Effective: April 20th, 2022
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Pin Corporation is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Pin Corporation may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Trusted Partners are third party companies that may partnered with Pin Corporation.
Privacy of Children
Protecting the privacy of children is especially important. For that reason, Pin Corporation does not knowingly collect any Personal Information from anyone under the age of 13. In no other way do we knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of our Website is directed to persons under 13. If Pin Corporation learns that Personal Information of persons under 13 years of age has been collected through its Website or a Mobile Product, then Pin Corporation will take the appropriate steps to delete this information.
Information Collection and Use
Pin Corporation collects data from our websites and applications as follows:
Pin Corporation collects information under the direction of the Publishers and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Publishers and would no longer like to be contacted by one of our Publishers that use our service, please contact the Publishers that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Publishers.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Pin Corporation Publisher (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of the Publishers for up to ten years to provide services to the Publishers. Pin Corporation will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Disclosure and Sharing of Information
General Data Protection Regulation (GDPR)
As of May 25, 2018, the EU General Data Protection Regulation (GDPR) went into effect through the EEA countries and Switzerland. The GDPR requires that companies provide users with certain information about the processing of their "Personal Data" "Personal Data" is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or natural "persona" for instance, names, addresses, cookie identifiers, mobile device identifiers, precise location data and biometric data.
To comply with GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so please do not rely on the below, if you’re not):
a. Legal grounds for processing your Personal DataGDPR requires us to tell you about the legal basis we’re relying on to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out in the section entitled Information Collection and Use will typically be because:
b. Transfers of Personal Data
When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. In general, our data transfers of our Personal Data are safeguarded by mechanisms such as Privacy Shield, European Standard Contractual Clauses, and Data Processing Agreements where this is required by European Data Protection Law. Feel free to contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
As Pin Corporation may work with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside the EEA or Switzerland, and which have no data protection laws or laws that are less strict compared with those in Europe.
c. Personal Data Retention
As a general matter, we may retain your Personal Data for up to ten years to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. Please note that we may retain this (and other) Information whenever and so long as we have a significant legal or operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.
If you are a customer of ours and thus have an account with us, we may typically retain your Personal Data for up to ten years in order to serve the purpose for which it was collected, such as to provide you relevant information about our products and services.
d. Your Rights as a Data Subject
The GDPR provides you with certain rights in respect of Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).
e. Pin Corporation as a data controller and a data processor
EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process Personal Data on behalf of other organizations (known as "data processors"). As noted above, we are not always a data controller of the data in our possession but are sometimes a data processor for other companies such as our customers. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.
Pin Corporation does not disclose customers’ personal information to third parties for the third parties direct marketing purposes, as governed by California Civil Code 1798.83.
Access and Choice
Upon request Pin Corporation will provide you with information about whether we hold or process on behalf of a third party, any of your personal information. To request this information please contact us at email@example.com.
If you wish to request access, or deletion of your personal information please contact us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe.
If you provide Personal Information to us through our website, such as signing-up for our newsletter, you may request that we delete such Personal Information from our system, by sending a request to email@example.com, or by choosing the limit ad tracking setting on your device’s privacy settings page. We will promptly cease use of any such Personal Information and will remove such Personal Information from our servers in accordance with our standard practices. Certain other components of your Data relating to your use of the Website or Mobile Products, such as Mobile Advertising Identifiers, may be retained for up to ten years in order to serve the purpose for which it was collected.
Reset an Advertising Identifier
Resetting an advertising identifier is very easy on both iOS and Android (step-by-step guide below):
Social Media Sites, Links to Other Sites
We may have pages, accounts or presence on various social networking and media sites or services, such as Facebook and Twitter. Social media buttons or interactive mini programs that run on our website may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Any information you post or provide through such social media sites and services will be subject to the policies of the applicable site or service.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.