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PRIVACY POLICY

Date of Last Revision: August 27, 2008.

Spinning Key Principles.............................................................................................................1


Changes to this Privacy Policy...................................................................................................1
Collection and Use of Personal Information...............................................................................2
Registrations...........................................................................................................................2
Online Registration.................................................................................................................2
Promotions or Surveys............................................................................................................3
Customer Service....................................................................................................................3
Website Information................................................................................................................3
Sweepstakes............................................................................................................................3
Cookies...................................................................................................................................3
Marketing....................................................................................................................................4
Disclosure of Personal Information............................................................................................4
Third party processors and agents...........................................................................................5
Third Party Products and Services..........................................................................................5
Sale or merger of Business......................................................................................................5
Legal.......................................................................................................................................5
Third party Websites and Advertisers.........................................................................................5
Security of Personal Information................................................................................................6
Accessing and Correcting your Personal Information................................................................6

Spinning Key Principles


We built Spinning Key to make it easy to share useful information with the rest of the world
and to find one when you need it. You should be aware that all Listings are intended to be
public. Listings that you post on WWiC (WorldWide info Center) will become publicly
available on the WWiC.

Thank you for visiting Spinning Key Ltd. website. Your privacy is important to us, and we are
committed to ensuring your privacy is respected and protected. As part of this commitment,
we have prepared this Privacy Policy to explain the manner in which Spinning Key Ltd.
collects, use, disclose and otherwise treat the personal information of consumers based in the
European Union. Spinning Key is governed by this Privacy Policy.

Changes to this Privacy Policy


We reserve the right, at our sole discretion, to change, modify, add, or delete portions of these
Privacy Policy at any time without further notice. If we do this, we will post the changes to
these Privacy Policy on this page and will indicate at the top of this page the date these terms
were last revised. Your continued use of our website after any such changes constitutes your
acceptance of the new Privacy Policy. If you do not agree to abide by these or any future
Privacy Policy, do not use or access (or continue to use or access) our website. It is your
responsibility to regularly check the Site to determine if there have been changes to these
Privacy Policy and to review such changes.
Collection and Use of Personal Information
You are able to enjoy and visit many areas of our websites without providing us with any
personal information. However, we do collect personal information when you:
- register as Basic User;
- register as Premium User;
- register as Company User;

Registrations

When you register with one of our User accounts, we will ask you to provide your personal or
company details for the purposes of fulfilling your subscription, sending you invoices,
contacting you about the expiry of your subscription, and service messages about your
subscription.

Online Registration

You do not have to register to browse some areas of our websites. However, if you register as:
- Basic User we will ask you to provide your name, mailing address, e-mail address
information and a user name and password that you select for the purposes of fulfilling
your subscription, contacting you about the expiry of your subscription, and service
messages about your subscription. Registration as Basic User is requried in order to
submit content (post adds) in WWiC.
- Premium User we will ask you to provide your name, mailing address, e-mail address,
credit card or other payment information and a user name and password that you select
for the purposes of fulfilling your subscription, sending you invoices, contacting you
about the expiry of your subscription, and service messages about your subscription.
Registration as Premium User is required in order to have the full access to all
Spinning Key offerings.
- Company User we will ask you to provide Company name, mailing address, e-mail
address, TAX number, ID number and a user name and password that you select, as
well as contact persons name, e-mail address and phone number information for the
purposes of fulfilling your subscription, contacting you about the expiry of your
subscription, and service messages about your subscription. Registration as Company
User is required in order submit content (post adds), organize sweepstakes and prepare
discount offers for Premium Users.

We collect this information to identify who you are and to provide you with the service or
information you requested. We may also use this information for promotional and marketing
purposes in accordance with this Privacy Policy.

Please remember that any information you disclose in WWiC becomes public information and
is immediately accessible to other users, so it is important for you to carefully consider what,
if any, personal information you reveal in these areas. We may use information disclosed by
you in this way to promote our and other companies products and services in advertising
communications.

Promotions or Surveys
Our surveys ask for opinions on various issues and may be sponsored by our advertisers and
partners. Most information obtained through surveys is aggregated and used internally. We
may share survey information with advertisers and marketing partners in an aggregated, non-
personally identifiable form. In the event personal information is requested as part of a survey,
such personal information will only be provided to unaffiliated third parties after ensuring that
depending on the circumstances you have either consented or not objected.
Optional Information: Occasionally, we may request demographic information (like your age
or gender) or information about your interests and purchasing preferences. We use this
optional demographic and preference information to tailor or improve our and our partners,
product and service offerings, including our offerings to you where this is in accordance with
this Privacy Policy, as well as for internal marketing research purposes.

Customer Service
When you e-mail us with a comment or question, you may be asked for information that
identifies you, such as your name, address and telephone number, to help us promptly answer
your question. We may retain this information to assist you in the future, for instance with any
further queries you may have or by sending you information about other products or services
of ours which we believe may interest you, in accordance with this Privacy Policy. We also
may use your feedback, suggestions and comments to monitor and/or improve our offerings.

Website Information
Generally, you can visit our websites without telling us who you are or providing us with any
personal information. We collect the IP (Internet protocol) addresses of all visitors to our
websites and clickstream and other related information such as page requests, browser type,
operating system and average time spent on our websites. We use this information to monitor
and improve our websites.

Sweepstakes
We reserve the right to announce User details on Spinning Key website in case of winning the
prize in one of our Sweepstakes, or in Sweepstakes organized through our Site.

