Privacy Policy

Last updated 08/04/2023

This Privacy Policy covers the processing of personal data by Spin Digital Ltd, having its principal address at Trinity Chambers PO Box 4301, Road Town, Tortola, British Virgin Islands (“Spin”, “we” or “us”). Spin is committed to protecting the privacy of your personal information whilst striving to provide the very best user experience. We want our website located at evm.vault.spin.fi, and services provided through the website (collectively the “Service”) to be safe and enjoyable for everyone. Under applicable data protection laws we have a legal duty to protect the personal information we collect from you. In this Privacy Policy we also inform you about your rights as a data subject.

We do not collect any of your personal data beyond what is described in this Privacy Policy. We do not process personal data in a way that contradicts the purpose for which the personal data was obtained. When processing your personal information, we will comply with the rules of the applicable data protection laws.

Please read this Privacy Policy very carefully as it becomes legally binding when you use our website. Further, please revisit us regularly to keep track of any Privacy Policy updates.

Information We Collect

When you access and use the Service we may collect the following information from you:

Social Media: when you interact with us through social media and messaging platforms we see.

Financial Information: we may also collect and process information such as your digital wallet information, transaction history, trading data and associated fees paid. This data is stored in the blockchain.

Transaction Information: we may also collect and process information such as information about the transactions you make on the Service, such as the type of transaction, transaction amount, and timestamp. This data is stored in the blockchain.

Online Identifiers: we use cookies and similar tracking technologies which allow us to collect and process such data as your geo location, browser fingerprint, operating system, browser name and version, and IP addresses, etc.

Usage and Diagnostics Data: we collect and process information such as conversion events, user preferences, crash logs, device information and other data collected via cookies and similar technologies.

How We Use Your Information

We use your personal data for the following purposes:

Services. To allow you access and use the services. Create user accounts, process transactions, send information about confirmations, updates, notices, etc.

Diagnosis & Troubleshooting. To diagnose problems with our servers, to administer our website and services. This is not directly linked to any personally identifiable information, unless it is necessary to prevent fraud or abuse on our website and systems.

User Experience. To enhance our services and give you a better user experience on our website.

Security. To prevent, detect and investigate illegal activities, breaches of any agreements entered into between you and us and threats to the security of our website.

Statistics. To produce aggregate statistical information about users of and their activities on our website from which individuals cannot be identified.

Legal & Compliance. To investigate any claims or disputes concerning the use of our services and website. We may also share your personal data with law enforcement authorities if we are ever asked to. We will try our best to inform you before sharing your information with such an authority. However, we may not be able to notify you due to technical, administrative or legal hurdles.

Research & Development. To improve and enhance the safety and security of our services and website, as well as to design and develop new features and products relating to our services.

Principles of Data Processing

When you access our website or use the Service, we need to collect, use, and otherwise process your information, as set out in this Privacy Policy.

We understand the importance and value of your privacy and are committed to respect your privacy. We follow the following fundamental principles when we process personal data:

• We aim to collect only the minimum personal data that we need to deliver any services to you.
• We aim for full transparency on how we use your information to comply with legal or other lawful purposes and respect your privacy.
• We make sure we only use your information for the purposes you have given us permission for.
• We make sure we do not store your information for a longer period than necessary.

Legal Bases of Data Processing

We rely on a number of legal bases to collect, store and process your information, as set out in this Policy:

Consent. We rely on your consent to collect, store and process certain information about you. This is where you have actively agreed such as when you accept our use of cookies and other online trackers to collect and process certain information about your experience with us.

Performance of a contract. If you are our user meaning that you are using our services based on the Terms of Service we will process your personal data on the basis that it is necessary for us to provide our services to you.

Legal Compliance. We may have to process and share your personal data in order to comply with our legal obligations, or to protect our rights or the rights of others. For example, we may be required to comply with a subpoena, court order, or a similar legal procedure.

Legitimate interests. In some limited situations we rely on our legitimate business interests in order to collect and process your personal data. Before using your data for our legitimate interests, we always carry out a balancing test to carefully consider the impact of the processing on your interests, rights and freedoms. We only process your data if we are satisfied there is no negative impact on you. Particularly, we rely on Legitimate Interests for the following activities:

• providing, maintaining, improving and developing our services;
• analyzing the use of our services;
• using aggregated (non-personally identifiable) statistical and analysis data to identify usage trends;
• dealing with user queries and complaints;
• personalizing your experience on our website;
• identifying fraudulent behavior and ensuring our website and systems are safe and secure.

Who May We Share Your Data With?

We disclose entire or part of your personal information in the limited circumstances described below and with appropriate safeguards applicable thereto:

Our group companies, employees, and independent contractors. We may share your personal information to our group companies, subsidiaries, business partners, employees, external consultants, or other third parties that need to know the information in order to assist us provide our services, or to process the information on our behalf and also for administrative purposes. We require all of them to comply strictly with this Privacy Policy and educate them regularly on the importance and value of your personal information.

