Manage SPIN – Privacy Policy

Last updated: September 5th, 2019

OVERVIEW

Welcome to Manage SPIN (“Manage SPIN,” “we,” “us” or “our”). Manage SPIN is a powerful self-regulation tool in the fight against internet pornography. Manage SPIN is owned and operated by National Education Technologies Inc. and is located in British Columbia, Canada. We collect and store your personal information in Canada and the United States.

  • Our Privacy Policy explains how we use, share and protect information in relation to our mobile services, web site, and any software provided on or in connection with Manage SPIN services (collectively, the “Service”), and your choices about the collection and use of your information.
  • By using our Service you understand and agree that the service by its nature collects personal information from the device (browsing history, applications usage, etc). This means that other Users (accountability partners or sponsors) may see this information.
  • Our Policy applies to all visitors, users, and others who access the Service (“Users”).

1. INFORMATION WE COLLECT

We collect the following types of information.

Information you provide us directly:

  • Your email address when you request a token via our Prevent Removal feature.
  • Profile information that you provide for your user profile (e.g., first and last name if shared in support messages).
  • Communications between you and Manage SPIN. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails.

Collected data:

  • Manage SPIN application collects certain information from the device to display it to the accountability partner (parents), e.g., location data, phone number, IMEI number, visited web sites, used applications, etc.

Analytics information:

  • We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information about your visits to our websites that assists us in improving the Service. In addition, we utilize Facebook, Firebase and Google analytics to help with user acquisition, measuring of how effective our ads are and to monitor our services to ensure uptime and provide you with a great experience.

Cookies and similar technologies:

  • When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use Manage SPIN and provide features to you.

Log file information:

  • Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
  • When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.
  • Application Logs: When you send a support request from your device, you have an option to include application logs. In this case all logs generated by the Manage SPIN application will be sent to our servers. In addition, to serve you better, we automatically send information to our servers if the Manage SPIN app crashes. Application Logs are used to resolve issues and provide you and our customers with continually improved versions.

Device identifiers:

  • When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Manage SPIN.

2. HOW WE USE YOUR INFORMATION

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive to:

  • help you efficiently access your information after you sign in
  • remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
  • provide, improve, test, and monitor the effectiveness of our Service
  • develop and test new products and features
  • monitor metrics such as total number of visitors, traffic, and demographic patterns
  • diagnose or fix technology problems
  • automatically update the Manage SPIN application on your device (only if you checked the corresponding checkbox while installing Manage SPIN)

3. SHARING OF YOUR INFORMATION

We will never give, sell, rent or share ANY of your personal information with any third party, without your express permission, except as noted in this Policy.

We will not let anyone, including our employees, view your personal data.

No one can view your personal data except you. The only way to see your personal data is to login to your account with your username and password. Please ensure that you store your password safely.

Parties with whom we may share non-personal information:

  • We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Manage SPIN is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences).
  • We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.

What happens in the event of a change of control:

  • If we sell or otherwise transfer part or the whole of Manage SPIN or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

Responding to legal requests and preventing harm:

  • We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

4. HOW WE STORE YOUR INFORMATION

Storage and Processing:

  • Your information collected through the Service may be stored and processed in the United States or any other country in which Manage SPIN, its Affiliates or Service Providers maintain facilities.
  • Manage SPIN, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
  • By registering for and using the Service you consent to the transfer of information to the U.S. or to any other country in which Manage SPIN, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
  • We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, Manage SPIN cannot ensure the security of any information you transmit to Manage SPIN or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
  • Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Manage SPIN, at all times.

5. YOUR CHOICES ABOUT YOUR INFORMATION

Your account information and profile/privacy settings:

  • Update your account at any time by logging in and changing your profile settings.
  • Unsubscribe from email communications from us by clicking on the “unsubscribe link” provided in such communications. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).
  • If you have any questions about reviewing or modifying your account information, please contact us directly at support@nationaledtech.com.

How long we keep your data:

  • When you delete a device from your group or when you terminate your account, all relative data is deleted from our database.
  • Following termination or deactivation of your account, Manage SPIN, its Affiliates, or its Service Providers may retain information (including your profile information) and collected data for a commercially reasonable time for backup and archival purposes.
  • If you have any questions about termination or deactivation of your account, please contact us directly at support@nationaledtech.com.

General Data Protection Regulation (GDPR) Rights:

  • Right to be forgotten: Removing Manage SPIN from your device will remove all personal data that we have for that specific Device.
  • Right to object: You are welcome to use Manage SPIN so that it does not identify you by your name or your accountability partner by their names. All Manage SPIN requires is a unique email to allow communication for support and requests to unlock our Prevent Uninstallation feature.  If you have any other objection, please reach out to support@nationaledtech.com.
  • Right to rectification: We do not store your primary email except locally when you use Manage SPIN on your device.
  • Right of access: Our Privacy Policy describes what data we collect and how we use it.  You may contact us at support@nationaledtech.com.
  • Right of portability: We do not store any data on our servers.

6. CHANGES TO OUR PRIVACY POLICY

Manage SPIN may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Manage SPIN or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

7. LEGAL DISCLAIMER

Though we make every effort to preserve your privacy, please note that:

Manage SPIN makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents of this web site and related products and expressly disclaims liability for errors and omissions in the contents of this web site and related products. No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of noninfringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to the contents of this web site or its hyperlinks to other Internet resources. In no event shall Manage SPIN be liable for any direct, indirect, incidental, special, exemplary, or consequential damages (including, but not limited to, procurement of substitute goods or services; loss of use, data, or profits; or business interruption) however caused and on any theory of liability, whether in contract, strict liability, or tort (including negligence or otherwise) arising in any way out of the use of Manage SPIN, even if advised of the possibility of such damage.