We recognize the importance of keeping the information you (“you” or “your”) provide to us private and secure. This Policy applies, in general, to all Internet sites operated by or on behalf of us (the “Site”) and related services (the “Services”).
1. User Consent.
By using our Site or providing Personal Information to us, you are consenting to the collection, use and disclosure of your Personal Information as described in this Policy. If you do not consent to the collection, use and disclosure of your Personal Information as described in this Policy, do not use our Site.
2. Types of Information We Collect.
When we refer to “Personal Information” we mean information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing information. When we refer to “Anonymous Information” we mean information that is not associated with or linked to your Personal Information and which cannot be identified as belonging to you.
We may collect Personal Information from you, such as your first and last name, mailing address, phone number, e-mail address, billing address, credit card or debit card information, PayPal account, and similar information when you create an account. Our Site may collect information from you, including your browser type, operating system, IP address, web pages visited, web pages viewed, buttons or links clicked, time spent on website, time spent on web pages, etc.
3. Use of Your Personal Information.
Whenever we collect Personal Information on our Site, we will:
- not disclose, transfer, sell or otherwise provide your Personal Information to any third party unless required by law or as expressly stated herein;
- collect and use your Personal Information only with your consent, which may be express or implied, depending on the sensitivity of the Personal Information, legal requirements, and other factors;
- collect your Personal Information only for specific, limited purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;
- process your Personal Information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented; and
- not use your Personal Information for direct marketing purposes without giving you an opportunity to “opt-out”.
We may use Personal Information:
- to create your membership or user profile account and provide the Services you request;
- to access the third party services you specifically request access to;
- to register you for a webinar or online workshop or streaming workshop;
- to place transactions or orders to purchase software, research or membership access;
- to provide support and assistance for email requests or questions related to our Services;
- to the extent you choose to participate, to conduct questionnaires and survesy in order to provide better Services and Products;
- to personalize marketing communications and website content based on your preferences, access level, user level, Services purchased;
- to provide improved administration of our Site and Services including billing, mailing, email, phone number, name updates or edits;
- to send you administrative e-mail notifications and other Services related communications;
- to send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes;
- to contact you regarding opportunities to compensate you for your algorithm’s performance;
- to share anonymized and/or aggregated algorithm performance statistics with third parties, for example potential investors or for marketing purposes; and
- to market our products and services (and those of third parties) to you that we believe may be of interest, both on and off the Site.
- to facilitate communication with other Members of the Site as you direct us through the Services.
4. Control and Retention of Personal Information.
5. Security of Personal Information.
Your Personal Information will generally be stored in our or our servers (which are hosted by a third party service provider) located in the United States. To the extent required by law, if your Personal Information will be transferred outside of this country, an appropriate notice will be provided. We maintain safeguards to protect the confidentiality, security and integrity of your Personal Information. However, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security unless we have acted in a grossly negligent manner.
6. Use of Anonymous Information.
We may create Anonymous Information records from Personal Information by excluding any information that makes the information personally identifiable to the data subject. We use this Anonymous Information to so that we may enhance the content of our Services and improve Site performance. We reserve the right to use Anonymous Information for any purpose and disclose Anonymous Information to third parties at its sole discretion.
7. Third Party Service Providers.
We use software plugins and other third-party plugins on this site in order to facilitate and support our business and users. These plugins include payment gateways and other payment transaction processors, analytics and website tracking software, membership management and access delivery software, commenting and forum software, marketing and promotion software as well as video, audio, content, and social media plugins. The current list of active software plugins and third-party plugins we use on this site include: Google Analytics, Wave, Bluehost, Themify, All-in-One WP Migration, Calendly,
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us as already outlined in the “We may use Personal Information” section above. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
In certain, limited circumstances we may required share or transfer Personal Information to other unrelated third parties. For example, we may provide Personal Information to a third party: (i) at your request; (ii) to comply with a legal requirement or court order; (iii) to investigate a possible crime, such as identity theft; (iv) in connection with the sale, purchase, investment in, merger, reorganization, liquidation or dissolution of our company or business; or (v) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your Personal Information.
8. Third Party Websites.
10. Users Outside of the United States.
11. Your Rights and Choices Under GDPR
You may update, correct or delete information about you at any time by requesting such deletion by completing the “Contact Us” form on this Website at https://spintwig.com/contact.
You may exercise your right to withdraw your consent to the Service at any time. The withdrawal of consent will require deactivation of your account. To withdraw consent and deactivate your account, please contact support by completing the “Contact Us” form on this Website at https://spintwig.com/contact. If you wish to exercise your right to data portability or right to erasure, please complete the “Contact Us” form on this Website at https://spintwig.com/contact, but note that we may retain certain information as required by law or for legitimate business purposes.
We may also retain cached or archived copies of information about you for up to 12 months. You have the right to lodge a complaint with a supervisory authority.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
Our Services and Site are not directed to children and children are not eligible to use our Services. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years of age, and no part of our Site or Services is designed to attract people under 13 years of age. If we later learn that a user is under 13 years of age, we will take steps to remove that user’s Personal Information from our databases and to prevent the user from utilizing the Site and the Services.
13. Changes in this Privacy Statement.
14. Contact Us.
Notice to California Residents: