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Privacy Policy

Last Modified: November 17, 2022

Pinseeker, Inc. (“Pinseeker”) values the privacy of users of its web and mobile applications (“Pinseeker Apps”), as well as visitors to the websites operated by Pinseeker. This privacy policy summarizes what information we might collect from you and what we will and will not do with it. Your use of the Pinseeker Apps or any of our websites, services or mobile applications will signify your assent to this Privacy Policy.

What we do with your personally identifiable information

“Personally Identifiable Information” means information that can be used to identify you as an individual, such as, for example:

  • your name, company, email address, phone number, billing address, and shipping address
  • your date of birth
  • your social security or tax identification number
  • your user ID and password (if applicable) for use of the Pinseeker Apps
  • any account-preference information you provide us
  • your computer’s domain name and IP address, indicating
  • where your computer is located on the Internet
  • the device identifier and the IP address assigned to any mobile device used to access our services;
  • the location of any mobile device used to access our services; 
  • session data for your login session, so that our Services can ‘talk’ to your computer or mobile device while you are logged in.

If you do provide Personally Identifiable Information to us, we will:

  • take commercially reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction;
  • not use or disclose the information except:
    • as necessary to permit you to make use of the Pinseeker Apps;
    • to confirm the location from which the Pinseeker Apps are being accessed using your mobile device;
    • to confirm that you meet the applicable criteria with respect to participation in any competition or the award of a prize in connection with a competition;
    • to communicate with you by email or through the Pinseeker Apps concerning the Pinseeker Apps and your account;
    • to communicate with you by email or through the Pinseeker Apps about products and services offered by Pinseeker and Pinseeker’s marketing partners;
    • to display or to facilitate the display of advertisements to you, through the Pinseeker Apps and other websites (provided that the Personal Information used for such purpose will not include your name, company, email address, phone number, billing address, and shipping address, date of birth, social security number, user ID, password or account-preference information);
    • to establish and to administer your account with our eWallet and payments processing platform (including, without limitation, Dwolla, Inc.);
    • to process any payments by you or to you with respect to your participation in any competition;
    • in other ways permitted in this privacy policy or to which you have otherwise consented; 
    • in the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);
    • as required by law, for example, in response to a subpoena or search warrant;
    • to outside auditors who have agreed to keep the information confidential;
    • to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or disposition of all or a portion of Pinseeker’s assets. The successor organization’s use and disclosure of your personally-identifiable information will continue to be subject to this privacy policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your personally-identifiable information will be subject to the successor organization’s own privacy policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use the Pinseeker website.) If you submit personally-identifiable information after such a transfer, that information may be subject to the successor entity’s privacy policy;
    • as necessary to protect the rights, safety, or property of Pinseeker, Pinseeker’s users, or others; this may include (for example) exchanging information with other organizations for fraud protection and/or risk reduction.

What Data We Collect

We collect Personally Identifiable Information.

In addition, we may collect other information that might not be readily used to identify you, such as (for example) the domain name and IP address of your computer and the device identifier and the IP address assigned to any mobile device used to access our services. We may use this information, individually or in the aggregate, for technical administration of our Web site(s) and services, research and development, and customer and account administration.

How Do We Collect Your Data

You directly provide us with most of the data that we collect. We collect and process data when you create an account on our Apps, purchase from our websites, fill out forms in our Apps or websites, fill out customer surveys, allow the use of browser cookies on our websites, and when you connect your bank account through our Apps.

We may also receive your data directly from software and hardware partners running the PinSeeker App.

Cookies and Third Party Technologies

We may use “cookies” and other tracking technologies to detect whether you’re properly logged in to the Pinseeker Apps or our website, to provide functionality and services tailored to individual user preferences, to monitor the performance of the Pinseeker Apps or our website and to conduct advertising and marketing related activities through and in connection with the Pinseeker Apps,our website or third-party websites. If you set up your web browser so that cookies are not allowed (such as by activating the “Do Not Track” function), you might not be able to use some or all of the features of our website.

