Destini | United States Privacy Policy

United States Privacy Policy

For the UK Privacy Policy, please click here.

 

Introduction

Destini Global LLC, a wholly owned subsidiary of SPINS LLC, provides a product locator service that enables you to search for locations that sell certain products.  In connection with your use of the product locator, we will obtain limited information that is linked to certain identifying information that indicates a single user that we use to operate the locator service. We refer to information that we gather from you in connection with your use of the product locator as “Personal Information.” We refer to the record that we create to indicate a single user as an “Identifier”, and an Identifier is part of the Personal Information. We want to assure you that we respect your privacy, so we have prepared this privacy policy to explain to you how we treat your Personal Information that we obtain in connection with your use of the product locator.

Please read this privacy policy so that you can make an informed decision about using the product locator. By using the product locator, you are agreeing to this privacy policy and providing your consent to our collection, use, and disclosure of your Personal Information as described in this privacy policy. You may exercise certain rights pertaining to your Personal Information which are outlined in the Your Personal Information Rights section of this Policy.

Although the product locator appears on the website or in the application of our client, the product locator service is provided by Destini Global LLC and our affiliates and service providers. In this privacy policy, words like “we”, “us” and “our” refer to Destini Global LLC and our affiliates and service providers, collectively.  We will disclose information, including your Personal Information, to these other entities in connection with providing the product locator, as described further below, and these other entities may use and disclose information as provided in this privacy policy.

This privacy policy was last modified on March 28, 2023.

Personal Information

 

We obtain Personal Information about you in the following ways:

  • Information that you provide to us. We may obtain Personal Information when you request information, products, or services from us. As you use the product locator, there may be other circumstances in which you provide us with additional information about yourself such as your name, phone number, and email address.
  • Information that we obtain from your use of the product locator. When you use the product locator, we may obtain information about how you use the product locator. This may be related to the products you’re interested in, the offerings you view or purchase, or how your interact with our systems.
  • Information that we obtain from other sources. From time to time we may obtain information from other sources, such as providers of other services where you have consented to that service providing information about you to us, or from third parties that develop information about consumers.
  • Information collected automatically. We may obtain information about you through the use of first or third party cookies, web beacons, web logs, IP addresses, and other technologies that receive and store certain types of information whenever you interact with us by using the product locator. These technologies may collect data related to your devices like IP address, mobile device identification, the type of device or operating system in use, or the type of browser being used. They may collect data related to your online activity like the duration of your use of the product locator, the number and frequency of uses of the product locator, or any search terms you used in the product locator. These technologies may also collect the precise geolocation of your device when you grant such access in your device’s settings. These types of technical information do not identify you personally.

 

We do not require you to provide your name in order to use the product locator. We are unable to identify you personally using only the Personal Information that we have from your use of the product locator. However, the Personal Information that we have is linked to an Identifier and when used in combination with other sources of data or in conjunction with third-party service providers, could be used to identify you personally.

We provide product locator services to many clients, and we may be able to link Personal Information from the product locators that we provide to several clients based on a single Identifier that is common to all of those product locators.

Use of Personal Information

We use your Personal Information to provide the product locator service to you, to provide our services to our clients, including targeted advertising services, to understand the usage of the product locator so that we can make improvements to the product locator and our other services, to analyze in an effort to better understand our products, services, and business in general, and to understand your behavior and preferences so we can offer additional products, services and other opportunities that we believe will be of value to you, and to market and promote our, our affiliate’s, and our partners’ products and offerings.

Disclosure of Personal Information for Our Business Purposes

We have several affiliates that provide services to us, and we may disclose Personal Information to these affiliates.  The affiliates are entities that we control, are controlled by, or are under common control with. Our affiliates may use and disclose Personal Information only as permitted in this privacy policy.

