additionally, even after the Customer opts out from receiving commercial messages from SpinRamp, the Customer will continue to receive administrative messages from SpinRamp regarding the SpinRamp Service.
6 SpinRamp Service Log Data
When the Customer uses the SpinRamp Service, SpinRamp servers automatically record information (“Log Data”) that the Customer’s browser, mobile application or connected service sends when you visit a website or perform other actions. This Log Data may include information such as Customer IP address, device identifiers, browser type or the domain from which the Customer is visiting, web pages the Customer visited, the search terms the Customer used, and any advertisements on which the Customer clicked. For most users who are accessing the Internet from an Internet service provider the IP address will be different every time the Customer logs on. SpinRamp uses Log Data to monitor the use of and the technical administration of the SpinRamp Service. The Log Data is considered a part of Customer Dataset.
7 Cookies and Identifiers
7.1 SpinRamp uses technologies to automatically collect additional SpinRamp Service usage data to improve the SpinRamp Service and for other business purposes. This includes the use of cookies, which are small data files that SpinRamp transfers to available storage on a Service User’s device. This may also include the use of other available identifiers, or stored trackers on a Service User’s device or applications running on that device. These will be collectively referred to as ‘Identifiers’.
7.2 SpinRamp may use both session Identifiers and persistent Identifiers to better understand how the Customer interacts with SpinRamp Service, to monitor aggregate usage by SpinRamp users and for SpinRamp traffic routing on the SpinRamp Service, and to improve the SpinRamp Service. A session Identifier enables certain features of the SpinRamp Service and is deleted from Customer computer when the Customer disconnects from or leaves the SpinRamp Service. A persistent Identifier remains after the Customer disconnects from the SpinRamp Service (such as closing Customer browser) and remains available for use on subsequent use of the SpinRamp Service.
7.3 Persistent cookies used on a Customer’s browser can be removed by following browser help file directions. Most Internet browsers automatically accept cookies. The Customer can instruct the browser, by editing its options, to stop accepting cookies or to prompt the Customer before accepting a cookie from the web sites the Customer visits. Please note that if the Customer deletes, or chooses not to accept, cookies from the SpinRamp Service, the Customer may not be able to utilize the SpinRamp Service at all.
7.4 SpinRamp does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use SpinRamp Service.
7.5 SpinRamp may also automatically record certain information from Customer’s device by using various types of technology, including “clear gifs” or “Web beacons.” This automatically collected information may include Customer IP address or other device address or ID, SpinRamp browser and/or device type, the web pages or sites that the Customer visited just before or just after the Customer used the SpinRamp Service, the pages or other content the Customer viewed or otherwise interacted with on the SpinRamp Service, and the dates and times that the Customer visited, accessed, or used the SpinRamp Service. SpinRamp also may use these technologies to collect information regarding Customer interaction with email messages, such as whether the Customer opened, clicked on, or forwarded a message. This information is gathered from all Customers and Service Users, and may be connected with other information about the Customer. This information may also be gathered from third party sites where the SpinRamp Service may place Web Beacons and/or Buttons tracked by Spinramp or aggregated with other third party services.
7.6 All Identifiers and aggregated information so described in this section will be considered part of the Customer Dataset.
8 Third Party Web Beacons and Third Party Buttons
8.1 SpinRamp may display third-party content on the SpinRamp Service or on affiliated sites or applications, including third-party advertising. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with Customer viewing of the third party content on the SpinRamp Service. Additionally, SpinRamp may implement third party buttons (such as the Facebook “share” button) that may function as web beacons even when the Customer does not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by SpinRamp but may be shared with SpinRamp.
8.2 Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
8.3 Other than what is provided for SpinRamp’s use, such information is not part of Customer Dataset.
9 Information Sharing and Disclosure
SpinRamp’s primary purpose for using the Customer Dataset is to provide the SpinRamp Service. In addition, SpinRamp may share and disclose Customer information for the following reasons:
9.1 SpinRamp Service Providers. SpinRamp engages third parties to perform functions and provide services to SpinRamp, including, without limitation, hosting and maintenance, billing, customer relationship, database storage and management, and direct marketing campaigns and will share Customer personally identifiable information with these third parties to the extent necessary to perform these functions and provide such services.
