Privacy Policy

In this document, definitions, words, or phrases will have the same meaning as in the Standard Contract, unless and to the extent the context requires otherwise.

Dutch law is exclusively applicable. Under Dutch law, the Publisher is the data controller of Personal Data collected when signing up for our services while being a data processor for the Personal Data you use through the Offering. Reference is made to the Data Processing Agreement in this respect.

This Privacy Policy is meant to help you understand what information is collected when visiting our website and/or using our Offering, why we collect it, and how you can update, manage, export, and delete your information.

When you interact with us through our Offering, we may collect information from you when you voluntarily provide such information, such as when you register for access to the Offering or third-party services: For example, through Azure Marketplace, AppSource Marketplace, Office 365 or Azure directly.

When you are not signed into the Offering, we store the information we collect with unique identifiers tied to the browser, application, or device you are using. This helps us do things like maintain your language preferences across browsing sessions.

On our public website https://www.spinpanel.com, we also use tracking data to understand the usage of our website. We use a variety of tools to do this, including Google Analytics.

Information we collect. The information we collect, and how that information is used, depends on how you use the Offering and depends on the level of consent you have given us. Your company administrator can also give the consent on your behalf. The default Azure Active Directory consent is: User level.

We collect information about the apps, browsers, and devices you use to access the Offering. The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, and application version number. We also collect information about the interaction of your apps, browsers, and devices with our Offering, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request.

We collect information about your location, determined by your IP address, when you use our Offering, which helps us present content in your local language and present a localized service offering.

We may also collect information about you delivered by Microsoft Azure Application Insights, which provides us with information to protect against abuse and provides data for analytics and measurement to understand how our Offering is used. For example: we analyze data about your visits to our Offering to perform tasks like optimize product design. We use various technologies to collect and store information, including cookies, databases, and server logs.

 

Data we collect

What kind of data is this?

Example of the use of this data by Spinpanel

Consent level

Personal data

First name, Last Name, Microsoft UPN, Microsoft Azure Active Directory Object Identifier

For authorization within (the use of) Spinpanel

User level

Personal data

First name, Last Name, Microsoft UPN, Microsoft Azure Active Directory Object Identifier, license assigned to the user

For authorization within (the use of) Spinpanel and Microsoft license assignment

Administrator or Microsoft partner level (on behalf of the user "you")

Office 365 usage

Exchange: personal (average) number of email sent, received and read, percentage storage used

OneDrive: personal (average) number of files viewed, edited, shared (externally), synchronized, storage used

SharePoint: organisation files viewed, edited, shared (externally), synchronized, Groups activity, messages in Groups, storage used

Skype for Business: personal amount of sessions, organisation number of sessions, file transfers, audio minutes, video minutes, active users per day, active versus total users

Yammer: personal activity, number of posts, read or liked, organisation activity, number of active users, active versus total users

Metadata (statistics) related to Office 365 usage, for reporting purposes

Administrator or Microsoft partner level (on behalf of the user "your" organization)

Azure usage

usageStartTime: the start of the usage aggregation time range. The response is grouped by the time of consumption (when the resource was actually used vs. when was it reported to the billing system).

usageEndTime: the end of the usage aggregation time range. The response is grouped by the time of consumption (when the resource was actually used vs. when was it reported to the billing system).

Resource: contains an AzureResource object
quantity: the quantity consumed of the AzureResource
unit: the type of quantity (hours, bytes, etc.) This property is optional
infoFields: key-value pairs of instance level details. This object may be empty
instanceData: contains an AzureInstanceData object that contains key-value pairs of instance level details. This property is optional and may not be included.

Attributes: the metadata attributes. Contains "objectType": "AzureUtilizationRecord"

currency: the currency in which the rates are provided.

isTaxIncluded: all rates are pretax, so this will always be returned as "false".

locale: the culture in which the resource information is localized.

meters: array of AzureMeter objects.

offerTerms: array of AzureOfferTerm objects.

attributes: the metadata attributes. Contains
"objectType": "AzureRateCard"

Id: Meter's unique identifier.

