Privacy Policy

Last updated: February 2023

With the rising security and privacy concerns worldwide we thought it would be a good idea for us to share with our users what are we doing about it at SpinOffice CRM.

We’re committed to the confidentiality and security of your personal information. If you are the customer of one of our clients, you may not have heard of us. Still, there is nothing more important to us than our relationship with you. You may not know why we would have data about you in our system. We process data on behalf of companies with whom you have a relationship, with whom you have shared your data. In simple terms, you are a data subject, your service provider is a data controller (who determines how your data can be processed) and we act as a data processor. We’re committed to the confidentiality and security of any personal information that has been provided to us about you. This Privacy Policy explains how we protect your rights and care for your information.

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Mulberry Garden B.V. (“us”, “we”, or “our”) operates the www.spinoffice-crm.com website and the SpinOffice CRM application (hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

1. Definitions

• Service
  Service means the https://www.spinoffice-crm.com website and the SpinOffice CRM application operated by Mulberry Garden B.V.
• Personal Data
  Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data
  Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Cookies
  Cookies are small files stored on your device (computer or mobile device).
• Data Controller
  Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
  For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
• Data Processors (or Service Providers)
  Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
  We may use the services of various Service Providers in order to process your data more effectively.
• Data Subject (or User)
  Data Subject is any living individual who is using our Service and is the subject of Personal Data.

2. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you. Types of Data Collected are as follows.

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

The below list details the cookies used in our website.

Cookie	Type	Duration	Description
AWSALBCORS		7 days	This cookie is used for load balancing services provided by Amazon inorder to optimize the user experience. Amazon has updated the ALB and CLB so that customers can continue to use the CORS request with stickness.
AnalyticsSyncHistory		1 month	No description
CONSENT		2 years	YouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data.
IDE	session	1 year 24 days	Used by Google DoubleClick and stores information about how the user uses the website and any other advertisement before visiting the website. This is used to present users with ads that are relevant to them according to the user profile.
JSESSIONID		session	The JSESSIONID cookie is used by New Relic to store a session identifier so that New Relic can monitor session counts for an application.
PHPSESSID		session	This cookie is native to PHP applications. The cookie is used to store and identify a users' unique session ID for the purpose of managing user session on the website. The cookie is a session cookies and is deleted when all the browser windows are closed.
UserMatchHistory		1 month	Linkedin - Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences.
_GRECAPTCHA		5 months 27 days	This cookie is set by Google. In addition to certain standard Google cookies, reCAPTCHA sets a necessary cookie (_GRECAPTCHA) when executed for the purpose of providing its risk analysis.
__cf_bm		30 minutes	This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.
__utma		2 years	This cookie is set by Google Analytics and is used to distinguish users and sessions. The cookie is created when the JavaScript library executes and there are no existing __utma cookies. The cookie is updated every time data is sent to Google Analytics.
__utmb	session	30 minutes	The cookie is set by Google Analytics. The cookie is used to determine new sessions/visits. The cookie is created when the JavaScript library executes and there are no existing __utma cookies. The cookie is updated every time data is sent to Google Analytics.
__utmc		session	The cookie is set by Google Analytics and is deleted when the user closes the browser. The cookie is not used by ga.js. The cookie is used to enable interoperability with urchin.js which is an older version of Google analytics and used in conjunction with the __utmb cookie to determine new sessions/visits.
__utmt		10 minutes	The cookie is set by Google Analytics and is used to throttle request rate.
__utmz		6 months	This cookie is set by Google analytics and is used to store the traffic source or campaign through which the visitor reached your site.
__zlcmid		1 year	This cookie is used by Zendesk live chat and is used to store the live chat ID.
_fbp		3 months	This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website.
_ga		2 years	The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
_ga_02E6VQHV95		2 years	This cookie is installed by Google Analytics.
_gat_UA-1682656-7		1 minute	A variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to.
_gat_gtag_UA_1682656_7		1 minute	Set by Google to distinguish users.
_gcl_au		3 months	This cookie is used by Google Analytics to understand user interaction with the website.
_gid		1 day	Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
ac_enable_tracking		1 month	This cookie is set by the Active Campaign. This cookie is used to keep track of the site usage.
bcookie		2 years	This cookie is set by linkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the page.
bscookie		2 years	This cookie is a browser ID cookie set by Linked share Buttons and ad tags.
cky-consent		1 year	The cookie is set by CookieYes to remember the users's consent settings so that the website recognizes the users the next time they visit.
cookielawinfo-checkbox-advertisement		1 year	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Advertisement".
cookielawinfo-checkbox-analytics	0	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	0	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-functional	0	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	0	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-necessary	0	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	0	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	0	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
cookieyes-advertisement		1 year	CookieYes sets this cookie to remember the consent of users for the use of cookies in the 'Advertisement' category.
cookieyes-analytics		1 year	CookieYes sets this cookie to remember the consent of users for the use of cookies in the 'Analytics' category.
cookieyes-functional		1 year	CookieYes sets this cookie to remember the consent of users for the use of cookies in the 'Functional' category.
cookieyes-necessary		1 year	CookieYes sets this cookie to remember the consent of users for the use of cookies in the 'Necessary' category.
cookieyes-performance		1 year	CookieYes sets this cookie to remember the consent of users for the use of cookies in the 'Performance' category.
cookieyesID		1 year	CookieYes sets this cookie as a unique identifier for visitors according to their consent.
dashboardHash		past	No description
debug		never	No description available.
joe-chnlcustid		1 year	This is a HTTP type cookie used for client side customer identification.
lang		session	This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website.
li_gc		2 years	No description
lidc		1 day	This cookie is set by LinkedIn and used for routing.
logger		2 years	No description available.
pll_language		1 year	This cookie is set by Polylang plugin for WordPress powered websites. The cookie stores the language code of the last browsed page.
prism_253216449		1 month	No description
spd-custhash		1 year	No description available.

