Privacy Policy
Introduction and Overview
This Privacy Policy ( “Policy” ) explains how SPINNING TECH LTD, which does business as “trendspinning”, collects, uses, shares and processes your Personal Data when you use or access this website (collectively, the “Site” ) or use any of our services, communication platforms, and any other related services we own (collectively the “Services” ) The Policy also describes your rights regarding your personal data and explains how you can contact us to learn more about our data practices or to exercise your rights.
SPINNING TECH LTD uses the Site and sells products offered there under license, therefore, SPINNING TECH LTD is the controller of your personal data, and responsible for processing and protecting your personal data. In this Policy, the terms “trendspinning,” “Company”, “we”, “us” or “our” refer to SPINNING TECH LTD.
Please read our Terms& Conditions and this Policy before accessing or using our Services. If you cannot agree with this Policy or the Terms and Conditions, please do not visit our site or use our Services.
Policy Modifications: Trendspinning may change this Policy from time to time, to reflect changes in how we process personal data, if we make changes, we revise effective date or last modified data at the top of this Policy. If we make changes that materially affect your privacy rights, we will attempt to provide advanced notice (including via real- or near real-time disclosures via the App) or otherwise via the Site or the Apps, or by some other means of contact, so that you have a reasonable opportunity to review the changes before you continue to use the Site, the Apps, or the Services.
If you do not agree with the modified Policy, please stop using the Site, the Apps, or the Services.
CONTENTS
1. How We Collect and Use Your Personal Data
Your trust in our data practices is a key part of our business, and we’re providing this Policy to transparently explain our data practices to you.
We collect personal Data when you use our Services, visit our Site, or use our Apps.
Pursuant to the EU General Data Protection Regulation ( “GDPR” ) and applicable Data Protection laws, Personal Data in this Policy means all information that can identify or is capable (either alone or in combination) of identifying you as an individual person.
Personal Data does not include Information that has been effectively irreversibly anonymized such that we can no longer reasonably use it to identify you.
The chart below details the Personal Data we collect from you, and explains why we collect that data:
| Purpose | The Personal Data We Collect | Legal Basis for Processing |
|---|---|---|
| To create an account with us and to manage your account, to provide you with our Services; | Contact information, including email address and password, to register with our Site, Apps, or other Services. | Necessary for the performance of a contract or to take steps at your request prior to entering into a contract |
| Profile data, including your style preference, if you voluntarily choose to provide it for personalization purposes. | Consent | |
| To fulfill or process orders; | Identity and contact information such as name, phone number and shipping address, as well as financial information or payment account information, for delivery, returns, refund, sales tax determinations, and payment operations;Transaction details, such as return and refund details, gift card number, and order history, in our Services, in order to fulfill basic functions, including processing your payment and return requests, and keeping you informed of the order status and shipping logistics. | Necessary for the performance of a contract or to take steps at your request prior to entering into a contract |
| Location data at an IP address-based level, to tailor your experience in terms of displaying the appropriate local website, language, or user experience. | Our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services. | |
| To provide customer service and support, or to provide you with service-related communications; | Photographs you upload to our Services in accordance with our Terms and Conditions, to provide product advice and to allow you to voluntarily show other potential customers what items may look like when purchased or worn. | Consent |
| Your communication history with us via various channels, such as email, phone, social media, mail, instant chat, and our customer service platform, to respond to your requests, as well as to keep you updated about your account and the Services. | Our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services. | |
| To undertake marketing, advertising or other promotional activities; | Contact information, such as phone number and email address, for telemarketing and email marketing purposes;Non-directly identifiable device identifiers, operating system information, and cookie information, to direct and measure the effectiveness of the advertising we offer;Data about how you engage with our Services, such as browsing, adding to your shopping cart, saving items, placing an order,, and returns) for market research, statistical analysis and the display of personalized advertising based on your activity on our site and inferred interests;Contact and identity information, such as name, email address, and phone number, when you voluntarily elect to participate in a competition, market survey, event, or other marketing campaigns organized by us via the Site, the Apps, or the Services;To share your personal data with third party advertisers. | Consent |
| Postal address to send advertising brochures via traditional mail to the address of individual customers who previously purchased products on the website.No Advertising materials will be sent to individuals who are on the national lists of Objections or Mailing Preference Services which will be reviewed and updated based on the applicable national legal requirements. | Our legitimate interest is to better promote or optimize our Services | |
| To improve our product or service, or for personalization; | Collect your device information, and usage data in our Site or Apps for system performance analysis, troubleshooting, debugging, security monitoring, and system maintenance, as well as setting default options for you, such as language and currency;When you optionally provide such information, we may collect general Personal Data that cannot readily identify you, such as body shape, personal height, chest/waist/hip circumference, and weight, but that could be combined with other Personal Data about you and become Personal Data. This information may be used so we can recommend clothing sizes or styles, enhance the personalization of our Site or Apps, or provide fit prediction services for you;To share your Personal Data within and across our corporate organization for our business needs and personalization;Collection of your expressed preferences product reviews or “votes” when prompted so we can better understand your preference between items and provide preference setting options;The display of information you choose to post in public areas of the Services, for example, a customer review or a photograph of you wearing our products. | Our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services. |
| To prevent and investigate fraud, security incidents, and other illegal activities; | Information automatically collected through the Site, Apps, or Services, such as browser type, device information, operating system and account setting information for fraud prevention, security monitoring, and detection and credit risk reduction;Log-in data for information security risk control and fraud reporting;Billing address to verify payment information. | Our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services. |
| To comply with legal or compliance requirements; | Where required, identify information y, such as ID- or passport-related information, for customs clearance purposes;Transaction history and certain personal information about your identity may be collected if needed to handle and resolve questions, and legal disputes, for regulatory investigations purposes, information security and to comply with lawful requests from competent law enforcement agencies or courts in compliance with applicable law. | Compliance with legal obligations or your vital interests |
| Other Purposes. | We may use your data for any other purpose disclosed to you prior to you first providing us your Personal Data or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction. | Consent |
Please note: When communicating with us by email or through forms on our Site, Apps, or via the Services, or when you publicly share content through our Services, please do not send us any sensitive information pertaining to yourself or to others.
