Privacy Policy

The Spinny Earn team is committed to protecting and respecting your privacy.

We designed this Privacy Policy (“Privacy Policy”) together with our Terms of Use and any other documents referred to therein sets out the basis on which any personal data We collect from You or about You, or that You provide to us, will be processed by Us. Please read the following carefully to understand our practices regarding Your personal data and how we will treat it.

By using/ accessing the Spinny Earn App and by providing any information through the Spinny Earn App, You agree to the terms of this Privacy Policy.

For the purpose of the Information Technology Act, 2000 read with Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data And Information) Rules 2011, and such other applicable laws (including foreign laws)(hereinafter referred to as “Laws”), We have devised this Privacy Policy.

Terms not defined in the Privacy Policy shall have the same meaning as ascribed to them in the Terms of Use. We process the data in compliance with the Laws, the purpose of personal data processing by Us is to organize and ensure that We fulfil Our obligations ensure protection of Our rights arising from Your registration on the Spinny Earn App/ use of the Spinny Earn App. The processing of the data by Us is done pursuant to the rules described below.

What Information do we collect?

We may collect and process the following data about You:

You may give us information about You by filling in the registration forms on the Spinny Earn App or by corresponding with us by name, e-mail or otherwise. This includes information You provide when You register to use the Spinny Earn App, subscribe to be a user, search for a product, place an order on the Spinny Earn App, participate in discussion boards or other social media functions on the Spinny Earn App, enter a competition, promotion or survey and when You report a problem with the Spinny Earn App. The information You give us may include Your:

Name,

email address,

profile picture.

The information that we request will be retained by us and used as described in this privacy policy.

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

• Google Play Services
• AdMob
• Firebase Analytics
• Facebook
• Crashlytics

Name,

E-mail address

Hereinafter collectively referred to as “Personal Data“or “Personal Information”

Please note, if You do not want to disclose your personally-identifiable information, please do not submit it. Please be aware that if You do not provide such information, we may not be able to provide the services under the Spinny Earn App.

Our primary goal of collecting Your Personal Information is to provide You a safe, efficient, smooth and customized experience. This allows Spinny Earn App to provide Services and features that most likely meet Your needs, and to customize Our Spinny Earn App to make Your experience safer and easier.

Automatic Information: We store all such information which automatically gets accessible to Us by the virtue of You installing Spinny Earn App on Your mobile device or on any other operating systems, as may be notified and added by Us, like location, email-id etc. (app permissions). We receive and store certain types of information whenever You interact with other users using Spinny Earn App. For example, like many web sites, We use Cookies & Advertisement ID and We obtain certain types of information when Your Web browser accesses Spinny Earn App or advertisements and other content served by or on behalf of Spinny Earn App. Cookie is a small data file that Our server sends to Your browser when You visit the Spinny Earn App (“Cookies”). The use of cookies helps us to assist Your use of certain aspects of the Spinny Earn App. You can delete cookies at any time or You can set Your browser to reject or disable Cookies. We may use information from cookies for the following purposes:

Traffic monitoring;

IP address from which You access the Spinny Earn App;

type of browser and operating system used to access the Spinny Earn App;

date and time of your access to the Spinny Earn App;

pages you visit

Internet address of the website from which you accessed the site to recognize repeat visitors for statistical / analytical purposes.

Stored Information: We store all such data which are shared by You or by a third party on Your behalf either at the time of installation of the Spinny Earn App or at any other later stage on Our Spinny Earn App such as image files, documents etc.

Use of Your Personal Information/ Personal Data

We use the Personal Information/ Personal Data held by Us, about You in the following ways:

To carry out our obligations from any contracts entered into between You and Us and to provide You with the information, products/ services that you request from us through the Spinny Earn App;

To resolve any disputes, collect fees and troubleshoot problems;

To offer you goods/ services;

To provide you with the rights and benefits as You may be entitled to under our contractual obligations;

To comply with applicable laws;

To ensure that You are in compliance with the applicable policies, rules and laws;

To provide You, or permit selected third parties to provide You, with information about goods or services we feel may interest You. We will only contact you through the Spinny Earn App or by electronic means (e-mail or SMS, Whatsapp or other social media means) with information about goods and services which may be similar to those which have been viewed or purchased by You. We will do so only if you have consented to this. If You change your mind and do not want us to use Your data in this way, or to pass Your details on to third parties for marketing purposes, please: select relevant tick box in your user settings on your Account with Us or contact customer service by sending an email to jen.ph2010 at gmail dot com

To notify You about any changes to our services;

To ensure that content on the Spinny Earn App is presented in the most effective manner for You;

To ensure effective management of the network of users by ourselves but also by other members of our consultants networks (mainly Your sponsor/ referror);

To administer our Spinny Earn App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

To allow You to participate in interactive features of our service, when You choose to do so;

To keep the Spinny Earn App safe and secure;

To measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertisments to You, this includes performance of the consumer satisfaction study and alike studies;

To respond to requests and legal demands from regulators or other authorities.

