Pinipol

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            <h2>PRIVACY POLICY – PINIPOL</h2>
            <p><b>www.pinipol.app</b></p>
            <p><b>Effective date: 1st August 2022</b></p>

            <p>
                The Pinipol Mobile Application (“App”) available on Apple App Store (IOS) and Google Play Store (Android) is owned and operated by Spinnovations Ltd from the United Kingdom. Throughout the Site and the App, the terms “we”, “us”, “Pinipol”, “App” and “our” refer to Spinnovations Ltd.
            </p>
            <p>
                This privacy policy has been compiled to better serve those who are concerned with how their personal data is used online. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your Personal data
            </p>
            <p>
            For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”), Spinnovations Ltd is the “data controller” (as defined in the GDPR) of the personal data, when it determines the purposes and means of the processing of personal data
            </p>

            <h5><u>PERSONAL INFORMATION WE COLLECT</u></h5>

            <p>
            <b>Personal information you provide to us.</b>  Personal information you may provide to us through the Service or otherwise includes:
            </p>
            <ul>
                <li><b>Contact data</b>, personal information such as your first and last name, email and mailing addresses, phone number and professional title.</li>
                <li><b>Registration data</b>, such as information that you provide to register for an account or sign up, including the day and month of your birth.</li>
                <li><b>Profile data</b>, such as your username and password that you may set to establish an online account with us and your, occupation, gender, religion, interests and preferences.</li>
                <li><b>Marketing data</b>, such as the email address or contact details that we use to send marketing communications and your preferences for receiving communications about our activities, events, sweepstakes and contests.</li>
                <li><b>Purchase data</b>, including your order history and information needed to process and fulfill your order, including order details and billing address.</li>
                <li><b>Other information</b> that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.</b></li>
            </ul>

            <p>
                <b>Automatic collection.</b>  We and our service providers may automatically log information about you, your computer or mobile device, and your activity occurring on or through the Sites/App, such as:
            </p>
            <ul>
                <li>
                    <b>Device data</b>, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing our site/app, and general location information such as city, state or geographic area.
                </li>
                <li><b>Online activity data</b>, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.</li>
            </ul>
            <p><b>Cookies and similar technologies.</b> Some of our automatic data collection is facilitated by cookies and similar technologies.  </p>
            <p><b>Managing Your Personal Information.</b> You have the ultimate control over the Personal Information that we collect and use. You can always chose not to provide certain Personal Information, but please keep in mind that you may not be able to use some of the features offered by our Sites and App. </p>
            <h5>HOW WE USE YOUR PERSONAL INFORMATION</h5>
            <p>We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:</p>
            <p><b>Service delivery.</b>We may use your personal information to:</p>
            <ul>
                <li>provide, operate and improve the Service, such as to enable you to make purchases of our premium services etc;</li>
                <li>establish and maintain your account on the Service;</li>
                <li>communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;</li>
                <li>provide customer support and maintenance for the Service.</li>
            </ul>
            <h5>OTHER USES</h5>
            <p><b>Direct Marketing.</b> We may use your personal information to send you Pinipol - related marketing communications as permitted by law.  You will have the ability to opt-out of our marketing and promotional communications as described in the Your Choices section below.</p>
            <p><b>For research and development.</b> We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. </p>
            <p><b>To create anonymous data.</b> We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you.  We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.</p>
            <p><b>To comply with laws and regulations.</b> We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. </p>
            <p><b>For compliance, fraud prevention and safety.</b> We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.</p>
            <p><b>With your consent.</b> In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. </p>
            <p><b>Anonymized data.</b> We may keep anonymized data on a permanent basis even after the termination of user account to provide our services.</p>
            <h5>Cookies</h5>
            <p>A cookie is a small text file which is placed onto your computer or mobile (or other electronic) device when you access the Website/App. We use cookies and other online tracking devices to:</p>
                <ul>
                    <li>recognize you whenever you visit the Website/App;</li>
                    <li>obtain information about your preferences, online movements and use of the internet;</li>
                    <li>carry out research and statistical analysis to help improve the content, products and services and to help us better understand our visitor and customer requirements and interests;</li>
                    <li>target our marketing and advertising campaigns more effectively by providing interest-based advertisements that are personalized to your interests; and</li>
                    <li>make your online experience more efficient and enjoyable.</li>
                </ul>
            <p>The information we obtain from the use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you—but only where you voluntarily provide it (e.g. by completing an online form) or when your purchase or services from us.</p>
            <h5>Third party cookies</h5>
            <p>Third-party suppliers are responsible for the cookies they set on our Website/App. </p>
            <p>We may use Google Analytics or any other Analytic portal on our website/App. This is a tracking cookie which enables us to track how popular our site/App is and to record visitor trends over time. The cookie does not contain any personal data but it does use your computer’s IP address to determine where in the world you are accessing the website/App from, and to track your page visit within the site/App</p>
            <h5>How to turn off cookies</h5>
            <p>If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may be unable to purchase items from us. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org</p>
            <h5>Security</h5>
            <p>We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site/App. The security on the internet is not 100% guaranteed, however we use best efforts to keep it secure for the users. We do not accept liability for unintentional disclosure. We encourage you to use caution when using the Internet.</p>
            <h5>CCPA  - FOR UNITED STATES</h5>
            <p><b>Section effective as of: January 1, 2020</b></p>
            <p>We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their Personal Information, and of the rights and choices, we offer to California residents concerning that Personal Information. </p>
            <p><b>Personal information that we collect, use, and share. </b> We do not sell personal information.  As we explain in this Privacy Policy, we use cookies and other tracking tools to analyze website/App traffic and facilitate advertising.  </p>
            <p><b>Your California privacy rights.</b> The CCPA grants California residents the following rights.  However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.</p>
            <ul>
                <li>
                	<b>Information.</b> You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.
                    <ul>
                        <li>The categories of Personal Information that we have collected.</li>
                        <li>The categories of sources from which we collected Personal Information.</li>
                        <li>The business or commercial purpose for collecting and/or selling Personal Information.</li>
                        <li>The categories of third parties with whom we share Personal Information.</li>
                        <li>Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.</li>
                        <li>Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.</li>
                    </ul>
                </li>
                <li><b>Access.</b> You can request a copy of the Personal Information that we have collected about you during the past 12 months.</li>
                <li><b>Deletion.</b> You can ask us to delete the Personal Information that we have collected from you.</li>

