Pinkaloo Technologies Privacy Policy

Instituted: May 30, 2019

Deprecated: March 12, 2020

OUR APPROACH TO PRIVACY

Pinkaloo Technologies, LLC (“Pinkaloo”) knows that you care about how your personal information is used and shared. Pinkaloo respects your privacy and is committed to protecting it through this privacy policy. To make this privacy policy easy to find, we make it available on the Pinkaloo website at pinkaloo.com and through our mobile applications (collectively, the “Website”). You may also email us at privacy@pinkaloo.com with any privacy-related questions you have.

Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using the Website you agree to this privacy policy, which may change from time to time. We will notify you of any material change. Your continued use of the Website after we make changes and notify you is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1.     APPLICABILITY OF PRIVACY POLICY

This privacy policy applies to all information we collect from you. When you are no longer our customer, we may continue to use your information as described in this policy.

This privacy policy doesn’t cover third-party websites accessed via our Website.Pinkaloo does not control the information collection of third-party websites that can be reached through links from the Website. We encourage our users to be aware when they are leaving the Website.Such third-party websites are governed by the terms applicable to your relationship with that third party, and Pinkaloo accepts no responsibility or liability in respect of third-party websites or apps.

2.     THE INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.

Information you give to us. We collect personal information about you when you voluntarily submit information directly to us by filling in forms on our Website, allow third-parties such as financial institutions or your employer to share your personal information with us, and by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the Website, participate in any social media functions on our Website, when you report a problem with our Website, or use some other feature of the Website as available from time to time.

You can log in to our site using a Single Sign-On service, such as that from Facebook, Google, your employer, a financial institution or another entity of which you are affiliated. These services will authenticate your identity and share certain personal information with us such as your name, email address, payment methods or bank account information, and other information you have authorized. We collect this information to give you access to the Website and to personalize our service.

If you choose not to provide personal information, we may not be able to provide the Website to you or respond to your other requests.

Information we receive from other sources. We may receive personal information about you from individuals or corporate entities which are subscribers to the Website (“Subscribers“) and who designate you as a user.

We also work closely with third parties (including, for example, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.

Table 1 sets out the categories of personal information you provide to us and that we receive from other sources, and how we use that information. The table also lists the legal basis which we rely on to process the personal information and information as to how we determine applicable retention periods.

Information we automatically collect. We also automatically collect personal information about you indirectly about how you access and use the Website and information about the device you use to access the Website.

Table 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and information as to how we determine applicable retention periods.

We may link or combine the personal information we collect and/or receive about you and the information we collect automatically. We may also anonymize and aggregate any of the personal information we collect so that it does not identify you and share it with third-parties. We use such anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Website and developing new products and features.

3.     DISCLOSURE OF YOUR PERSONAL INFORMATION

We may share your personal information within Pinkaloo and with the Subscriber who has designated you as a user of the Website. The Subscriber could use such information in connection with their business, including to contact you. The Subscriber’s potential use of your personal information is governed by the terms of the relationship between you and the Subscriber.

We will not share your personal information with any third parties except as described in this privacy policy or in connection with the Website. We may share your information with selected third parties, including:

  • With your consent to share personal information, such as when you choose to share your personal information when donating to a charity;

  • Payment processors for the purpose of fulfilling relevant payment transactions, including those distributing charitable donations on your behalf;

  • Analytics and search engine providers that assist us in the improvement and optimization of our Website;

  • In connection with products and services offered by Pinkaloo’s business partners and/or companies who perform services on our behalf;

  • Third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

  • In response to lawful requests by public authorities, including to meet law enforcement requirements. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of Pinkaloo, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 4.     STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

All information you provide to us is stored on secure servers in a controlled environment with limited access. Any payment transactions will be encrypted in transit using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. You should not share your password with anyone. If you do disclose your password or other login credentials to a third party or allow a third party to use your device’s authentication feature, you are authorizing that party to use the Services.  You agree that we may rely on the authority of anyone who provides your login credentials or uses your device’s authentication feature to access the Services (an “Authorized User”).  We will not be liable for and will not reimburse you for any losses that may occur as a result of the use of your login credentials or your device’s authentication feature by such Authorized Users.  You agree to tell us immediately if someone you did not authorize learns your password or other login credentials or is able to use your device’s authentication feature.

While no transmission of information via the internet is completely secure, we take reasonable measures to protect your personal information. We cannot guarantee the security of your personal information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Pinkaloo password with anyone.

International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the European Union (“EU“), your personal information will be processed outside of the EU including in the United States; these international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.

5.     RETAINING YOUR INFORMATION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

6.     HOW WE USE COOKIES

When you visit or use the Website we and certain business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”). We use Cookies to recognize you as a customer; customize the Website, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across our Website.

We use the following types of Cookies:

  • Strictly necessary Cookies. These Cookies are required for the essential operation of our Website such as to authenticate you and prevent fraudulent use.

  • Analytical/performance Cookies. These Cookies allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that you can find information easily.

  • Functionality Cookies. These Cookies are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting Cookies. These Cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use Cookies, over which we have no control.