We do not collect or store sensitive personal data (as that term is defined in applicable data protection laws).
2. Sharing Your Personal Data
3. Cookies and Other Tracking Technologies
We may use cookies, tags, and similar technologies to automatically collect information on our Site, Apps, or Services. Cookies are small texts that are placed on your computer by our Site or, in some cases, by third parties. Tags are certain keywords used to describe your interaction with a particular feature on our Sites, Apps, or Services. Tags can be placed by us or by third parties. These, and related technologies, help us understand how you use our Sites, our Apps, and our Services. If required by law, we will request your consent before using cookies or other tracking technologies. Information within this section describes our use of cookies and your ability to control the use of cookies for advertising-related purposes. As described below, we will not use cookies tags, or similar tracking technologies that process your Personal Data, unless they are Strictly Necessary Cookies, or you opt-in, i.e. consent, by using the cookie banner or consent manager found on our Site. You may withdraw your consent or update your preferences at any time by clicking the “Manage Cookies” link within the website footer.
- A.Cookies We use the following types of cookies, tags, and related technologies on our Site, Apps, and Services:
- Strictly Necessary Cookies These cookies are essential because they enable you to use our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
- Functional Cookies. We use functional cookies to remember your choices so we can tailor our Site’s content to provide you with enhanced features and personalized content.We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
- Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including the pages you visit and the links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.
- Advertising or Targeting Cookies These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
- B.Your Choices. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here: Google Chrome , Internet Explorer , Mozilla Firefox , Safari (Desktop) , Safari (Mobile) , Android Browser , Opera Mobile .
- C.Pixel Tags . To measure how well our Services are performing we may use “pixel” tags to measure certain metrics, like conversion, page view, or Site usage patterns derived from information about your computer or mobile devices technical specifications.
- D.Analytics . We may use third-party service providers to monitor and analyze the use of our Services. Presently, we use Google Analytics . Google Analytics is a web analytics service that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en . Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout .
- If Google Analytics is structured to collect personal data, the cookie banner on our Site will provide you the opportunity to consent to Google Analytics and the data controller will be Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. We have implemented Google Analytics with the “AnonymizeIP” function, which makes sure that your IP address will be shortened before it is sent to servers in the U.S. Exceptionally, the shortening may take place after such transfer to the U.S. Google uses this data to evaluate your use of our Services, to compile reports on activities on our online services and to provide us with other services related to Site, App and internet use.
- E.Ad Retargeting . We also use retargeting services to advertise on third-party websites to you after following your visit to our Sites. For this purpose, visitors are grouped by certain actions on our Services, e.g., by the duration of a visit. This enables us to understand your preferences and to show you relevant advertising even if you are currently visiting another website.
- We use the following tools and services for purposes:
- Google Ads remarketing service is provided by Google. You can opt-out of this by visiting the Google Ads Settings page: https://www.google.com/settings/ads .
- If Google Ads is structured to collect personal data, the data controller will be Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland.
- Bing Ads is a service operated by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Please read Microsoft’s privacy statement for more information on how Microsoft processes your information https://privacy.microsoft.com/en-US/ . When you access our Site via advertisements on Bing Ads, a cookie is set on your computer. In addition, a Universal Event Tracking tag is integrated on our Site. This is a code that, in combination with the cookie, stores data about the use of the Site, e.g. length of time spent on the Site, areas accessed, and ads used to reach the Site. In addition, Microsoft may track your usage patterns across multiple of your electronic devices through so-called cross-device tracking. The information collected is transferred to a Microsoft server in the United States. If Bing Ads is structured to collect personal data, the cookie banner on our Services will provide you the opportunity to consent to Bing Ads.