9.2 Compliance with Laws and Law Enforcement. SpinRamp cooperates with government and law enforcement officials or private parties to enforce and comply with the law. SpinRamp may disclose any information about the Customer to government or law enforcement officials or private parties as SpinRamp, in SpinRamp’s sole discretion, believes necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of SpinRamp or a third party, to protect SpinRamp against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the SpinRamp Service and any equipment used to make the SpinRamp Service available, or to comply with the law.
9.3 Mergers, Acquisition, Reorganization. SpinRamp may sell, transfer or otherwise share some or all of its assets, including Customer’s personally identifiable information, in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. The Customer will have the opportunity to opt out of any such transfer if the new entity’s planned processing of Customer information differs materially from that set forth in this Privacy Policy. Such communication will be made available on the SpinRamp Site and any opt-out request may be mailed, in response to such notice, to Support@spinramp.com
9.4 Other Third Parties. SpinRamp may make certain aggregated, automatically-collected, or otherwise non-personal information available to third parties for various purposes, including, but not limited to, business or marketing purposes or to assist third parties in understanding SpinRamp’s Customers and Service Users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the SpinRamp Service.
10 Managing Customer Information
The Customer may access, update, correct or delete the information the Customer provided to SpinRamp within the SpinRamp Service or by e-mailing SpinRamp at support@SpinRamp.com. Please note that while any changes the Customer makes will be reflected in active user databases within a reasonable period of time, SpinRamp may retain all information the Customer submitted for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where SpinRamp otherwise reasonably believes that SpinRamp has a legitimate reason to do so.
11 Confidentiality, Security
11.1 SpinRamp is committed to safeguarding the confidentiality of the Customer Dataset and employs commercially reasonable measures designed to protect the Customer Dataset from unauthorized access.
11.2 Customer acknowledges that no security measures are perfect or impenetrable. SpinRamp cannot and does not guarantee that Customer Dataset will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of SpinRamp administrative, physical, and electronic safeguards.
11.3 SpinRamp will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of Customer’s unencrypted electronically stored personal data to the Customer via email or posting on this SpinRamp Site in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
12 3rd Party Services
The SpinRamp Service contains links and interfaces to other third party websites and applications (3rd Party Services). The fact that the SpinRamp Service links to a 3rd Party Service is not an endorsement, authorization or representation of SpinRamp’s affiliation with that third party. SpinRamp does not exercise control over 3rd Party Services. These other 3rd Party Services may place their own cookies or web beacons or other files on Customer computer, collect data or solicit personally identifiable information from the Customer. Other 3rd Party Services follow different rules regarding the use or disclosure of the personally identifiable information that the Customer submits to them. Spinramp is not responsible for the content, privacy and security practices, and policies of 3rd Party Services to which links or access is provided through the SpinRamp Service. SpinRamp encourages the Customer to read the privacy policies or statements of the other 3rd Party Services the Customer visits, connects with or subscribes to.
13 Children
The SpinRamp Service is not directed at Customers or Service Users below the age of 13. SpinRamp does not knowingly collect personally identifiable information from children under 13. If SpinRamp becomes aware or is contacted by a parent or guardian that a child under 13 has provided SpinRamp with personally identifiable Information, SpinRamp will delete such information from SpinRamp files. However Customers of the SpinRamp Service may collect such data with the consent of the child and their parent or guardian subject to applicable laws. If a parent or guardian becomes aware that his or her child has provided a Customer of the SpinRamp Service with personally identifiable information without their consent or in violation of applicable laws, he or she should contact the Customer and act as necessary under applicable laws. And further notify Support@Spinramp.com.
14 Changes to Privacy Policy
This Privacy Policy may be updated from time to time for any reason; each version will at a minimum apply to information collected while it was in place. Spinramp reserves the right to apply the updated Privacy Policy to prior data as well. SpinRamp will notify the Customer of any modifications to SpinRamp Privacy Policy by posting the new Privacy Policy on SpinRamp Site and indicating the date of the latest revision. Customers are advised to consult this Privacy Policy regularly for any changes.
A Customer’s continued use of the SpinRamp Service after the revised Privacy Policy has become effective indicates that the Customer has read, understood and agreed to the current version of this Privacy Policy.
14 Customer California Privacy Rights
Residents of California have the right to request a disclosure describing what types of personal information SpinRamp has shared with third parties for their direct marketing purposes, and with whom SpinRamp has shared it, during the preceding year. The Customer may request a copy of that disclosure by contacting SpinRamp at support@SpinRamp.com.
This Privacy Policy is effective as of May 1, 2018. If the Customer has any thoughts or questions about this Privacy Policy please let SpinRamp know.