Analytics company. We engage with analytics service providers such as Google and other companies who use your information to provide us with analytical and statistical information that allows us to understand how you interact with us and how we can improve our services.

Third-Party Services. We use third-party services such as hosting service providers, project management applications for a variety of business purposes. When using such service providers may share your personal and non-personal information with them. For example, a hosting service provider will help us to host the Service and data.

Law enforcement. When we are required by law and we are requested to do so by law enforcement agencies, we may share your information with such agencies. We will try all efforts to inform you before we share any such information. However, we do not guarantee this.

Business Transfers. In connection with any merger, acquisition of all or a portion of our business by another company, sale of company assets user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events happens, we will make sure to take any relevant and reasonable steps to notify you and this Privacy Policy would continue to apply to your information and the party receiving your information shall continue to use your information, but only consistent with this Privacy Policy.

Data Retention Periods

We will not keep your personal information for any longer than is necessary in light of the reason(s) for which it was first collected. You can always request that we suspend or remove your personal data by writing to sec@spin.fi.

Security Measures

We use Secure Sockets Layer (SSL) software to encrypt the information you enter on our website in order to protect its security during transmission to and from our website.

Further, we apply access restrictions to your personal data by our employees. We make sure to educate and train our employees about the importance of confidentiality and privacy of customer personal information on a continuous basis. We maintain appropriate safeguards to protect your personal information from unauthorized access by our employees.

Please note, despite all the measures we take to maintain the safety and security of your personal information, no transmission over the Internet can ever be guaranteed to be secure. Consequently, we cannot fully guarantee the security of any personal information that you transfer over the Internet to us.

Restrictions for Minors

The Service is not directed, in any way, to children under the age of 16. If a child under 16 submits personal information to us, and we find out about this, we will immediately take reasonable steps to remove such personal information from our databases. If you happen to believe that we might have any personal information from a child under 16, please contact us using the details provided in section “Questions and contacts”.

Where We Store Your Data

The hosting facilities for our website and facilities that we use to host some data are situated in different parts of the world, including the United States of America and the European Union.

Financial and transaction data is stored on the Blockchain

By using our website and the Service you consent to any transfer, storage or processing of your personal information outside of your country. We rely on the fact that you have been properly informed in this Privacy Policy about our company and our data processing activities, and by choosing to continue using our services you are deemed to have given us the consent for the transfer of your personal information internationally. However, we will take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this Privacy Policy.

Third-Party Links

Our website may contain links to third party services and websites (“Third-Party Sites”). When you click on such a link, you will leave our website and go to another site. Please note that we have no control over and are not responsible for these Third-Party Sites.

Please be advised that the terms of this Privacy Policy do not apply to these Third-Party Sites, or to any collection of your personal information after you click on links to such websites. Thus, we strongly encourage you to read the privacy policies of every website you visit.

Cookies & Tracking Technologies

We use cookies and other similar technologies (collectively the “Cookies”) on our website and services. Cookies allow us to deliver our services to you and enhance your experience with us. We do not set any cookies on your device before obtaining your consent, unless the cookie in question is strictly necessary for the delivery of the service to you upon your request made through your web browser.

Cookies are small textual files that may be stored on your device (i.e. computer, smartphone or other device) when you visit a website. They are generally used to facilitate browsing on the website, keep track of actions within the website, measure how well the website is doing, remember your login details, and so on.

How to delete cookies?

It is you who decides whether we can install cookies on your device. You are also able to configure your browser to accept or reject cookies by default through your browser setting. You can refer to official information provided by your browser software provider on how to deactivate and delete cookies.

In the event that you set your browser to reject all cookies or delete our cookies, that may lead to the unavailability to access to some of the services provided by us and that your experience when you use the service may be less satisfactory.

Notice to EU Residents

Residents of the European Union/European Economic Area (EU/EEA) have special rights under the General Data Protection Regulation (GDPR). We work to uphold your rights under the GDPR at all times.

You can always contact us by writing sec@spin.fi in order to find out more or receive answers to your questions in connection with how we collect, store and process your personal information.

Data Subject Rights

Data subjects from the European Union have the following rights under the GDPR. We will always work to uphold your following rights:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
• The right to access the personal data we hold about you.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
• The right to ask us to delete or otherwise dispose of any of your personal data that we hold (also known as the right to be forgotten) — apart from the data that is stored on Blockchain and is unamendable
• The right to restrict the processing of your personal data.
• The right to object to us for using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

Changes to Privacy Policy

We retain the right to make changes to this Privacy Policy from time to time. This may be necessary, for example, if the laws and regulations which we are compelled to comply with change, or if we change our business in a way that affects personal data protection.

If there is any change it will be immediately posted on our website. Therefore, we strongly recommend that you revisit this page regularly to keep up-to-date. Please note, you will be deemed to have accepted the terms of the Privacy Policy on your first use of our website following the alterations.

Questions and Contacts

In order to contact us with regard to anything concerning your personal data and data protection, including to make a subject access request, please use the following details:

Email address: sec@spin.fi