What types of information are not allowed on Spinny Earn App?

Nudity or other sexually suggestive content;

Hate speech;

credible threats or direct attacks on an individual or group;

Content that contains self-harm or excessive violence;

Fake or impostor profiles; and

Spam.

With whom We may share Your Content?

Generally, Spinny Earn App will not disclose personally identifiable information that We collect through Your use of the Spinny Earn App to unaffiliated third parties. We reserve the right, however, to provide such information to Our affiliates, third party contractors, employees, contractors, agents, and designees to the extent necessary to enable them to perform certain Spinny Earn App-related services (e.g., Spinny Earn App hosting, improve Spinny Earn App related services and features, or maintenance services) on Our behalf.

business partners: suppliers and sub-contractors for the performance of any contract we enter into with them or You. This includes among others: carriers, credit collection agencies, factoring services providers, logistics services (such as picking and packing) providers, customer support services providers, third party software developers, third party products/ services providers, etc.

Other members of our consultants network (primarily to your sponsor/referror in our network and Your down-line consultants/ referrals) for the purpose of effective management of our consultants network. If You do not want us to pass Your personal information to the other consultants in the network for mentioned purpose, please contact customer service by sending an email to jen.ph2010 at gmail dot com.

Advertisers and advertising networks that require the data to select and serve relevant advertisements to You and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 200 men under the age of 40 have viewed the relevant advertisement or accessed the link). We may also use such aggregate information to help advertisers reach the kind of audience they want to target.

Analytics and search engine providers that assist us in the improvement and optimisation of our site. We use Google Analytics to understand how visitors engage with our sites and apps. This means that when you visit our website or use the Spinny Earn App Your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you’re visiting and your IP address. You will find the details of how the Google technology collects and processes data following this link: https://www.google.com/policies/privacy/partners/. If You don’t want the Google Analytics to be used in Your browser, you can install the Google Analytics browser add-on. You can find more about the Google Analytics and Google privacy policy here. Users are always free to decline cookies if their browser permits, although doing so may interfere with their use of some of Spinny Earn App. Please find detailed information on how to disable cookies here (http://www.allaboutcookies.org/manage-cookies/).

Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with You.

We may also disclose your Personal Information to third parties:

In the event that we sell, buy or in other way transfer any business or assets, in which case we may disclose Your Personal Data to the prospective seller, buyer or acquirer of such business or assets.

If our Team or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.

We also reserve the right to disclose such information to any third party if We believe that We are required to do so for any or all of the following reasons: (i) by law; (ii) to comply with legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Spinny Earn App or Our network; and/or (iv) to protect the rights, property, or safety of Spinny Earn App or its employees, the users of the Spinny Earn App, the public, or You.

Technical and functional management of the Spinny Earn App:

When You use Our Spinny Earn App, We may also process technical data such as Your IP-address, device ID, and information about the manufacturer, model, and operating system of Your mobile device. We use this data to enable us to deliver the functionalities of the Spinny Earn App, resolve technical difficulties, and provide You with the correct (prevent the transmission of spam, viruses and/or unlawful, defamatory, obscene or otherwise undesirable material or content) and most up to date version of the Spinny Earn App.

Security:

Spinny Earn App takes your security seriously and we take precautions to keep your information secure. We have put in place appropriate physical, electronic and managerial procedures to safeguard the information we collect. However, due to the open communication nature of the internet, we cannot guarantee that communications between You and Spinny Earn App, or information stored on our Spinny Earn App, will be free from unauthorized access by third parties. Any transmission of information by You to our Spinny Earn App is at Your own risk.

Where we have given you (or where you have chosen) a password which enables you to access the Spinny Earn App (hereinafter your “Account”), You are responsible for keeping this password confidential. We ask You not to share a password with anyone. If You do share Your password with others, You will be responsible for all actions taken in the name of Your Account.