You may block Cookies by activating the setting on your browser that allows you to refuse the setting of all or some Cookies. However, certain aspects and features of our website and services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of our website and services may be limited or not possible. Pinkaloo does not support the Do Not Track browser option.

Our Website includes social media features, such as Facebook Like button and widgets such as the Share button. These features may collect your IP 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 hosted on our site or by a third party, and your interactions with these features are governed by the privacy policy of the company providing such features.

7.     MARKETING AND ADVERTISING

From time to time we may contact you with relevant information about the Website and our other products and services. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.

If you do not want to receive such messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can also change your marketing preferences at any time by following the unsubscribe link at the bottom of our emails.

8.     CALIFORNIA PRIVACY RIGHTS

California residents have the right to request certain information regarding our disclosure of personal information (as defined by the California Shine the Light Act) to third parties for their direct marketing purposes unless we provide them with an ability to exercise choice regarding such disclosures. We comply with this law by providing California residents with the ability to opt-out of, or prospectively withdraw their consent, if they have previously opted-in to, the disclosure of personal information to third parties for their direct marketing purposes.  If you are a California resident, to receive confirmation of how we comply with this law, or to make a request or to opt out at any time, please contact us at privacy@pinkaloo.com or mail us at the address provided in the Notice section below.  Any request must include “California Privacy Rights Request” in the first line of the description and must include the requestor’s name, street address, city, state, and ZIP code. 

9.     MINORS AND CHILDREN

The Website is not intended for use by persons under the age of 18 years.  Pinkaloo does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register to use our Website.  In the event that we learn that we have collected personal information of a child under the age of 13, we will delete that data to the extent required by applicable law as quickly as possible. If you believe that we might have any personal information from or about a child under 13, please contact us at privacy@pinkaloo.com.

10.  CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof and shall apply to business terms only, which may be given by means including, but not limited to, issuing an email to the email address listed by registered users and/or by posting a notice and the revised Privacy Policy on the Website. You acknowledge that it is your responsibility to maintain a valid email address as a registered user, and to review the Website and this Privacy Policy periodically in order to be aware of any modifications. If you object to any changes to the revised Privacy Policy, you can stop using our services and close your account with us. However, if you continue to use the Website after we publish a new or updated privacy policy, you acknowledge that such continued use means that the treatment of your personal information will be subject to the new or updated Privacy Policy.

11.  HOW TO CONTACT US

Regardless of your location, any questions, comments and requests regarding this privacy policy are welcome and should be addressed to our Chief Operating Officer, Daniel Gardner, at privacy@pinkaloo.com. Communication can also be addressed to:

 

Pinkaloo Technologies, LLC

301 W 29th St. Suite 2003

Baltimore, MD 21211

TABLE 1 – PERSONAL INFORMATION WE COLLECT
Category of personal information How we use it Legal basis for the processing
Contact information and basic personal details. Such as your name, phone number, address, geo-location, IP address, e-mail address, professional details such as your employer and position, and any information provided to us by a Subscriber. We use this information to communicate with you, including sending statements, news, alerts and marketing communications. The processing is necessary for our legitimate interests, namely for marketing purposes, and for communicating with you effectively and responding to your queries.
We use this information to deal with inquiries and other requests made by or about you, including customer service issues, relating to the Website.
We use this information to operate, maintain and provide to you the features and functionality of the Website. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely our Terms of Service).
Correspondence and comments. When you contact us directly, e.g. by email, phone, mail, we may record your comments and opinions. To address your questions, issues and concerns and resolve your customer service issues. The processing is necessary for our legitimate interests, namely communicating with you effectively for the purposes of resolving your issues.
Payment information. Details such as your credit card or other financial information. We use this information to facilitate payment for use of the Website, distributing donations, and to detect and prevent fraud. The processing facilitating payment is necessary for the performance of our contract with you (namely our Terms of Service). The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.
All personal information set out above. We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Website, to monitor and improve the Website and our business, for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to keep the Website safe and secure, and to market products and services. The processing is necessary for our legitimate interest, namely to administer and improve the Website and our business develop new services, and undertake marketing activities to offer you products or services that may be of your interest.
TABLE 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY
Category of personal information How we use it Legal basis for the processing
Information about how you access and use the Website. For example, the website from which you came and the website to which you are going when you leave our Website, your social media profiles, how frequently you access the Website, the time you access the Website and how long you use it for, whether you open emails or click the links contained in emails, whether you access the Website from multiple devices, and other actions you take.

We also gather information, which may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. 		We use this information to:
  • conduct market analysis, monitor the Website and how it is used in order to improve our business and help us develop new products and services, and to market products and services; and
  • generate marketing leads and determine news, alerts and other products and services that may be of interest to you for marketing purposes.
 The processing is necessary for our legitimate interests, namely: to conduct relevant analysis to improve the Website generally and for marketing purposes.
Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Website through the device, your Internet service provider or mobile network, your IP address. We use this information to:
  • enable the Website to be presented to you on your device;
  • operate, maintain and provide to you the features and functionality of the Website; and
  • to monitor and improve the Website and business, to help us develop new products and services, and to market products and services.
 The processing is necessary for our legitimate interests, namely: to conduct relevant analysis to improve the Website generally and for marketing purposes.