Flipspins.com Privacy Policy

Operated by Diversify Media, Inc. (“DMI”)

Effective Date: October 22, 2026 | Last Updated: October 22, 2026

This policy applies to all visitors worldwide.

If you have any questions regarding this Privacy Policy, please contact us at: pto @ diversifymedia.com

1. Introduction and Scope

Diversify Media, Inc. (“DMI,” “we,” “us,” or “our”) operates Flipspins.com (the “Site”). We are committed to protecting your personal information and respecting your privacy rights regardless of where you are located in the world.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit or use our Site, and describes your privacy rights under applicable law, including:

United States: the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) and the California Online Privacy Protection Act (CalOPPA); the Virginia Consumer Data Protection Act (VCDPA); the Colorado Privacy Act (CPA); the Connecticut Data Privacy Act (CTDPA), including its amendments effective July 1, 2026; the Utah Consumer Privacy Act (UCPA); the Texas Data Privacy and Security Act (TDPSA); the Oregon Consumer Privacy Act (OCPA); the Montana Consumer Data Privacy Act (MCDPA); the Florida Digital Bill of Rights (FDBR); the Iowa Consumer Data Protection Act (ICDPA); the Delaware Personal Data Privacy Act (DPDPA); the New Hampshire Data Privacy Act; the Nebraska Data Privacy Act (NDPA); the New Jersey Data Privacy Act (NJDPA); the Tennessee Information Protection Act (TIPA); the Minnesota Consumer Data Privacy Act (MCDPA); the Maryland Online Data Privacy Act (MODPA); the Indiana Consumer Data Protection Act (INCDPA); the Kentucky Consumer Data Protection Act (KCDPA); the Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA); consumer health data laws including the Washington My Health My Data Act and Nevada SB 370; and all other applicable state-level privacy laws.
European Union: General Data Protection Regulation (GDPR).
United Kingdom: UK GDPR and the Data Protection Act 2018.
Canada: Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial laws (including Alberta/BC PIPA and Québec Law 25).
India: Digital Personal Data Protection Act 2023 (DPDPA).
Australia: Privacy Act 1988 and Australian Privacy Principles.
Brazil: Lei Geral de Proteção de Dados (LGPD).
Japan: Act on the Protection of Personal Information (APPI).
South Korea: Personal Information Protection Act (PIPA).
Other applicable international privacy and data protection frameworks.

By using the Site, you acknowledge you have read and understood this Privacy Policy. If you do not agree, please discontinue use of the Site.

2. Your Acceptance

In accessing the Site and/or our Service, you accept all the terms and conditions of this Privacy Policy. We ask that you bookmark and periodically review this Privacy Policy to ensure continuing familiarity with the most current version. If you do not agree with the terms and conditions of this Privacy Policy, please immediately cease using and accessing the Site.

3. Information We Collect

You will be informed each time our Site asks for information and how we intend to use your data. DMI collects information from you in two ways: information you give to us, and information that we gather from your use of our Service, collectively known as “Personally Identifiable Information” or “PII”.

“Personal Information” means information that personally identifies you, such as your first and last name, email address, physical address, telephone number, or billing information.
“Non-Personal Information” means information that does not specifically identify you.

3.1 Information You Give to Us

We collect information that you give to us. For example, you may provide your email address or other information to receive newsletters and notifications about certain features of our Service.

3.2 Information We Collect Automatically

We, like many websites, collect information about what parts of our Service you use and how you use them. This may include:

Computer or browser information such as your system activity, the domain name of the website from which you linked to our Site, time and duration of your visit, browser type, and browser language.
Device information such as your hardware model, operating system, operating system version, mobile device type, unique identifiers, and IP address.
Approximate location data (country/region level) derived from your IP address.
Cookie identifiers, advertising IDs, and similar tracking technology identifiers (see Section 6).
Clickstream and interaction data detailing your engagement with content and advertisements.

3.3 Information from Third-Party Partners

Our advertising, analytics, and affiliate partners may share data about your interactions with their platforms, which may be combined with information we hold. This includes ad interaction data, purchase and click data from affiliate programs, and analytics data from third-party measurement providers.

3.4 Sensitive Personal Information — Data Minimization

We do not request, and we do not knowingly collect or process, “sensitive personal information” or “sensitive data” as defined under applicable law — including precise geolocation, government-issued identification numbers, financial account credentials, racial or ethnic origin, religious beliefs, health or biometric data, neural data, sexual orientation, citizenship or immigration status, or the personal data of known children. Consistent with applicable data minimization requirements (including the Maryland Online Data Privacy Act), we limit our collection of personal data to what is reasonably necessary and proportionate to provide the Site and the services described in this Policy, and we do not sell sensitive data.

