Privacy policy

1. Personal information that may be requested

Depending on your use of our website, we may ask you for the following information:

Contact

In case you would like us to contact you for a future partnership or collaboration, we will ask you for your full name, company, job position, country, email, phone number, language, additional information that may help us to provide a detailed response.

You would be able to find more information about data protection in the respective contact form.

Newsletter

If you are interested in being updated about our products, services and activity; we will ask you for a contact email so that we can communicate with you.

You would be able to find more information about data protection in the respective newsletter form.

Cookies

During your usage of our website, we would need to process your cookies information.

Cookies are text files used to identify your device while you use our website. The information contained in a cookie is created by the server once you enter the website. This data is classified with an ID unique to you and your computer. It allows our system to recognise when you come back to our networks.

Once you enter our website, we will ask you to confirm and accept your cookie settings.

Spinmatic Limited will not be responsible for the privacy and cookie policy that third parties websites that appear in this page.

Reminder: Please, if you are younger than 18 years, do not complete any form we have or try to contact us.

2. Data processor and contact details

All the data provided by you will be processed according to the General Data Protection Regulation (GDPR) and national laws and regulations. You can find the contact data of the controller/responsible, processor, Data Protection Officer and public authorities below:

Contact

Responsible

Spinmatic Limited

Company no.: C 82276

Address: 66, Apt 5, Old Theatre Street, Valletta VLT 1427, Malta

E-Mail

gdpr@goldenrace.com

If you have any problem with the information or solutions provided, you can contact with Malta's Office of the Data Protection Commissioner.

Malta Data Protection Commissioner

Address

Mr Joseph Ebejer 2, Airways House High Street, Sliema SLM 1549

Phone

+356 2328 7100

Fax

+356 2328 7198

E-Mail

commissioner.dataprotection@gov.mt

Website

www.idpc.org.mt

For another Data Protection Commissioner you can enter the following link:

www.ec.europa.eu

3. Which are the uses of your data?

The data you provide, as per section 1 of this policy will be processed to:

• Respond to requests for information made by visitors at spinmatic.com through its forms.
• To send commercial information as requested by the users.
• Control of the website in order to prevent and detect any fraudulent use as well as unauthorised accesses.
• Improve your web browsing experience.

4. Legitimation for the treatment

The legal basis for the processing of data is your consent. If you are interested in receiving information from us by sending forms, you express your free, informed and voluntary consent to the processing of data by Softquo Holding, its group or companies intended to provide you with this information.

You may withdraw your consent to the processing of your data at any time by contacting our team, in accordance with the information in section two of this policy.

If our relationship is contractual, the legal basis for data processing is the execution of a contract.

We will process the information for the duration of the contract and store the information for the legally determined period.

5. Information transfer

Spinmatic Limited is a subsidiary company of Softquo Holding Limited, in order to provide you with any requested information or to process the data as per section three we may need to disclose your information to the parent company (Softquo), as all commercial communications will be handled on behalf of Softquo.

This information may also be shared with our designated company for marketing purposes “Virtual Reality Development” (Spain) as well as with the service provider for the management of communication lists “Mailchimp”.

In the case that there would be any data transmission to a country outside the EU, we assure you the compliance with formal and security requirements as required by GDPR.

6. Third parties' links

As you can verify, in our website there are several links to external websites. This Privacy Policy is not suitable for them, so we are not responsible for their data processing. If you have any problem with their activity, we invite you to contact public authorities in point 2 (Data Protection Commissioner).

7. Cookies

Cookies are text files used to identify your device while you use our website. The information contained in a cookie is created by the server once you enter the website.

This data is classified with an ID unique to you and your computer. It allows our system to recognise when you come back to our networks.

Please note that when you visit our website, we will need to process certain (necessary) cookies, as shown below. All other cookies not marked as necessary are optional and we will ask for your consent to process them.

Please note that several cookies are re-directed from external providers, please access the following links for their cookie policies and terms:

• Google Analytics
• Facebook Pixel
• LinkedIn Insight
• Microsoft Clarity

8. Basic user’s rights

According to GDPR, you can exercise the following rights:

Basic information of data protection

Access

The organisation must inform about:

• The purposes of the treatment, categories of personal data that are processed and the possible data communications and their recipients.
• If possible, the period of conservation of your data. If not, the criteria to determine this term.
• The right to request the rectification or suppression of the data, the limitation to the treatment, or to oppose it.
• The right to file a claim with the Control Authority.
• If an international data transfer occurs, receive information on the appropriate guarantees.
• The existence of automated decisions (including profiles), the applied logic and consequences of this treatment.

Rectification

Interested parties can request:

• The rectification of inaccurate data and complete incomplete personal data, even with an additional declaration.

Suppression / Deletion

Interested parties can request:

• The suppression of personal data without due delay when any of the cases contemplated concur. For example, illicit treatment of data, or when the purpose that motivated the treatment or collection.
• However, a series of exceptions are regulated in which this right will not apply. For example, when the right to freedom of expression and information should prevail.

Limitation of the treatment

Interested parties can request the person in charge to suspend the processing of data when:

• The accuracy of the data is contested, while the accuracy is verified by the person responsible.
• The interested party has exercised his right of opposition to the processing of data, while verifying if the legitimate reasons of the responsible party prevail over the interested party.
• Ask the person responsible to keep your personal data when:
• The data processing is illegal, and the interested party opposes the deletion of their data and requests instead the limitation of its use.
• The person in charge no longer needs the data for the purposes of the treatment, but the interested party does need them for the formulation, exercise or defence of claims.

Data portability

Interested parties can:

• Receive the personal data provided in a structured format, of common use and mechanical reading, and be able to transmit them to another responsible, whenever technically possible.

Opposition

Interested parties can oppose to the personal data treatment:

• When for reasons related to your personal situation, the processing of your data must cease unless a legitimate interest is proven or is necessary for the exercise or defence of claims.
• When the treatment is focused on direct marketing.

Not to be object of individualised decision

Interested parties have the right not to be the subject of a decision based solely on automated processing, including profiling, which produces legal effects or affects them.

Exceptions:

• When it is necessary for the conclusion or execution of a contract.
• When it is allowed by the Law of the EU or the Member States, with adequate measures to safeguard the rights and freedoms of the owner of the data.
• When there is explicit consent of the owner of the data.

9. Changes to the privacy policy

Spinmatic Limited may modify and update this Privacy Policy from time to time, it is the visitor's responsibility to read and accept the Privacy Policy in case new versions are issued.