We use third parties to provide services to us in connection with the product locator services, including the targeted advertising services we provide to our clients, and we provide Personal Information to these third parties.  We allow certain clients to place tracking technologies like cookies and pixels in our offerings, which allow those parties to receive information about you or your activity on the product locator that is associated with your Personal Information. That data may be used to serve you more relevant ads on the product locator, our affiliate’s offerings, or other websites. Except for this kind of selling or sharing, we don’t otherwise sell any of your Personal Information. You may opt out of this selling or sharing at any time. For more information about opting out, please see the “Opt-Out Request” section of this privacy policy. Please note that we share Personal Information with third parties only if they agree to maintain the confidentiality of your Personal Information. These other entities may use and disclose information only as provided in this privacy policy.

Disclosure of Personal Information to Unaffiliated Third Parties for Other Purposes

 

We may disclose Personal Information to any unaffiliated third party for any legally permissible use by that third party, including without limitation for marketing purposes. Third parties may combine Personal Information with other data and be able to identify you personally, which would allow them to link your Personal Information to you personally. If you do not want us to disclose your Personal Information to third parties as permitted in this paragraph, you may opt out of our disclosing your Personal Information. For more information about opting out, please see the “Opt-Out Request” section of this privacy policy.

 

Disclosure of Non-Identifiable Personal Information

We may derive information from your Personal Information that is not linked to an Identifier.  For example, we may aggregate certain information regarding use of the product locator services so that the usage of the product locator with respect to a single Identifier is not discernable from the aggregate usage of the product locator.  We may use, sell, and share with third parties any information that we derive from Personal Information that is not linked to an Identifier.

Disclosure of Personal Information with your Consent

We may obtain your consent to disclose your Personal Information to a third party, in which case we will limit our disclosure and the use of your Personal Information only to the purposes for which we obtain your consent.  If we disclose your Personal Information to a third party with your consent, then your Personal Information will become subject to the privacy policy or other privacy commitments, if any, of that third party.  For example, we may enable you to post Personal Information to a social media account, in which case that Personal Information will become subject to the privacy policy of that social media platform, or we may enable you to submit a request for a product to one of our clients in which case the Personal Information in that request will become subject to our client’s privacy policy.  It is your responsibility to understand the third party’s privacy policy or other privacy commitments.

Disclosure of Personal Information for Legal Purposes

We may disclose Personal Information if compelled to in connection with a legal or regulatory proceeding, or in connection with enforcing our rights or defending ourselves in a legal or regulatory process.

Exercising Your Personal Information Rights

We limit access to your Personal Information to people and entities that have a need to use your Personal Information for our business purposes.  You may access or request to correct, amend or delete any Personal Information that is inaccurate or incomplete, by contacting us at privacy@spins.com.

You may limit our use of your Personal Information, request that your Personal Information be erased, or object to the processing of your Personal Information. If you have previously provided us with consent to process your Personal Information, you may withdraw the consent you have previously provided us at any time. If you decide not to provide or to limit your Personal Information, it may diminish the functionality of the product locator services, you may not be able to use certain features of the product locator services, and we may not be able to provide certain services to you.

To exercise the rights listed above, please contact us at privacy@spins.com. If you do not want to receive email offers or other notices from us in the future, you may opt out of receiving email communications by following the opt-out instructions located within an email received from us.

Procedures for Exercising Your Personal Information Rights

 

Remember that we cannot process your request to exercise your rights if you do not provide us with sufficient detail to allow us to understand and respond to it.  We verify all requests through email before actioning them and reserve the right to deny a request where we are unable to verify an identity satisfactorily. This also applies to requests submitted on your behalf by someone else, such as an administrator. Once you have submitted a request, we may take a few days to process the request.

 

Opt-Out Requests

You may opt out of our disclosing your Personal Information to third parties as stated above by emailing privacy@spins.com. We may take a few days to process the opt-out request. Once the opt-out request is processed, we will no longer include Personal Information associated with the Identifier linked to the opt-out request in the Personal Information we disclose to unaffiliated third parties as provided above.

If you opt-out, please note that the opt-out is effective only for the Identifier that we link to the opt-out request. We provide product locator services to many clients, and an opt-out for an Identifier will be valid with respect to Personal Information linked to that Identifier associated with other product locators that we provide.