4. How We Use Your Information

We collect information from you to administer our business activities and to measure and improve our Service. We use your information for the following purposes:

To operate, maintain, and improve the Site and its content.
To send newsletters and marketing communications where you have subscribed or consented.
To respond to your inquiries and provide customer support.
To serve and measure personalized and non-personalized advertising.
To support our affiliate marketing partnerships and track referral commissions.
To conduct analytics and understand user behavior to improve our Service.
To show advertising and promotions tailored to your interests.
To detect, prevent, and address fraud, security incidents, or technical issues.
To comply with applicable laws, regulations, and legal obligations.
To enforce our Terms of Use and protect our legal rights.

Affiliate Disclosure: Flipspins.com participates in affiliate marketing programs, both directly with brands and through affiliate networks and platforms (which may include programs such as Amazon Associates). We may earn a commission when you click on links on the Site and make a purchase or sign up for a service, at no additional cost to you. This is disclosed in accordance with the U.S. Federal Trade Commission’s Endorsement Guides (16 C.F.R. Part 255) and applicable law. Affiliate compensation does not affect our editorial independence. For full details, please see our Affiliate Disclosure and our Terms of Use.

AI / Large Language Model Disclosure (Connecticut and similar laws): We do not collect, use, or sell personal data for the purpose of training large language models or other generative artificial intelligence systems.

We may combine your Personal Information with information obtained from business partners or other companies. If we do so, the combined information will be treated as Personal Information for as long as it remains combined.

5. Information Sharing and Disclosure

We do not sell your personal information for money. However, we allow third-party advertising and analytics partners to collect personal information (such as cookie and advertising identifiers, IP address, device and browser information, and your activity on the Site) through cookies and similar technologies for targeted advertising and measurement. Under the CCPA/CPRA and similar state laws (including the Rhode Island Data Transparency and Privacy Protection Act), this activity is a “sale” or “sharing” of personal information, and we treat it as such; under other state privacy laws it is processing for “targeted advertising.” We do not sell or share the personal information of consumers we actually know to be under 16 years of age (see Section 9.2). You can opt out at any time using the “Do Not Sell or Share My Personal Information” link shown at the bottom of our web pages, by sending a Global Privacy Control signal (Section 17), or by contacting us (Section 9).

Third parties to whom personal data has been or may be “sold” or “shared” (as those terms are defined by applicable law): Google (Google AdSense, Google Ad Manager, Google Display Ads, and Google Analytics); MGID; Amazon (Amazon Associates); Microsoft (Microsoft Advertising and, where used, Microsoft Clarity); Meta Platforms (Meta Pixel, where used); Taboola (Taboola Pixel, where used); Yahoo Advertising; affiliate networks and advertisers whose programs are active on the Site from time to time (identified in Section 6.3); our web analytics and measurement providers (e.g., Google Analytics). This list is provided in the interest of transparency and to comply with state laws (including Rhode Island’s RIDTPPA) that require identification of third parties to whom personal data may be sold or shared.

We may share your information with third parties in the following circumstances:

Consent: We will share Personal Information with third parties when we have your explicit consent to do so.
Advertising & Affiliate Partners: We share or permit the collection of data by our advertising and affiliate partners for targeted advertising, affiliate tracking, and measurement, subject to your consent preferences where required.
Analytics Providers: We use analytics services to understand how the Site is used. These providers process data on our behalf under data processing agreements.
Service Providers: We engage third-party vendors who assist in operating the Site (e.g., web hosting, email delivery, security). These parties are contractually restricted to processing data only on our behalf.
Affiliates: We may share information with corporate affiliates of Diversify Media, Inc., who will process it consistent with this Policy.
Legal Requirements: We may disclose information as required by law, regulation, subpoena, court order, or government request, or to establish or exercise our legal rights.
Business Transfers: If DMI undergoes a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via the Site prior to any such transfer.

We reserve the right to share Non-Personal Information publicly and with our partners, for example in aggregate or anonymized reports. DMI disclaims any liability for third-party actions concerning your information. We urge you to contact third parties directly regarding their use of your information. Where we hold de-identified or aggregated data, we commit to maintaining and using it only in de-identified form, to not attempting to re-identify it (except to test our de-identification process), and to contractually obligating any recipient to do the same.

