Privacy policy

1. Introduction

At SPiN — Space Products and Innovation (“us”, “we”, “our” or “the Company”) we value your privacy and the importance of safeguarding your data. This policy describes our privacy practices for the activities set out below and explains how we collect, store, access and otherwise process information relating to individuals. Personal data (“Personal Data”) refers to any information that, on its own or in combination with other available information, can identify an individual.

We are committed to protecting your privacy in accordance with the highest level of privacy regulation. As such, we follow the obligations under the regulations below.

Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation
Quebec Law 25
The EU General Data Protection Regulation (GDPR)
Brazil’s Data Protection Legislation (LGPD)
California’s Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) and the California Online Privacy Protection Act (CalOPPA)
Colorado Privacy Act (CPA)
Utah Consumer Privacy Act (UCPA)
Connecticut Data Privacy Act (CTDPA)
Virginia Consumer Data Protection Act (VCDPA)
South Africa’s Protection of Personal Information Act (POPIA)

Scope

This policy applies to the SPiN websites, domains, applications, services and products.

It does not apply to third-party applications, websites, products, services or platforms that may be accessed through links we provide. Those sites are owned and operated independently from us and have their own privacy and data collection practices. Any Personal Data you provide to them is governed by their own policy. We cannot accept liability for the actions or policies of these independent sites.

Processing activities

This policy applies when you interact with us by making use of our application and services as an authorised user, or by visiting any of our websites that link to this statement.

2. Personal data we collect

When you make a purchase, or attempt to make a purchase, we collect the following types of Personal Data.

Account information such as your name, email address and password
Payment information such as your billing address, phone number, credit card, debit card or other payment method
Demographic data including age and gender
Mobile device specific identifiers such as make and model, IMEI and phone number
Location data
Work-related information such as your occupation and employment details

How we collect your Personal Data

We collect Personal Data from the following sources.

From you. You may give us your Account Information, Payment Information, Financial Information, Demographic Data, Purchase Information, Content, Feedback and Product Information by filling in forms, using our products or services, entering information online or by corresponding with us by post, phone, email or otherwise. This includes data you provide when you create an account, purchase products, use our services, express interest in them, download software, subscribe to a newsletter, complete a survey, contact us with an enquiry or report a problem, or log in via social media.

Automated technologies or interactions. As you interact with our website, we may automatically collect Device Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data using cookies, server logs and similar technologies.

Third parties. We may receive Personal Data about you from various third parties, including Account and Payment Information from another individual purchasing a gift for you, Device and Usage Data from analytics providers such as Google, Account and Payment Data from social media platforms when you log in through them, Content from communication services where you give us permission, data from fraud prevention and credit risk reduction organisations, and data from technical, payment and delivery service providers.

If you provide us, or our service providers, with Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this policy. If you believe your Personal Data has been provided to us improperly, or you wish to exercise your rights, please contact us using the details in the “Contact us” section.

Device and usage data

When you visit an SPiN website we automatically collect and store information about your visit using browser cookies or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The help feature on most browsers explains how to accept, disable or be notified about cookies. If you do not accept cookies, some features of our service may not work and we recommend leaving them on.

We also process information when you use our services and products, which may include location information and data collected from third parties. That Personal Data is subject to the relevant third party’s own separate privacy and data collection policies. Where a third party is unresponsive to your rights, you may contact our Data Protection Officer.

Purpose and legal basis for processing

We collect and use your Personal Data with your consent to provide, maintain and develop our products and services and understand how to improve them. These purposes include delivering your product or service, fulfilling orders including electronic and non-electronic shipment, providing technical and customer support, research and development, and communicating with you about the products and services.

Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services, maintain our relationship with you and protect our business against fraud. Consent will be required to initiate services with you, and new consent will be required if the type of data collected changes. Within our contract, if you fail to provide consent, some services may not be available.

Third-party tools

We use third-party tools to store your information. The site you are reading is served by Cloudflare; the original site was hosted by Wix.

International data transfer and storage

Where possible, we store and process data on servers within the general geographical region where you reside — although this may not be within the country in which you reside. For European-based companies we use servers in the European Economic Area. Your Personal Data may also be transferred to, and maintained on, servers residing outside your state, province, country or other governmental jurisdiction where data laws may differ. We take appropriate steps to ensure your Personal Data is treated securely and in accordance with this policy and applicable data protection law.

More information about the standard contractual clauses is available at eur-lex.europa.eu (Commission Implementing Decision (EU) 2021/914).

Sharing and disclosure

We will share your Personal Data with third parties only in the ways set out in this policy or at the point when the data is collected.

Legal requirement. We may use or disclose your Personal Data to comply with a legal obligation, in connection with a request from a public or government authority, in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical, we will tell you in advance of such disclosure.

Service providers and other third parties. We may use third-party service providers, independent contractors, agencies or consultants to deliver and help us improve our products and services. We may share your Personal Data with marketing agencies, database service providers, backup and disaster recovery providers, email service providers and others, but only to maintain and improve our products and services. For further information on recipients, please contact us.

3. Cookies

A cookie is a small file with information that your browser stores on your device. Information in this file is typically shared with the owner of the site and potentially with partners and third parties. The collection of this information may be used in the function of the site and to improve your experience.

To give you the best experience possible, we use the following types of cookies: strictly necessary cookies, which we require to run the service; preference cookies, used to remember how you like to use the service; analytics cookies, which tell us about the types of people who visit; and marketing cookies, shared with third-party advertisers and partners to provide a personalised marketing experience.

Global Privacy Control (GPC) is a setting you can enable in your browser to communicate your privacy preference with respect to ad trackers. For details, including how to turn on GPC, visit globalprivacycontrol.org. Please note this may impact the functionality of our website.

This rebuilt site is static, sets no cookies of its own, and does not load third-party analytics or advertising scripts.

4. Retention and deletion

We retain your Personal Data only for as long as necessary for the purpose for which it was collected and to the extent required by applicable law. When we no longer need Personal Data, we remove it from our systems and/or take steps to anonymise it.

5. Merger or acquisition

If we are involved in a merger, acquisition or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy. Under certain circumstances we may be required to disclose your personal information if required by law or in response to valid requests by public authorities.

6. How we keep your data safe

We have appropriate organisational safeguards and security measures in place to protect your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Communication between your browser and our website uses a secure encrypted connection wherever your Personal Data is involved. We require any third party contracted to process your Personal Data on our behalf to have security measures in place and to treat such data in accordance with the law. In the event of a Personal Data breach, we will notify you and any applicable regulator when we are legally required to do so.

7. Children’s privacy

We do not knowingly collect Personal Data from children under the age of 18 years.

8. Your rights

Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations. These may include the right to access, the right to rectification, the right to be forgotten, the right to restrict processing, the right to portability, the right to opt out, the right to object, non-discrimination and non-retaliation, and the right to file an appeal or a complaint with a competent data protection authority.

If you are based in the EEA, a list of local data protection authorities is available at edpb.europa.eu/about-edpb/about-edpb/members_en.

Withdrawing consent. If you have consented to our processing of your Personal Data, you have the right to withdraw that consent at any time, free of charge — for example where you wish to opt out of marketing messages. To withdraw consent, contact us using the details below.

How to exercise your rights. Send a request to our privacy team using the contact details below. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.

9. Changes

We may modify this policy at any time. If we make changes, we will post an updated version at this website. When using our services, you will be asked to review and accept our privacy policy. In this manner we may record your acceptance and notify you of any future changes.

10. Contact us

To request a copy of your information, unsubscribe from our email list, request that your data be deleted, or ask a question about your data privacy, email [email protected].

Or write to: Data Privacy Officer, SPiN — Space Products and Innovation, Via Santa Croce 5, 00044 Frascati (RM), Italy.

Last updated: 3 October 2024.