Spinning Globe Terms and Conditions and Privacy Policy – Overview

Last Updated: 26/10/2017

Welcome to Spinning Globe. Please read this overview and the following sections (together the “Terms”) carefully because they govern your use of our website located at www.spinningglobe.com and any associated website or software applications (together the “Site”), and also your use of our trip planning services accessible via our Site and via third-party websites:

  1. our Terms of Use below (the “Terms of Use”)
  2. our Terms of Registration below (the “Terms of Registration”) and
  3. our Privacy Policy below (”Privacy Policy”)

To make these Terms easier to read, the Site and our services are collectively called the “Services.

Who we are

The terms “Spinning Globe” or “us” or “we” refer to Spinning Globe Limited, the owner of the Site, whose registered office is Spinning Globe, 30 Parkside, Welwyn, Hertfordshire, AL6 9DQ, UK. This company is registered in the UK under number 09045122. The term ‘you’ refers to the user or viewer of the Site.

Agreement to Terms

By using our Services, you agree to be bound by these Terms and any documents referred to in them. If you do not agree to be bound by these Terms, you should not use the Services. If you are accessing and using the Services on behalf of a company (such as your employer) or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to these Terms. In that case, “you” and “your” will refer to that company or other legal entity.

Privacy Policy

Please refer to our Privacy Policy below for information on how we collect, use and disclose information from our users, including our use of cookies. You acknowledge and agree that your use of the Services is subject to our Privacy Policy. Again, if you do not agree to be bound by our Privacy Policy you should not use the Services.

Changes to Terms or Services

We may modify the Terms at any time, in our sole discretion. If we do so, we’ll let you know either by posting the modified Terms on the Site or through other communications with you, including email notifications where appropriate. It is important that you review the Terms whenever you access our Services to check for modifications, because if you continue to use the Services after we have posted modified Terms on the Site, you are indicating to us that you agree to be bound by the modified Terms. If you do not agree to be bound by the modified Terms, then you may not use the Services anymore and should stop using them.

The dates when each section of the Terms was last updated are given at the start of each section.

Our Services are evolving all the time and we therefore reserve the right to update, suspend, withdraw, change or discontinue all or any part of the Services, at any time as we see fit and without notice, at our sole discretion. While we try to make sure that the Services are up-to-date, available and free from errors, we cannot promise that they will be. Further, we do not promise that the Site will be available at all times nor do we promise the uninterrupted, error free or secure use by you of the Services. If you have any difficulties using the Services, please contact us to let us know. We will not be liable to you if for any reason the Platform is unavailable at any time or for any period.

Applicable law

These Terms, their subject matter and formation, are governed by the law of England and Wales.

You and we both agree that the courts of England and Wales will have exclusive jurisdiction over any dispute arising out of your use of the Services. However, if you are a consumer and are resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a consumer and are resident of Scotland, you may also bring proceedings in Scotland.

(1) Spinning Globe Terms of Use

Last Updated: 26/10/2017

Spinning Globe Terms of Use

Your use of the Services is subject to the following terms of use:

· The Site and any text, graphics, images, music, software, audio, video, other works of authorship of any kind, and any information or other materials that are posted, generated, provided or otherwise made available through the Services (“Content”) are provided for your general information and use only and are subject to change without notice.

· Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance or completeness of any Content or as to the suitability of any Content for any particular purpose. You acknowledge that such Content may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law. Your use of or reliance on any Content on the Site or available through the Services is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any Content, products, services or other information available through the Services meet your specific requirements. WITHOUT LIMITING THE FOREGOING, WE EXPLICITLY DISCLAIM ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, QUIET ENJOYMENT OR NON-INFRINGEMENT, AND ANY WARRANTIES ARISING OUT OF COURSE OF DEALING OR USAGE OF TRADE. See also the “Disclaimer” below.

· Subject to your continued compliance with these Terms, Spinning Globe grants you a limited, non-exclusive, non-transferable, non-sublicensable licence to access and view the Content solely in connection with your permitted use of the Services under these Terms and solely for your personal and non-commercial purposes.