We use certain third-party technologies in connection with the Pinseeker Apps or our website and the marketing activities we conduct in connection with the Pinseeker Apps or our website, including the following third-party technologies:

  • Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
  • Firebase: Firebase is an analytics service provided by Google. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en. We also encourage you to review Google’s policy for safeguarding your data:  https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
  • Google AdSense & DoubleClick: Google, as a third party vendor, uses cookies to serve ads within our Services. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Services or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
  • AdMob: AdMob is provided by Google. You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en. For more information on how Google uses the collected information, please visit the “How Google uses data when you use our partners’ sites or app” page: http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of Google: http://www.google.com/policies/privacy/
  • Google Ads (AdWords): Google Ads (AdWords) remarketing service is provided by Google. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
  • Twitter: Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405. You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
  • Facebook/Instagram: Facebook remarketing service and Instagram are both provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

We may store your data on servers provided by third-party hosting service providers with whom we have contracted. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations.

If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop us from contact you for marketing purposes or from giving your data to third party providers which may limit or reduce the quality of your experience.

We provide paid products and/or services within the Pinseeker Apps or our website. We use third-party services for eWallet, payment processing and identity verification purposes. Without limiting the foregoing, prize money awarded in connection with the competitions conducted in connection with the Pinseeker Apps is provided to prize-winners using the Dwolla eWallet solution (for U.S. payments) and by EFT transfers (for payments outside the U.S.). We will not store or collect your bank account or payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their respective privacy policies. With respect to credit card payments, payment processors are required to adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. Payment and related services used in connection with the Pinseeker Apps and the competitions available through the Pinseeker Apps include the following:

  • Plaid: The payment processor we currently use in connection with the Pinseeker Apps is Plaid. More information concerning the privacy practices of Plaid can be viewed at https://plaid.com/legal/#consumers. 
  • Dwolla: The eWallet solution we currently use in connection with the Pinseeker Apps is Dwolla. More information concerning the privacy practices of Dwolla can be viewed at https://www.dwolla.com/legal/privacy/#legal-content.
  • Persona: We use the services of Persona for the purposes of verifying the identity of participants in our competitions. More information concerning the privacy practices of Persona can be viewed at https://withpersona.com/legal/privacy-policy
  • Shopify: We use Shopify to facilitate the distribution of coupons for the purpose of obtaining Pinseeker merchandise in connection with certain competitions conducted in connection with Pinseeker Apps. More information concerning the privacy practices of Shopify can be viewed at https://www.shopify.com/legal/privacy/customers

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

How We Use Your Data

We collect your data so that we can process your entries into tournaments, process your orders on our websites, process tournament winnings and payouts, manage your account, and send you special offers, account information, and marketing communications including via email, text message, and/or push notifications. In order to comply with Anti-Money Laundering regulations and other laws and regulations, we may send your data to third-parties to verify your identity or for credit reference purposes.

Service Providers

We may grant access to your personal data to trusted third parties who assist us in operating the Pinseeker Apps and our website(s) and services and conducting our business, so long as those parties agree to keep this information confidential. This may include service providers that provide IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment, legal and financial services, to the extent such sharing of data is necessary for customer support, marketing, technical operations and account management purposes.

How We Store Your Data

We securely store your data at Heroku. In order to protect your data, we encrypt all your data at rest with industry standard AES-256, block-level storage encryption. Heroku’s physical infrastructure is hosted and managed within Amazon’s secure data centers and utilize the Amazon Web Service (AWS) technology. Amazon continually manages risk and undergoes recurring assessments to ensure compliance with industry standards. Third party security testing of the Heroku application is performed by independent and reputable security consulting firms. Heroku utilizes ISO 27001 and FISMA certified data centers managed by Amazon. Amazon has many years of experience in designing, constructing, and operating large-scale data centers. Firewalls are utilized to restrict access to systems from external networks and between systems internally. By default, all access is denied and only explicitly allowed ports and protocols are allowed based on business need. Managed firewalls prevent IP, MAC, and ARP spoofing on the network and between virtual hosts to ensure spoofing is not possible. Each application on the Heroku platform runs within its own isolated environment and cannot interact with other applications or areas of the system. You can find more details about Heroku’s security policy at https://www.heroku.com/policy/security.
We keep and store your data for one year after you have closed your account; except that, we keep payment and payout records, which include your tax identification number, as applicable law requires which may be indefinitely.

