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Spinnable Back to Home Privacy Policy Last updated: September 29, 2026 About This Policy At Spinnable, we believe you should understand how we handle your data, in clear, straightforward language. This Privacy Policy explains what information we collect, how we use it, and your rights to control it. Company Details: Spinnable, Inc. (Delaware C-Corp) Registered Office: 251 Little Falls Drive, Wilmington, New Castle County, Delaware 19808 Data Protection Officer: Contact at [email protected] Data Processing Agreement For details on how we process personal data on behalf of our customers as a data processor, please refer to our Data Processing Agreement. 1. What We Do Spinnable provides AI-powered digital co-workers that help you manage your work. Our AI agents can assist with email, calendar management, document processing, and communications across various platforms including WhatsApp, Slack, email, and voice. To do this effectively, we need access to certain data, but only what's necessary to provide our services. 2. Information We Collect Information You Give Us Account Information: Name, email address, company details, and payment information Platform Connections: When you connect Gmail, Google Calendar, Slack, Outlook, or other services, we receive the access permissions you grant Note on Future Expansion: As we expand our integrations and features, we may process additional types of data from new systems and platforms. We will update this policy and notify you of any material changes to data processing activities. Information We Process on Your Behalf When our AI agents work for you, they access: Email content and metadata (sender, recipient, subject, timestamps) Calendar events and availability Documents and files you share or that are stored in connected platforms Messages from WhatsApp, Slack, Teams, and other communication tools Customer data from integrated platforms like Guesty, Notion, LinkedIn, and Twitter Technical Information Usage data: How you interact with our service Device information: Browser type, IP address, operating system Performance data: To improve our AI and fix issues Cookies and Similar Technologies Our website uses cookies and similar technologies to keep the site working, remember your preferences, understand how visitors find and use the site, and measure our advertising. In the European Economic Area, the United Kingdom and Switzerland, our analytics and advertising tools (Mixpanel, Google Analytics, Meta and LinkedIn) only load after you accept them in our cookie banner. Elsewhere they load by default and you can switch them off. You can change your choice at any time from the Cookie settings link at the bottom of any page. Our Cookie Policy lists each cookie, what it is for, how long it lasts, and how to manage it. 3. How We Use Your Information We use your data to: Provide our services: Execute tasks, respond to messages, manage calendars, and process documents as instructed AI models: Spinnable does not train AI models on your data. Maintain and improve service quality: Our engineering team may access your data to debug issues, investigate problems reported by you, and develop new features to improve the service. Communicate with you: Send service updates, respond to questions, and provide support Ensure security: Detect and prevent fraud, abuse, and security threats Comply with legal obligations: Meet regulatory requirements and respond to valid legal requests What We Don't Do: We don't sell your personal data to anyone We don't use your data for advertising to third parties We don't train our AI on your confidential information without anonymization 4. How We Share Information We only share your data in these situations: With Your Permission We share information with platforms you've connected (Gmail, Slack, etc.) to perform the tasks you've requested. With Service Providers We work with trusted third-party companies that help us operate our service (cloud hosting, payment processing, analytics). These providers are contractually required to protect your data and only use it for specified purposes. For website analytics and advertising measurement we use Mixpanel, Google Analytics, Meta, and LinkedIn. Our Cookie Policy explains the technologies involved. A complete list of sub-processors is available on our Trust Center. For Legal Reasons We may disclose information when required by law, to enforce our terms, protect our rights, or respond to valid legal requests from authorities. Business Transfers If Spinnable is acquired or merged with another company, your data may be transferred as part of that transaction. You'll be notified of any such change. 5. Data Security We take security seriously and implement industry-standard measures to protect your data: Encryption: Data is encrypted in transit (TLS/SSL) and at rest Internal Access Controls: Access to customer data is restricted to authorized personnel on a need-to-know basis: Engineering Team: Can access data for debugging, quality assurance, and feature development Customer Support: Can access data to troubleshoot issues and respond to your inquiries Security Team: Can access data to prevent fraud, abuse, and security incidents Regular security testing and reviews: We continuously test and improve our security measures Secure infrastructure: We use reputable cloud providers with strong security practices However, no system is 100% secure. While we work hard to protect your data, we cannot guarantee absolute security. For certifications, security controls, and compliance documents, see our Trust Center. 