PRIVACY POLICY
SPINCO Inc., SPINCO Franchising and their affiliates ("SPINCO," "our," "us," "we") value your privacy. By visiting and/or using the SPINCO website(s), including www.SPINCO.ca (
When you visit our Website, use our App, or communicate with SPINCO via email, you are communicating electronically. You will receive communications from SPINCO electronically in accordance with the consent that you provide to us. SPINCO will communicate with you by email or by posting notifications on our Website and/or the App. You understand and agree that all agreements, notices, disclosures and other communications that SPINCO provides electronically, satisfy any legal requirement that such communications be in writing.
This Policy applies to personal information about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. This Policy does not impose any limits on our collection, use or disclosure of the information exempted under applicable privacy legislation, such as business contact information and certain publicly available information.
A. Consent
We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where:
· The information is publicly available, as defined by statute or regulation;
· We are obtaining legal advice; or
· We reasonably expect that obtaining consent would compromise an investigation or proceeding.
Other exceptions may apply.
Your consent can be express, implied or given through authorized representative such as a lawyer, agent or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish for your personal information to be collected / used / disclosed for various purposes after you have received notice of those purposes) or otherwise.
You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give reasonable notice of withdrawal of consent to us. On receipt of notice of withdrawal of consent we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.
B. The Information We Collect About You
We collect information about you directly from you and from third parties, as well as automatically through your use of our Website, App, or Services.
Information We Collect Directly From You.
We collect information from you when you contact us, register with our Website or App, reserve classes, make a purchase, or otherwise interact with our Website or our App or use or interact with our Services. The type of information that we collect varies based on your interaction with us and may include: your name, email address, password, phone number, date of birth, gender, health or medical conditions, and, if you make a purchase from us, payment information, purchase history, and shipping address. We also may collect information about your workout preferences, such as your bike size and settings, and your shoe size preferences.
Information We Collect from Third Parties.
To create an account and participate in one of our classes, we need emergency contact information for our customers. When a customer creates an online account with us, we will collect the name and phone number of their emergency contact. Our customers also may provide us information about their friends, e.g., so that we can invite others to try our classes.
Information We Collect Automatically.
We automatically collect information about your use of our Website and App through cookies, web beacons, and other technologies, including technologies designed for mobile apps. We combine this information with other information we collect about you. Please see the section "Cookies and Other Tracking Mechanisms" below for more information.
· Website:
· Domain name;
· Your browser type and operating system;
· Web pages you view; links you click; your IP address;
· The length of time you visit our Website and or use our Services; and
· The referring URL or the webpage that led you to our Website.
· App:
· Mobile device ID; device name and model; operating system type, name, and version;
· Language information;
· Activities within the App; and the length of time that you are logged into our App;
· Location information. With your permission, we will collect location information from your mobile device to help you locate the nearest SPINCO location. You may turn off this feature through the location settings on your mobile device;
· Calendar. With your permission, we may access your mobile device's calendar to help you keep track of your upcoming classes; and
· Contact list. With your permission, we may access your contacts to allow you to identify your emergency contact and upload their contact information.
Limits on Collection.
We will not collect information indiscriminately and will limit collection of information to that which is reasonable and necessary for the above purposes. We will also collect information as is otherwise authorized by law.
C. How We Use Your Information
As permitted by applicable law, we use your information, including your personal information, for the following purposes:
· To provide our services to you, to communicate with you about your use of our services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
· To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Website or App.
· For marketing and promotional purposes. For example, as permitted by applicable law and where necessary, with your consent, we and our third party partners may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including third party products and services. We also may use the information that we learn about you to assist us in advertising our services on third party websites. Information on how to opt-out of receiving these promotional emails is provided near the end of this policy under Section M.
· To better understand how users access and use our Website and App, both on an aggregated and individualized basis.
· To improve our Website and App.
· For research and analytical purposes.
· To administer surveys and questionnaires.
· To comply with applicable legal obligations, including responding to a subpoena or court order.
· In the context of a merger or acquisition, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding.
· Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our New Rider Agreement, Terms or this Policy.
· To authenticate your identity.
· To allow you to participate in our contests, and to administer those contests.
· To monitor your compliance with any of your agreements with us.
· To collect debts owed to us.
· For other purposes we may inform you about from time-to-time.
Please also note that we may transfer your personal information across provincial or national borders to fulfil any of the above purposes, including to service providers located in the United States and other jurisdictions outside of Canada who may be subject to applicable disclosure laws in those jurisdictions. You may contact our Privacy Officer (whose contact information is provided below) to obtain information about our policies and practices regarding our transfer of data or use of service providers outside of Canada, or to ask questions about the collection, use, disclosure or storage of personal information outside of Canada.
D. How We Share Your Information
We may share your information, including personal information, as follows:
· Affiliates.
We may disclose the information we collect from you to our affiliates or subsidiaries; including for their own direct marketing purposes where it is not prohibited by applicable law.
· Service Providers.
We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
· Third Parties.
In accordance with applicable law, we may share information with our third party partners or other third parties so they may send you information about their products and services.
We may also share information in the following circumstances:
· Partners.
We may disclose the information we collect from you with our partners, including for their own direct marketing purposes where it is not prohibited by applicable law. For example, we disclose information to our partners in connection with offering co-branded services, selling or distributing products or services, or engaging in joint marketing activities or promotions.
· Business Transfers.
If we are acquired by or merged with another company, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
· In Response to Legal Process.
We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
· To Protect Us and Others.
