Your privacy matters to us at SpinCar. This Privacy Notice (Notice) explains the personal information SpinCar may collect. It applies to our suite of digital merchandising products, our website, and our mailing list. If you have questions about the Notice, please feel free to contact us at email@example.com. The Notice explains how we collect, use and share personal information. You have several rights concerning your information. Please read the Notice carefully to understand what we do and what your rights are.
Who we are
We are Augmented Reality Concepts, Inc. (d/b/a SpinCar). We can be reached at firstname.lastname@example.org or
Attn: Data privacy
344 S Warren St, Suite 200
Syracuse, NY 13202
We create interactive images of vehicles, display them on the websites of our customers, such as car dealers, help our customers display relevant ads on websites, and provide our customers with information about the use of their websites. References to “we”, “us”, and “our” mean SpinCar. References to “third-party” mean someone who is not you or us.
Who you are
In the Notice, “you” means you as a:
- Consumer — a visitor to the website of one of our customers. If you are a Consumer, you have no direct relationship with SpinCar.
- Customer of SpinCar — a representative of a company that uses SpinCar’s services and is a customer of SpinCar.
- Prospective customer of SpinCar — a visitor to the spincar.com website, who may submit a contact request form and may become a customer of SpinCar.
What legal basis do we have for processing your personal information?
We process your personal information based on:
- Taking action on your requests, such as viewing images of and receiving information about relevant vehicles.
- Our legitimate interest in marketing relevant vehicles to consumers and receiving information about which web pages, vehicles and vehicle features are important to Consumers.
- Consent you provide when you submit a contact request form and where we do not rely on another legal basis. You have the right to withdraw your consent at any time.
What information do we collect?
As a Consumer, if you visit the website of one of our Customers, we may collect your IP address, the type of device or web browser used, and a record of pages viewed, items viewed on those pages, and amount of time spent viewing them. We may look up the IP address and store the corresponding geographic address. We do not collect your name, email, phone or other personal information unless you choose to provide this information by submitting an online contact form. If you choose to provide personal information to us or one of our Customers, we or the Customer may collect this information and may combine it with your IP address, device and pageview information.
As a SpinCar Customer, we may collect your name, email address, phone number, mailing address, billing information and other details necessary to provide our services to you.
As one of our Prospective Customers, if you submit a contact request form on the spincar.com website, we may collect your name, email address, and any messages you send us.
How do we use personal information?
We use the information we collect from you as a Consumer to show you images of and information about relevant vehicles and to inform Customers about web pages, vehicles and vehicle features that Consumers have viewed.
We use the information we collect from Customers to set up and administer your account, to provide you with training and technical support, to send you reports via email, to market additional SpinCar services to you, and for billing purposes.
We use the information we collect from Prospective Customers to answer your inquiries and to market SpinCar’s services to you.
When do we share personal data?
We may share information about you with:
- Customers by providing reports about usage of their websites.
- Resellers who provide SpinCar’s services to our Customers on our behalf. These partners may have access to the same reports.
- Customers by forwarding the information you provide by submitting an online contact form, but only if you submit such a form.
- A third-party service to use your IP address to look up the corresponding geographic address.
- Vendors such as MailChimp that help us manage email communications, Stripe that help us with billing, and Zendesk that help us manage support tickets.
Where do we store and process personal data?
We store the information we collect from you on servers provided by Amazon Web Services in the US and Ireland. For development and testing purposes, the information we collect from you may also be stored on desktop and laptop computers used by SpinCar employees and partners in the US and other countries. The information we collect from you in the EU may be transferred from and kept outside the EU because our operations are located in the US. We rely on the EU-U.S. Privacy Shield in order to transfer your information outside the EU.
How long do we keep your personal data?
In our primary data store on Amazon Web Services, we retain your information for 60 days. We also may retain your information indefinitely in the following secondary data stores:
- Database backups
- Log files
- Reports that were generated using the information
Old records in the primary data store are detected and removed automatically using built-in Amazon Web Services functionality.
What are your rights?
You have the right:
- To know if we are collecting, using or sharing your information and to request access to this information.