· This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice below, which forms part of these Terms.

· This Site and all intellectual property rights in it (including copyright, trademarks, service marks, trade names, logos, designs or any other intellectual property right of any nature) are owned by us, our licensors or both (as applicable). Such rights are protected by copyright, trademark and other laws and treaties around the world. We and our licensors reserve all of our and their rights in any such rights in connection with these Terms. All trademarks or similar rights that are reproduced on or in the Site and which are not the property of, or licensed to, Spinning Globe are acknowledged on the Site.

· Unauthorised use of the Site may give rise to a claim for damages and/or be a criminal offence. We shall be entitled to take action against you if we, in our sole discretion, deem this necessary to protect our rights or the rights of others.

· From time to time, the Services may also include links to other websites or resources. These links are provided for your convenience and/or to provide further information. They do not signify that we endorse these other website(s) or resource(s). We have no responsibility for the content of the linked website(s) or resource(s) and we will not be responsible or liable in any way in respect of the content, products or services on or available through such linked website(s) or resource(s). Your use of a linked website or resource will be governed by the applicable terms and conditions of that website or resource and it is your responsibility to ensure you are happy with such terms and conditions. You acknowledge sole responsibility for, and you assume all risk arising from, your use of any third-party website(s) or resource(s).

General Prohibitions and Spinning Globe Enforcement Rights

Without prejudice to any of the terms of use above, you agree not to do any of the following:

· Use, display, mirror or frame the Services or any individual element within the Services, Spinning Globe’s name, any Spinning Globe trademark, logo or other proprietary information, or the layout and design of any page or form contained on a page of the Site, without Spinning Globe’s express written consent;

· Access, tamper with, or use private, restricted or otherwise non-public areas of the Services, Spinning Globe’s computer systems, or the technical delivery systems of Spinning Globe’s providers;

· Attempt to probe, scan or test the vulnerability of any Spinning Globe system or network or breach any security or authentication measures;

· Avoid, bypass, remove, deactivate, impair, descramble or otherwise circumvent any technological measure implemented by Spinning Globe or any of Spinning Globe’s providers or any other third party (including another user) to protect the Services or Content;

· Attempt to access or search the Services or Content or download Content from the Services through the use of any engine, software, tool, agent, device or mechanism (including spiders, robots, crawlers, data mining tools or the like) other than the software and/or search agents provided by Spinning Globe or other generally available third-party web browsers;

· Send any unsolicited or unauthorized advertising, promotional materials, email, junk mail, spam, chain letters or other form of solicitation through, or through the use of, the Services;

· Use any meta tags or other hidden text or metadata utilizing a Spinning Globe trademark, logo URL or product name without Spinning Globe’s express written consent;

· Use the Services or Content, or any portion thereof, for any commercial purpose or for the benefit of any third party or in any manner not permitted by these Terms;

· Forge any TCP/IP packet header or any part of the header information in any email or newsgroup posting, or in any way use the Services or Content to send altered, deceptive or false source-identifying information;

· Attempt to decipher, decompile, disassemble or reverse engineer any of the software used to provide any part of the Services or Content;

· Interfere with, or attempt to interfere with, the access of any user, host or network, including, without limitation, sending a virus, overloading, flooding, spamming, or mail-bombing the Services;

· Collect or store any personally identifiable information from the Services or from other users of the Services without their express permission;

· Violate any applicable law or regulation;

· Do anything, or through omission permit anything to be done, that would reasonably constitute a breach of these Terms by or on behalf of you; or

· Encourage or enable any other individual or entity to do any of the foregoing.

Although we are not obligated to monitor access to or use of the Services or Content or to review or edit any Content, we have the right to do so for the purpose of operating the Services, to ensure compliance with these Terms, and to comply with applicable law or other legal requirements. We reserve the right, but are not obligated, to remove or disable access to any part of the Services and/or to any Content, at any time and without notice, including, but not limited to, if we, at our sole discretion, consider any user to be in violation of these Terms, and we shall not be liable to any user in respect of any such removal or prevention of access. We have the right to investigate violations of these Terms or conduct that affects the Services. We may also consult and cooperate with law enforcement authorities to prosecute users who violate the law.

