Privacy & Data Protection

Privacy Policy

Effective Date: 30 November 2023

SpinCrunch, an enterprise analytic service brought to you by Spin Mobile Limited and its affiliates, (referred to in this policy as “we” “us” or “our”) is committed to maintaining the trust of our Clients and Customers. Please read this policy (the “Privacy Policy”) carefully to learn more about our privacy practices and policies with respect to Consumer Data (defined below) that is collected and/or processed through our Internet application (the “Web App”), or administrative interface (collectively the “Service”) or engage with us in other related ways, including any communication sales, marketing, or events.

Interpretation

Definitions

For the purposes of this Privacy Policy:

  • "Account" means a unique Account created for You to access our Service or parts of our Service.
  • “Client” means a person who has engaged Spin Mobile Limited to provide the Services on behalf of the Client’s Customers.
  • "Consumer", means the ultimate person whose data is the subject of the Services.
  • "Cookies" are small files that are placed on Your computer, mobile Device or any other Device by a website, containing the details of Your browsing history on that website among its many uses.
  • "Data Controller" person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • “Data Processor” means entity processing data on behalf of Data Controller.
  • “Data Protection Laws” means all applicable laws, regulations, guidelines, and standards, that pertain to the collection, processing, storage, transfer, and protection of Personal Data.
  • "Device" means any Device that can access the Services such as a computer, a cell phone or a digital tablet.
  • "Personal Data" is any information that relates to an identified or identifiable individual.
  • "Service" has meaning ascribed to hereinto above.
  • "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

This Privacy Policy applies to “Personal Data,” of a Consumer that is Data that is associated with an identified or identifiable natural person and is protected as personal data or personal information under applicable data protection law.

By using the Services, you signify your acceptance of this Privacy Policy. If you do not agree or are not comfortable with any policy described in this Privacy Policy, your only remedy is to discontinue use of the Services.

We may as Data Processors be contracted by a client, acting as Data Controller, to provide the Services to their Consumers in which case this Policy will apply with necessary modifications. In such case the Client is responsible:

  • to ensure that specific consent from the Consumer as data subject is obtained for collection, processing sharing and transfer out of the country the Personal Data in accordance with the Kenya Data Protection Act 2019 (“DPA”).
  • disclosing the rights of Consumers with respect to their Personal Data and other information regarding the collection and use of that Personal Data, in accordance with the DPA, and other laws requiring such disclosures.

If you still have any questions or concerns, please contact us at info@spinmobile.co

Spin Mobile Limited

2nd Floor, Block C, Cassia Court Complex, Kiambere Road, Upperhill Nairobi

Office Tel: +254 723 81 55 86

P.O. Box 56013 – 00200 | Kenya

Email: info@spinmobile.co