Last modified: December 17, 2021

unspun ("unspun" or "We") respects your privacy and is committed to protecting it through our compliance with this privacy policy.

This privacy policy describes the types of information we may collect from you or that you may provide to us when you visit unspun.io or use our mobile device application (our "Website and Mobile App") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. 

If you do not agree with our policies and practices, your choice is not to use our Website and Mobile App. By accessing or using this Website and Mobile App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website and Mobile App after we make changes is deemed to be acceptance of those changes, so please check this privacy policy periodically for updates. 

CHILDREN UNDER THE AGE OF 16

Our Website and Mobile App is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website and Mobile App. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website and Mobile App or use any of the interactive or public comment features of this Website and Mobile App. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@unspun.io.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Personal Information. We collect several types of information from and about users of our Website and Mobile App, including information: (i) by which you may be personally identified, such as name, postal address, e-mail address, telephone number, 3D body scan used to create patterns for pants (or jeans) that are unique to your body shape, gender and any other identifier by which you may be contacted online or offline; (ii) that is about you but individually does not identify you; and/or (iii) about your internet connection, the equipment you use to access our Website and Mobile App, and usage details.

We collect the following information: (i) directly from you when you provide it to us; (ii) automatically as you navigate through the Website and Mobile App. Information collected automatically may include usage details, IP addresses, and information collected through cookies. 

Information You Provide to Us. The information we collect on or through our Website and Mobile App may include:

  • Information that identifies you such as your first and last name, username, gender and data of birth. You provide such information on the Website and Mobile App when you create an account or place an order. 
  • Information from you regarding the type of clothing you prefer. You might provide this information at the time of registering for an account or when using our Website and Mobile App.  
  • Feedback information or surveys you provide about our product, a problem with your order, your in-store shopping experience, or our Website and Mobile App (i.e., your experience booking an appointment at one of our locations).
  • Your 3D body scan data captured through the 3D body scanner in the store, on our Mobile App via TrueDepth Data, or by opting-in through a third party mobile scanning app or website.
  • Your photos and videos that you upload on the Website and Mobile App. 
  • Any content (which is public and not subject to this privacy policy) you provide on our forums, blogs, or social media pages. Such content is public, therefore please be aware that your posted information through these channels may not be protected. 
  • Billing information such as billing address, delivery address, email address, including payment information when you check-out of the on-line store to finalize a purchase. 
  • Job application, resume, employment history.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your profile data such as your username and password, purchase or orders made by you, preferences, feedback and survey responses.  
  • Information you provide if you participate in a sweepstake or contest. 
  • Your search queries on the Website and Mobile App.

“TrueDepth Data” Usage: By choosing to scan using our Mobile App, you are consenting to share data from your phone’s TrueDepth sensor with us (“TrueDepth Data”). TrueDepth Data will NOT be used for marketing, advertising or use-based data mining, including by any third parties. TrueDepth Data will only be used to create patterns for pants (or jeans) that are unique to your body shape. TrueDepth Data will not be used for any other purposes.

INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES  

Information about Your Computer or Device. As you navigate through and interact with our Website and Mobile App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website and Mobile App, including traffic data, logs, and other communication data and the resources that you access and use on the Website and Mobile App.
  • Information about your computer or device and internet connection, including your IP address, operating system, browser type, and device model.

Information about Your Activities. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). If you wish to opt-out, please contact us at privacy@unspun.io. 

Do Not Track”. Our Website and Mobile App does not support Do Not Track settings (“DNT”) at this time. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your website visits collected across websites when you have not interacted with that service on a page.

Statistical Data. The information we collect automatically includes statistical data which helps us to improve our Website and Mobile App and to deliver a better shopping on-line shopping experiences, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Speed up your searches.
  • Recognize you when you return to our Website and Mobile App.

Technologies We Use. The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website and Mobile App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website and Mobile App.
  • Flash Cookies. Certain features of our Website and Mobile App may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website and Mobile App. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our the Website and Mobile App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies.

  • Some content or applications, including advertisements, on the Website and Mobile App are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 
  • We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and Mobile App and its contents to you.
  • To fulfill your order.
  • To provide you with information about our products or services that you request from us.
  • To use 3D body scans, TrueDepth Data, gender, date of birth and other related information to create and design a pattern for pants (i.e., jeans) that are customized specifically to your body shape. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website and Mobile App.
  • To advertise or market (including promotions and specials) to you regarding products or services based on your interests.
  • To allow you to participate in interactive features on our Website and Mobile App such as booking an appointment in the store.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent. 

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

Aggregate Data. We may disclose aggregated information about our users that does not identify any individual, without restriction. 

We may disclose personal information to third parties. We do not rent, sell, or share your personal information about you with other people or nonaffiliated companies for their direct marketing purposes. We use third party service providers to perform functions or services on our behalf. When we transfer your information, we require all our service providers to maintain the privacy, confidentiality and security of the personal information and data. We take steps to ensure that these parties take protecting your privacy as seriously as we do. We may disclose:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them (i.e., credit card processors, shipping, hosting services, web analytics, and other services). 
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by unspun about our Website and Mobile App users is among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website and Mobile App, we will transmit the contents of that email and your email address to the recipients.