6. Cookies, Web Beacons, Tracking Technologies, and Advertising

6.1 Types of Cookies and Technologies We Use

We and our partners use cookies, web beacons, pixel tags, JavaScript, local storage, and similar tracking technologies. These fall into the following categories:

Strictly Necessary Cookies: Required for the Site to function properly. Cannot be disabled.
Functional/Preference Cookies: Remember your preferences and settings.
Analytics Cookies: Help us understand how visitors use the Site. We use Google Analytics (including through Google Tag Manager), and we may use other analytics tools such as Microsoft Clarity, which can also record heatmaps and session replays showing how visitors interact with pages.
Advertising/Targeting Cookies: Used by our ad partners to show relevant, interest-based ads and measure performance.

Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some aspects of the Service may not function properly without cookies. For more information about cookies and how to control and delete them, please visit:

www.allaboutcookies.org/manage-cookies/
www.aboutads.info/consumers

6.2 IP Addresses

An IP address is used by your computer every time it connects to the Internet. IP addresses are automatically collected by our Site as part of demographic and profile data (“traffic data”). We use your IP address to help diagnose server problems and administer the Site. DMI will not use your IP address to attempt to identify you personally or to build a profile about you beyond what is necessary to provide the services you request.

6.3 Our Advertising and Affiliate Partners

The Site works with, or may work with, the following advertising, analytics, and affiliate partners, each of whom may place cookies, web beacons, or tracking technologies on your device:

Google AdSense, Google Ad Manager & Google Display Ads: Google, as a third-party vendor, uses cookies and unique device identifiers to serve ads on our Site based on user visits to this and other websites. Users may opt out of personalized advertising by visiting Google’s Ad Settings. You can review Google’s Advertising Principles at: https://support.google.com/adwordspolicy/answer/1316548. To opt out of Google’s personalized advertising, visit: https://www.google.com/settings/ads. To understand how Google uses data when you use partner sites, visit: https://policies.google.com/technologies/partner-sites.
Google Analytics & Google Tag Manager: We use Google Tag Manager to load measurement and advertising tags on the Site (which may include Google Ads conversion measurement), and Google Analytics (including Google Analytics 4) to understand how visitors use the Site. Google Analytics uses cookies and similar identifiers to collect usage data such as pages viewed, approximate location, and device and browser information. You can opt out of Google Analytics by installing the browser add-on at: https://tools.google.com/dlpage/gaoptout.
MGID: We display native advertising and recommended-content units provided by MGID. MGID and its partners may use cookies, device identifiers, and similar technologies to select and measure ads, which may include interest-based ads. Learn more and manage your choices at: https://www.mgid.com/services/privacy-policy and https://www.mgid.com/opt-out.
Advertising and Measurement Tags: Depending on the page and your consent choices, tags we deploy through Google Tag Manager or directly on the Site may include Google Ads conversion measurement, the Microsoft Advertising Universal Event Tracking (UET) tag, the Meta Pixel (Meta Platforms, Inc.), the Taboola Pixel, and third-party click and conversion tracking services that attribute visits from advertising campaigns. These providers may set cookies or use pixels to measure campaign performance, build audiences, and show you ads on their own platforms. Learn more in the privacy notices of Microsoft, Meta, Taboola.
Contact Forms and Spam Protection: Information you submit through our contact forms is processed by the form software that runs on our website. We use Google reCAPTCHA on some forms to help prevent spam and abuse; reCAPTCHA collects hardware and software information, such as device and application data, and sends it to Google for analysis, subject to the Google Privacy Policy.
Embedded Content: Our pages may embed videos (for example, from YouTube), images, or other content from third-party services. These services may receive your IP address and set cookies when the content loads, as described in their own privacy policies.
Other Advertising and Analytics Partners (Current and Future): We may also work with additional advertising, native-advertising, and analytics partners — for example, Yahoo Advertising (Yahoo Privacy Dashboard), Microsoft Clarity (heatmaps and session replay; https://clarity.microsoft.com/terms), Outbrain, or similar providers. Not every partner is active on every one of our websites, and the partners active on this Site will change over time.
Other Affiliate Programs (Current and Future): We participate in, or may in the future participate in, affiliate programs, whether directly with brands or through affiliate networks and platforms — for example, Amazon Associates, the eBay Partner Network, JustAnswer, impact.com, CJ Affiliate, Awin, ShareASale, Rakuten Advertising, Partnerize, or FlexOffers. Not every program is active on every one of our websites, and the programs active on this Site will change over time. When a program is active on the Site, its partner may place cookies or tracking pixels on your device to attribute referrals and measure conversions, subject to your consent preferences where required; active tracking technologies are described in this Section 6. You may opt out of interest-based advertising from many of these partners through the Network Advertising Initiative at: https://optout.networkadvertising.org.