6. Data Retention We keep your data only as long as necessary: Active accounts: Data is retained while your account is active and you're using our services After account deletion: We delete or anonymize your data within 90 days, except where we must retain it for legal compliance or legitimate business purposes Backups: Deleted data may persist in backup systems for up to 90 additional days before permanent deletion You can request earlier deletion by contacting our Data Protection Officer. 7. Your Privacy Rights Depending on where you live, you have specific rights regarding your data: Rights for Everyone Access: Request a copy of the data we hold about you Correction: Update or correct inaccurate information Deletion: Request that we delete your data (subject to legal obligations) Export: Receive your data in a portable format Opt-out: Unsubscribe from marketing communications Additional Rights (GDPR - EU/UK/EEA) Object to processing: Oppose certain uses of your data Restrict processing: Limit how we use your data Withdraw consent: Revoke permission for processing based on consent. For website analytics and advertising cookies, use the Cookie settings link at the bottom of any page Lodge a complaint: File a complaint with your local data protection authority Additional Rights (CCPA/CPRA - California) Know what's collected: Learn what personal information we collect Know if data is sold: We do not sell personal information Non-discrimination: Exercise rights without facing discrimination Additional Rights (Other Jurisdictions) If you're in Canada, Australia, Brazil, or other jurisdictions with privacy laws, you may have similar rights. Contact us to learn more. To exercise your rights: Email our Data Protection Officer at [email protected] We'll respond to verified requests within 30 days (or as required by applicable law). 8. International Data Transfers Our core infrastructure is hosted in the EU. Some service providers process data outside the EU, including in the US. When we transfer data internationally, we use approved mechanisms to ensure adequate protection: Standard Contractual Clauses (SCCs) approved by the European Commission Adequacy decisions recognizing equivalent privacy protection Other lawful transfer mechanisms as appropriate 9. Children's Privacy Our Services are intended solely for individuals who are at least 18 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not use the Services or provide any personal information to us. If we learn that we have collected personal information from an individual under the age of 18, we will delete that information as quickly as possible. If you believe that a person under 18 may have provided us with personal information, please contact us at [email protected]. 10. Changes to This Policy We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we'll: Update the "Last Updated" date at the top Notify you via email or through our service Give you the opportunity to review changes before they take effect (where required by law) Your continued use of Spinnable after changes become effective means you accept the updated policy. 11. Contact Us Have questions or concerns about your privacy? Data Protection Officer: Our Data Protection Officer can be reached at [email protected] Address: Spinnable, Inc., 251 Little Falls Drive, Wilmington, New Castle County, Delaware 19808 We're committed to addressing your concerns promptly and transparently. Regional-Specific Information For EU/UK/EEA Residents Legal basis for processing: Consent, contract performance, legitimate interests, and legal obligations Legitimate Interest: We have a legitimate interest in ensuring our service functions correctly and continuously improving it. This includes: Product improvement, debugging, and quality assurance: We have a legitimate interest in ensuring our service functions correctly and continuously improving it. This includes allowing our engineering team to access your data when investigating reported issues, debugging problems, and developing new features. Data Protection Authority: You can file complaints with your local supervisory authority EU Representative: Contact our DPO at [email protected] For California Residents Shine the Light: California residents can request information about sharing data with third parties for marketing purposes (we don't do this) CCPA Notice: We do not sell personal information and have not sold personal information in the preceding 12 months Authorized agent: You may designate an authorized agent to make requests on your behalf For Other Jurisdictions We comply with applicable privacy laws in all jurisdictions where we operate. Contact us for jurisdiction-specific information. This Privacy Policy is part of our Terms of Service and governs your use of Spinnable's services. Terms & ConditionsData Processing AgreementTrust Center