3. Use of Data

Mulberry Garden B.V. uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

4. Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Mulberry Garden B.V. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Mulberry Garden B.V. may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• For payment processing purposes
• To comply with the law

5. Retention of Data

Mulberry Garden B.V. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Mulberry Garden B.V. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

6. Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Netherlands and choose to provide information to us, please note that we transfer the data, including Personal Data, to Netherlands and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Mulberry Garden B.V. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

7. Disclosure of Data

Business Transaction

If Mulberry Garden B.V. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Mulberry Garden B.V. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Mulberry Garden B.V. may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Mulberry Garden B.V.
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

8. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

9. Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

10. Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Mulberry Garden B.V. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Mulberry Garden B.V. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

11. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Amazon Web Services

Mulberry Garden B.V. uses Amazon Web Services (AWS) (https://aws.amazon.com) to host the application servers that are needed to run its service SpinOffice CRM. All client databases, email messages and files are securely saved and managed on AWS. The data centers that we use are located within the EU and our network is a private network. Our virtual private network spans over two AWS data centers within one availability zone. This allows us to host our servers it two separate data centers. In case of a problem in one data center, the other one will pickup the load and users can continue to work.

AWS’s Privacy Policy is available here: https://aws.amazon.com/privacy/.

ActiveCampaign

For email marketing, Mulberry Garden B.V. uses ActiveCampaign, developed by ActiveCampaign LLC, 1 N Dearborn Street, Chicago, IL 60602, USA. ActiveCampaign is a service which organizes and analyzes the distribution of newsletters. If you provide data (e.g. your email address) to subscribe to our newsletter, it will be stored on ActiveCampaign servers in the USA. ActiveCampaign is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States. We use ActiveCampaign to gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our marketing email. For more information please review the ActiveCampaign privacy policy available under: https://www.activecampaign.com/privacy-policy.

Calendly

Mulberry Garden B.V. uses uses Calendly, developed by Calendly LLC, Calendly LLC, 1315 Peachtree St NE, Atlanta, GA 30309, United States of America, to schedule calendar appointments for SpinOffice CRM. Usage data, as well as the information that you enter in the Calendly widget, will be stored and processed on servers in the United States. Calendly complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland, to the United States. For more information please review the Calendly privacy policy under: https://calendly.com/pages/privacy.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Behavioral Remarketing

Mulberry Garden B.V. uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

• Google Ads (AdWords)
  Google Ads (AdWords) remarketing service is provided by Google Inc.
  You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: www.google.com/settings/ads
  Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
• Facebook
  Facebook remarketing service is provided by Facebook Inc.
  You can learn more about interest-based advertising from Facebook by visiting this page: www.facebook.com/help/164968693837950
  To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: www.facebook.com/help/568137493302217
  Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA www.aboutads.info/choices, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca or the European Interactive Digital Advertising Alliance in Europe www.youronlinechoices.eu, or opt-out using your mobile device settings.
  For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: www.facebook.com/privacy/explanation

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Apple Store In-App Payments
  Their Privacy Policy can be viewed at www.apple.com/legal/privacy
• PayPal
  Their Privacy Policy can be viewed at www.paypal.com/webapps/mpp/ua/privacy-full
• mollie
  Their Privacy Policy can be viewed at www.mollie.com/en/privacy

Authentication

We built our Service to respect and protect your data. We utilize OAuth 2.0 authentication with Google. OAuth 2.0 is an open standard authorization protocol that allows third parties to access user data without needing to know or store user passwords. Also, OAuth 2.0 authentication allows users to revoke app access at any moment in app settings. If a user revokes Loop app access, our Services do not have access to any of the user data anymore. Where OAuth 2.0 is not supported, we need to get your account username and password secure in our Services.

• Our Service uses OAuth for user authentication. We never have access to Google, Microsoft, Apple, or Android passwords.
• Our Service uses https://mail.google.com/ to read, delete, and manage a user’s Gmail account in our Service, so users can manage their email accounts through our Product and sync the changes with their Gmail account.
• Our Service uses www.googleapis.com/auth/userinfo.email to view user’s email address.
• Users give access to the Service via OAuth 2.0 authorisation, allowing a full synchronisation between our Service and a Gmail account.

12. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

13. Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

14. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15. Contact Us

If you suspect that your data is not properly secured, has been misused or if you believe that Mollie does not adequately guarantee the correct processing of personal data, please send an email to: info@spinoffice-crm.com.