This privacy policy ("Policy") applies for the offering and use of the “OKSpin” services (hereinafter referred to as “OKSpin”, or "Services"), which is provided to you by OKSPIN CO.,LIMITED (hereinafter referred to as “we” or “us”) for use on your mobile device. It describes how we collects, protects and uses the personally identifiable information ("Personal Information", or "Personal Data") you ("User", "you" or "your") may provide on our website ("Website") and any of our OKSpin services . It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. Access to OKSpin is possible via partner apps, which integrate OKSpin in their apps (hereinafter referred to as “OKSpin partner app”). The OKSpin partner app acts as a distribution channel for OKSpin. The provider of the OKSpin partner app does not become the contractual partner of the user for using OKSpin. Neither do we become the contractual partner of the user for using the OKSpin partner app.

You acknowledge that you have read this Policy and agree to all its terms and conditions. By access to or using our Website or Services you express your acceptance of this Policy, as such Policy may be amended from time to time. Each time You use our Services, you agree and expressly agree to our collection, use, storage, transfer and disclosure of the information as described below. Please do not use or access our Website and Services if you do not agree to be bound by this Policy.

“Personal Information” (hereinafter also referred to as “Personal Data” ) , or parts thereof, is the means which can identify you either directly (e.g. by your name) or indirectly (e.g. by pseudonymised data such as a unique ID). This means that personal data includes, for example, email addresses, addresses, mobile phone numbers, user names, profile pictures, personal preferences and use behaviour regarding the apps used on your end device, user content, financial information and health-related information, CPF, PAN card number, Aadhaar information including Aadhaar number or Virtual ID KYC related information such as videos or other online/ offline verification documents as mandated by relevant regulatory authorities, your business-related information.

Besides the foregoings, one-time identifiers such as the IP address of your end device or the browser you use, and other specific information about your mobile device could also be included.

We receive and store any information you knowingly provide to us when you create an account, as well as when you fill any online forms on the Website. When required, this information may include your email address, address, name, mobile phone number, CPF, PAN card number, or other Personal Information.It includes information from the clipboard and the gallery.You can choose not to provide us with certain information, but certain features of the Website may not be accessible. Users who are uncertain about what information is mandatory are welcome to contact us.

When you use OKSpin service, our servers automatically record information that your browser sends. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences, the web page you were visiting before your access to our service the time spent on those pages, information you search for on our Website, access times and dates, the images you actively select and upload, the passwords you copy during your participation in activities, and other statistics.

This Privacy Policy covers all personal information that is stored and processed when you are using OKSpin.

You are able to access, add to, update and delete certain Personal Information about you. The information you can view, update, and delete may change as the Website or Services change. When you update information, however, we may maintain a copy of the original unrevised information in our records. Some information may remain in our private records after your deletion of such information from your account. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

Any of the information we collect from you may be used to improve customer service and respond to queries and emails of our customers; run and operate our Website and Services. Information collected via our Services is used for the purpose of delivering ads that we believe you may be interested in. Non-Personal Information collected is used only to identify potential cases of abuse and establish statistical information regarding Website usage. This statistical information is not used in such a way that would identify any particular user of the system.

We may process Personal Information related to you if one of the following applies:

1. You have given consent for one or more specific purposes. Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. This, however, does not apply, whenever the processing of Personal Information is subject to EU General Data Protection Regulation (GDPR) under the European Data Protection Law;
2. Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
3. Processing is necessary for compliance with a legal obligation to which you are subject;
4. Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
5. Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
In any case, we will be happy to clarify the specific legal basis that applies to the processing in your case, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

We share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us, pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use PI they receive from us for any other purpose.

We may share your information with business partners and other third parties in order to allow them to provide you with offers, promotions, or ads that we think you may enjoy. If you do not want us to share your personal information with these companies, please contact us using the information below. privacy@okspin.com

If you are visiting our Website or using OKSpin from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to various locations and processing globally. By providing your personal information, you consent to any transfer and processing in accordance with the Policy.

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by inquiring with us using the information provided in the contact section.

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. Should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification.

Any requests to exercise User rights can be directed to the Owner(person who exercising power)through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Our Website and Services, including our OKSpin, are not directed to children under the age of 18, and we do not knowingly collect any personal information from children under the age of 18. Please do not submit any Personal Information through our Website or Service if you are under the age of 18. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website or Service. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our Website or Service, please contact us, and we will delete that information immediately.

If you have actual knowledge that a user is under the age of 18, please notify us using the mechanisms provided through our platform or tools, or contact us using the information below.

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transaction-related emails.

The Website uses "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To learn more about cookies and how to manage them, visit internetcookies.org

In addition to using cookies and related technologies as described above, we also may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These companies may deliver ads that might also place cookies and otherwise track user behavior.

If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

1. Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http:// optout.aboutads.info/) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices).

2. European Interactive Digital Advertising Alliiance (EDAA)'s consumer opt-out page (http://youronlinechoices.eu).

3. Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).

In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple's IDFA or Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http:// www.networkadvertising.org/mobile-choices.

Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Our Website does not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

Our Website contains links to other websites that are not owned or controlled by us. When activating these links, you will be forwarded directly to the websites of the other service providers. Please be aware that we are not responsible for the privacy practices of such other websites or third-parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information. We cannot accept any responsibility for the confidential handling of your Personal Data on these websites of third-party companies, as we have no influence on the compliance of these companies with the data protection regulations. Please inform yourself about the use of your Personal Data by these companies directly on these websites.

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite all best efforts.

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website and/or send you an email.

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and personal data will likely be among the assets transferred.

Your personal information will only be stored for as long as your participation in the use of OKSpin, for the fulfilment of your wishes, or for our legitimate interests for the purposes of which we have logged your personal information, or for as long as is permitted or required by law:

For as long as you use OKSpin, we will store and process your personal information for the duration of your use of OKSpin, until you end it or request that we erase your personal information;
For as long as you set up a user account for our services, we will store and process your personal information for the duration of your use of OKSpin, until you terminate it or until you request that we erase your data;
If you send us a query, we will process your personal information for the duration of the processing of your query.
When we no longer require your personal information, we will erase it from our systems and records, or anonymise it so that it can no longer be identified.
We can retain certain personal information in order to comply with our statutory and regulatory obligations, and to enable us to manage our rights (e.g. the assertion of our rights in court), or for statistical purposes.

We may update this Privacy Notice and the “last updated” date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. We will provide notice of substantial changes of this policy on the homepage of the Site, or we will send you an e-mail to the e-mail address that you may have provided us of such changes. The changes will be made within 7 days after the notification was provided. Continued use of the Website after any such changes shall constitute your consent to such changes.

If you have any questions about this Policy, please contact us. privacy@okspin.com



This Privacy Policy is effective on September 01, 2021.