Effective date: June 15, 2020

Spin Live, Inc. ("Spin", "we", "us", or "our") is committed to respecting the privacy and security of your personal information. This Spin Privacy Policy describes how we collect, use, and share information that we process in connection with your use of the Spin website, however accessed, and application (collectively, "App") that links to this Privacy Policy.

Spin's App allows you to interact with third-party retailers and merchants (collectively, "Merchants") who promote and sell their products ("Products") to you through third-party individuals who host ("Host") livestreamed or recorded shows and marketing events ("Events") through our App. Please review this Privacy Policy carefully to better understand our privacy practices as you use our App. If you do not agree with our them, do not use our App. By browsing, accessing or using our App, you agree and accept the privacy practices set forth in this Privacy Policy.

The Information We Collect

The information we collect varies depending on the type of activity you are performing on our App. When you use the App we collect the follow information:

  • Information you provide to us,
  • Other information we collect automatically when you use our services (for example technical information or information from technologies such as "cookies")

Below we explain each of these ways in more detail.

Information You Provide Us

When you sign up to become a registered user, engage in Events, or otherwise communicate with us or use our App to purchase Products, we collect certain personal information that you provide us such as:

  • Name
  • e-mail address
  • Address
  • Phone Number
  • Credit or debit card number or other payment information
  • Video or photographs

Social Media Log-in: If you use the option to log in with a social media account we will receive the information included in your public profile, such as your social media handle, your gender, age range, country, and language.

Other Information

In addition to the information noted above, we may collect certain information automatically by means of various software tools in order to provide our App and services (collectively, the "Other Information"). We have a legitimate interest in using such information to assist in systems administration, information security and abuse prevention, to track user trends, and to analyze the effectiveness of our services. Below are examples of information we collect automatically

Log Files

Log files refers to the information that is automatically sent by your web browser or device (or otherwise automatically collected) each time you view or interact with our App. The information inside the log files may include IP addresses, type of browser, internet service provider, date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.

Device and Online Usage Information

We may collect information about your mobile phone, computer, browser, mobile or other device that you use to access our App. We may use cookies, pixels, log files and other techniques to collect such information, including IP address, device identifiers and other unique identifiers such as universally unique ID ("UUID") and advertising identifier ("IDFA"), MAC address, operating system and version (e.g., iOS, Android or Windows), carrier and country location, browser type, browser language, operating system name and version, device name and model, version, camera resolution, network type, referring and exit pages, dates and times of service access, links clicked, features uses, crash reports and session identification information.


Information that we collect using "cookie" technology. Cookies are small packets of data that a website stores on your computer's or mobile device's hard drive so that your computer will "remember" information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience. We use cookies that enable you to navigate our service and use its features, such as accessing secure areas of our App. Because required cookies are essential to operate our Service, there is no option to opt out of these cookies. We use cookies to provide features and services such as:

  • Remembering your preferences and allowing you to enter your information less frequently;
  • Presenting information that's targeted to your interests, which may include our content presented on another website;
  • Measuring the effectiveness of our sites, services, content, and advertising;
  • Providing other services and features that are only available through the use of cookies.

How to Manage Cookies

The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be transferred to your device, including how to disable such technologies. You can disable our cookies or all cookies through your browser settings, but please note that disabling cookies may impact some of our service features and prevent the service from operating properly.

Web Beacons and Similar Tracking Technologies

When you visit our service, we may also use web beacons alone or in conjunction with cookies to compile information about your usage of our service and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. We may use web beacons to operate and improve our App and optimize advertising to you.

How We Use Your Information

We use the personal information and Other Information (collectively, the "Information") we collect through our App for a variety of purposes that serve your needs and Spin's legitimate interests. More specifically, we use your Information to:

  • Provide you with the services on our App, including enabling you to purchase Products and engage with Merchants and Hosts
  • Process your transactions and enable Merchants to fulfill Product orders
  • Provide, analyze, administer, improve, and personalize the App, our products, or services
  • Communicate with you in connection with the service, notifications, events, programs or offerings;
  • Administer promotional programs
  • Solicit your feedback or administer surveys about your preferences or interests
  • Provide personalized advertising to you;
  • Enable you to participate in blogs and post testimonials. If you provide a testimonial, your name will be publicly posted along with the testimonial. Please remember that blogs and testimonials are located in the public areas of our Site. Do not share content that you would not want others to read, save, or share
  • Protect our rights or our property and to ensure the technical functionality and security of the service
  • Comply with applicable law, assist law enforcement, and to respond to regulatory or other legal inquiries.
  • Fulfill any other purpose for which you direct us to use your Information or provide consent for us to use it

How We Use Aggregated or Deidentified Information

To better serve our users, business partners, and to improve our App or services, we may conduct research on user demographics, interests and behavior or engage in other activities based on personal information that we aggregate or de-identify. Aggregated or de-identified information is not considered personal information and does not identify a user personally. We may share this aggregated or de-identified information with our affiliates, agents, business partners, and/or other third parties within our discretion.

