Last Updated: February 26, 2020
Our Commitment to Privacy
SPINCO IP Holdings Inc. (“SPINCO” “we”, “us” and “our”) values and is committed to protecting your privacy by ensuring that your Personal Information (defined below) is treated with care and is not used or disclosed in ways to which you have not consented.
By visiting and/or using the SPINCO website located at www.spinco.ca/ (the “Site”), booking or purchasing SPINCO classes, purchasing merchandise, communicating with SPINCO, using and attending SPINCO studios (“Studio(s)”), and/or utilizing any other services we provide in connection with the above (collectively, the “Services”), you agree that your Personal Information will be handled as described in this Policy as well as any other terms that are described to you when your Personal Information is collected. If you do not agree with this Policy or such other terms, please do not use the Site or our Services or otherwise provide your Personal Information to us.
SPINCO uses video surveillance technology at each of its Studios for security purposes, including to protect against harm to the rights, property and safety of SPINCO, our employees, clients and others. Cameras will be located in the reception area of each Studio with a view of the reception, merchandise and entrance to the Studio. The cameras may have the ability to zoom, conduct facial recognition and operate using night vision. Sound may be recorded. Cameras will not view spaces where individuals have a heightened expectation of privacy (e.g., washrooms). Only authorized personnel (including the Studio owner, the manager on duty at each Studio and the Privacy Officer) may operate the video surveillance system and access the information it contains. Cameras will operate and record 24 hours per day.
We will securely store all video surveillance in the cloud for a period of 30 days, in accordance with this policy. Recordings will only be retained for more than 30 days where the footage is required as part of an investigation or for the purposes of evidence. SPINCO will not disclose recordings containing any Personal Information without your consent, except where required by law. If you submit a formal request to our Privacy Officer to access a recording that you appear in, we will ensure that Personal Information about any other individuals in the recording is not included.
SPINCO is responsible for approving and directing compliance with this policy and resolving any issues relating to the policy, including its implementation, administration, evaluation and the documentation of access to recordings and the retention or disposal of recordings. SPINCO will evaluate this policy every three years to accommodate legal and technological developments and to ensure the policy continues to meet our needs. You may contact our Privacy Officer at the address indicated below if you have any questions about the video surveillance.
Online Data Collection
When you visit our Site or communicate with SPINCO via email, you are communicating electronically. You will receive communications from SPINCO electronically in accordance with the consent that you provide to us. SPINCO will communicate with you by email or by posting notifications on our Site. You understand and agree that all agreements, notices, disclosures and other communications that SPINCO provides electronically, satisfy any legal requirement that such communications be in writing.
SPINCO will never disclose, sell or lease to any third party any Personal Information that you provide to us, without your permission, other than as described in this Policy, or unless we are required to do so by law. Notwithstanding this, this Site is hosted and administered by a third party. Accordingly, the Personal Information provided through this Site will be available to that third party for the limited purposes of hosting and administering this Site.
It is SPINCO’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.
We may modify, revise or update this Policy at any time by updating this posting. Each time you use the Site, the version of this Policy then posted will apply to that use, so you should check this page each time you use the Site.
What is Personal Information?
“Personal Information” is information about an identifiable individual. Personal Information includes but is not limited to your name, residential address, telephone number and e-mail address.
What Personal Information Do We Collect?
Personal Information You Provide to Us
Personal Information is collected by us when you provide it to us, such as when you register for an account on our Site, book or pay for classes, send us a question or comment through the Site, when you meet with us in person, register at one of our Studios, or when you phone us with an inquiry. The type of information that we collect varies based on your interaction with us and may include the following:
· your contact information (name, residential address, telephone number(s) and email address);
- your password for your user account on the Site;
· your shoe size (if you need to use our bike shoes);
· the company you are affiliated with (optional);
· your date of birth (optional);
· your payment information, if you make a purchase from us;
- any purchase or reservation history;
- interaction with our social media channels; and
- any other Personal Information you choose to provide to us in your comments and questions, when you meet with us in person, or when you phone us with an inquiry.
We do not knowingly connect Personal Information from minors. If we discover that Personal Information has been provided by a person who is under the age of majority in the province where he/she has provided such information, SPINCO reserves the right to delete such information.
Personal Information We Collect from Third Parties
To create an account and participate in one of our classes, we need emergency contact information for each of our customers, including the name and phone number of a person to contact in case of an emergency and their relationship to our customer. Please ensure that these third parties are aware of, and consent to, you providing their Personal Information to us for this limited purpose.