6.4 Consent Management

We use a consent management tool provided by Google to manage your privacy choices. What you see depends on where you are:

European Union and United Kingdom: You will see Google’s consent message on your first visit. Through this message, you may accept all cookies, reject non-essential cookies, or customize your preferences.
United States: You will see a “Do Not Sell or Share My Personal Information” link at the bottom of our web pages, which you can use to opt out of the sale or sharing of your personal information for targeted advertising.

You may change or withdraw your consent choices at any time by clicking the “privacy and cookie settings” link shown at the bottom of our web pages (EU and UK visitors) or by using the “Do Not Sell or Share My Personal Information” link shown at the bottom of our web pages (U.S. visitors).

6.5 Managing Cookies and Opting Out of Interest-Based Advertising

You can manage or opt out of personalized advertising at any time using the following independent resources:

Google Ads Settings: https://www.google.com/settings/ads
Digital Advertising Alliance (DAA) opt-out (US): https://www.aboutads.info/choices
Network Advertising Initiative (NAI) opt-out: https://optout.networkadvertising.org
European Interactive Digital Advertising Alliance (EDAA) – Your Online Choices (EU/UK): www.YourOnlineChoices.com
All About Cookies – Managing Cookies: www.allaboutcookies.org/manage-cookies
Your browser’s built-in cookie and privacy controls.
The “privacy and cookie settings” link shown at the bottom of our web pages (EU and UK visitors).
The “Do Not Sell or Share My Personal Information” link shown at the bottom of our web pages (U.S. visitors).

7. Google – Additional Disclosures

Google, as a third-party vendor, uses cookies and device identifiers to serve ads on our Site. Third-party vendors, including Google, use these tracking technologies to serve ads based on your prior visits to this website or other websites on the internet. These vendors may automatically collect:

IP address
Browser type and version
Device information and operating system
Interaction data with served advertisements

If you are located in a region that requires user consent (such as the EU, EEA, or UK), our Site shows Google’s consent message, allowing you to accept, reject, or manage your preferences. When you opt out of personalized advertising, Google and its partners serve non-personalized ads that rely on contextual relevance rather than historical browsing identifiers.

8. Legal Basis for Processing (EU, UK, and GDPR-Equivalent Jurisdictions)

DMI acts as the data controller for personal data processed in connection with the Site. For visitors in the EU, UK, and other jurisdictions requiring a defined lawful basis, we rely on:

Consent: Where you have given clear, affirmative, and informed consent (e.g., personalized advertising cookies or email marketing subscriptions). You may withdraw this consent at any time without affecting the lawfulness of processing prior to withdrawal.
Legitimate Interests: Where processing is necessary for our legitimate business interests, provided your fundamental rights and interests do not override them (e.g., operating the Site safely, preventing fraud, maintaining site security, and analyzing aggregated audience behavior).
Contract Performance: Where processing data is necessary to fulfill a service or contract you have requested.
Legal Obligation: Where we are required to process your data to comply with explicit legal or regulatory obligations.

Certain third-party advertising and analytics partners act as independent data controllers for their own respective processing activities.

9. Your Privacy Rights

Depending on your geographic location, you may have some or all of the statutory rights listed below. To exercise any of your rights, you may (1) email us at pto @ diversifymedia.com, or (2) submit your request through our Contact page. Please tell us which right you are exercising and the state or country in which you live.

Verification: We must verify that a request to know, delete, or correct comes from you or from someone authorized to act for you. Because we hold very little information about most visitors, we will usually verify a request by matching the email address you contact us from with information we already hold (for example, a newsletter subscription or earlier correspondence) and, where necessary, by asking you to confirm the request from that address. Information you provide for verification is used only to verify the request. If we cannot verify your identity, we may deny the request and will tell you why. Requests to opt out of sale, sharing, or targeted advertising do not require verification, although we may ask for information needed to apply the opt-out.

Authorized agents: You may designate an authorized agent to make a request on your behalf. We may ask the agent to provide your signed, written permission, and we may ask you to verify your identity directly with us or to confirm that you gave the agent permission. An agent holding a power of attorney, or a court-appointed conservator or guardian, need only provide proof of that authority.

Timing and fees: We will confirm receipt of a request to know, delete, or correct within 10 business days and respond within 45 days of receipt. Where reasonably necessary and permitted by law, we may extend that period once by a further 45 days after notifying you. Where your local law sets a shorter period (for example, one month under the GDPR and UK GDPR, or 30 days under Canadian privacy law), we will meet it. We do not charge a fee to respond to privacy requests unless a request is manifestly unfounded, excessive, or repetitive, as applicable law allows.