Your Privacy Rights

Every user is entitled to (a) the right to request copies of your personal data for which we may charge a fee, (b) the right to request that we correct or complete any information you believe is inaccurate, (c) the right to request that we delete your personal data under certain conditions, (d) the right to restrict the processing of your personal data under certain conditions, (e) the right to object to our processing of your personal data under certain conditions, and (f) the right to request that we transfer the data we have collected to another organization or directly to you under certain conditions. If you make a request, we will respond to you within one month. You may exercise any of these rights by submitting a request via email to [email protected].

Your privacy responsibilities

To help protect your privacy, be sure:

  • not to share your user ID or password with anyone else;
  • to log off our website(s) and services when you are finished;
  • to take customary precautions to guard against “malware” (viruses, Trojan horses, bots, etc.), for example by installing and updating suitable anti-virus software; and
  • to follow the instructions set forth in the Choices section of this policy to communicate your preferences with respect to how certain personal information is handled.

Transferring personal data from the EU to the US

Pinseeker has its headquarters in the United States. Information we collect from you will be processed in the United States. The United States has not received an “adequacy” finding from the European Union under Article 45 of the GDPR. We limit the transfer of personal information from the EU to specific situations set forth in Article 49 of the GDPR. Specifically, we collect and transfer your personal data to the U.S. only with your consent, to perform a contract with you, or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms. By providing personal information to us, you are consenting to its transfer, storage and use in the U.S. as described herein. We apply suitable safeguards to protect the privacy and security of personal data and to use it only as described in this privacy policy. 

California Consumer Privacy Act Notice

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may apply to the collection and use of your personal information. The CCPA defines “personal information” as information that identifies, relates to, or could reasonably be linked with a specific individual or household. This Privacy Policy describes the categories of personal information we’ve collected, and our use and disclosure of such personal information, over the last twelve (12) months. We do not sell personal information. 

Under the CCPA you may request the following information about our collection, use and disclosure of your personal information during the 12-month period preceding the request: 

  • the categories of personal information collected
  • the categories of sources from which we obtained your personal information
  • the business purpose for our collection of your personal information
  • the categories of the third parties with whom we have shared your personal information
  • the specific pieces of personal information about you we collected

The CCPA also allows you to request that we delete personal information we collected from you.

California residents can exercise their rights by sending a request by email to [email protected] or by writing to us at 908 S 8th Street, 3rd Floor, Louisville, KY 40203. We will need to verify your identity and place of residence before fulfilling your request. You will not be denied goods or services for exercising any of these rights. Even if you are not a resident of California, you may submit a request and we will process it in the manner described in this policy, even though the CCPA does not require us to do so.

We will endeavor to process requests within one month. We will contact you if we need additional information respecting your request. It might take us longer than a month to process some requests, depending upon the complexity and number of requests we receive.

Information collected from children

You must be at least 13 years old to use Pinseeker’s website(s) and service(s). Pinseeker does not knowingly collect information from children under 13. (See the U.S. Children’s Online Privacy Protection Act.)

Privacy Policies of Other Websites and Apps

Our websites, apps, and marketing communications will from time to time contain links to other websites and apps. This Privacy Policy applies only to PinSeeker; so, if you click on a link to another website or app, you should read their privacy policy.

Changes to this Privacy Policy

We reserve the right to change this privacy policy as we deem necessary or appropriate because of legal compliance requirements or changes in our business practices. If you have provided us with an email address, we will endeavor to notify you, by email to that address, of any material change to how we will use personally identifiable information.

Choices

To access or edit or delete your personal information, if any, in our possession, please visit your account profile in the PinSeeker Game app. To delete your profile or personal information, contact us at [email protected].

You may opt out of receiving any, or all, email communications from us by following the unsubscribe link or instructions provided in any marketing email we send. Unsubscribing from marketing emails will not unsubscribe you from transactional emails such as purchase confirmations or shipping notifications should we send such transactional emails.

Questions or comments?

If you have questions or comments about our privacy policy, send an email to [email protected].

How to Contact The Appropriate Authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact:

  • United States: The Federal Trade Commission, 600 Pennsylvania Avenue, NW, Washington, DC 20580. (202) 326-2222
  • UK: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, UK, 0303 123 1113
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