Name: Friendly name of the meter
rates: Meter rates. The key is the meter quantity (string) and the value is the meter rate (number)
tags: Optional meter tags. This array can be empty
Category: Category of the resource
Subcategory: Sub-category of the resource.

Region: Region of the id

Unit: The type of quantity (hours, bytes, etc.)
IncludedQuantity: Meter quantity that is included free of charge
EffectiveDate:
The date this meter is in effect
Name: Friendly name of the offer term
Discount: The discount applied, if any
ExcludedMeterIds: Meters excluded from the offer, if any

Metadata (statistics) and billing information related to Azure usage, for reporting purposes

Administrator or Microsoft partner level (on behalf of the user "your" organization)

Company data

Name, address, postal code, city, country, technical credentials

For authorization within (the use of) Spinpanel, contacting your company, synchronization and provisioning with/of Microsoft Partner Center and Microsoft Azure

Administrator or Microsoft partner level (on behalf of the user "your" organization)

Location data based on your IP address

Location data based on your current IP address

Present content in your local language and present a localized service offering

Administrator or Microsoft partner level (on behalf of the user "your" organization)

Browser type and settings, device type and company settings, operating system, and application version number

Company issued settings for your device

For device management by a company administrator

Administrator or Microsoft partner level (on behalf of the user "your" organization)

Company applications, printers, drive mappings (data locations)

Installed company applications, printers and data locations

For device management by a company administrator

Administrator or Microsoft partner level (on behalf of the user "your" organization)

Data concerning and for agreements

Company data, data regarding products you have purchased through us

Determining whether a product is suited for you or your company, changes apply to you, i.e. changes regarding technical specifications or price changes

Administrator or Microsoft partner level (on behalf of the organization)

(video)Chat logging

Email regarding support: tickets, name, email address

We can use (video)chat log for support, information in case of fraud, or technical issues

User level

Third party services. You may give us permission to collect your information in other services. Your company administrator can also give the consent on your behalf. For example: you or your company administrator may connect a billing or invoicing solution to the Offering. When you do this, it allows us to obtain information from those accounts for the use of synchronization of billing information from the Offering to you billing or invoicing solution.

Why we collect information. The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your Personal data. To the extent those laws apply, our legal grounds are as follows: to honor our contractual commitments to you, much of our processing of Personal data is to meet our contractual obligations to our Customer’s or to take steps at your request in anticipation of entering a contract with you.

For example: we handle Personal Data on this basis to create your account and provide our Offering.

Legitimate interests. In many cases we handle Personal Data claiming it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes:

  • providing a safe and enjoyable user experience;
  • customer service;
  • marketing, e.g. sending emails or other communications to let you know about new features;
  • protecting our users, personnel and property;
  • analyzing and improving our business, e.g. collecting information about how you use our Offering to optimize the design and placement of certain features;
  • processing job applications;
  • managing legal issues.

Legal compliance. Publisher needs to use and disclose Personal Data in certain ways to comply with our legal obligations.

Consent. Publisher is required by law and in some other cases, we handle Personal Data on the basis of your implied or express consent.

Our disclosure of information. Publisher is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. We do not share your Personal Data with companies, organizations, or individuals outside of Spinpanel except in the following cases:

  • With your consent;
  • With your company administrator(s);
  • If you work for an organization that uses Publishers services, your domain administrator(s) who manage your account will have access to your account information;
  • With your Microsoft partner or delegated administrator.

If you work for an organization that uses Publishers services, depending on the Microsoft relationship you have agreed on with your Microsoft partner, your Microsoft partner who manage your account will have access to your account information.

Your company administrator(s), Microsoft partner or delegated administrator may be able to:

  • Access and retain information stored in the Offering;
  • View statistics regarding your Spinpanel account;
  • Change your account password;
  • Suspend or terminate your Spinpanel account access;
  • Receive your Spinpanel account information in order to satisfy applicable law, regulation, legal process, or enforceable governmental request;
  • Restrict your ability to delete or edit your information or your privacy settings.