DISCLAIMER

The Services act as a conduit to connect users with third parties whose goods, services, experiences, accommodation or other offerings are advertised on or available through the Services. Spinning Globe do not own, manage, run or otherwise provide any of the goods, services, experiences, accommodation or other offerings available through the Services. Spinning Globe does not give any endorsement, recommendation, warranty or other guarantee of any kind in relation to such goods, services, experiences accommodation or other offerings advertised on or available through the Services.

YOU HEREBY EXPRESSLY ACKNOWLEDGE AND AGREE THAT SPINNING GLOBE ARE NOT, NOR WILL WE EVER BE, A PARTY TO ANY CONTRACT OR AGREEMENT THAT DOES OR MAY EXIST FROM TIME TO TIME BETWEEN YOU AND ANY THIRD PARTY PROVIDER WHOSE GOODS, SERVICES, EXPERIENCES, ACCOMMODATION OR OTHER OFFERINGS ARE ADVERTISED ON OR AVAILABLE THROUGH THE SERVICES. SPINNING GLOBE ACCEPTS NO RESPONSIBILITY OR LIABILITY WHATSOEVER IN RESPECT OF ANY ASPECTS OF ANY SUCH CONTRACT OR AGREEMENT THAT MAY EXIST BETWEEN YOU AND ANY SUCH THIRD PARTY PROVIDER. ANY SUCH CONTRACT OR AGREEMENT IS YOUR SOLE RESPONSIBILITY AND IS ACCEPTED BY YOU SOLELY AT YOUR OWN RISK.

 

 

 

(2) Spinning Globe Registration Terms

Last Updated: 26/10/2017

Eligibility

You may use the Services only if you are 18 years or older and capable of forming a binding contract with Spinning Globe and are not barred from using the Services under applicable law.

Registration and Your Information

If you want to use certain features of the Services you will have to create an account (“Account”). You can do this via the Site or through your account with certain third-party social networking services such as Facebook (each an “SNS Account”). If you choose the SNS Account option we will create your Account by extracting from your SNS Account certain personal information such as your name and email address and other personal information that your privacy settings on the SNS Account permit us to access. Such information is processed in accordance with our Privacy Policy below.

It is important that you provide us with accurate, complete and up-to-date information for your Account and you agree to update such information, as needed, to keep it accurate, complete and up-to-date. If you do not, we may not be able to make the Services available to you and we might even have to suspend or terminate your Account.

You agree that you will not disclose your Account password or other login information to anyone and you will notify us immediately of any unauthorized use of your Account. You acknowledge that you are solely responsible for all activities that occur under your Account, whether or not you know about them.

We have the right to disable any Account at any time if in our reasonable opinion you have failed to comply with any of the provisions of these Terms.

Feedback

We welcome feedback, comments and suggestions for improvements to the Services (“Feedback”). You can submit Feedback by emailing us at feedback@spinningglobe.com. You grant to us a non-exclusive, worldwide, perpetual, irrevocable, fully-paid, royalty-free, sublicensable and transferable license under any and all intellectual property rights that you own or control to use, copy, modify, create derivative works based upon and otherwise exploit the Feedback for any purpose.

Specific Use Restrictions on Registered Users

Without prejudice to the General Prohibitions and Spinning Globe Enforcement Rights set out in the Terms of Use above, where you register an Account on the Site to use the Services you also agree not to do any of the following:

· Post, upload, publish, submit or transmit any Content that: (i) infringes, misappropriates or violates a third party’s patent, copyright, trademark, trade secret, moral rights or other intellectual property rights of whatever nature, or any rights of publicity or privacy; (ii) violates, or encourages any conduct that would violate, any applicable law or regulation or would give rise to civil liability; (iii) is fraudulent, false, misleading or deceptive; (iv) is defamatory, obscene, pornographic, vulgar or offensive; (v) celebrates, encourages or otherwise promotes in any way any discrimination, bigotry, racism, hatred, harassment or harm of whatever nature against any individual or group; (vi) is violent or threatening or promotes or encourages violence or actions that are threatening to any person, group or entity; or (vii) promotes illegal or harmful activities or substances;

· Impersonate or misrepresent your affiliation with any person or entity; or

· Encourage or enable any other individual or entity to do any of the foregoing.