Financial incentives: We do not offer financial incentives, price differences, or service differences in exchange for the collection, retention, sale, or sharing of your personal information, and we do not operate loyalty, rewards, or similar programs that would require a notice of financial incentive.

9.1 All Visitors (Global)

Access: Request a copy of the personal data we hold about you.
Correction/Rectification: Request correction of inaccurate or incomplete data.
Erasure/Deletion: Request deletion of your personal data, subject to lawful retention exceptions.
Restriction: Request that we restrict the processing of your personal information in certain scenarios.
Objection: Object to data processing based on legitimate interests or for direct marketing purposes.
Data Portability: Receive your data in a structured, commonly used, and machine-readable format.
Withdraw Consent: Where processing is strictly consent-based, withdraw it at any time.

9.2 US State Residents (Including California CCPA/CPRA)

Residents of states with comprehensive privacy laws have the following rights:

Right to Know: Request the categories and specific pieces of personal information collected, disclosed, or sold/shared over the trailing 12 months (or, for information collected on or after January 1, 2022, over a longer period on request, unless doing so proves impossible or would involve disproportionate effort).
Right to Delete: Request deletion of personal information we have collected from you.
Right to Correct: Request correction of inaccurate personal information.
Right to Opt Out of Sale/Sharing: Request to opt out of the “sale” or “sharing” of personal data for cross-context behavioral advertising via the “Do Not Sell or Share My Personal Information” link shown at the bottom of our web pages, by sending a Global Privacy Control signal (Section 17), or by emailing pto @ diversifymedia.com with “Do Not Sell or Share” in the subject line.
Right to Opt Out of Targeted Advertising and Profiling: Opt out of the processing of your personal data for targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects. We do not engage in profiling that produces legal or similarly significant effects concerning consumers.
Right to a List of Specific Third Parties (Oregon, Minnesota, Delaware, Connecticut, and similar laws): Request a list of the specific third parties to which we have disclosed your personal data (or, at our option where the law allows, a list of third parties to which we have disclosed any personal data). The third parties to which personal data may be disclosed for advertising purposes are identified in Section 5.
Right to Limit Use of Sensitive Personal Information: We do not collect or process sensitive personal information beyond what is strictly necessary to provide our direct services, and we do not sell sensitive data (see Section 3.4).
Right to Non-Discrimination: We will not discriminate against you or alter your site experience for exercising any statutory privacy rights.
Right to Appeal: If we decline to take action on a privacy rights request, residents of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Delaware, New Hampshire, Nebraska, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and other states that provide an appeal right may appeal our decision by replying to our response or by emailing pto @ diversifymedia.com with the subject line “Privacy Rights Appeal.” We will respond within the timeframe required by your state’s law. If your appeal is denied, you may contact your state Attorney General to submit a complaint.

Notice at Collection (CCPA/CPRA): categories of personal information collected in the last 12 months, their sources, our purposes, and how each is disclosed. Retention criteria for each category are in Section 11. We do not use or disclose sensitive personal information for purposes other than those permitted by law (see Section 3.4).

Identifiers (name and email address when you contact us or subscribe; IP address; cookie, device, and advertising identifiers). Sources: you; your browser or device; our advertising, analytics, and affiliate partners. Purposes: operating and securing the Site, responding to you, sending newsletters you requested, analytics, and advertising and affiliate measurement. Disclosed for a business purpose to: hosting, email, security, and analytics service providers. Sold or shared with: advertising networks and analytics providers (Section 5).
Internet or other electronic network activity information (pages viewed, time on page, referring site, clicks, and interactions with content and advertisements). Sources: your browser or device; our partners. Purposes: analytics, advertising, affiliate attribution, and security. Disclosed for a business purpose to: analytics and security service providers. Sold or shared with: advertising networks and analytics providers.
Geolocation data (approximate country or region derived from your IP address; we do not collect precise geolocation). Sources: your device or IP address. Purposes: showing region-appropriate content and consent notices, legal compliance, and advertising. Sold or shared with: advertising partners.
Commercial information (click, purchase, or sign-up confirmation data that affiliate networks report to us; we do not receive payment card numbers). Sources: affiliate networks and advertisers. Purposes: tracking referral commissions. Not sold or shared.
Inferences (interest segments that advertising partners derive from browsing activity to select ads). Sources: our advertising partners. Purposes: advertising optimization. Sold or shared with: advertising networks.
Sensitive personal information: none knowingly collected (Section 3.4).