For external processing We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with the Standard Contract and any other appropriate confidentiality and security measures.

For legal reasons We will share personal information outside of Spinpanel if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

  • meet any applicable law, regulation, legal process, or enforceable governmental request;
  • enforce applicable terms of use, including investigation of potential violations;
  • detect, prevent, or otherwise address fraud, security, or technical issues;
  • protect against harm to the rights, property, or safety of Publisher, our users or the public as required or permitted by law.

We may share non-personally identifiable information publicly and with our partners — like marketplace sellers, developers or rights holders. For example: we share information publicly to show trends about the general use of our Offering.

If Publisher is involved in a merger, acquisition, or sale of assets, we will continue to ensure the confidentiality of your personal information and give affected Customers notice before personal information is transferred or becomes subject to a different privacy policy.

Unsolicited Information You may provide us with ideas for new products or modifications to existing products and other unsolicited submissions (Unsolicited Information). All Unsolicited Information shall be deemed to be non-confidential, and we shall be free to reproduce, use, disclose and distribute such Unsolicited Information to others without limitation or attribution.

Children Publisher does not offer services to children, due to the nature of the service provided (business-to-business). Thus, we do not identify it as relevant to control the age of users signing up for our services.

Children might still be able to use the Offering, via a Customer. To this extent, the Customer is responsible for checking against their own users and activities regarding children’s regulations.

Links to other web sites This Privacy Policy applies only to the Offering. The Offering may contain links to other websites not operated or controlled by us (Third-Party Sites). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Offering do not imply that we endorse or have reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Data security We take reasonable steps to protect the information provided via the Offering from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Email sent to or from the Offering may not be secure. Therefore, you should take special care in deciding which information you send to us via email. Please keep this in mind when disclosing any information via the Internet.

Data retention We generally retain Personal Data for so long as it may be relevant to the purposes identified herein. To dispose of Personal Data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Your data rights and choices Spinpanel believes that End Users should be treated equally no matter where they are, and so we are making the following options to control your data available to all End Users, regardless of their location.

You can update certain information by accessing your profile via the Offering. You can also unsubscribe from certain emails by clicking the ‘unsubscribe’ link they contain.

Individuals in the European Economic Area, Canada, Costa Rica, and some other jurisdictions have certain legal rights to obtain confirmation of whether we hold Personal Data about them, to access Personal Data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances. They may also object to our uses or disclosures of Personal Data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways.

How can I access the Personal Data you have about me?

If you would like to submit a data access request, you can do so by sending a request to privacy@spinpanel.com. We will then start the process and provide you a link to access the Personal Data that Publisher has on you within 30 days.

How do I correct, update, amend or delete the Personal data you have about me?

Please email us at privacy@spinpanel.com with the words “Personal Data Request” in the subject or body of your message, along with an explanation of what data subject right you are seeking to exercise. For your protection, we may take steps to verify identity before responding to your request.

How do I object or restrict the way Publisher processes my Personal Data?

You have a right to ask us to stop using or limit our use of your Personal Data in certain circumstances. For example: if we have no lawful basis to keep using your data or if you think your Personal Data is inaccurate.

The rights and options described above are subject to limitations and exceptions under applicable law. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first and we will do our very best to resolve your concern.

Changes to this Privacy Policy. Publisher reserves the right to make changes to this Privacy Policy at any time, and any changes will be effective immediately upon posting to the applicable Publisher URL or as otherwise communicated to the Customer. Please review this policy periodically, and especially before you provide any information. Continued use of the Offering following any changes shall constitute acceptance of the changes.

Contacting Spinpanel. Please also feel free to contact Spinpanel if you have any questions about this Privacy Policy or the information practices of the Offering. You may contact us as follows: privacy@spinpanel.com.