Privacy Policy

Effective Date: May 13, 2025

GENERAL INFORMATION

LLC “EKSTRYM LIVE” (hereinafter referred to as “Spinner”, “we”, “our”, or “us”) is a product-oriented IT company that develops software used by millions of users and operates the primary website https://spinner.live, which serves as the main online platform for Spinner. This Website provides news and updates about us, including but not limited to, information about potential collaboration opportunities (hereinafter referred to as the “Website”). The Website operates in accordance with our Terms of Use and is fully optimized for use across various operating systems and devices (both desktop and mobile).

By accessing or using our Website, you agree to be bound by our [Terms of Use]. Please read them carefully before proceeding. In order to provide you with access to and functionality of our Website, and to enter into a contractual relationship with you, we may need to collect and process certain personal data. Spinner acts as the data controller for any personal data collected and is responsible for its processing.

We are committed to respecting your privacy and protecting your personal data in accordance with applicable data protection laws.

This Privacy Policy (hereinafter referred to as the “Policy”) outlines how we collect, use, and protect your personal data that you provide to us or that we otherwise collect or receive in connection with your use of our Website, as defined in the Terms of Use. We aim to describe our privacy practices in clear and straightforward language, while maintaining legal accuracy.

WHO IS SPINNER

The company responsible for your personal data under this Policy (the “data controller”) is: Limited Liability Company “EKSTRYM LIVE” Address: 38 Shovkovychna Street, Office 39, Kyiv, 01024, Ukraine

SCOPE OF APPLICATION

This Policy applies to the personal data collected through our Website, which is operated and administered by Spinner.

PERSONAL DATA WE COLLECT

When you visit our Website and our social media pages, or submit relevant inquiries for feedback (including, but not limited to, collaboration requests), we may ask you to provide us with the following information: • your IP address • your full name • your email address • your mobile phone number • your date of birth • your city • any data contained in a file attached to the relevant inquiries

HOW WE USE YOUR PERSONAL DATA

We strive to ensure a smooth and user-friendly experience on our Website. The primary reason we use your information is to provide and enhance the functionality of our Website. Additionally, we use your data to help keep you safe. Accordingly, we use your personal data and other information you provide to us or that we receive from you for the following purposes: • to optimize and maintain the Website’s performance • to communicate with you

LEGAL BASIS FOR PROCESSING

We process your personal data based on one or more of the following legal grounds: a) Contractual necessity. By using our Website, you enter into a contract with us in accordance with the Terms of Use. We must process certain personal data to fulfill our obligations under this contract. Providing your personal data is a prerequisite for accessing and using the Website. b) Legitimate interests. We may process your data to pursue our legitimate interests, such as ensuring security, preventing fraud, protecting our legal rights and property, complying with applicable laws, and enforcing the Terms of Use. c) Consent. We may ask for your explicit consent to process your personal data for specific purposes. In such cases, we will inform you of the purpose and scope of processing. You may withdraw your consent at any time. d) Legal obligations. We may process your data to comply with applicable legal requirements or requests from competent authorities.

DATA STORAGE

The retention period for your personal data depends on the purpose of processing and the technology used (e.g., cookies). Spinner retains personal data only for as long as necessary to provide access to the Website and fulfill contractual or legal obligations. We use Amazon Web Services, Inc. as our data hosting provider. Data may be stored or processed in various jurisdictions, including the United States. Any international data transfers are carried out in compliance with this Policy and applicable data protection laws. Please note that data shared with third parties is governed by their own privacy policies, which we do not control.

DATA SHARING

To operate and maintain the Website, we may share your personal data with the following categories of third parties: a) Service providers. We engage third-party providers to support the operation, hosting, and security of our Website. b) Competent authorities. We may disclose personal data to regulators or law enforcement agencies if required or permitted by applicable law. c) Other third parties. We may share personal data to protect our legal rights, ensure user safety, or respond to potential violations of our Terms of Use.

DATA SECURITY

We implement appropriate technical, organizational, and physical safeguards to protect your personal data. These include: • encryption of personal data where appropriate • ensuring data availability in the event of a physical or technical incident • regular assessment and testing of our security measures We also require our service providers to apply adequate data protection standards.

YOUR CONSENT

Your explicit consent may serve as a legal basis for processing your personal data. Consent is obtained, for example, when you accept the Terms of Use or agree to share information with third parties. We may ask for your consent to process your data — for example, when we intend to share your information with third parties. In such cases, we will explain why your data is needed and how it will be processed, including any intended data sharing. You have the right to withdraw your consent at any time. Please note that withdrawing consent related to the Terms of Use will prevent you from using the Website.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

We collect and process your personal data in strict accordance with applicable law. Depending on your jurisdiction, you may exercise certain rights concerning your personal data, including but not limited to the following:

a) Rights under the General Data Protection Regulation (GDPR):

If you are located in the European Union or in countries such as Iceland, Liechtenstein, Norway, or Switzerland, you have the right to:

withdraw your consent at any time
request access to your personal data, or request its correction or deletion (the "right to be forgotten")
under certain conditions, restrict or object to the processing of your personal data
request the portability of your data to another service provider
obtain information regarding the retention period of your data, or the criteria used to determine that period
receive details about the source of your data, particularly if it was not collected directly from you
lodge a complaint with the data protection authority in your jurisdiction
not be subject to decisions based solely on automated processing, including profiling, unless necessary for the performance of a contract with you or otherwise permitted by law.