Other Reasons to Disclose Your Information. We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Sale and Website and Mobile App Terms of Use unspun.io/terms or and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of unspun, our customers, or others. 

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the ability to control over your information. 

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Promotional Offers from unspun. If you do not wish to have your email address used by unspun to promote our own or third parties' products or services, you can opt-out by sending us your request to opt-out to privacy@upspun.io. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by email at privacy@unspun.io. 

Third Parties. 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. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

California Residents. California residents may have additional personal information rights and choices. Please see Privacy Notice for California Residents unspun.io/ccpa for more information.

Nevada Residents. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit their request by email at privacy@upspun.io. However, please know we do not currently sell data triggering that statute's opt-out requirements.

YOUR CHOICES (ACCESSING OR CORRECTING YOUR INFORMATION AND OPTING-OUT)

Right to withdraw consent. To the extent unspun requests and you provide your consent to the processing of your personal information, you can withdraw your consent at any time by contacting us by email at privacy@unspun.io. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.

Change Personal Information. You can review and change your personal information by logging into the Website and Mobile App and visiting your account profile page. 

Access, Correct, Delete. You may also send us an email at privacy@upspun.io to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from the Website and Mobile App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website and Mobile App users. Proper access and use of information provided on the Website and Mobile App, including User Contributions, is governed by our Terms of Sale and Website and Mobile App Terms of Use unspun.io/terms.

Right to erasure (or, “Right to be Forgotten”).  As explained above, we allow you to delete your account at any time. You can request erasure of personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing to which you previously consented, but later withdrew such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

Data Portability. If you would like us to transmit your personal information to another company providing similar services and we are required to so by law, we will work with them to do so upon request and verification of such request with both the requestor and the company receiving the Personal Information. 

Object to Processing or Redress for European Residents. Object to processing of your personal data when there is something about your particular situation which makes you want to object to processing on this ground. Please see our Privacy Shield Policy unspun.io/privacy-shield.

Personal Information for California Residents. California residents may have additional personal information rights and choices. Please see Privacy Notice for California Residents unspunt.io/ccpa for more information. 

INTERNATIONAL TRANSFERS

Whenever we transfer your personal data out of the European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. 

EU-US Privacy Shield. Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield unspun.io/privacy-shield.

Model Contract Clauses. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Standard Contract Clauses (Model Contracts) at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en for the transfer of personal data to third countries. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website and Mobile App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website and Mobile App like message boards or product reviews. The information you share in public areas may be viewed by any user of the Website and Mobile App.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website and Mobile App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website and Mobile App. 

RECORDS RETENTION

We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy policy, unless a longer retention period is required or permitted by law. 

The criteria we use to determine our retention periods include: (i) the duration of our relationship with you; (ii) whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us; (iii) whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit PRIVACY NOTICE FOR CALIFORNIA RESIDENTS unspun.io/ccpa.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website and Mobile App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@unspun.io.

NEVADA RESIDENTS  

Pursuant to Nevada law, you may direct a business that operates an internet website not to sell certain Personal Information a business has collected or will collect about you. unspun does not sell your personal information pursuant to Nevada law. For more information about how we handle and share your personal information or your rights under Nevada law, contact us at privacy@unspun.io.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website and Mobile App home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and Mobile App and this privacy policy to check for any changes.

CONTACT INFORMATION

To ask questions, make a complaint or comment about this privacy policy and our privacy practices, contact us at: 

Data Protection

unspun

371 10th Street

San Francisco, CA 94103

privacy@unspun.io

unspun

Privacy Notice for California Residents

Effective Date: [DATE]

Last Reviewed on: [DATE]

This Privacy Notice for California Residents supplements the information contained in the unspun Privacy Policy unspun.io/privacy or  our mobile device application (“Website and Mobile App” and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. In the event of any conflict between the terms of this notice and the Website and Mobile App Privacy Statement, the terms of this notice prevail.

INFORMATION WE COLLECT

Our Website and Mobile App collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). 

In particular, our Website and Mobile App has collected the following categories of personal information from its consumers within the last twelve (12) months: 

Category

Information Collected

Identifiers

A real name, postal address, employer (company name), title, credit card, unique personal identifier, online identifier, Internet Protocol address, email address, account name

Categories of personal information described in California Customer Records Statute

Education and employment history for employment candidates

Protected classification characteristics federal law

Gender, date of birth, age (such factors help characterize body shape) 

Commercial information

Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Biometric information

3D body scans, TrueDepth Data.

Internet or other network activity

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Geolocation Data

Physical location. 

Inferences drawn from other personal information

Profile reflecting a person’s preferences and behavior



Our Website and Mobile App obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, we collect your name, address and telephone number when you set up an account or place an order.
  • Indirectly from you. For example, from observing your actions on our Website and Mobile App using cookies.  