Although we are not obligated to monitor submission of User Content or to review or edit any User Content, we have the right to do so for the purpose of operating the Services, to ensure compliance with these Terms, and to comply with applicable law or other legal requirements. We reserve the right, but are not obligated, to remove or disable access to any User Content, at any time and without notice, including, but not limited to, if we, at our sole discretion, consider such User Content to be objectionable or in violation of these Terms, and we shall not be liable to any user in respect of any such removal or prevention of access. We have the right to investigate violations of these Terms or conduct that affects the Services. We may also consult and cooperate with law enforcement authorities to prosecute users who violate the law.

Content Rights, Ownership, Responsibility and Removal

For purposes of these Terms, “User Content” means any Content that Account holders (including you) provide to be made available through the Services, including how you describe and label your itineraries. References to Content include User Content.

Spinning Globe does not claim any ownership rights in any User Content and nothing in these Terms will be deemed to restrict any rights that you may have to use and exploit your User Content.

Subject to the foregoing, Spinning Globe and/or its licensors (as applicable) exclusively own all right, title and interest in and to the Services and Content (excluding User Content), including all associated intellectual property rights. You acknowledge that such rights in and to the Services and Content are protected by copyright, trademark, and other laws and treaties around the world. We and our licensors reserve all of our and their related rights in connection with these Terms. You agree not to remove, alter or obscure any copyright, trademark, service mark or other proprietary rights notices incorporated in or accompanying the Services or Content.

By making any User Content available through Services you hereby grant to Spinning Globe a non-exclusive, perpetual, irrevocable, transferable and sublicensable, worldwide, royalty-free license to use, copy, modify, distribute, create derivative works based upon and otherwise use your User Content in connection with operating, providing, improving, promoting, monitoring and administering the Services to and/or for you and other Account holders, such licence being subject at all times to the terms of our Privacy Policy.

You are solely responsible for all your User Content. You represent and warrant that neither your User Content, nor your use and provision of your User Content to be made available through the Services, nor any use of your User Content by Spinning Globe on or through the Services will infringe, misappropriate or violate a third party’s intellectual property rights, or rights of publicity or privacy, or result in the violation of any applicable law or regulation. We will not be responsible, or liable to any third party, for the content or accuracy of any User Content submitted to or available on the Site that is posted by you or any other user of the Site.

We have the right to disclose your identity to any third party who is claiming that any User Content posted or uploaded by you to the Site constitutes a violation of their rights, including their intellectual property rights or their right to privacy. We may also consult and cooperate with law enforcement authorities to prosecute users who violate the law.

You can remove your User Content by specifically deleting it. However, in certain instances, some of your User Content may not be completely removed from the server or storage facilities that underpin the Services and copies of your User Content may continue to exist on the Services. You acknowledge that if you delete your User Content from the Services the removal thereof will depend on automated processes and we are not responsible or liable for confirming the removal or deletion of (or responsible or liable the failure to remove or delete) any of your User Content. If you become aware that your User Content is still present on and accessible through the Services after you have specifically deleted it please let us know.

 

 

Copyright Policy

We respect the intellectual property rights of others and expect our users to do the same. It is our policy, in appropriate circumstances and at our discretion, to disable and/or terminate the Accounts of users who repeatedly infringe or are believed to be repeatedly infringing the intellectual property rights (including copyrights) of others.

If you are a copyright owner, or are authorized to act on behalf of one, or authorized to act under any exclusive right under copyright, please report alleged copyright infringements taking place on or through the Site by notifying us in writing at “Copyright Agent, Spinning Globe, 57-61 Charterhouse Street, Farringdon, London EC1M 6HA” and/or “legal@spinninglgobe.com” giving us enough information to identify you and the alleged act of infringement and deal with your request accordingly. Following receipt of such notification we will take whatever action, in our sole discretion, we deem appropriate, including removal of the challenged material from the Site.