Please note that because we do not require your name or other account registration to use the product locator, if you opt-out then the opt-out will be effective only for the Identifier that we have that is linked to the opt-out request. This means that if, for example, you use the product locator from different devices or using different web browsers, you will need to opt-out from each device and web browser. This also means that if you opt-out and for any reason, the information that we use to associate Personal Information with an Identifier is changed, you will need to opt-out again. This also means that if you are using methods to use the internet anonymously, block cookies, prevent your internet usage from being tracked, or otherwise obscure your identity, your opt-out may not be effective with respect to future usage of the product locator because the Identifier that is linked to the opt-out request will not be linked to future usage of the product locator.

An opt-out is valid for a period of six months due to technical limitations with respect to how we create an Identifier and the degradation in the accuracy of an Identifier over time. If you wish to continue to opt-out as provided in this section after six months, you must opt-out again.

Retention of Personal Information

We will retain your Personal Information for as long as necessary to meet our business needs and to comply with applicable legal and regulatory requirements, or until you ask us to delete it.  Your Personal Information is primarily stored in digital media, and when we no longer need to retain your Personal Information we will dispose of your Personal Information, whether stored in digital media or in hard copies, in a secure manner.

Cookies

The product locator and applications within the product locator may use “cookies” and other similar technology to store and track Personal Information about you. We use cookies for many reasons, including but not limited to, improving the functionality of the product locator; analyzing the use or performance of the product locator; for advertising or marketing purposes; and personalizing your experience using the product locator. We may also supplement Personal Information collected via cookies and similar technologies with information acquired from other third party sources. If you prefer that we do not use cookies, you can disable cookies in your web browser’s or device’s privacy settings. Please note that the functionality of the product locator may be compromised by blocking cookies.

Data Security

We use industry-standard security measures to protect your Personal Information and require our service providers to do the same.  However, you must understand that no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We are not responsible for the data security or the privacy practices of any third party to whom we disclose Personal Information. In addition, we limit access to your Personal Information as explained above in the section on Exercising Your Personal Information Rights.

Third Party Email Addresses

You may provide us with an email address for yourself, a friend, family member, or other third party so that we can send the information that you request to that email address.  We will use that email address to send an email to that address for the purpose you provided the email address. The recipient of the email may contact us to remove the email address from our systems, and we provide information regarding how to remove the email address in the email that we send.

No Use by Children

The product locator may be used only by adults who are United States residents and of sufficient age and otherwise able to enter into a legally binding contract. We do not knowingly collect or use any Personal Information from children under the age of 16. In no event may the product locator be used by a child under the age of 16.

Transfer of Personal Information

We reserve the right to transfer all Personal Information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale of all or a portion of our assets. Subject to legal requirements, the use and disclosure of all Personal Information will be subject to this privacy policy, or to a new privacy policy, so long as you are given notice of the new policy and provided with the opportunity to opt out of it.

Notice to California Residents

Residents of California have additional rights under the California Consumer Privacy Act (“CCPA”) and California Consumer Rights Act. If you are a resident of the state of California, you may request specifics regarding the Personal Information collected by us during the preceding twelve months. You may request the following: i) the specific Personal information we have collected about you, ii) information regarding the categories of Personal Information we have collected from you, iii) the categories of sources from which we have collected this Personal Information, (iv) the commercial purposes for collecting the Personal Information, and (v) the categories of third parties with whom we have shared the Personal Information. To exercise your rights by making this request, please contact us privacy@spins.com.

We do not use or disclose sensitive Personal Information as defined under the CCPA.

Contact for Questions or Complaints

If you have questions or complaints regarding this privacy statement, our privacy practices, or your Personal Information, you may contact us at privacy@spins.com. You may also send us mail to:

Destini Global LLC

222 W. Hubbard Street Suite 300

Chicago, IL 60654

Attn: General Counsel

 

Notice of Changes

We reserve the right to change, modify or add to this policy at any time, and to apply any such change, modification, or addition to Personal Information that we have already collected. We may provide you with notice of a change, modification, or addition by posting a notice or a revised privacy policy via the product locator. When we update this privacy policy, we will note the date of its most recent modification above. You agree to review the current policy and any changes, modifications, or additions.

You agree to review this privacy policy from time to time and any changes, modifications, or additions.