- To request that we correct your information if it is inaccurate or incomplete.
- To ask us to erase your information if
- Your information is no longer necessary for the purposes for which it was collected, used or shared.
- You withdraw the consent on which the collection, use or sharing is based.
- You object to the collection, use or sharing and there is no overriding legitimate interest for continuing the collection, use or sharing.
- You object to the collection, use or sharing of your information for direct marketing purposes.
- Your information was unlawfully collected, used or shared.
- Your information has to be erased in order to comply with a legal obligation.
- Your information was collected in order to offer online services to children.
- To obtain from us a restriction on the collection, use or sharing of your information if
- You contest the accuracy of your information.
- You have objected to the collection, use or sharing based on legitimate interest and we are considering whether our or a third-party’s legitimate interest ground overrides your interest.
- The collection, use or sharing is unlawful, and you oppose erasure and request the use be restricted instead.
- We no longer need your information, but you require your information to establish, exercise or defend a legal claim.
- To be able to take with you the information you provided to us and to transmit that information to another organization where our collection, use or sharing of that information is carried out by automated means and is based on your consent or the performance of a contract.
- To object to collection, use or sharing based on the purposes of legitimate interest or performance of a legal task, direct marketing and scientific/historical research and statistics.
- Not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you.
- To lodge a complaint with a supervisory authority.
How do you exercise your rights?
As a Customer or Prospective Customer, you may access, correct, or delete your account information or cancel your account at any time by emailing us at email@example.com. Please note that in some cases we may retain certain information about you as required by law or for legitimate business purposes to the extent permitted by law.
You can opt out of our marketing communications at any time, and you have the right to be removed from our email list at any time, using the opt-out link provided in our mailings. If you opt out, we may still send you non-promotional communications, such as those about your account or about our ongoing business relations. SpinCar does not endorse or take responsibility for content on other websites accessed from links on spincar.com.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
The Privacy Shield Principles
Recourse, Enforcement and Liability
SpinCar’s participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework is subject to investigation and enforcement by the U.S. Federal Trade Commission.
In compliance with the Privacy Shield Principles, SpinCar commits to resolve complaints about its collection or use of your personal data. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact SpinCar at: firstname.lastname@example.org.
SpinCar has further committed to refer unresolved Privacy Shield complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks to TrustArc, an alternative dispute resolution provider located in the U.S. If you do not receive timely acknowledgement of your complaint from us, or your complaint is not satisfactorily resolved, please contact or visit TrustArc for more information or to file a complaint. The services of TrustArc are provided at no cost to you.
Under certain conditions, an individual has the possibility to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Please see Annex 1 for more information.
The Federal Trade Commission has jurisdiction over SpinCar’s compliance with the EU-U.S. and Swiss Privacy Shield Frameworks.
SpinCar may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Accountability for Onward Transfer
In the event we transfer personal data covered by this Privacy Shield Policy to a third-party acting as a controller, we will do so consistent with any notice provided to individuals and any consent they have given and only if the third-party has given us contractual assurances that it will (i) process the personal data for limited and specified purposes consistent with any consent provided by the individuals, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it make a determination that it cannot do so, and (iii) cease processing of the personal data or take other reasonable and appropriate steps to remediate if it makes such a determination.
In the event we transfer personal data covered by this Privacy Shield Policy to a third-party acting as an agent, we will (i) transfer such data only for limited and specified purposes, (ii) require the agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles, (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal data transferred in a manner consistent with our obligations under the Privacy Shield Principles, (iv) require the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, and (v) upon notice (including that it can no longer provide the same level of protection as is required by the Privacy Shield Principles), take reasonable and appropriate steps to stop and remediate unauthorized processing.
SpinCar is responsible for the processing of personal data it receives under the Privacy Shield and subsequently transfers to a third-party acting as an agent on its behalf and remains liable under the Privacy Shield Principles if its agent processes such personal data in a manner inconsistent with the Privacy Shield Principles, unless SpinCar proves that it is not responsible for the event giving rise to the damage.