How We Share Your Information with Third Parties

In operating and providing you our App and services, we may share your Information in the following ways:

  • With our Merchants, Hosts, and other service providers — We disclose Information with our third-party Merchants and Hosts as part of our services on our App, but only so that they can interact with you to provide you services on our App, including fulfilling Product orders or engaging with you through Events. We also provide your Information to our other third-party service providers to perform tasks on our behalf and to assist us in providing our App and services. For example, we may share your Information with service providers who assist us in performing core functions (such as hosting, payment processing, data storage, and security) related to our operation of the App or services and/or by making certain interactive tools available to you as a user.
  • With third parties for legal or security reasons
    • We may share information about you if we reasonably believe that disclosing the information is needed to:
      • comply with any valid legal process, governmental request, or applicable law, rule, or regulation.
      • investigate, remedy, or enforce potential violations of our Terms of Use or Privacy Policy
      • protect the rights, property, and safety of us, our users, or others.
      • detect and resolve any fraud or security concerns.
  • With third parties as part of an acquisition or liquidation
    • We are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company or if we undergo liquidation or bankruptcy proceedings, we may share your information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed.
  • With your consent —We may share information in other ways if you give us consent or direct us to do so.

How We Share Your Information On Our App

The App is a live video broadcasting service. Except for your personal information (like your email, phone number and passwords) which are not publicly available, the information you share and the content you voluntarily submit – for example in comment or chat areas or – when using the App is public. In addition to the content you voluntarily share, other information associated with your account (like your profile information which includes your name or username, user icon) is available to other users on our App, for example when you buy a product in our Shopping Game, we will identify you as a buyer by displaying your Spin username.

How We Use Analytics Services, Including Google Analytics

We use third-party analytics services (such as Google Analytics) to evaluate your use of the App, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the App and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. For example, we use Google Analytics on our Services to track user trends and usage. For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the App.

How We Protect the Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. Accordingly, you use the App and our services at your own risk.

Do Not Track Signals

We do not currently respond or take any action with respect to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of information about an individual consumer's online activities over time and across third-party websites or online services.

Access and Control of Your Information

We enable you to have control over the accuracy of your personal information. If you have registered for the App, you may access, review, and make changes to your personal information and certain Other Information by following the instructions found on the App. You may also send us an e-mail at ­­­­­­­legal@spin.live. To protect your privacy, before we give you access or let you update your information, we may ask you to verify your identity or provide additional information. We will try to update and allow you to access your information for free, but if it would require a disproportionate effort on our part, we may charge a fee that is calculated in accordance with applicable law. We will disclose the fee before we comply with your request. We may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users, requires technical efforts that are disproportionate to the request, is repetitive, or is unlawful.

California visitors

Residents of the State of California may request a list of all third parties to which Spin has disclosed certain information collected in connection with this App during the preceding year for the third parties' direct marketing purposes. We do not, however, share your Information with third parties for their own marketing purposes.

Important Notice to Non-U.S. Residents

It is important to note that the App and its servers are operated in the United States. Spin does not direct its App or services to any users outside the United States. If you are located outside of the United States, you accept the privacy practices set forth herein.


We do not knowingly collect Personal Information from children under the age of 13 through the App and our Accounts and access to the App are limited individuals 17 years of age or older. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

External Sites

The App may contain links to External Sites, and we have no control over the privacy practices or the content of any External Sites or any other websites of our business partners, advertisers, or sponsors. We are not responsible for the content or the privacy policies of External Sites, and you should check the applicable third-party privacy policy and terms of use when visiting any External Sites.

Social Media and Plug-Ins

Our online services may use social media plug-ins (e.g., the Facebook "Like" button, "Share to Twitter" button) to enable you to easily interact with certain social media websites (e.g., Facebook, Twitter, Instagram) and share information with others. When you visit our online services, the operators of the available social media plugins can place a cookie on your device enabling such operators to recognize individuals who have previously visited our online services. If you are logged into these social media websites while visiting our online services, the social media plugins allow the relevant social media websites to receive information that you have visited our online services or other information. The social media plugins also allow the applicable social media websites to share information about your activities on our online services with other users of the social media website. For example, Facebook Social Plugins allow Facebook to show your "Likes" and comments on our online services to your Facebook friends. Facebook Social Plugins also allow you to see your friends' Facebook activity on our online services. We do not control any of the content from the social media plugins. We may also interact with you on social media platforms. If you contact us on one of our social media platforms, request services, or otherwise communicate directly with us on social media, we may contact you to interact with you. For more information about social media advertising and social media plugins from other social media websites, please refer to those websites' privacy and data sharing statements.

Location-Based Services

We collect information about your estimated location which may be deduced by various technologies including IP address. While we do not currently collect precise geolocation, but if we enable that, we will obtain your consent or acknowledgement before doing so.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. By accessing the App and/or using our services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please contact us via e-mail at legal@spin.live with "Privacy Policy" in the subject line.