Cookies
To enhance your experience on our sites, many of our web pages use "cookies". Cookies are
small text files that we place in your computer's browser to store your preferences. Cookies,
by themselves, do not tell us your e-mail address or other personal information unless you
choose to provide this information to us by, for example, registering at one of our sites. Once
you choose to provide a web page with personal information, this information may be linked
to the data stored in the cookie. A cookie is like an identification card. It is unique to your
computer and can only be read by the server that gave it to you.

We use cookies to understand site usage and to improve the content and offerings on our sites.
For example, we may use cookies to personalise your experience on our web pages (e.g. to
recognise you by name when you return to our site, or to tailor content or product and service
offerings).

Most browsers automatically accept cookies. You can set your browser option so that you will
not receive cookies and you can also delete existing cookies from your browser. You may find
that some parts of the site will not function properly if you have refused cookies. If you wish
to block cookies please open your internet browser and then click through the following
relevant path:
- Internet Explorer (recent versions): Tools (on the top menu)/ Internet Options/
Privacy / select your security level / Click on 'OK'. To download the latest version of
Internet Explorer visit their oficial website.
- Netscape (recent versions): Edit (on the top menu)/ Preferences/ Advanced/ scroll
down and select your security level/ Click on 'OK'. To download the latest Netscape
browser visit their oficial website.
- Mozilla Firefox (recent versions): Tools (on the top menu)/Options/Privacy/ make
your selection / Click on 'OK'. To download the latest Mozilla Firefox browser visit
their oficial website.

Our websites may also use small pieces of software code to collect anonymous and aggregate
advertising metrics, such as counting page views, promotion views, or advertising responses.
It can recognise certain types of information, such as a user's cookie number, time and date of
a page view, and description of the page.

Marketing
Collected information data which you provide us with registration will be occasionally used to
send you marketing content to your e-mail address which you specified during the registration
process or in your profile. Alternatively your information may be collected automatically
during your website visit as described elsewhere in this Privacy Policy. We may also combine
personal information we received from you with publicly available outside records.
In all the above cases we will use this information to enhance our ability to market products
and services that may be of interest to you by way of appropriate marketing messages, either
during your site visit or by way of subsequent communications. This process leads to your
being placed on our mailing list. When you terminate your user account with us, we will also
remove you from our mailing list.

Disclosure of Personal Information


We will not disclose, rent, sell or otherwise transfer your personal information without your
consent, except as otherwise set out in this Privacy Policy or in any specific disclosure given
to you when obtaining personal information from you.
Third party processors and agents

Certain personal information may be transferred among your registration to other third parties
solely for the purposes of processing your credit card. We may also transfer (or otherwise
make available) your personal information to third parties who administer sweepstakes
through our system, or who provide circulation audit and other services on our behalf. We will
store and process personal information in Slovenia or any other country in which we (or any
of our affiliates, subsidiaries, processors or agents) maintain facilities. All of our service
providers are required to maintain the confidentiality and security of your personal
information and to use it only in compliance with applicable data privacy laws, and are
prohibited from using or disclosing your personal information for any purpose other than
providing the services on our behalf or as otherwise permitted by applicable law.

Third Party Products and Services

If you have registered with one of our user accounts, disclosures we give you when obtaining
your personal information and your indicated preferences may lead to your contact
information being shared with carefully selected marketing partners who will contact you by
mail or e-mail with offers about products and services that may be of interest to you. You
should allways be able to remove yourself from the future sharing of your contact information
with third parties. If not, you can contact us by e-mail: reports@spinningkey.com.

Sale or merger of Business

It is possible that all or part of Spinning Key Limited. could merge with or be acquired by
another business. If this happens we may share the information that relates to you.

Legal

We may provide your personal information in response to a search warrant or other legally
valid inquiry or order, or to an investigative body in the case of a breach of an agreement or
contravention of law, or as otherwise required by law. We may also disclose personal
information to assist us in collecting a debt owed by you, or otherwise where necessary for the
establishment, exercise or defence of legal claims.

Third party Websites and Advertisers


Our websites may provide links to third party websites. The inclusion of any link does not
imply our endorsement of any other company, its websites, or its products and/or services.
These linked websites have separate and independent privacy policies, which we recommend
you read carefully. We have no control over such websites and therefore have no
responsibility or liability for the manner in which the organizations that operate such linked
websites may collect, use, disclose or otherwise treat your personal information.

Our websites may use reputable third parties to present or serve the advertisements that you
may see at its web pages and to conduct research about the advertisements. This Privacy
Policy does not cover any use of personal information that such third parties may have
collected from you or the methods used by the third-parties to collect that information (e.g.,
cookies, web beacons and clear gifs).

Security of Personal Information


Although we take appropriate measures to safeguard the personal information in our custody
and control, we need you to understand that we are unable to guarantee that your personal
information will never be disclosed or accessed in a manner that is inconsistent with this
Privacy Policy. We have implemented measures in an effort to maintain the confidentiality of
all personal information in our custody and control, including only providing access to
personal information to employees and authorized service providers who require such
information for the purposes described in this Privacy Policy. We maintain administrative,
technical and physical safeguards in an effort to protect against unauthorized access, use,
modification and disclosure of personal information in our custody and control.
To provide you with an increased level of security online, access to your personal information
on certain of our websites may be protected with a password you select. We strongly
recommend that you do not disclose your password to anyone. We will never ask you for your
password in any unsolicited communication.

Accessing and Correcting your Personal Information


If you wish to access the personal information we have about you, or to correct factual errors
in our records, please visit our website, login and adequately change them (My Office/My
Account/Edit Personal Data or Change Password). You can also contact us on e-mail address
info@spinningkey.com.
To protect your privacy, we will take reasonable steps to help verify your identity before
granting access or making corrections.