Termination

We may terminate your access to and use of the Services, at our sole discretion, at any time and without notice or liability to you. Without limitation to the foregoing, we may prevent or suspend your access to or use of the Services if you do not comply with any part of these Terms, any terms or policies to which they refer, or any applicable law.

You may delete your Account at any time by sending an email to us at accounts@spinningglobe.com.

Indemnity

You will indemnify and hold harmless Spinning Globe and its officers, directors, employee and agents, from and against any claims, disputes, demands, liabilities, damages, losses, and costs and expenses (including, without limitation, reasonable legal and accounting fees) arising out of or in any way connected with (i) your access to or use of the Services or Content, (ii) your User Content, or (iii) your violation of these Terms.

Limitation of Liability

NEITHER SPINNING GLOBE NOR ANY OTHER PARTY INVOLVED IN CREATING, PRODUCING, OR DELIVERING THE SERVICES OR CONTENT WILL BE LIABLE FOR ANY:

· INCIDENTAL, SPECIAL, EXEMPLARY OR CONSEQUENTIAL DAMAGES; OR

· ANY OTHER LOSS OR DAMAGE INCLUDING WITHOUT LIMITATION LOSS OF PROFITS, LOSS OF DATA OR GOODWILL, SERVICE INTERRUPTION, COMPUTER DAMAGE OR SYSTEM FAILURE OR THE COST OF SUBSTITUTE SERVICES,

IN EACH CASE ARISING OUT OF OR IN CONNECTION WITH THESE TERMS OR FROM THE USE OF OR INABILITY TO USE THE SERVICES OR CONTENT, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), BREACH OF STATUTORY DUTY, PRODUCT LIABILITY OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT SPINNING GLOBE HAS BEEN INFORMED OF THE POSSIBILITY OF SUCH DAMAGE.

Notwithstanding the above limitation wording, nothing in these Terms excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be lawfully excluded or limited.

 

 

 

 

 

(3) Spinning Globe Privacy Policy

Last Updated: 26/10/2017

Protecting your privacy is important to us. We are providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. However, this Privacy Policy does apply to portions of our Services that are accessible via third-party websites. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as given elsewhere in our Terms . So, please make sure that you have read and understand all of our Terms.

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy (including, without limitation, changes which alter the information we collect or the manner in which we collect it, or the purposes for which we process or share your information), we will notify you of those changes by posting them on the Services and/or by sending you an email or other notification, and we will update the “Last Updated Date” above to indicate when those changes will become effective. If you access or use the Services and/or submit any information to or through the Services after this Privacy Policy has been changed you will be deemed to have agreed to the changes.

Data Protection

References in this Privacy Policy to:

· “Data Protection Law” means: the Data Protection Act 1998 (until repealed) (“DPA”), the Data Protection Directive (95/46/EC) (until repealed) and, from 25 May 2018, the General Data Protection Regulation 2016/679 (“GDPR”) or any equivalent provision which may replace the GDPR following the formal political separation of the United Kingdom from the European Union; the Regulation of Investigatory Powers Act 2000; the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699); the Electronic Communications Data Protection Directive (2002/58/EC); the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003); and all applicable laws and regulations which may be in force from time to time relating to the processing of Personal Data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction; and

· “personal data”, “data controller” and “data processor”, “processing” and “Information Commissioner” shall have the meanings given to them in the DPA or, from 25 May 2018, the GDPR.

For the purposes of applicable Data Protection Law, we (Spinning Globe Limited) are a data controller and therefore we are responsible for, and control the processing of, your personal data in accordance with applicable Data Protection Law. “Personal data” has a legal definition but, in brief, it refers to information from which a living person can be identified. Such information must be protected in accordance with applicable Data Protection Law.

Collection of Your Information

Account Information . If you create an Account, we will collect certain information that can be used to identify you, such as your name and email address (“ PII”). If you create an Account using your login credentials from one of your SNS Accounts, we’ll be able to access and collect your name and email address and other PII that your privacy settings on the SNS Account permit us to access. If you create an Account through the Site or one of your SNS Accounts, we may also collect your gender, date of birth and other information that is not, on its own, considered PII because it cannot be used by itself to identify you.