Categories of third parties with whom personal information is shared: Advertising networks, affiliate marketing networks, and web analytics providers. Specific named partners are listed in Sections 5 and 6.3.

Minors: We do not knowingly sell or share the personal information of consumers under the age of 18, and we do not knowingly process the personal data of consumers under 18 for targeted advertising, without the affirmative authorization (or, where required, parental consent) mandated by applicable law — including New Jersey’s and Delaware’s protections for consumers aged 13–17 and Oregon’s and Connecticut’s protections for minors. Under the CCPA/CPRA, we do not sell or share the personal information of consumers we actually know to be under 16 unless the consumer (if aged 13 to 15) or the consumer’s parent or guardian (if under 13) has affirmatively opted in; we do not have actual knowledge that we sell or share the personal information of any consumer under 16.

California Online Privacy Protection Act (CalOPPA) disclosures:

Users may visit our Site anonymously.
A clear link to this Privacy Policy is displayed on our homepage and within our global footer.
We notify users of material changes to this Policy on this page.

California’s “Shine the Light” Law: California residents may request once per year, free of charge, information regarding personal information disclosed to third parties for direct marketing purposes. Contact us at pto @ diversifymedia.com with “Shine the Light Request” in the subject line.

9.3 EU and UK Residents (GDPR / UK GDPR)

In addition to global rights, EU and UK residents may:

Lodge a formal complaint with their national Data Protection Authority (DPA). UK residents may contact the Information Commissioner’s Office (ICO) at https://ico.org.uk.
Receive transparent information about international data transfers and deployed structural safeguards (see Section 11).

We aim to respond to all GDPR/UK GDPR requests within 30 days. Complex requests may legally take up to an additional 2 months; we will inform you of any extension requirements within the initial 30-day window.

9.4 Canadian Residents (PIPEDA / Québec Law 25)

Canadian residents may request access to and correction of their personal information, withdraw consent at any time, and file a formal inquiry with the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca. Québec residents have clear rights under Law 25, including data portability, de-indexing, and the right to be informed of automated decision-making or profiling mechanisms.

9.5 Indian Residents (DPDPA 2023)

Under India’s Digital Personal Data Protection Act 2023, Indian residents have the right to access summary information, correct inaccuracies, erase personal data, and nominate an alternative representative in the event of incapacity. Contact us at pto @ diversifymedia.com and mark your email “India DPDPA Request.”

9.6 Australian Residents

Under the Privacy Act 1988 and Australian Privacy Principles, Australian residents may request access to and correction of personal information. Privacy complaints may be formally lodged with the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au.

9.7 Brazilian Residents (LGPD)

Under Brazil’s LGPD, you maintain explicit rights of access, correction, anonymization, data portability, deletion, and the right to clear disclosure regarding with which public or private entities your data is shared. Complaints may be filed directly with the Autoridade Nacional de Proteção de Dados (ANPD).

9.8 Other International Jurisdictions

Residents of other regions operating under comprehensive privacy laws (including Japan, South Korea, Singapore, and South Africa) may exercise applicable local rights. We utilize reasonable business efforts to honor all verifiable identity requests in accordance with local legal frameworks.

10. Consumer Health Data (Washington, Nevada, and Similar Laws)

Some content on Flipspins.com may relate to health, fitness, or wellness topics. We want to be clear about how we treat information connected to those topics. Please also see our Medical Disclaimer.

We do not ask you for, and we do not knowingly collect, “consumer health data” as defined by the Washington My Health My Data Act, Nevada SB 370, or similar consumer health data laws. We do not use the articles you read on the Site to make inferences about your health status, diagnoses, conditions, or treatments, and we do not sell consumer health data. We do not use geofencing around health care facilities.

Please note that our third-party advertising partners operate under their own privacy policies. Where required by law, interest-based advertising on the Site is delivered only with your consent (via Google’s consent message) and is subject to the opt-out tools described in this Policy. If you are a resident of Washington, Nevada, or another state with a consumer health data law and believe we hold consumer health data about you, you may exercise the rights available under that law (including access, deletion, and withdrawal of consent) by contacting us at pto @ diversifymedia.com. You may also appeal any decision we make regarding such a request by replying to our response with the subject line “Health Data Appeal.”

11. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the operational and commercial purposes described in this Policy, including:

Providing ongoing services and responding to custom user requests.
Complying with statutory, tax, legal, and regulatory retention obligations.
Resolving formal disputes and enforcing active corporate agreements.

