Spinkolik Affiliate provides full data protection procedures set and relies on international law on personal information gathering, storing and processing.

This Policy explains procedures which are applied on the website of the Company. Novi B.V. (hereinafter referred to as “the Company” or “We”) controls and processes all the information on this website, with the registered address Dr. M.J. Hugenholtzweg 25 Curacao, established under the laws of Curacao.

The subjects of personal data processing are visitors of the website or whoever uses the functional instruments of the website (they are referred in this Policy as “Users” or “You”). The Company and the User whenever mentioned together shall be referred to as “the Parties”. This Policy aims to give information on how we gather, use and store personal data which are collected from visitors.

1. are “transparently” collected in strict legal field;
2. are gathered to process certain procedures, are limited to the purposes stated in this Policy – “purpose limitation”;
3. are measured and limited with what is needed to achieve the purposes stated by this Policy – “data minimization”;
4. are updated when necessary and erased or changed whenever are found to be incorrect or inadequate taking into account the purposes they were gathered for – “accuracy”;
5. are kept during a limited period of time which is necessary for achieving purposes which they were collected for – “limitation of storage”;
6. are stored and processed with full protection from any kinds of unauthorized processing, breaching, accidental losses, illegal changes – “integrity and confidentiality”.

The Company can gather, store and process such personal details from the Users: name and surname, address of actual living, mailing information, e-mail address, payment details, username. In order to provide User’s verification the Company reserves the right to ask for a scan-copy of personal documents like passport. The Users must provide adequate and up-to-date data, the Users are responsible for completeness of the data provided.

Ways of using personal data. When the User registers on the website, we use his or her personal details in order to identify personality, to provide identification of payment details when making any payments both from You to the Company and from the Company to You. The range of payment details which are used by the Company: cardholder name, card number expire date of the card. This is needed for providing any kinds of payments by using bank card. These are main purposes for using Users’ personal information: to provide Users with the services on the website; to maintain Users’ accounts and keep records; to contact Users within the services of the website; to answer any kinds of comments or requests of Users; to estimate the use of the website and evaluate the quality of our services; to determine the interest in the Company’s services; to make services of the website better for Users; to give Users information on any kinds of personal propositions, promo actions, important updates; to determine Users’ experience when getting services of the Company; to get any requests and questions from Users by conducting surveys or by any other ways; to resolve any disputes; to charge Users with fees which are described in Terms and Conditions, this Policy and also in other agreements on the website; to fix errors and problems on the website; to prevent any kinds of fraud or other illegal activities of Users; to ensure that Users comply with this Policy, Terms and Conditions and with other agreements published on the website.

We may disclose or transfer Users’ personal information to affiliated companies and partners which are involved in the process of providing services on the website. The data may be disclosed to business partners at any geographical location. The information maybe disclosed only in limited amount of cases which are described by the purposes of using personal information in this Policy. We guarantee that any company which will get access to Users’ personal details complies with General Data Protection Regulation (Regulation (EU) 2016/679). We and our business partners reserve the right to involve third parties in the procedures of processing and storing Users’ personal information. Such cooperation will be governed by contracts and arrangements which are allowed and prescribed by law. Personal information of Users may also be disclosed to governmental institutions worldwide or executive bodies if such disclosure is permitted by law.

1. to request any kinds of changes in personal information which is stored by the Company or to ask for erasure of such data; to object the processing of data which are stored by the Company;
2. to provide incomplete data set to the Company (additional explanations will be needed for such incomplete information set);
3. to restrict data processing under such conditions: the accuracy of the information stored by the Company is disputed by User (for the period of check); data processing is not legal, the User opposes to data erasure but requires restrictions in processing details; the Company does not need the personal information of the User, but the storing is needed for protecting or processing any legal requirements of Users; the User sends objection to personal details processing before he or she can check the legal frames and purposes of processing personal information;
4. to receive the User’s personal information by sending a special request to the Company(the data which were provided by the User to the Company). The information must be sent in a machine-readable structured way. The User has rights to transfer such personal details to other entities with no interference of the Company;
5. to request and get information about the fact of storing the User’s personal details;
6. to request and get from the Company the list of purposes which the User’s personal information are being processed by the Company for;
7. to get access to the User’s personal details which are being stored and used by the Company;
8. to ask for and get the information about the period of time during which the Company will store your personal data or, if it’s impossible to count, to get the information about principles of counting the period of storing;
9. to file any objections if the User believes there are violations of the law in the sphere of personal data protection. Any objections should be filed at Office of the Commissioner for Personal Data Protection of Cyprus.