Information We Collect Automatically
When you visit our Site, we also automatically collect other non-identifiable technical information that is recorded by the standard operation of our Internet servers on an anonymous basis, such as:
- your browser type and operating system;
- links you click within our Site, your IP address;
- details of your visits to our Site (including information such as date, time and pages visited);
- the length of time you visit our Site and or use our Services; and
- the referring URL or the webpage that led you to our Site.
This information is used on an aggregate basis and in a non-personally identifiable form, including: (i) for Site and system administration purposes; (ii) to improve the Site; (iii) to conduct internal reviews of the number of visitors to the Site; (iv) to help us better understand visitors’ use of our Site; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Site when necessary.
When you view the Site, we may place a “cookie” on the hard drive of your computer which allows the Site to remember who you are. Cookies provide additional functionality to websites to better match users’ interests and preferences. With most Internet browsers, you can erase cookies from your computer hard drive, block the creation of cookies, or receive a warning before a cookie is stored, although doing so may affect your use of the Site and your ability to access certain features of the Site. Please refer to your browser instructions or the help section of your browser to learn more about these functions.
Our Site may use web beacons. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, web beacons will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
Third Party Analytics
For What Purposes Do We Collect Personal Information?
We collect and use Personal Information primarily for the following purposes:
- to provide you with our Services;
· to respond to your communications and inquiries and for other customer service purposes;
· to maintain your user account;
- for internal purposes such as marketing and to improve our customer experience. Information and feedback allows us to improve and personalize your experience, as well as address any requests or issues;
- to monitor use of our Site;
- to improve our Site to ensure that our layout and content is effectively and efficiently presented;
- to improve our offering (whether it be pricing, class times, etc.);
- to pull reports to assist with marketing;
- to process transactions;
- to send correspondence about updates, company news, contests, or any other important information that SPINCO would like to relay or that we feel will interest you, in accordance with applicable law.
- to enforce this Policy and our Terms and Conditions;
- to protect against harm to the rights, property and safety of SPINCO, our employees, clients and others; and
- to meet any legal, regulatory, audit, security, and financial requirements under federal and provincial laws.
We do not collect more Personal Information than we require for the purposes for which Personal Information is being collected, unless we are required or permitted by law to collect additional information.
We will notify the individual from whom the information is collected of the purposes for which we are collecting the information. This notice will be provided at or before the time that we collect the Personal Information. Depending on the way in which Personal Information is collected, this may be done orally or in writing.
When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will communicate the new purpose prior to using the information for the new purpose, unless the new purpose is required or permitted by law.
Other than as required or allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), your Personal Information will not be used for any other purpose without your consent.
Disclosure of Your Personal Information
Your Personal Information will never be sold, exchanged, transferred or shared with another company other than as set out in this Policy without your consent.
We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your Personal Information will be subject to this Policy.
We may disclose the information we collect from you to third party service providers, contractors or agents who perform functions on our behalf.
We may share your Personal Information if we are acquired by or merged with another company, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding. We may transfer the information we have collected from you to the other company.
We may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Policy, or as evidence in litigation in which we are involved.
Security, Retention and Disposal of Personal Information
We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, and employee education.
We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a password that nobody else knows or can easily guess, and keeping your username and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Processing of Personal Information
Your Personal Information may be stored on servers located outside of Canada, including in the U.S., and as a result may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction.
Links to Other Websites
Our Site may provide links or references to websites operated by third parties. These third party websites are not governed by this Policy but by other privacy policies that may differ from our Policy. This Policy does not extend to the collection of Personal Information by these third parties and we do not assume any responsibility for the privacy practices, policies or actions of third parties. In visiting any third party websites, whether linked to this Site or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party website or any content in such website. We encourage you to review the privacy policies of each website visited before using those websites or disclosing any Personal Information to third parties.
Correcting Your Personal Information
We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information.
Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed.
You may modify Personal Information that you have submitted by logging into your account and updating your profile information.
Access to Personal Information
If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information.
You may contact our Privacy Officer at the contact information below to request access to Personal Information that we have about you. We will respond to requests within 30 days.
Questions and Further Information
We are accountable for all Personal Information in our custody and control and have designated a Privacy Officer, who is ultimately accountable for the handling of all Personal Information in our custody and/or control and for ensuring that the principles described in this Policy are being complied with.
We make information about our privacy policies and practices readily available. If you have any concerns, complaints, or if you would like further information regarding our privacy policies or practices, please contact our Privacy Officer at:
SPINCO Privacy Officer
2 St. Clair Ave. E. Suite 1204
Toronto, ON, Canada , M4T 2T5