SpinPanel provides Cloud Automation application(s) and/or Infrastructure and/or Platform Facilities made and kept available for users (“you”) by SpinPanel against payment (collectively, the “Cloud Service(s)”).
The Cloud Service is operated by SpinPanel, trade name of the private limited company Computron, located at De Horst 4, 6581TE, Malden, The Netherlands (the “Company”, “we” or “us”) for users of the Cloud Service (“you”).
When you interact with us through the Cloud Services, we may collect information from you when you voluntarily provide such information, such as when you register for access to the Cloud Services or use certain Cloud Services. For example, through Microsoft AppSource, Azure Marketplace, Office 365 or Azure directly.
When you’re not signed in to SpinPanel, we store the information we collect with unique identifiers tied to the browser, application, or device you’re using. This helps us do things like maintain your language preferences across browsing sessions. On our public website www.spinpanel.com, which is not part of the Cloud Services, we also use tracking data to understand the usage of our website. We use a variety of tools to do this, including Google Analytics.
When you’re signed in, we also collect information that we store in our Cloud Services, which we treat as personal information and which may include:
INFORMATION WE COLLECT
The information we collect, and how that information is used, depends on how you use our Cloud Services and depends on the level of consent you have given us. Your company administrator can also give the consent on your behalf. The Cloud Services default consent is: User level.
We collect information about the apps, browsers, and devices you use to access the Cloud Services. 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 services, 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 Cloud Services, 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 Cloud Services are used. For example: we analyze data about your visits to our Cloud Services 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
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 such as Autotask or Dynamics Navision to your SpinPanel account. When you do this, it allows us to obtain information from those accounts for the use of synchronization of billing information from SpinPanel 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 users or to take steps at users’ request in anticipation of entering into a contract with them.
For example: we handle personal data on this basis to create your account and provide our Cloud Services.
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:
Legal compliance: we need to use and disclose personal data in certain ways to comply with our legal obligations.
To protect the vital interests of the individual or others: for example: we may collect or share personal data to help resolve an urgent medical situation.
Consent: where required by law and in some other cases, we handle personal data on the basis of your implied or express consent.
WHERE INFORMATION IS PROCESSED
The Company is based in The Netherlands. No matter where you are located, you consent to the processing and transferring of your information in and to the Netherlands.
SpinPanel runs on Microsoft Azure, we offer services from multiple Azure regions, which are located in the EEA and United States. Regardless the Azure region the Cloud Service(s) are provided from, data is only stored in Azure regions West-Europe and North-Europe.
OUR DISCLOSURE OF YOUR INFORMATION
The Company 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 information with companies, organizations or individuals outside of SpinPanel except in the following cases:
If you work for an organization that uses SpinPanel services, depending on the Microsoft relationship you have agreed on with your service provider or reseller, your service provider(s) or reseller(s) who manage your account will have access to your SpinPanel Account information.
Your company administrator(s), service provider(s) or reseller(s) may be able to:
For external processing
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:
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 Cloud Services.
You may provide us with ideas for new products or modifications to existing products and other unsolicited submissions (collectively, “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.
Our Cloud Services are for users age 18 and over and we do not knowingly collect personal information from children under the age of 18. If you are a parent or guardian of a child under the age of 18 and believe he or she has disclosed personal information to us, please contact us at firstname.lastname@example.org. For residents of the EEA, where processing of personal information is based on consent, SpinPanel will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.
LINKS TO OTHER WEB SITES
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.
We take reasonable steps to protect the information provided via the Cloud Services 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 Cloud Services 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.
YOUR DATA RIGHTS AND CHOICES
We believe that 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 users, regardless of their location.
You can update certain information by accessing your profile via “Settings”. You can also unsubscribe from certain emails by clicking the “unsubscribe” link they contain. You can opt out from certain cookie-related processing by following the instructions above in “Other Information.”
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 email@example.com. We will then start the process and provide you a link to access the personal data that SpinPanel has on you within 30 days.
How do I correct, update, amend or delete the personal data you have about me?
Please write us at firstname.lastname@example.org 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 SpinPanel 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.