Privacy Policy

About This Policy

At Spinnable, we believe you should understand how we handle your data—in clear, straightforward language. This Privacy Policy explains what information we collect, how we use it, and your rights to control it.

Company Details:

• Spinnable, Inc. (Delaware C-Corp)
• Registered Office: 251 Little Falls Drive, Wilmington, New Castle County, Delaware 19808
• Data Protection Officer: Contact at legal@spinnable.ai

1. What We Do

Spinnable provides AI-powered digital co-workers that help you manage your work. Our AI agents can assist with email, calendar management, document processing, and communications across various platforms including WhatsApp, Slack, email, and voice.

To do this effectively, we need access to certain data—but only what's necessary to provide our services.

2. Information We Collect

Information You Give Us

• Account Information: Name, email address, company details, and payment information
• Platform Connections: When you connect Gmail, Google Calendar, Slack, Outlook, or other services, we receive the access permissions you grant

Note on Future Expansion: As we expand our integrations and features, we may process additional types of data from new systems and platforms. We will update this policy and notify you of any material changes to data processing activities.

Information We Process on Your Behalf

When our AI agents work for you, they access:

• Email content and metadata (sender, recipient, subject, timestamps)
• Calendar events and availability
• Documents and files you share or that are stored in connected platforms
• Messages from WhatsApp, Slack, Teams, and other communication tools
• Customer data from integrated platforms like Guesty, Notion, LinkedIn, and Twitter

Technical Information

• Usage data: How you interact with our service
• Device information: Browser type, IP address, operating system
• Performance data: To improve our AI and fix issues

3. How We Use Your Information

We use your data to:

• Provide our services: Execute tasks, respond to messages, manage calendars, and process documents as instructed
• Improve our AI: Train and refine our models to better serve you (we anonymize data for this purpose)
• Maintain and improve service quality: Our engineering team may access your data to debug issues, investigate problems reported by you, and develop new features to improve the service. When we use data for AI model training or improvement, we anonymize it first to remove identifying information.
• Communicate with you: Send service updates, respond to questions, and provide support
• Ensure security: Detect and prevent fraud, abuse, and security threats
• Comply with legal obligations: Meet regulatory requirements and respond to valid legal requests

What We Don't Do:

• We don't sell your personal data to anyone
• We don't use your data for advertising to third parties
• We don't train our AI on your confidential information without anonymization

4. How We Share Information

We only share your data in these situations:

With Your Permission

We share information with platforms you've connected (Gmail, Slack, etc.) to perform the tasks you've requested.

With Service Providers

We work with trusted third-party companies that help us operate our service (cloud hosting, payment processing, analytics). These providers are contractually required to protect your data and only use it for specified purposes.

A complete list of sub-processors is available in Annex II of our Data Processing Agreement.

For Legal Reasons

We may disclose information when required by law, to enforce our terms, protect our rights, or respond to valid legal requests from authorities.

Business Transfers

If Spinnable is acquired or merged with another company, your data may be transferred as part of that transaction. You'll be notified of any such change.

5. Data Security

We take security seriously and implement industry-standard measures to protect your data:

• Encryption: Data is encrypted in transit (TLS/SSL) and at rest
• Internal Access Controls: Access to customer data is restricted to authorized personnel on a need-to-know basis:
  • Engineering Team: Can access data for debugging, quality assurance, and feature development
  • Customer Support: Can access data to troubleshoot issues and respond to your inquiries
  • Security Team: Can access data to prevent fraud, abuse, and security incidents
• Regular security audits: We continuously test and improve our security measures
• Secure infrastructure: We use reputable cloud providers with strong security practices

However, no system is 100% secure. While we work hard to protect your data, we cannot guarantee absolute security.

6. Data Retention

We keep your data only as long as necessary:

• Active accounts: Data is retained while your account is active and you're using our services
• After account deletion: We delete or anonymize your data within 90 days, except where we must retain it for legal compliance or legitimate business purposes
• Backups: Deleted data may persist in backup systems for up to 90 additional days before permanent deletion

You can request earlier deletion by contacting our Data Protection Officer.

7. Your Privacy Rights

Depending on where you live, you have specific rights regarding your data:

Rights for Everyone

• Access: Request a copy of the data we hold about you
• Correction: Update or correct inaccurate information
• Deletion: Request that we delete your data (subject to legal obligations)
• Export: Receive your data in a portable format
• Opt-out: Unsubscribe from marketing communications

Additional Rights (GDPR - EU/UK/EEA)

• Object to processing: Oppose certain uses of your data
• Restrict processing: Limit how we use your data
• Withdraw consent: Revoke permission for processing based on consent
• Lodge a complaint: File a complaint with your local data protection authority

Additional Rights (CCPA/CPRA - California)

• Know what's collected: Learn what personal information we collect
• Know if data is sold: We do not sell personal information
• Non-discrimination: Exercise rights without facing discrimination

Additional Rights (Other Jurisdictions)

If you're in Canada, Australia, Brazil, or other jurisdictions with privacy laws, you may have similar rights. Contact us to learn more.

To exercise your rights: Email our Data Protection Officer at legal@spinnable.ai

We'll respond to verified requests within 30 days (or as required by applicable law).

8. International Data Transfers

Spinnable operates globally. Your data may be processed in the United States, Portugal, or other countries where our service providers operate.

When we transfer data internationally, we use approved mechanisms to ensure adequate protection:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions recognizing equivalent privacy protection
• Other lawful transfer mechanisms as appropriate

9. Children's Privacy

Spinnable is not intended for children under 16. We do not knowingly collect data from children. If you believe we've inadvertently collected information from a child, please contact us immediately, and we'll delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we'll:

• Update the "Last Updated" date at the top
• Notify you via email or through our service
• Give you the opportunity to review changes before they take effect (where required by law)

Your continued use of Spinnable after changes become effective means you accept the updated policy.

11. Contact Us

Have questions or concerns about your privacy?

Data Protection Officer: Our Data Protection Officer can be reached at legal@spinnable.ai

Address: Spinnable, Inc., 251 Little Falls Drive, Wilmington, New Castle County, Delaware 19808

We're committed to addressing your concerns promptly and transparently.