Aggregated web analytics data is typically retained for a standard 26 months. Email subscriber data is retained until you unsubscribe or request deletion. Contact form submissions and correspondence are kept for as long as needed to respond to you and to keep a record of the exchange, and are then deleted. Server logs containing IP addresses are kept for a limited period for security and troubleshooting and are then deleted or overwritten. Cookie lifetimes are set by the party placing the cookie: session cookies expire when you close your browser, and persistent cookies expire on the date set by the party that placed them (see Section 6 and the partner policies linked there). We do not retain personal information indefinitely; data that is no longer reasonably necessary for the purposes for which it was collected is deleted or de-identified. You may request deletion of your data at any time (subject to transactional legal exceptions) as described in Section 9.

12. International Data Transfers

Diversify Media, Inc. is headquartered in the United States. Your information may be transferred to, stored, or processed in countries other than your country of residence — including the United States and Canada — which may maintain distinct data protection laws from your home jurisdiction.

For structural transfers of personal data originating from the EU, EEA, or UK, we rely on:

Standard Contractual Clauses (SCCs) officially approved by the European Commission.
The UK International Data Transfer Agreement (IDTA) or Addendum for UK-specific transfers.
Adequacy decisions and the EU-U.S. Data Privacy Framework (and its UK Extension), where a recipient is certified, where applicable.

By continuing to use the Site, you acknowledge and agree that your data may be transferred internationally. You may request detailed information regarding active transfer safeguards by contacting us.

13. Children’s Privacy

13.1 COPPA (Children Under 13)

We fully comply with the Children’s Online Privacy Protection Act (COPPA) and its implementing Rule, as amended by the Federal Trade Commission effective June 23, 2025 (with full compliance required by April 22, 2026). Our Service is a general-audience service that is not directed to, nor intended for, children under the age of 13. We do not knowingly collect, maintain, or disclose Personal Information from children under 13, and we do not retain any such information indefinitely. If you believe we have inadvertently collected such information, please contact us immediately at pto @ diversifymedia.com and we will promptly purge it from our systems.

13.2 Children Between the Ages of 13 and 18

If you are between the ages of 13 and 18, please ensure you review this Privacy Policy with your parent or legal guardian and obtain their permission before transmitting any Personal Information to us. As described in Section 9.2, we do not knowingly sell or share the personal data of minors or use it for targeted advertising without legally required authorization.

13.3 GDPR / UK GDPR (Children Under 16)

For users located within the EU, EEA, and UK, where we rely on consent as the legal basis for processing, we do not knowingly accept consent from a child under 16 years of age (or the lower age, not below 13, set by the applicable member state) without the authorization of a parent or guardian. If we learn that we have collected personal data from a child in reliance on consent that was not validly given, we will delete it.

13.4 Information for Parents

We strongly encourage parents to monitor and spend time online with their children to become familiar with the types of content available on the internet. We do not require a child to disclose more information than is reasonably necessary to participate in any Site activity. Parents may request a review, modification, or total removal of their child’s Personal Information at any time by contacting us at pto @ diversifymedia.com. To protect a child’s privacy and security, we will take reasonable steps to verify the parent’s identity before granting access to a child’s Personal Information.

14. Data Security and Confidentiality

We strictly limit operational access to your personal information to employees and contracted vendors of DMI who reasonably require access to that information to perform their jobs or to deliver requested products and services. We maintain appropriate physical, electronic, administrative, and procedural safeguards designed to protect and restrict unauthorized access to personal information.

Specific security measures deployed include:

Enforced encryption of data in transit using industry-standard TLS/SSL protocols.
Access controls that limit personal information to the personnel and vendors who need it, including password protection and, where available, multi-factor authentication on administrative accounts.
Periodic review of our security practices, timely software updates, and security monitoring provided by our hosting and security vendors.
Data minimization and pseudonymization practices where commercially viable.

Please note that no method of transmission over the internet or electronic storage can be guaranteed 100% secure. In the event of a confirmed data breach affecting your rights and freedoms, we will notify affected individuals and relevant supervisory authorities as required by applicable laws (e.g., within 72 hours for GDPR/UK GDPR compliance; as promptly as required under applicable US state frameworks).

15. Fair Information Practices

The Fair Information Practices Principles form the foundation of privacy law in the United States, and their structural concepts play a globally significant role in the ongoing development of international data protection laws. To align with Fair Information Practices, we commit to notifying you via an on-site alert or email notice should a material data breach occur, as required by applicable law.

We also explicitly agree to the Individual Redress Principle, which legally requires that individuals maintain enforceable rights against data collectors and processors who fail to adhere to statutory compliance frameworks. This principle establishes that individuals have clear recourse to judicial systems or government oversight agencies to investigate and prosecute non-compliance by data processors.