Information Collected Using Cookies and other Web Technologies . Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.

Cookies” are small text files that are placed on your device by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party service providers that we engage (including third-party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.

Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

Information Related to Use of the Services . Our servers automatically record certain information about how a person uses our Services (we refer to this information as “ Log Data”), including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, which third-party website hosted the Services that brought a User the Services, search terms, information a User inputs related to their trip planning, adjustments made to an existing itinerary, the links on our Services that a User clicked on, and other statistics.

Information Sent by Your Mobile Device . We collect certain information that your mobile device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services (as above).

Location Information . When you use our site on a mobile device, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. If you do not want us to collect location information, you may refuse to enable, or you may disable at any time, that feature on your mobile device.

We will keep your information only for as long as we need to hold it for the purposes set out in this Privacy Policy, however if required we will be entitled to hold information for longer periods in order to comply with our legal or regulatory obligations.

Our Legal Basis for Processing Your Information

From 25 May 2018, under applicable Data Protection Law we may only process your information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Privacy Policy, our legal basis for processing your information is your consent (for which see below) and/or the legitimate interest of providing services to our clients through the Platform, which requires the processing of your Information to enable us to provide these services to our clients (note that such processing is subject to “Your Rights” below).

Your Consent to Processing

We will seek consent from you when you first submit your information to or through the Services, including without limitation your consent to marketing activities (see “Marketing and opting out” below). If you do not consent to us processing your information as set out in this Privacy Policy you should not submit any information to or through the Services. If you have previously given consent you may freely withdraw such consent at any time through your Account or by notifying us in writing. If you withdraw your consent, and if we do not have another legal basis for processing your information (see above), then we will stop processing your information. If we do have another legal basis for processing your information then we may continue to do so subject to your legal rights (for which see “Your Rights” below).

We offer you choices regarding the collection, use and sharing of your PII and we will respect the choices you make. However, please note that if you decide not to provide us with the PII that we request, or if you object or do not consent to us processing your information (or later withdraw your consent), you may not be able to access all of the features of the Services.

Use of Your Information

Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services (and the globe!). We may also use your information (including personal data):

· to improve and personalize our Services for you;

· to investigate and address any comments, queries or complaints made by you or our customers regarding the Services;

· to ensure that Content available on or through the Services is presented in the most effective manner for you and for your device;

· to conduct research, statistical analysis and behavioural analysis (including anonymizing data for these purposes), including using a person’s IP address to generate aggregate, non-identifying information about how our Services are used;

· to provide insights based on aggregated, anonymous data collected through the research and analysis referred to above;

· for administration, maintenance and improvements of the Services;

· to allow you to participate in interactive features of the Services, including inputting information and providing feedback;

· to contact you for marketing purposes if we have permission to do so (see “Marketing and opting out” below);

· to disclose your information to selected third parties as permitted by this Privacy Policy (see ‘Information that We Share with Third Parties’ below);

· to notify you about changes to the Services; and

· to comply with our legal obligations, including obligations relating to the protection of personal data.

We use Log Data to administer the Services and we analyse (and may engage third parties to analyse) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences.

Information that We Share with Third Parties

We will not share any PII that we have collected from or regarding you except as described below:

Information Shared with Our Services Providers . We may engage third-party services providers to work with us to administer and provide the Services. These third-party services providers have access to your PII only for performing services on our behalf and we will ensure that they have appropriate measures in place to protect your PII.

Aggregate Information Shared with Third Parties . We may share aggregated, anonymised information and non-identifying information, or insights based on such aggregated and non-identifying information, with third parties for industry research and analysis, demographic profiling and other similar purposes. In such circumstances we do not disclose any information which can identify you personally.

Information Shared with Group Companies . We may share information about our users, including PII, with other companies within our group of companies from time to time (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006) and we will ensure that they have appropriate measures in place to protect your PII.

