Privacy Policy

This Privacy Statement explains the ways Spinwheel Solutions Inc. (collectively, “Spinwheel”, “we”, “our”, and “us”) collect, use, and share information about you in connection with your access to or use of Spinwheel’s websites and our products and services (collectively, “Services”), and in connection with any other information we collect when you interact with us, except as outlined in the paragraph below. We hope you will take some time to read this Privacy Statement carefully.

Please note that this Privacy Statement does not apply to the information we collect about the end users of our developers’ software applications or when you otherwise connect your financial accounts through Spinwheel, except as otherwise provided herein. If you are an end user of one of our developers’ applications or have connected your financial account through Spinwheel, please refer to our End User Privacy Policy.

As explained in greater detail below, Spinwheel has collected identifiers, electronic network activity information, professional information, location information, and other types of information.

Information you provide to Spinwheel directly. We collect the information you provide directly to us, such as the information you provide when you create a developer account, update your profile, fill out our “contact us” form, sign up for our emails, request customer support, enroll in billing, execute a services agreement, complete a compliance questionnaire, or otherwise communicate with us. The types of information we collect include identifiers (such as full name, email address, postal address, phone number, driver’s license, and taxpayer identification number), professional information (such as company name and title), and any other information you choose to provide (such as date of birth or personal information you may disclose to us in support messages).

Information we receive when you test our technology. You may provide us with login information for your bank account or other financial account to test and evaluate how our technology will appear and operate in your application. If you test our technology in this way, we collect information as described in our End User Privacy Policy.

Information we collect when you use our Services. When you use our Services, we automatically collect information about you as follows:

• Log Information: We collect log files when you use our Services, which includes identifiers and electronic network activity information, such as the type of browser you use, access times, pages viewed, and your IP address.

• Approximate Location: We derive the approximate location of the device you use to access our Services from your IP address.

• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect identifiers and electronic network activity information when you use our Services, including cookies and web beacons. Cookies are small data files stored by your web browser, on your hard drive, or in device memory that help us improve our Services and your experience, determine usage of parts and features of our Services, and monitor for and detect potential harmful conduct. Web beacons are electronic images that are used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. You can find more information about how we use cookies and your related choices in our Cookie Policy.

Information we collect from other sources. We also collect information about you from other sources. For example, we may collect information from other members of your company and from vendors that help us identify new customers, including identifiers, such as your name, email address, and social media profile URL.

How We Use Your Information

We use the information we collect for the following business and commercial purposes:

• To operate, improve, and develop our Services;

• To verify your identity and the identities of other members of your company;

• To bill developers for our Services and to transmit payment;

• To comply with law, such as for tax reporting purposes;

• To send you technical notices, updates, security alerts, and administrative messages;

• To respond to your comments, questions, inquiries, and customer service requests;

• To help personalize the Services experience for you;

• To communicate with you about products, services, offers, and events offered or sponsored by Spinwheel, and to provide news and other information we think may be of interest to you;

• To monitor and analyze trends, usage, and activities in connection with our Services;

• To detect and prevent fraud, malicious activity, and other illegal activities;

• To protect the rights, privacy, safety, or property of Spinwheel and others; and

• For any other purpose described to you when the information was collected.

How We Share Your Information

We share information about you as follows, or as otherwise described in this Privacy Statement:

• With our data processors and other service providers, partners, contractors, or vendors in connection with the services they perform for us, including collection agencies in the event of delinquent payments from our developers;

• If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena), including in connection with requests from law enforcement or other governmental authorities;

• If we believe your actions are inconsistent with our agreements or policies, or to protect the rights, privacy, safety, or property of Spinwheel or others;

• In connection with a change in ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy);

• Between and among Spinwheel and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership; and

• With your consent or at your direction.

We also collect, use, and share aggregated, de-identified, or anonymized information for any purpose permitted under applicable law.

We do not sell or rent personal information that we collect.

Advertising and Analytics Services Provided by Others

We allow third parties to provide analytics services and serve advertisements on our behalf across the internet, including Google Analytics. These entities use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information is used by Spinwheel and these third parties to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and online services, and to better understand your online activity.

For more information about interest-based ads, including to learn how you may be able to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. For more information about how Google uses your data, please visit www.google.com/policies/privacy/partners/.

Your Choices

• Developer Account Information. You may update information you provide to us as part of your developer account.

• Cookies. You can find more information about how we use cookies and your related choices in our Cookie Policy.

• Marketing Communications. You may opt out of receiving marketing emails from Spinwheel by following the instructions in those emails. If you opt out and are one of our developers, subject to limitations and exceptions provided by law, we may still send you other types of emails, such as those about your account or our ongoing business relations.

Your Data Protection Rights

Depending on your jurisdiction, you have certain rights under applicable law regarding the personal data we process, which may include the right to request access or deletion.

If you are a resident of California, subject to limitations and exceptions provided by law, you have the right to: (i) request access to the categories and specific pieces of personal information collected about you in the last twelve months (including personal information disclosed for business purposes); (ii) request deletion of your personal information; (iii) opt-out of any sales of your personal information if a business is engaged in selling your information; and (iv) not be discriminated against for exercising these rights.

As described above in “Your Choices,” if you are one of our developers, you can access your account information. To otherwise exercise your data protection rights, where applicable, please submit a request using our online form (available here ), or contact us at the contact information provided below. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

Changes To This Policy

We may update or change this Policy from time to time. If we make any updates or changes, we will post the new policy on Spinwheel’s website at https://www.spinwheel.io/legal and update the effective date at the top of this Policy. We will also notify developers of any material changes in accordance with our developer agreements, as they are generally best positioned to notify their end users about such changes to this Policy, as appropriate.

Contacting Spinwheel

If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at hello@spinwheel.io or by mail at: 490 43rd Street Unit 24 Oakland, California 94609.