If You lose control of Your password, You may lose substantial control over Your Personal Data and may be subject to legally binding actions taken on Your behalf. Therefore, if Your password has been compromised for any reason, You should immediately notify us and change Your password. We will never ask for Your password except during the login process. Our employees are subject to additional requirements in the area of information protection.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Personal Data, we cannot guarantee the security of Your data transmitted; any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.

Entrustment of personal data processing – Your Obligations

As a member of our user network, we entrust You the processing of the personal data of other members of our user network on the basis of the below provisions.

You must ask users expressly whether or not they wish to receive commercial communications about Spinny Earn App, products/ services from you, keep a record of their marketing preferences and respect those preferences.

You must immediately return the entrusted personal data after termination of your relationship with us (i.e. upon your deregistration as our User), and to remove these data from any electronic data carriers on which they were recorded by You for the purpose of achievement of the objectives described above. If You wish to sponsor/ refer a user to become a member You may collect certain personal information directly from the user. You must strictly follow our procedures for sponsorship/ referral from time to time. Spinny Earn App application’s online tools may allow You to use a user’s personal information to send commercial communications, strictly subject to the following conditions:

You must have sponsored/ referred the user to become a user, unless otherwise expressly agreed, such commercial communications concern only Spinny Earn App and products and services offered on the Spinny Earn App, the commercial communication shall be clearly identifiable as such, the communication includes Your name and contact details as the sender of the commercial communication and a valid email address at which users can reach You to notify you of their preference to opt out of further commercial communications, commercial communications must not be sent to users that have opted out of receiving them, promotional offers, such as discounts, premiums and gifts, where permitted by applicable law, shall be clearly identifiable as such, and the conditions which are to be met to qualify for them shall be easily accessible and presented clearly and unambiguously, and the content of such commercial communications is compliant with the terms of this policy and all applicable law regarding commercial communications.

We reserve the right to audit the methods of protecting the entrusted personal data applied by you. You are obliged to provide us with an opportunity to conduct such an audit immediately after being requested to do so.

We are not liable for your obligations towards the third parties resulting from personal data processing in contravention with this Privacy Policy.

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on our website / Spinny Earn App. The amendments will be also available at our premises. They will be effective as of the publication date. Your use of the Spinny Earn App subsequently to the publication of the amended Privacy Policy or a placement of order with us will be deemed acceptance of such changes.

Contact and complaints

Questions, comments, complaints and requests regarding this Privacy Policy are welcomed and should be addressed to our customer service at jen.ph2010 at gmail dot com.

If you believe that we have not complied with this Privacy Policy, you may also write to the address above. Please describe in as much detail as possible the ways in which you believe that this Privacy Policy has not been complied with. We will investigate your complaint promptly.

Legal Disclaimer

We reserve the right to disclose Your personally identifiable information as required by law and when We believe that disclosure is necessary to protect Our rights and/or to comply with a judicial proceeding, court order or legal process served on Our Spinny Earn App. We may be required to share the aforesaid information with government authorities and agencies for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences. You agree and consent for Spinny Earn App to disclose Your Information, if so required under the applicable law.

A Special Note about Children:

The Services under the Spinny Earn App is not directed towards children under 18(eighteen), they are not allowed to register with or use the Service, or provide personal data. If We discover that We have collected personal information from a child under 18, We will delete that information immediately.

Revisions to Privacy Policy:

Spinny Earn App reserves the right to update and revise this Privacy Policy at any time. You can determine if this Privacy Policy has been revised since Your last visit by referring to the “Effective Date of the current Privacy Policy ” date at the top of this page. You should therefore review this Privacy Policy regularly to ensure that You are aware of its terms and amendments. Your use of Spinny Earn App constitutes Your acceptance of the terms of the Privacy Policy as amended or revised by Us.

Governing Law:

The laws of India, shall govern this Privacy Policy, regardless of Your location. You hereby expressly consent to the exclusive jurisdiction and venue located in Delhi, India, for all matters or disputes arising out of or relating to these Terms of Use or Your access or use of the Spinny Earn App.

ANY CAUSE OF ACTION ARISING OUT OF OR RELATED TO THE TERMS OF USE OR YOUR USE OF THE ONEAD APPLICATION MUST BE BROUGHT BY YOU WITHIN ONE (1) MONTH OF THE DATE SUCH CAUSE OF ACTION FIRST AROSE, OR SUCH CAUSE OF ACTION IS FOREVER WAIVED BY YOU. EACH CAUSE OF ACTION SHALL BE ADJUDICATED INDIVIDUALLY, AND YOU AGREE NOT TO COMBINE YOUR CLAIM WITH THE CLAIM OF ANY THIRD PARTY.