Information Disclosed about Business Transactions . Information that we collect from our users, including PII, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your PII, may be disclosed or transferred to a third-party acquirer in connection with the transaction, and to our and their business and legal advisers.

Information Disclosed for Our Protection and the Protection of Others . We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, including legal claims and actions; (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity including, without limitation, material breaches of our Terms.

Information Disclosed under a Legal Obligation . We will disclose your information if we are under a duty to do so in order to comply with any legal obligation, including (but not limited to) any request or order from government and/or law enforcement agencies and/or HMRC in connection with any investigation into unlawful activity.

Marketing and Opting Out

If you have given permission, we may contact you by email about our products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your information) and seek your permission if we intend to use your data for such purposes. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see below).

If you have given permission, we may contact you by email about products, services, promotions and special offers that may be of interest to you from carefully selected third parties. We will inform you (before collecting your information) and seek your permission if we intend to use your data for such purposes. If you prefer not to receive such third party marketing information from us, or you no longer wish to receive it, you can opt out at any time (see below).

If you have given permission, we may share your information (including PII) with carefully selected third parties and business partners and they may contact you directly by email about products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your information) and seek your permission if we intend to disclose your information to third parties for such purposes. If you prefer not to receive direct marketing communications from our third party partners, or you no longer wish to receive them, you can opt out at any time (see below).

You have the right at any time to ask us, or any third party, to stop processing your information for direct marketing purposes. If you wish to exercise this right, you should use the ‘unsubscribe’ instructions in the communications you receive from us or them, or contact us by sending an email to accounts@spinningglobe.com, or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request.

Please note that from time to time we do need to send you certain communications regarding the Services, e.g., communications regarding updates to our Terms of Service or this Privacy Policy or information about billing. These communications are necessary for us to provide the Services and are not marketing communications and you will therefore not be able to opt out of these communications.

Your Rights

If you are an individual, this section sets out your legal rights in respect of any of your personal data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us giving us enough information to identify you and respond to your request.

· You have the right (possible subject to the payment of a small fee depending on when you request this right) to request information about personal data that we may hold and/or process about you, including: whether or not we are holding and/or processing your personal data; the extent of the personal data we are holding; and the purposes and extent of the processing.

· You have the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the information that you have provided changes, or if you become aware of any inaccuracies in such information, please let us know in writing giving us enough information deal with the change or correction.

· You have the right in certain circumstances to request that we delete all personal data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the personal data for legal compliance purposes. If this is the case we will let you know.

· You have the right in certain circumstances to request that we restrict the processing of your personal data, for example where the personal data is inaccurate or where you have objected to the processing (see below).

· You have the right to request a copy of the personal data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you we will let you know.

· You have the right in certain circumstances to object to the processing of your personal data. If so, we shall stop processing your personal data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know.

· You have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you we will let you know

· You have the right to object to direct marketing, for which see “Marketing and Opting Out” above.

 

Modifying Your Information . You can delete your PII and your Account by contacting us at accounts@spinningglobe.com with your request. We’ll take steps to delete your information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Responding to Do Not Track Signals

Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.

The Security of Your Information

We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. Our website is secured with HTTPS. However, submission platforms that lead to our Services may not have the same level of security. Please be aware that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Links to Other Sites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We are not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

International Transfer

Your PII may be transferred to, and maintained on, computers located outside of your region, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. In particular, if you are located outside the United Kingdom and choose to provide your PII to us, we may transfer your PII to the United Kingdom and process it there. If we do transfer your PII to such places (including countries outside the European Economic Area) we will take reasonable steps in accordance with applicable Data Protection Law to ensure adequate protections are in place to ensure the security of your PII. By submitting your information (including PII) to us in accordance with this Privacy Policy you consent to these transfers for the purposes specified in this Privacy Policy.

Our Policy Toward Children

Our Services are not directed to children under 13 and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of a child under 13 we will take steps to delete such information from our files as soon as possible.

Questions?

Please contact us at accounts@spinningglobe.com or Spinning Globe, 57-61 Charterhouse Street, Farringdon, London EC1M 6HA

if you have any questions about our Privacy Policy.