- Facebook Ads. Using Facebook Business Tools , we may display interest-based ads to you when using Facebook. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook’s Ad Preferences in addition to the Your Choices section below. We do not share any of your Personal Data with Facebook. We may also show ads to audiences that share similar characteristics as you. To do so, a list of email addresses is irreversibly encrypted through hashing and uploaded or transmitted from our site, and Facebook matches the hashed data against its own users, generating a lookalike audience and deleting the uploaded list. We do not have access to the identity of anybody in the “lookalike” audience, unless they choose to click on one of our advertisements.
- F.Software Based Tracking . Parts of our Site may also use small pieces of embedded computer code Java scripts (called “software development kits” or “SDKs”). These SDKs accelerate the refresh speed of certain aspects of our Site or Apps, they help us monitor usage of various online components; they allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and they enable local storage of certain interactive web content files (called “HTML5”) HTML5 on your computer’s or mobile device’s local storage so it remains there whenever you visit the Site or use the Apps.
- G.Do Not Track . Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
- H.Location Information . You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.
4. Security Precautions
We maintain reasonable physical, electronic, and procedural safeguards designed to guard your personal data from unauthorized processing, use, or disclosure. Our security measures include physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information.
The Internet is not a secure environment, and we cannot guarantee that your personal data will be secure. We therefore strongly recommend that you use a secure method and use a complex password to help us ensure the security of your account. We also strongly advise that you neither share your password with others nor re-use passwords on our Services that you use on other sites or apps, as doing so increases the likelihood of your being the victim of malicious cyber behavior. If you feel that the security of your account or personal data has been compromised, please immediately contact us or as otherwise described in the Contact Us section below.
5. Your Rights
To exercise your rights under this Policy and applicable law, you may contact us.
5.1 Access, Rectification, Portability, and Deletion of your Personal Information. You have the right to correct or update your personal data, object to processing of your personal data, ask us to restrict processing your personal data or to request portability of your personal data. To protect the privacy and the security of your personal data, we may request data from you to enable us to confirm your identity and your right to access such data, as well as to search for and provide you with the personal data we maintain upon your request. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the Personal Data that we maintain.
To exercise your rights, you may make updates within your customer account on the Site or Apps, or you may contact us. If you no longer wish to be our customer, or cease using or accessing our Services, you can request us to close your account and delete all Personal Data we hold about you subject to certain legal requirements.
5.2 Withdrawal of consent. You have the right to withdraw your consent to the processing of your personal data, as well as to access, correct, or delete the Personal Data that we collect, subject to certain exceptions.
Please be aware that there are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the Personal Data that we maintain.
5.3 Unsubscribe from Our Marketing Communications. If you no longer wish for us to use your email account to send you marketing emails or non-transactional promotional materials, please contact us.
5.4 Object to the receipt of advertising brochures via traditional mail. If you no longer wish for us to use your postal address to send you marketing brochures by means of traditional mail based on legitimate interest, please contact us to submit your request to unsubscribe from further postal.
5.5 Lodging Complaints If you believe we have infringed or violated your privacy rights, please contact us so that we may attempt to resolve any issues to your satisfaction. Notwithstanding the approaches of exercising your rights stated, this is without prejudice to your right to lodge a claim or complaint with your data protection authority (more details on data protection authorities and their contact info can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en).
6. Retention
We will retain your Personal Data, , including any correspondence you have with us, only for as long as is necessary for the purposes set out in this Policy, including retaining Personal Data in order to comply with our legal obligations, to resolve disputes, for information security purposes, and to enforce our legal rights, terms, and policies.
7. Third-Party Websites
Our Apps or Site may contain links to third-party sites. This Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit as we are not responsible for the privacy practices of those sites.
8. Children
Our Services are not directed to, and we do not knowingly collect Personal Data from, children under the age of 16 or minors. If you are a minor, please do not attempt to fill out our forms or send any Personal Data about yourself to us. If a minor has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact us immediately to remove the relevant Personal Data and unsubscribe the minor.
If we become aware that a minor has provided us with personal information, we will take steps to promptly delete such information from our files. As described further in our Terms& Conditions , please do not upload photographs showing other people, in particular if they are minors.
9. Transfer of Your Personal Data
When you access or use our Services, your personal data may be processed or transferred outside the European Union, including to the United States, China and/or Singapore. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside.
For these transfers we rely on appropriate safeguards as permitted under the GDPR such as Standard Contractual Clauses, modified from those adopted by the European Commission pursuant to Article 49 (1) (b) of the GDPR to provide our Services pursuant to the Terms & Conditions. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you reside, you should immediately stop accessing or using the Services.
10. Contact Us
If you have questions or concerns regarding any information in this Privacy Policy, please contact us.
Our Privacy Office can be contacted via the email address below or via our postal address below in writing:
Address:
Level 1, Devonshire House, 1 Mayfair Place, London, England, W1J 8AJ, UK
Email: service@trendspinning.com