1. to ensure that the data provided are accurate, up-to-date and true, they must be in full volume and be given in accordance with this Policy, Terms and Conditions and any other agreements placed on this website;
2. to update the information once it changes or once User notices any incorrect details which are stored by the Company. Read through the section “Access, erasure and correction of personal details” in order to get instructions of how to update your personal details.
3. to notify the Company about any kinds of unauthorized access to the User’s personal details once the User revealed the fact of such access;
4. to let the Company know by special request that the User disagrees with any procedures or purposes of using personal information or if the User wishes to stop processing of his personal information by the Company the User ought to send request to company email [email protected]. The User must be aware that by sending such request for stopping processing of his or her personal details or for disagreeing with purposes of using the data it forms a legal ground for the Company to terminate any agreements that were previously made between the User and the Company (this Policy, Terms and Conditions, other agreements published on this website). The User is responsible for the accuracy of the personal information which he or she gives to the Company.

1. to terminate all agreements including this Policy, Terms and Conditions and any other agreements which are published on this website in case of not providing by the User needed and requested personal information;
2. to amend the Policy of Data Protection without any prior approval with Users.

1. to report restriction in processing of Users’ personal information, any cases of correction or erasure of personal details by sending such information to any third parties who got access to Users’ personal details within purposes of data processing stated by this Policy if it doesn’t prove impossible and doesn’t need excessive efforts from the Company;
2. to inform Users about the third parties to which the User’s personal information was disclosed (if a certain request was sent by the User);
3. to provide personal information of the User which is stored by the Company in answer for the appropriate request of the User. The data should be provided in a structured and machine-readable way.
4. to notify the supervisory authority about any cases of breaches of Users’ personal details within 72 hours after revealing such breaches. If the notification isn’t completed within 72 hours, the Company must provide reasons for the delay.
5. to notify the User about any cases of his or her data breach if the breach may result in a solid risk to the freedom and rights of the User.

The Parties keep all the rights which are provided by General Data Protection Regulation. The period of storing Users’ personal data extends to the whole period of cooperation of the user and the Company which is stated by the Terms and Conditions and also for the next three years after such cooperation is finished (in order to resolve all the disputes which may occur in legal field).

Legal protection. The Company complies with Law on the Processing of Personal Data (Protection of the Individual), no. 138(I)/2001 dated November 23, 2001, as amended; with General Information Protection Regulation (Regulation (EU) 2016/679) and Electronic Communications Privacy Directive (Directive 2002/58 / EC) as amended by Directive 2009/136 / EC.

Access, erasure and correction of personal details. If the User needs to view personal details which are stored by the Company about him or her, and also to erase, delete or correct them and also if the User wants to get information about the procedures of processing personal data and the ways of ensuring confidentiality of the User, the User may submit a special request. Such requests are only possible to submit in writing. Please put your name, full address, list of data you need to get, correct or erase. To submit the request please send a message to [email protected]. The Company needs to ensure confidentiality in disclosing the User’s personal details, so the User must enclose a scan copy of his or her passport to such request.

The Company may charge fees for duplicate requests for personal data, and also for requests for additional copies of data, and for requests that are found excessive or unreasonable.

The Company may refuse to provide personal data if the request is seen as unreasonable or excessive.

Cookies are tags and different identifying instruments. These are text files which are stored on Users’ computers and are aimed at collecting information about visiting websites and making some actions. The Company’s website creates Cookies for each session when the User visits it.

We use Cookies:

1. to make sure that all actions of the User on the website are properly recorded;
2. to analyze traffic patterns in order to provide needed improvements.

Users must be aware that they can’t use the website without creating Cookies. If the Users needs extra information about the ways of using Cookies by the Company, he or she may create a special request for getting such information.