Daltboard LLC

Privacy Policy

Last updated: August 10, 2023

This Privacy Policy (“Policy”) describes how Daltboard LLC (“Company”, “Spintel”, “we”, “us”, or “our”) we collect, use, and share in connection with the Spintel website at www.spintel.io (the “Site”) and our mobile application (the “Application”), as described in our Terms of Service (collectively, the “Services”). Using our Services signifies your acceptance of the terms of this Privacy Policy and provide us with your consent to the collection and use of your personal information as detailed herein. If you find any part of this Privacy Policy disagreeable or unacceptable to you, you should immediately discontinue your use of the Services.

Collection of your Personal Information

Information You Give Us.

• “Personal Data” means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below. We may Personal Data such as your blockchain address, which may become associated with Personal Data when you use our Service. We may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected. We may also collect Anonymous Data

• Personal Data also includes photos and/or videos that you upload to our Site or Application. Please note that we might store them into our systems including the metadata that may be associated with your photos and (or) videos by default (including, for example, geotags). We can access your photos and videos only after you grant us permission to access your camera or your devices’ photo library. You provide such a permission through the request that appears on your mobile device (it may differ depending on your device operating system). You may revoke permission to access your camera or photo library through the settings on your mobile device, and here’s how to do it.
  • If you use an iOS device:

• If you contact us, records, copies of your correspondence with us and contact details that you have provided us while making your inquiries(such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted online or offline), in order to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other inquiries in relation to Spintel.

Information We Get From Others. We may get Personal and/or Anonymous Data information about you from other sources such as third-party wallet providers giving us your blockchain address and other information you choose to share with those wallet providers. We may add this to information we get from this Site and through our Service.

Information Automatically Collected. We may automatically collect information about your computer hardware and software as you navigate through and interact with our Service. We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

1. To provide our Service and make it more useful to you, we (or a third-party service provider) collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps.
2. As is true of most websites and applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information can be used to personalize your experience.
3. Like many online services, we use cookies to collect information. 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 analyze how users interact with our Service, make improvements to our product quality, and provide users with a more personalized experience.
4. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow us to analyze how users find our Service, make the Service more useful to you, and tailor your experience with us to meet your particular interests and needs.
5. How We Respond to Do Not Track Signals: Our systems do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
6. In addition to the tracking technologies we place like Cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services (“Analytics Services”) that we engage to help analyze how users use the Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.

• Device information: Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system, and mobile network information.
• Usage details:Details of your use of Services, including frequency of use, areas and features of the application that you access and engagement with particular features. This information is used for in-app event analytics and, upon your consent, for marketing purposes.

1. (If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by Spintel, please follow the instructions below.
1. If you use an iOS device:

1. Details about your in-app purchases. This data is used to provide you with the Services and for our in-app analytics.

Such automatically collected data helps us operate our Services and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use our Services and what you like and dislike the most.

We encourage you to review the privacy statements of websites you choose to link to from us so that you can understand how those websites collect, use and share your information. We are not responsible for the privacy statements or other content on websites outside the Site or Application.

Use of your Personal Information

Spintel collects and uses your personal information to operate its Site or Application and deliver the Services you have requested. We use your Personal Data as follows:

• We may use your Personal Data to send information including confirmations, the Service you requested, technical notices, updates, security alerts, and support and administrative messages.
• We may use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
• We may use your Personal Data to provide and deliver the Service you requested.
• We may use your Personal Data to contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
• We may use your Personal Data to comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims.
• We may use your Personal Data act in any other way we may describe when you provide such data.
• We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Services and enhance Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.
• We may use your photos and videos for authentication purposes in connection with our Services.
• We may use your photos, videos, or profile for advertising or marketing purposes.

Sharing of Personal Information

Spintel does not sell, rent or lease its customer lists to third parties. We may share personal information as follows:

• We may share personal information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
• We may share your Personal Data with third party service providers to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to us and to the Service.
• To use our Service, you must use a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that third party.
• We may share personal information for legal, protection, and safety purposes.
• We may share information to comply with laws.
• We may share information to respond to lawful requests and legal processes.
• We may share information to protect the rights and property of the company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
• We may share information with those who need it to do work for us.

Use of Cookies & Similar Technologies

We use a variety of technologies to help us to deliver customized visitor experiences. We use Google analytics to collect information about your interaction with our website. We may use a technology called "cookies", for example, to count the number of unique visitors to a web page and to develop other statistics about the use of the website.

A cookie is a text file that is placed on your hard disk by a web page server when it visits a website. They allow the site to “remember” your computer, but not specifically who is using it, and improve your user experience. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize our pages, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your Personal Data. When you return to the same website, the information you previously provided can be retrieved, so you can easily use the features that you customized.

Security of your Personal Information

We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.

You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.

Data Retention of your Personal Data

We may retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

California Privacy Rights

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. We do not sell or share your Personal Data with third-party companies for their direct marketing purposes without your consent.

European Union (EU) Data Protection Rights

We are a US company and the personal information we collect is processed in the United States. We rely on your consent and EU Commission approved model contract clauses as our lawful basis for all transfers from the EU to the U.S.

Under EU data protection laws, you may have certain data protection rights, which may be subject to limitations and/or restrictions, and which includes: (i) the right to request access to and, rectification or erasure of your Personal Information; and (ii) the right to ask us to restrict the processing of your Personal Information. You may also have a right to object to processing of your Personal Information where carried out for our legitimate interest or direct marketing.

You may exercise your rights under this Policy, please send us your request using the Contact Information below.

You may also have a right to lodge a complaint about the processing of their Personal Information with their local data protection authority.

Children’s Privacy

We do not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

Opt-Out & Unsubscribe

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.

You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.

You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.

Changes to this Privacy Policy

We will occasionally update this privacy policy to reflect company and customer feedback. We encourage you to periodically review this privacy policy to be informed of how we are protecting your information. If we make any changes, we will change the Last Updated date above.

Contact Information

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us by contacting: support@spintel.io.