We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which SPINCO is involved.
· With Your Consent or at Your Request.
We may disclose the information we collect from you with your consent or to facilitate your requests.
· Aggregate and De-Identified Information.
We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
E. Limits on Using, Disclosing and Retaining Personal Information
We will only use and disclose your personal information for the purposes set out above and as authorized by law.
We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision, unless otherwise permitted or required by law.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
We will take due care when destroying personal information so as to prevent unauthorized access to the information.
F. Our Use of Cookies and Other Tracking Mechanisms
We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Website and our App. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf). We may also use cookies and tracking mechanisms to serve our remarketing campaigns so that third party vendors, including Google, Twitter and Facebook, show our ads on sites across the Internet. We may also use targeted advertising services to tailor our advertisements (both on the Website and on other sites) to your interests. You can opt out of these remarketing campaigns by turning off cookies in your browser as described below.
Cookies.
Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website and our App, while others are used to enable a faster log-in process or to allow us to track your activities at our Website or our App. There are two types of cookies: session and persistent cookies.
· Session Cookies.
Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Website.
· Persistent Cookies.
Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our Website and on third-party sites.
Disabling Cookies.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse certain areas of the Website, but some features may not function.
Clear GIFs, pixel tags and other technologies.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website and our App to, among other things, track the activities of our Website visitors and App users, help us manage content, and compile statistics about Website and App usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. We also use third party SDKs to, among other things, track our conversions, associate with your account how you use our Website and our App when you are not logged in to the account, and bring you advertising both on and off our Website and our App.
Third Party Analytics.
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and, to the extent permitted, our App. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services.
Do-Not-Track.
There is no industry do-not-track standard; SPINCO has processes in place that are designed to recognize web browser "do-not-track" signals. The Help portion of the toolbar on most browsers will tell you how to use your web browser's do-not-track feature. Please be advised that we cannot guarantee that our processes will capture all such do-not-track signals. You also may disable certain tracking as discussed in this section (e.g., by disabling cookies); you may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
G. Third-Party Ad Networks
We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party's specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.
Users in Canada may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance of Canada ("DAAC")Online Interest-Based Advertising FAQ for information about opting out of interest-based advertising and their choices regarding having information used by DAAC companies. Opting out from one or more companies listed on the DAAC will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAAC websites, your opt out may not be effective. Additional information is available on the DAAC's website at https://youradchoices.ca/.
H. Customer Matching
We use third-parties to serve advertisements targeted to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to the third-party (such as through Facebook Custom Audiences or Google Customer Match) or incorporating a pixel from the third-party on our Services, and the third-party matching common factors between our data and their data. We may also work with partners to deliver Matched Ads based on data about you and others in those partners’ own databases or match the partner’s data against our own customer lists. To opt-out of us using your data for Matched Ads, please contact us at infotoronto@spinco.ca and specify that you wish to opt-out of Matched Ads. We will request that the applicable third-parties not serve you Matched Ads based on information we provide to it. You may also contact the applicable third-party to opt-out. We are not responsible for such third-party’s failure to comply with our or your opt-out instructions.
I. Third-Party Links
Our Website and App may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
J. Security of Your Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
We may also process or transfer your information to jurisdictions outside of your home country where privacy laws may not be as protective. We take appropriate measures to ensure that your personal information remains secure when it is transferred outside of your home country, in accordance with applicable privacy laws.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
K. Access to My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Website or App for a period of time.
Also, upon written request to our Privacy Officer and authentication of identity, we will provide you with your other personal information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make that information available within 30 days or provide written notice where additional time is required to fulfil the request.
In some situations we may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed could harm our competitive position. We may also be prevented by law from providing access to certain personal information. When an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
L. Accuracy
We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete. In most cases, we rely on you to ensure that your information is current, complete and accurate.
If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested, but not made.
M. SPINCO Challenges
By participating on a team during any SPINCO challenges, your teammates may see your name, riding goal and riding progress. Not all members of a team are invited and some individuals may join a team through a random coding process. The creator of a SPINCO team may remove any teammate from his/her team at any time at his/her sole discretion.
N. What Choices Do I Have Regarding Promotional Emails?
As permitted by applicable law, we may send periodic promotional emails to you. You may opt-out of our promotional communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.
Upon completion of a SPINCO challenge, SPINCO will send one email to challenge participants, including those who have unsubscribed from general marketing messages, with his/her rewards details. Challenge participants can unsubscribe from receiving the rewards notification at any time by emailing infotoronto@SPINCO.ca.
You may also withdraw your consent to our collections, uses and disclosures of your information at any time, subject to legal, contractual and other restrictions, provided that you give reasonable notice of withdrawal of consent to our Privacy Officer.
O. Privacy of Minors
If SPINCO discovers that personal information has been provided by a person who is under the age of majority in the province where he/she has provided such information not in accordance with our Website and App Terms and Conditions or our New Rider Agreement, SPINCO reserves the right to delete such information.
P. Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact our Privacy Officer at infotoronto@SPINCO.ca. You can also contact our Privacy Officer by mail or telephone at SPINCO Inc.,: SPINCO Customer Service, 129 Spadina Ave, Toronto, ON, Canada, M4P 2J1
Q. Changes to the Policy
Our Policy is current as of the Effective Date set forth below. We may change the Policy from time to time, so please be sure to check back periodically. We will post any changes to the Policy on our Website and App. If we make any changes to the Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change in the Policy on our Website and App.
EFFECTIVE DATE: July 19, 2022
