Effective: July 31, 2020
Who we are
Spinnaker Support LLC is a Colorado limited liability corporation, with US registration number 20081405069. For the purpose of the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR, the data controller is Spinnaker Support LLC and its subsidiaries.
Our registered address is:
5445 DTC Parkway
Greenwood Village, CO 80111
Collection of personal data
Categories of personal data collected
The following are categories (with non-exhaustive examples) of personal data we may collect about you:
|A. Individual Identifiers and Demographic Information
||Name, postal address, email address, or other similar identifiers.
|B. Commercial Information
||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|C. Internet or Network Activity
||IP address, device identifier, browsing history, search history, information on an individual’s interaction with a website, application, or advertisement.
|D. Professional or Employment-Related Information
||Employer name, job title, company address, contact telephone numbers, information collected in connection with employment or application for employment.
Information we may collect from you or third parties
We collect your personal data when you voluntarily submit it to us or from other third party sources. For example, we may receive your personal data in the following circumstances:
- when you fill in a form on our website,
- when you meet us at trade events,
- when you become a client,
- when you submit a job application,
- when you use our Partner Portal,
- when you email, call, text, or fax us,
- from third party sources including joint marketing partners, and
- from publicly available sources such as LinkedIn.
Information we may collect automatically
When people visit https://www.spinnakersupport.com we use a third-party service, Google Analytics provided by Google, Inc., to collect information about the behavior patterns of our website visitors. This service sets a cookie in order to evaluate the use of the website and to compile a report on website traffic patterns.
We use Google AdWords in order to display our adverts to you when you enter appropriate search terms into Google’s search engine. Google, as our Data Processor, collects certain information from the browser you use, such as your IP address, device identifier, location data browser type and language, access times, the Uniform Resource Locator (URL) of the website that referred you to our website.
We also use Facebook remarketing in order to display adverts to you on the Facebook platform. When you visit our website, we drop a Facebook cookie on your browser which identifies your browser. This records the fact that you visited our website so that Facebook can display our adverts to you when you are on their platform.
Purposes and lawful bases of personal data collection
Data from our website form or at conferences
If you complete an inquiry form on our website or give us your details in person, for example at a conference, we will contact you by email or phone so that we can discuss the products or services in which you have indicated an interest. Data that you provide will be added to our Customer Relationship Management (CRM) system and used to send you marketing messages. You can opt out of these messages at any time by using the unsubscribe link that we put in every email.
Our lawful basis for processing these data is Consent. Unless you withdraw consent, we will keep your data in our systems for 10 years from the date we last had contact with you.
Data from our marketing partners
Our marketing partners may contact you by phone or email in order to tell you about our services. They will let you know who we are, where they obtained your data, and your right to opt out of future marketing. We will absolutely respect that right. If you express an interest in Spinnaker Support services, they will pass your data to us and we will contact you by email or phone and add your data to our CRM system so that we can continue to market to you.
Our lawful basis for processing these data is Legitimate Interest. Unless you exercise your right to object to processing, we will keep your data in our systems for 10 years from the date we last had contact with you.
When you become a client, we require your personal data in order for us to fulfill our contract with you. Our legal basis for processing is Contractual Obligation. We will also add your data to our CRM so that we can keep you updated with any information you might be interested in. Our legal basis for this processing is legitimate interest. We will continue to process your data for so long as you have an active account, or as needed to provide you with the services to fulfill our contractual or legal obligations.
If you submit a job application either directly or through a recruiter, our legal basis for processing your personal data is Consent or Legitimate Interest. We will use your data in connection with the specific job that you’ve applied for and it will be stored for the duration of your application. If we think there may be other roles for which you would be suitable, we will hold your details up to two years after completion of the initial application process. We will only do this with your consent except where retention is required by law (for example candidates from the US, whose details will be held for seven years).
Your personal data may be passed to or accessed by Spinnaker Support companies both inside and outside the European Economic Area in order to offer relevant job opportunities to you. You may withdraw your permission for your data to be processed outside the EU by making a request to our team using the Contact details below. You can update your CV at any time by simply submitting a new CV.
Our Partner Portal
When you become a Partner of ours, we collect your personal data from the login page. Our legal basis for processing these data is Contractual Obligation as we have agreed to provide you with marketing and other collateral to further our joint business objectives. We will continue to process your data for so long as you have an active account, or as needed to provide you with the services to fulfill our contractual or legal obligations.
Google Analytics, Facebook, and AdWords
Our lawful bases for all non-essential cookies (Google Analytics, Facebook, and AdWords) is Consent which we request when you visit our website for the first time or when no cookie exists on your browser.
We use Google Analytics to understand the location of our website visitors so that we can appropriately refine our business focus. You can opt-out (withdraw your consent) for Google Analytics here or you can clear your browser’s cache and not accept them on your next visit to our website.
We use Facebook cookies to show you targeted marketing messages on their platform. Details of how you can opt out of Facebook remarketing is available here or you can clear your browser’s cache as above.
The information collected by Google AdWords enables us to show you adverts on third party websites. We also use the data to assess the effectiveness of our campaigns. You can opt-out of these cookies here or, once again, you can clear your cache and not consent when we ask you on your next visit.
How we share your personal data
Related companies and M&A transactions
We may share your personal data with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we transfer all or part of its business or make a transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
Trusted third parties
Spinnaker Support will share your personal data with trusted third parties retained to provide services that you have requested or for our own legitimate business purposes. Such services include CRM, IT, marketing, hosting, database management, web analytics, fraud protection, or other professional support services.
Spinnaker Support LLC works with a number of trusted third parties to provide services to you:
- The hiring team uses Microsoft Office 365 services to store and process applications and contact details.
We may disclose personal data in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws or law enforcement requirements. We may also share your personal data in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other clients; or to prevent a violation of our agreements.
Transfer of personal data outside the EEA
We only transfer such information outside the EEA if:
- Your product or service inquiry is best handled by one of our companies located outside the EEA.
- There is legally adequate data protection mechanism through which to transfer your data to trusted partners located outside the EEA.
- You have submitted a job application and it needs to be reviewed by our hiring team in Denver and other offices.
Your rights as an EU data subject
Where the processing of your personal data is subject to EU data protection laws, you have the data subject rights as set out below. If you wish to exercise any of these rights, please click here. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes.
Your rights as an EU data subject are as follows:
The right to be informed
The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
- a) The purposes of the processing
b) The categories of personal data concerned
c) The recipients to whom the personal data has been disclosed
d) The retention period or envisioned retention period for that personal data
e) When personal data has been collected from a third party, the source of the personal data
If there are exceptional circumstances that provides us with the right to refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
The right to rectification
When you believe we hold inaccurate or incomplete personal data about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- a) The accuracy of the personal data is contested
b) Processing of the personal data is unlawful
c) We no longer need the personal data for processing but the personal data is required for part of a legal process
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing
The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfillment of a contractual obligation.
The right to object
You have the right to object to our processing of your personal data where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research; or
- Processing involves automated decision-making and profiling.
Your rights as a CA consumer
Where the processing of your personal data is subject to CA data protection laws, you have the consumer rights as set out below. If you wish to exercise any of these rights, please click here. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes.
Your rights as a CA consumer are as follows: