Lablaco and SPIN.FASHION are committed to protecting the privacy and security of personal data in compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This GDPR policy outlines our practices regarding the collection, use, and protection of personal data.
Your privacy is important to us, as it is for you. Our privacy policies explain the personal data Lablaco and SPIN.FASHION processes, how Lablaco and SPIN.FASHION processes it, and for what purposes. Lablaco is a circular fashion ecosystem, including phygital retail platform, SPIN.FASHION designed to enable brands and retailers to digitize and connect products worldwide, including IoT hardware devices, software that students use at school, and services developers use to create and host what’s next.
References to Lablaco products, may include SPIN.FASHION and CFS Media, in this statement include Lablaco services, websites, platforms, media, apps, software, servers, and devices. Please read the product-specific details in this privacy statement, which provide additional relevant information. This statement applies to the interactions Lablaco has with you and the Lablaco products listed below, as well as other Lablaco products that display this statement.
1. Data Controllers
Lablaco and SPIN.FASHION act as joint data
controllers for the personal data processed in the course of providing our
services. Our contact information is:
LABLACO HOLDING PTE. LTD.
Level 40, Ocean Financial Centre, 10
Collyer Quay, Raffles Place, Singapore 049315
Tax/Reg Number:
202004882N
(Here represented as “Lablaco” and “SPIN.FASHION”, or We)
SPIN.FASHION LIMITED
Address: 43 O'Connell Street Upper, Dublin 1,
D01 DK81, Ireland
Tax/Reg. Number: 718590
(Here represented as “SPIN.FASHION” and “Lablaco”, or “We”)
2. Types of Personal Data Collected
We may collect and process the
following types of personal data:
Contact Information: Name, surname, date of birth, gender, email address, phone number, and address.
Account Information: Username, password, and other credentials.
Transaction Data: Information related to purchases and transactions made on our platforms.
Usage Data: Information about how users interact with our platforms.
Technical Data: Device and browser information, IP address, and other technical details.
Marketing and Communication Data: Preferences for receiving marketing communications.
3. Purposes of Processing Personal Data
We only share your personal
data with your consent or to complete any transaction or provide any
product you have requested or authorized. We also share data with
Lablaco-controlled affiliates and subsidiaries; with vendors working on
our behalf; when required by law or to respond to legal process; to
protect our users; to protect lives; to maintain the security of our
products; and to protect the rights and property of SPIN.FASHION and its
users.
We process personal data for the following purposes:
Providing processes for user safety
Providing KYC for businesses to imit platform abuse from illicit transactions
Providing and managing user accounts.
Facilitating transactions and payments.
Personalizing user experience and improving our services.
Sending marketing communications (with explicit consent).
Ensuring the security and integrity of our platforms.
Complying with legal obligations.
4. Legal Basis for Processing
We process personal data on the
following legal bases:
Performance of a contract.
Consent.
Legitimate interests.
Compliance with legal obligations.
5. Data Subject Rights
Users have the following rights regarding
their personal data:
Right to access.
Right to rectification.
Right to erasure.
Right to restrict processing.
Right to data portability.
Right to object.
Right not to be subject to automated decision-making.
6. Data Security
We implement technical and organizational measures
to protect personal data from unauthorized access, disclosure, alteration,
and destruction.
7. Data Retention
We retain personal data only for as long as
necessary for the purposes outlined in this policy or as required by law.
8. Data Sharing
We may share personal data with third-party service
providers, business partners, or authorities for specific purposes
outlined in this policy.
9. International Data Transfers
If we transfer personal data outside
the European Economic Area (EEA), we will ensure adequate safeguards are
in place.
10. Changes to the Policy
We may update this policy from time to
time. Users will be notified of significant changes.
Contact
Information for Data Protection Concerns:
LABLACO HOLDING PTE LTD: support@lablaco.com
SPIN.FASHION: support@spin.fashion
11. User freedom of choice
You have choices when it comes to the
technology you use and the data you share. When we ask you to provide
personal data, you can decline. Many of our products require some personal
data to provide you with a service. If you choose not to provide data
required to provide you with a product or feature, you cannot use that
product or feature.
Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.
