Effective Date: 22nd April 2025
1. INTRODUCTION
This Privacy Policy sets out how Spinnaker International LLC (“we”, “us”, “our” or the “Company”), collects, uses, stores, discloses, and otherwise processes personal data in the course of its business activities. This includes the management of individuals operating on social media and subscription-based content platforms, and the operation of our corporate website and services.
This policy is issued in accordance with applicable United States federal and state privacy laws, including but not limited to the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and other applicable US data protection and consumer privacy regulations.
By accessing our website or providing information to us, you acknowledge that you have read, understood, and accepted the terms of this Privacy Policy.
2. DATA CONTROLLER INFORMATION
Spinnaker International LLC
1309 Coffeen Avenue STE 1200
Sheridan, Wyoming 82801
USA
Email for all data protection-related enquiries: [email protected]
3. CATEGORIES OF PERSONAL DATA COLLECTED
We collect the following categories of personal data:
From website visitors:
IP address
Device type, browser type, and browser settings
Referrer source, session duration, click paths, and engagement with website elements
Cookie data and analytics identifiers
From creators, applicants, or affiliates:
Full name
Date of birth
Email address and mobile number
Location or timezone
Social media account usernames, profile URLs, and associated performance metrics
Revenue data derived from content platforms or social media insights
Identity documents such as passports or driving licences
Login credentials for social media or content platforms, where explicitly provided for service facilitation
Communications and submissions made during application or onboarding processes
From marketing subscribers:
Email address
Consent preferences
Newsletter interaction statistics
We do not knowingly collect or process data relating to individuals under the age of 18. If you are under the age of 18, you must not use our website or submit any personal data to us.
4. METHODS OF DATA COLLECTION
We collect personal data through the following means:
Direct submission by the data subject, including via forms hosted on our website or through direct communication
Automated data collection via analytics tools such as Google Analytics and Meta Pixel, triggered upon visiting our website
Cookie usage and browser interaction
Tracking of performance data from managed platforms, subject to contractual consent
Internal assessments of creator performance for operational purposes
5. PURPOSES OF PROCESSING AND LEGAL BASES
We process personal data only where a lawful basis under applicable United States privacy laws applies.
These include:
To review and assess creator or affiliate applications
(Lawful basis: contractual necessity or legitimate business purpose)
To verify identity, eligibility, and authenticity of applicants
(Lawful basis: legal compliance and contractual necessity)
To manage creators’ access credentials and performance metrics
(Lawful basis: contractual necessity)
To access, manage, and optimise client-linked social media or content platform accounts
(Lawful basis: contractual necessity)
To send newsletters and promotional content to subscribers
(Lawful basis: consent)
To operate and enhance our website using cookies, analytics, and pixels
(Lawful basis: consent where required and legitimate business purpose)
To comply with financial, taxation, record-keeping, and regulatory obligations
(Lawful basis: legal obligation)
To protect, defend, or enforce our legal rights
(Lawful basis: legitimate business interest)
We do not sell personal data as defined under applicable US state privacy laws.
6. USE OF COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies for:
Functionality and usability of our website
Traffic analysis and visitor behaviour
Targeted advertising via external platforms (such as Meta)
Where required by applicable state laws, non-essential cookies are disabled until affirmative consent is received via our website’s cookie management banner. You may withdraw or modify your cookie preferences at any time via the cookie control interface or through your browser settings. For full details, please refer to our Cookie Policy.
7. DATA SHARING AND INTERNATIONAL TRANSFERS
We may share your personal data with third-party service providers where necessary to operate our business and provide services.
These may include:
Cloud storage providers and web hosts
CRM systems and workflow management tools
Marketing automation platforms
Advertising platforms such as Google Ads and Meta Ads
Professional advisors including legal and accountancy consultants
Payment processors and banking partners
Subcontractors engaged to fulfil specific agency-related functions
As a United States-based company, personal data may be processed in the United States and other jurisdictions where our service providers operate.
Where data is transferred internationally, we implement appropriate contractual and technical safeguards consistent with applicable US privacy regulations.
8. DATA RETENTION
We retain personal data for no longer than is necessary for the purposes for which it was collected, subject to applicable legal and regulatory obligations. Our standard retention periods are as follows:
Creator or affiliate application data: 12 months following last contact if not contracted
Creator account and contractual records: retained for the duration of the relationship plus six years
Identity verification and financial records: retained for six years following termination
Social media access credentials (where held): retained only for the period of the contractual engagement
Newsletter and marketing subscription data: retained until consent is withdrawn
Website usage and analytics data: retained for 6 to 24 months depending on the tool and settings
We may retain anonymised or aggregated data for research, benchmarking, or statistical analysis without limitation.
9. DATA SUBJECT RIGHTS
Under applicable United States privacy laws, individuals may have the following rights in respect of their personal data:
The right to know what personal data we collect and how it is used
The right to request access to a copy of their personal data
The right to request correction of inaccurate personal data
The right to request deletion of personal data, subject to legal exceptions
The right to opt out of targeted advertising or data sharing, where applicable
The right to non-discrimination for exercising privacy rights
To exercise any of the above rights, please contact [email protected]. We will respond within the timeframe required under applicable law. We reserve the right to request additional information to verify identity before complying with any such request.
10. MARKETING COMMUNICATIONS
We will only send marketing communications where we have obtained valid consent where required under applicable US marketing and consumer protection laws. You may withdraw consent at any time by clicking the unsubscribe link in our emails or by contacting [email protected].
11. DATA SECURITY
We implement appropriate technical and organisational measures to ensure the security of personal data, including:
Secure storage of identity documents and access credentials
Encryption of data in transit and at rest
Access controls and audit trails for sensitive systems
Regular internal review and access management procedures
Staff training on confidentiality and data protection responsibilities
While we strive to ensure robust security, no method of transmission or storage is completely secure. You acknowledge and accept this inherent risk.
12. THIRD PARTY LINKS
Our website may include hyperlinks to third-party websites or embedded content. We do not control these websites and are not responsible for their privacy practices. You are encouraged to review the privacy policies of such third parties before providing them with your personal data.
13. COMPLAINTS
If you have any concerns or wish to lodge a complaint regarding the way your data is handled, please contact us at [email protected].
You may also lodge a complaint with your relevant State Attorney General’s Office or applicable regulatory authority in your state of residence.
14. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time to reflect legal, regulatory, operational, or technological developments. Any such changes will be published on our website with an updated effective date. Continued use of our website and services after any such changes shall constitute your acceptance of the updated policy.
