PRIVACY POLICY

SpinaqDex Privacy Policy

At SpinaqDex, we are committed to protecting and respecting your privacy. This Policy explains when and why we may collect personal information about people who visit our website and utilize our services, how we use it, the conditions under which we may disclose it to others, and how we keep it secure. This Policy also explains how we use cookies and similar technology on our website(s).

We may change this policy from time to time at our discretion, so please check this page occasionally to ensure that you are satisfied with any changes. By accessing our website or otherwise using our services, you are agreeing to be bound by this Policy.

WHAT INFORMATION DO WE COLLECT?

The SpinaqDex team ("SpinaqDex", “we” or “us”) collects (a) the e-mail addresses of those who communicate with us via e-mail, (b) aggregate information concerning what pages users access or visit, (c) information volunteered by the user (such as transaction information, survey information and/or site registrations) and (d) information related to your use of the site and the services (e.g. voting, opinion related information), including IP address, geographic location, and date and time of your request.

HOW DO WE USE THE INFORMATION?

We may use collected information for the following purposes: To fulfill a contract or take steps linked to a contract such as processing your registration on our website or sending you information about changes to our terms or policies; Where it is necessary for purposes which are in SpinaqDex's or third parties’ legitimate interests such as: (a) to provide the information or content you have requested, (b) to contact you about our programs, products, features or services, (c) for internal business purposes such as identification and authentication or customer service, (d) to ensure the security of our website, by trying to prevent unauthorized or malicious activities, (e) to enforce compliance with our terms of use and other policies, (f) to help other organizations (such as copyright owners) to enforce their rights, and (g) to tailor content, advertisements and offers for you or for other purposes disclosed at the time of collection. If you do not wish to receive information about our programs, products, features or services, you may send an email to us to an address identified on https://spinaq.xyz/ from time to time. Where you give us consent: such as (a) where you ask us to send marketing information to you via a medium where we need your consent; (b) where you give us consent to place cookies and to use similar technologies; and (c) on other occasions where we ask you for consent, for a purpose which we explain at that time. Where we are legally required to do so. We may also provide access to your personally identifiable information when legally required to do so, to cooperate with investigations or other legal proceedings, to protect against misuse or unauthorized use of our website, to limit our legal liability and protect our rights, or to protect the rights, property or safety of visitors of the website or the public. In those instances, the information is provided only for that purpose. Our website uses third party cookies from Google Analytics for Display Advertisers, including Google Analytics Demographics and Interest Reporting - this gives us insight into behavior information relating to visitor age, gender, and interests on an anonymous and aggregate level. This will help us to understand browsing behavior to give you a better experience while visiting our sites.

HOW DO WE SHARE YOUR INFORMATION?

We do not share or sell your personal data to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission, or under the following circumstances: It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law. We transfer information about you if SpinaqDex is acquired by or merged with another company. In this event, SpinaqDex will notify you before information about you is transferred and becomes subject to a different privacy policy. We provide such information to trusted businesses or persons for the sole purpose of processing personally identifying information on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Privacy Policy and appropriate confidentiality and security measures. We provide such information to third parties who have entered into non-disclosure agreements with us. We provide such information to a company controlled by, or under common control with, SpinaqDex for any purpose permitted by this Privacy Policy. COOKIES AND WEB BEACONS A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies are required to use some SpinaqDex services. SpinaqDex uses cookies to record current session information. With cookies, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. You can opt-out of Google Analytics data collection with the Google Analytics Opt-out Browser Add-on. You may also wish to refer to this website for additional information about disabling cookies from your browser: http://www.allaboutcookies.org/manage-cookies/.

DATA STORAGE

SpinaqDex uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run SpinaqDex and related products. SpinaqDex owns the code, databases, and all rights to the SpinaqDex applications.

SECURITY

We take precautions to ensure the security of your personal information. However, we cannot guarantee that hackers or unauthorized personnel may not gain access to your personal information despite our efforts. You should note that in using the SpinaqDex services, your information will travel over the Internet and through third party infrastructures which are not under our control. We cannot protect, nor does this Privacy Policy apply to, any information that you transmit to other users. You should never transmit personal or identifying information to other users.

RETENTION OF YOUR PERSONAL INFORMATION

We retain information as long as it is necessary to provide the services and products requested by you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the services or until you ask us to delete it or your account is deleted, whichever comes first. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Use, and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy. Information about you that is no longer necessary and relevant to provide our services may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to SpinaqDex, such as statistics related to the use of SpinaqDex's website.

CHILDREN

The SpinaqDex services and products are not intended for children under the age of 18, and we do not knowingly collect information from children under the age of 18. Per our terms of use, children are expressly prohibited from utilizing the SpinaqDex services. By using SpinaqDex service(s), you are representing that you are at least 18 years old.

CONSENT TO WORLDWIDE TRANSFER AND PROCESSING OF PERSONAL INFORMATION

By accessing the website (https://spinaq.xyz/) and providing personal information through it, you agree and acknowledge and consent to the collection, maintenance, processing and transfer of such information in and to the British Virgin Islands, European Union, United States and other countries and territories. These other jurisdictions may have different privacy laws from your home jurisdiction and provide different levels of protection of personal information. You agree that the terms of this Privacy Policy will apply and you consent to the transmission and processing of your personal information in any jurisdiction.

EU AND EEA USERS’ RIGHTS

If you are habitually located in the European Union or European Economic Area, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We generally describe these rights below: You have the right to access your personal data and, if necessary, have it amended or deleted or restricted. In certain instances you may have the right to the portability of your data. You can also ask us to not send marketing communications and not to use your personal data when/if we carry out profiling for direct marketing purposes. You can opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails. Transactional account messages will be unaffected if you opt-out from marketing communications.

COMPLAINTS

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority, although we hope that we can assist with any queries or concerns you may have about our use of your personal data.

CHANGES

SpinaqDex may periodically update this policy. We may notify you about significant changes in the way we treat personal information by placing a notice on our website so please check back occasionally to ensure that you agree with the changes. If you do not, do not use the website or its services.

QUESTIONS

Any questions about this Privacy Policy should be addressed to an address specified on https://spinaq.xyz/ from time to time (e-mail or telegram).

Effective Date: 1 December 2023.