12. How We Use Personal Data
Lablaco uses the data we collect to
provide you with rich, interactive experiences. In particular, we use data
to:
Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data when it is required to provide the service or carry out the transactions you request.
Improve and develop our products.
Activate Circular Economy business models.
Personalize our products and make recommendations.
Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.
We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research. In carrying out these purposes, we combine data we collect from different contexts or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.
Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do.
To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made. For example, we manually review short snippets of voice data that we have taken steps to de-identify to improve our speech recognition technologies. This manual review may be conducted by Lablaco employees or vendors who are working on Lablaco’s behalf.
13. How to Access and Control Your Personal Data
You can make choices
about the collection and use of your data by Lablaco. You can control your
personal data that Lablaco has obtained and exercise your data protection
rights by contacting Lablaco or using various tools we provide. In some
cases, your ability to access or control your personal data will be
limited, as required or permitted by applicable law. How you can access or
control your personal data will also depend on which products you use. For
example, you can:
Control the use of your data for interest-based advertising from Lablaco by visiting our opt-out page.
Choose whether you wish to receive promotional emails, direct messages, SMS messages, telephone calls, and postal mail from Lablaco.
Access and clear some of your data through the Lablaco privacy dashboard.
Not all personal data processed by Lablaco can be accessed or controlled via the tools above. If you want to access or control personal data processed by Lablaco that is not available via the tools above or directly through the Lablaco products you use, you can always contact Lablaco at the address in the How to contact us section or by using our web form.
14. Data Deletion
Once user data is stored in Lablaco, our systems
are designed to store the data securely until it completes the stages of
Lablaco's data deletion pipeline. This section describes this process in
detail.
Stage 1 - Deletion Request
The deletion of user data begins when the
user initiates a deletion request. Generally, a deletion request is
directed to a specific resource, a Lablaco products (SPIN.FASHION, SPIN
Connect, CFS Media), or the user’s SPIN.FASHION account. Deletion requests
may be handled in different ways depending on the scope of the user’s
request:
Resource Deletion: Individual resources containing user data, such as SPIN.FASHION data storage, can be deleted in a number of ways from the SPIN Connect console or via SPIN.FASHION.
Assets Deletion: As a SPIN.FASHION user, you can delete any specific data or products, NFT, avatar, or media assets that act as a bulk deletion request for all resources tied to the corresponding account.
Account Deletion: When you delete your SPIN.FASHION account, it deletes all data and assets tied to SPIN.FASHION that are solely owned by you. Note that when there are multiple owners for a product or asset, the asset is not deleted until all owners are removed from the asset or delete their SPIN.FASHION accounts.
While deletion requests are designed primarily to be used by users to manage their data, Lablaco or SPIN.FASHION may issue deletion requests automatically, for instance when a user terminates their relationship with Lablaco or SPIN.FASHION.
Stage 2 - Soft Deletion
Soft deletion is the natural point in the
process to provide a brief internal staging and recovery period to ensure
that there is time to recover any data that has been marked for deletion
by accident or error. Individual SPIN.FASHION assets and products may
adopt and configure such a defined recovery period before the data is
deleted from the underlying storage systems so long as it fits within
Lablaco’s overall deletion timeline.
To illustrate, when assets are deleted, SPIN.FASHION first identifies the unique product or asset, then it broadcasts a suspension signal to the SPIN.FASHION platform and products containing that asset token.
At the end of a recovery period of 30 days, SPIN.FASHION broadcasts a signal to the same products to begin logical deletion of resources tied to the unique asset token.
When a SPIN.FASHION account is closed, Lablaco may impose an internal recovery period up to 30 days, depending on past account activity. Once that grace period expires, a signal containing the deleted billing account user_id is broadcasted to Lablaco products, and SPIN.FASHION resources tied solely to that user_id are marked for deletion.
Stage 3 - Logical Deletion from Active Systems
After the data is
marked for deletion and any recovery period has expired, the data is
deleted successively from Lablaco's active and backup storage systems. On
active systems, data is deleted in two ways.
In all assets and products under Compute, Storage & Databases, and Big Data except SPIN.FASHION Storage, copies of the deleted data are marked as available storage and overwritten over time. In an active storage system, like SPIN Connect, deleted data is stored as entries within a massive structured table. Compacting existing tables to overwrite deleted data can be expensive, as it requires re-writing tables of existing (non-deleted) data, so mark-and-sweep garbage collection and major compaction events are scheduled to occur at regular intervals to reclaim storage space and overwrite deleted data.