For more information about your rights, please consult the official text of the GDPR.

b) Rights under Ukrainian law: If you are subject to the Law of Ukraine “On Personal Data Protection,” you are entitled to:

know the sources of collection, the location of your personal data, the purpose of its processing, and the location or place of residence (stay) of the data controller or processor
obtain information about the conditions of access to your personal data, including information about third parties to whom it has been disclosed
access your personal data, including submitting a request to determine whether it is being processed and to obtain a copy. We will respond to such requests within 30 calendar days
submit a reasoned objection to the processing of your personal data
request the correction or deletion of your personal data if it is being processed unlawfully or is inaccurate
protect your data from unlawful processing, accidental loss, destruction, or damage
lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or file a lawsuit in court if you believe your rights have been violated
specify any restrictions regarding the scope or duration of data processing at the time of giving consent
withdraw your consent to processing, provided that consent was the sole legal basis for the processing
be informed of the logic involved in any automated processing of your personal data, and to be protected against decisions based solely on automated processing that produce legal or similarly significant effects.

For more detailed information, please refer to the official text of the Law of Ukraine “On Personal Data Protection”.

WHAT ARE COOKIES

Cookies are small text files sent from our Website (or another domain) and stored by your web browser on your computer, mobile phone, or other device. Cookies may be placed, read, or written by our Website or by third-party websites or services that recognize a specific cookie. This allows the website to “remember” or “recognize” your browser or device and, in some cases, to store information associated with it.

PURPOSE OF COOKIES

Cookies help you navigate and use our Website more efficiently and allow us to better understand your preferences and behavior. Most web browsers accept cookies by default, but you can usually modify your settings to decline or delete them. Detailed instructions are typically available on your browser developer’s website. Please note that disabling cookies may limit access to certain functionalities of websites.

HOW LONG COOKIES ARE STORED ON MY SYSTEM

We use cookies for various purposes. These include both “session” and “persistent” cookies. We use session cookies to identify you during a specific visit to our Website. Session cookies expire after a short time or when you close your browser. We use persistent cookies to help your device remember information, preferences, settings, or login credentials you have previously saved. These cookies are generally stored on your device, so they remain even after you close and reopen your browser.

HOW LONG COOKIES ARE STORED ON MY SYSTEM

TYPES OF COOKIES WE USE

We use the following categories of cookies on our Website: a) Essential Cookies These are necessary to operate our Website. They enable core functionality such as security, network management, and accessibility. For example, they identify you as a registered user and help secure your session. b) Functionality Cookies These cookies remember your preferences and choices, such as your selected language or region, to enhance your experience. c) Analytics and Performance Cookies These cookies collect information about how users interact with the Website (e.g., which pages are visited most often) to help us improve performance and user experience.

THIRD-PARTY COOKIES

Our Website may allow third parties to place cookies on your device. These third-party cookies are set by services not operated by us and may collect data such as browsing behavior and preferences. We currently use Google Analytics, a web analytics service provided by Google LLC (“Google”). This service uses cookies to help analyze how users interact with our Website. The information generated by these cookies (such as your IP address, time of visit, or referring source) is usually transmitted to and stored by Google on servers in the United States. This processing is governed by Google’s Privacy Policy. Google processes this data on our behalf and provides us with reports that help us understand user interests and improve the Website accordingly. To learn more about Google Analytics or to opt out of Google Analytics tracking, please click here. For a full list of cookies used on our Website, including their purpose, duration, and provider, please click here.

MANAGING COOKIES

You can manage or disable cookies at any time through your browser settings. However, disabling cookies may impact the functionality or availability of certain features of our Website. All modern browsers provide cookie management tools — refer to your browser’s Help section for guidance.

WHERE TO FIND MORE INFORMATION

For more information about cookies, including how to manage or disable them, please visit this website.

PERSONAL DATA OF INDIVIDUALS UNDER THE AGE OF 18

We do not knowingly collect personal data from individuals under the age of 18. If you become aware that a person under the age of 18 has provided us with personal data, please contact us immediately so that we can take appropriate action.

LINKS TO OTHER WEBSITES

Our Website may contain links to third-party websites, including social media platforms. Please be aware that we do not control how personal data is collected or processed on those external websites. We recommend reviewing the privacy policies of any external sites you visit.

CONTACT INFORMATION

If you have any questions about the processing of your personal data, wish to be removed from a database or mailing list, or would like to report a potential data protection violation, please contact us using the information below:

Limited Liability Company “EXTREME LIVE”

Email: info@spinner.live

Address: 38 Shovkovychna Street, Office 39, Kyiv, 01024, Ukraine

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