USE OF PERSONAL INFORMATION

We do not rent, sell, or share your personal information about you with other people or nonaffiliated companies for their direct marketing purposes. We may use (or disclose to a third party service provider) your personal information for one or more of the following purposes: 

  • To create, maintain, customize, and secure your account with us.
  • To process your payment, facilitate orders, new product orders, delivery, process returns.  
  • To fulfill or meet the reason you provided the information. For example, we collect your body scan (and gender) so we can make a pattern that is unique to your body. 
  • To communicate with you when you request a price quote or ask a question about our products or services. We may use your personal information to respond to your inquiry. 
  • To provide, support, personalize, and develop our Website and Mobile App, products, and services. For example, when you book an appointment with one of stores, you register with your name,  email address, and telephone number so we can text you to confirm your appointment. 
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website and Mobile App experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and Mobile App, third-party sites, and via email or text message (with your consent, where required by law).
  • To process your employment application. 
  • To help maintain the safety, security, and integrity of our Website and Mobile App, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website and Mobile App, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us  about our Website and Mobile App users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION

We may disclose your personal information to a third party for a business purpose. 

Business Purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Third Party Service Providers. We share your personal information with the following categories of third party service providers: hosting services, email service providers, credit card processors, marketing support services, database management, data analytics providers (Google Analytics), and social networks. 

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, unspun has disclosed the categories of personal information set forth in the above table of Categories of personal information for a business purpose. 

We disclose your personal information for a business purpose to third party service providers.

YOUR RIGHTS AND CHOICES 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Request Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request). 

Deletion Request Rights 

  • Request to Delete Personal Information. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 
    • Your Request to Delete May be Denied. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 
      • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product refund conducted in accordance with federal law, or otherwise perform our contract with you.
      • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
      • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      • Comply with a legal obligation.
      • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    Exercising Access, Data Portability, and Deletion Rights

    • Contact Us. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us by email or by mail. See our contact information below. 
    • You Must Verify Yourself. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and (ii) describe you request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

    Response Timing and Format

    We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 

    NON-DISCRIMINATION

    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

    However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. 

    OTHER CALIFORNIA PRIVACY RIGHTS

    California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website and Mobile App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@unspun.io or write us at: 371 10th Street, San Francisco, CA 94103.

    CHANGES TO OUR PRIVACY NOTICE

    We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and Mobile App and update the notice's effective date. Your continued use of our Website and Mobile App following the posting of changes constitutes your acceptance of such changes.

    CONTACT INFORMATION

    If you have any questions or comments about this notice, the ways in which unspun collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

    Data Protection

    unspun

    371 10th Street

    San Francisco, CA 94103 

    privacy@unspun.io 

    Privacy Shield Policy

    This Privacy Shield Policy ("Policy") describes how unspun, Inc. and its subsidiaries and affiliates in the United States ("US") ("Company," "we," or "us") collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area ("EEA"), and Switzerland ("Personal Data"). This Policy supplements our Website and Mobile App, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website and Mobile App. If there is any conflict between the terms in Website and Mobile App and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

    uspun recognizes that the EEA, and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, and. To provide adequate protection for certain Personal Data about consumers, corporate customers, clients, suppliers, and business partners received in the US from the EEA, and Switzerland, unspun has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). unspun adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

    For purposes of enforcing compliance with the Privacy Shield, unspun is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at https://www.privacyshield.gov. To review unspun's representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at https://www.privacyshield.gov/list.

    PERSONAL DATA COLLECTION AND USE 

    Our Website and Mobile App describes the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. We may receive the categories of Personal Data in the US. Please see (Information We Collect About You and How We Collect It) We process Personal Data for the purposes described on our Website and Mobile App (How We Use Your Information).  unspun will only process Personal Data in ways that are compatible with the purpose that unspun collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt-out  unspun maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

    DATA TRANSFER TO THIRD PARTIES

    Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Privacy Policy. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

    Third-Party Data Controllers. In some cases, we may transfer Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for purposes described in our Website and Mobile App. We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in if the Privacy Shield requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the Privacy Shield requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received.

    Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

    SECURITY

    unspun maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

    ACCESS RIGHTS

    You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

    QUESTIONS OR COMPLAINTS

    You can contact us directly with any questions or complaints about the use or disclosure of your Personal Data. Please see contact information below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. 

    If you are unsatisfied with the resolution of your complaint, you also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement. You can find the relevant supervisory authority name and contact details here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en.

    BINDING ARBITRATION 

    You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (i) raised your complaint      directly with unspun and provided us the opportunity to resolve the issue; (ii) made use of the independent dispute resolution mechanism identified above; and (iii) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework Annex I (Binding Arbitration) at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.  

    CONTACT US

    If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows: 

    Data Protection

    unspun

    371 10th street

    San Francisco, CA 94103

    privacy@unspun.io

     

    CHANGES TO THIS POLICY

    We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements.

    Effective Date: December 17, 2021