            </ul>
            <p>You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.</p>
            <p><b>How to exercise your California rights.</b> You may exercise your California privacy rights described above as follows:</p>
            <ul>
                <li><b>Right to information, access and deletion.</b> You can request to exercise your information, access and deletion rights, by emailing support@pinipol.app. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights.  As part of this process, government identification may be required.  Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.</li>
                <li><b>Request a list of third party marketers.</b> California's “Shine the Light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide certain information about the companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year (if any).  You can submit such a request by sending an email to support@pinipol.app with “Shine the Light” in the subject line.  The request must include your current name, street address, city, state, and zip code and attest to the fact that you are a California resident.</li>
            </ul>
            <p>We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.</p>
            <h5>FOR EUROPEAN RESIDENTS - GDPR</h5>
            <p>We may disclose your Personal Data in the good faith belief that such action is necessary to:</p>
            <ul>
                <li>
                	To comply with a legal obligation
                </li>
                <li>
                	To protect and defend the rights or property of Pinipol
                </li>
                <li>
                	To prevent or investigate possible wrongdoing in connection with the Service
                </li>
                <li>
                	To protect the personal safety of users of the Service or the public
                </li>
                <li>
                	To protect against legal liability
                </li>
            </ul>
            <p><b>Security of Data</b></p>
            <p>The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.</p>
            <p><b>Data Protection Rights under the General Data Protection Regulation (GDPR)</b></p>
            <p>If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Pinipol aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.</p>
            <p>If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.</p>
            <p>In certain circumstances, you have the following data protection rights:</p>
            <ul>
                <li>
                	The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
                </li>
                <li>The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.</li>
                <li>The right to object. You have the right to object to our processing of your Personal Data. The right of restriction. You have the right to request that we restrict the processing of your personal information.</li>
                <li>The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.</li>
                <li>The right to withdraw consent. You also have the right to withdraw your consent at any time where Pinipol relied on your consent to process your personal information.
                </li>
            </ul>
            <p>Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).</p>
            <h5>Sharing your personal information</h5>
            <p>We do not sell, trade, or rent Users personal identification information to others in accordance with the CCPA. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above</p>
            <h5>Children - COPPA</h5>
            <p>Pinipol is not intended for use by children under 13 years of age, and we do not knowingly collect information about children under age 13 through the Service.  If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian as required by law, we will delete it. We aim to comply with the COPPA.</p>
            <h5>Data Retention</h5>
            <p>We will retain your information for as long as needed to provide you the Site/App services, for our valid business purposes, and as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements.</p>
            <h5>Changes</h5>
            <p>
                Pinipol has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.
            </p>
            <h5>Acceptance</h5>
            <p>
                By using this Site/App, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site/App. Your continued use of the Site/App following the posting of changes to this policy will be deemed your acceptance of those changes.
            </p>
            <h5>Contacting us</h5>
            <p>
            If you have any questions about this Privacy Policy, the practices of this site/App, or your dealings with this site/App, please contact us at:
            </p>
            <h5>Spinnovations Ltd</h5>
            <p>Email: support@pinipol.ap</p>
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