16. Email Communications – CAN-SPAM, CASL, and GDPR Compliance

We collect your email address primarily to send requested information, respond to direct inquiries, and distribute newsletters or promotional offers.

In strict accordance with CAN-SPAM, CASL, and GDPR email compliance, we agree to the following protocols:

We will never use false, misleading, or deceptive subjects or email addresses.
We will clearly identify commercial messages as advertisements in a reasonable, transparent manner.
We will display the physical mailing address of our corporate or site headquarters within all electronic mailings.
We will continuously monitor any third-party email marketing services we employ for strict legal compliance.
We will honor opt-out and unsubscribe requests promptly (within 10 business days, as required by CAN-SPAM and CASL).
We will provide a clear, functional “Unsubscribe” link at the baseline of every marketing email.
We will only send commercial electronic messages to Canadian residents with express or implied consent under CASL.
We will only distribute marketing emails to EU/UK residents based on explicit consent or documented legitimate interest grounds under the GDPR.

If at any time you wish to stop receiving future marketing emails, you can follow the unsubscribe instructions located at the bottom of any email or contact us via our Contact page. Transactional, security, or service-related emails are not subject to standard promotional unsubscribe requests.

17. Global Privacy Control (GPC), Universal Opt-Out Mechanisms, and Cookie Settings

Traditional browser “Do Not Track” (DNT) signals lack an industry-standard definition and are widely unsupported by third-party ad networks, so this site does not respond to DNT signals. Some browsers and browser extensions can send a Global Privacy Control (GPC) signal. We treat a valid GPC signal as a request to opt out of the sale or sharing of your personal information and of targeted advertising, as required in California, Colorado, Connecticut, Texas, Oregon, Montana, Delaware, New Hampshire, Nebraska, New Jersey, Minnesota, Maryland, and other states that recognize universal opt-out mechanisms. Our consent tool and advertising partner Google read the GPC signal and treat it as an opt-out of personalized advertising for visitors in those states. The signal applies to the browser or device that sends it. Because GPC is a browser signal, it does not unsubscribe you from any email list; use the unsubscribe link in our emails for that.

You can also opt out of the sale or sharing of your personal information for targeted advertising at any time using the “Do Not Sell or Share My Personal Information” link shown at the bottom of our web pages, or by emailing pto @ diversifymedia.com with “Do Not Sell or Share” in the subject line. Visitors in the EU and UK can manage their choices through Google’s consent message or the “privacy and cookie settings” link shown at the bottom of our web pages.

18. External Links

By its nature, our Site contains hyperlinks to external, third-party websites (including affiliate retail platforms and ad networks). Please be aware that DMI does not control, and cannot be held responsible for, the privacy or information collection practices of third-party websites. We strongly encourage you to review the individual privacy policies of any external site you visit before interacting with it or submitting personal data.

19. Accessibility

We are deeply committed to making this Privacy Policy fully accessible to all users. If you require access to this Policy in an alternative, assistive format, please contact us at pto @ diversifymedia.com.

20. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time to reflect changing technical, commercial, or regulatory demands. The “Last Updated” date positioned at the top of this document will always reflect the most recent modification (including the month and year of the most recent update). Material changes will be actively communicated via a clear notice on our homepage or via direct email where legally mandated, and where required by law you will have a reasonable opportunity to withdraw consent to any materially new processing. Your continued use of the Site following the posting of modifications constitutes full acceptance of the revised terms.

Historical archives of prior policy versions can be formally requested by contacting us directly.

21. Contacting Us

If you have any questions, clarifications, or complaints regarding this Privacy Policy, our site data practices, or your interaction with Flipspins.com, please reach out to us at:

Email Contact: pto @ diversifymedia.com
Contact Page: https://flipspins.com/contact/
Corporate Postal Address:

Diversify Media, Inc.
17671 Irvine Blvd., Suite 104
Tustin, CA 92780
United States

EU/UK Representative Inquiries: If we have appointed a representative in the EU or UK under Article 27 of the GDPR or UK GDPR, you may obtain the representative’s contact details by emailing pto @ diversifymedia.com. EU and UK visitors may in any case contact us directly at that address.
India Data Protection Contact: Email pto @ diversifymedia.com with the subject line “India DPDPA Request.”

We will respond to verified privacy requests within the timeframes described in Section 9: generally within 45 days of receipt, or within one month (30 days) where the GDPR, UK GDPR, Canadian privacy law, or another shorter statutory period applies.