Stage 4 - Expiration from Backup Systems
In the case of backup
systems, user data is typically stored within large aggregate snapshots of
active systems that are retained for static periods of time to ensure
business continuity in the event of a disaster (e.g., an outage affecting
an entire data center), when the time and expense of restoring a system
entirely from backup systems may become necessary. Consistent with
reasonable business continuity practices, full and incremental snapshots
of active systems are made on a daily, weekly, and monthly cycles and
retired after a predefined period of time to make room for the newest
snapshots.
When a backup is retired, it is marked as available space and overwritten as new daily / weekly / monthly backups are performed.
Note that any reasonable backup cycle imposes a pre-defined delay in propagating a data deletion request through backup systems. When user data is deleted from active systems, it is no longer copied into backup systems. Backups performed prior to deletion are expired regularly based on the pre-defined backup cycle.
15. Deletion Timeline
Lablaco’s platforms are engineered to achieve a
high degree of speed, availability, durability, and consistency, and the
design of systems optimized for these performance attributes must be
balanced carefully with the need to achieve timely data deletion.
SPIN.FASHION commits to delete user data within a maximum period of about
six months (180 days). This commitment incorporates the stages of
Lablaco's deletion pipeline described above, including:
Stage 1 - Deletion Request: Once the deletion request is made, data is typically marked for deletion immediately, and our goal is to perform this step within a maximum period of 24 hours. After the data is marked for deletion, an internal recovery period of up to 30 days may apply depending on the service or deletion request.
Stage 2 - Soft Deletion: The time needed to complete garbage collection tasks and achieve logical deletion from active systems. These processes may occur immediately after the deletion request is received, depending on the level of data replication and the timing of ongoing garbage collection cycles.
From the deletion request, it generally takes about two months to delete data from active systems, which is typically enough time to complete two major garbage collection cycles and ensure that logical deletion is completed.
Stage 3 - Expiration from Backup Systems: SPIN.FASHION’s backup cycle is designed to expire deleted data within data center backups within six months of the deletion request. Deletion may occur sooner depending on the level of data replication and the timing of Lablaco's ongoing backup cycles.
16. Cookie policies
Lablaco uses cookies. Below you can find more
information about cookies, how they are used by Lablaco and which control
procedures we adopt with respect to the cookies themselves. By continuing
to use Lablaco products, after accepting our Banner, you consent to the
use of cookies, in accordance with this statement. If you do not agree to
the use of cookies, please disable them by following the instructions
below in this statement.
17. What are cookies
Cookies consist of small text files which are
sent on your electronic device while browsing a website oe app and which
provide certain information (“Cookies”). Cookies are then sent back to the
original website or app during each subsequent browsing or are sent to a
different website able to recognize that specific Cookie. Cookies act as a
memory for a website allowing the website to recognize your device at each
subsequent visit to that same website. Cookies also allow you to store
your browsing preferences offering you a more functional experience of the
Site, and making the content of the Site as personalized as possible.
Web browsers allow you to exercise a control over the Cookies through your browser settings. Most of the browsers allow you to block Cookies or block Cookies from certain sites. Browsers can also help you deleting Cookies when you close your browser. However, you should keep in mind that this may mean that any opt-outs or preferences you have set on the site will be lost. We invite you to refer to your browser’s technical information for instruction. If you choose to disable the Cookies setting or refuse to accept a Cookie, some parts of the service may not work properly or may be significantly slower.
18. Types of cookies
Cookies can be technical, analytical and
profiling.
The Site uses technical "session" cookies and persistent.
Moreover, the Site uses the following analytical cookies set by
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The Site does not use profiling cookies.
19. Cookies Purposes
The technical cookies used by our Site make
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Analytical cookies are used to analyze and monitor the ways you use the Site (e.g. number of accesses and pages viewed), for statistical purposes and to allow us to improve the Site in terms of operation and browsing.
20. How to control and remove cookies
You can authorize the use of
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21. How to disable the Cookies
Warning: the provision of data is
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