PinsXP (“PinsXP”, “we”, “us”, or “our”) respects your privacy and is committed to handling personal information responsibly.
This Privacy Policy explains how we collect, use, disclose, store and otherwise process personal information when you use the PinsXP mobile application, and any related services, together with the “Services”. It applies to personal accounts, community accounts and business accounts.
This Privacy Policy is available on our website and within the PinsXP app. If you do not agree with this Privacy Policy, please do not use the Services.
This Privacy Policy should be read together with our User Agreement, Community Guidelines, Child Safety Statement and any other policies or terms that apply to particular features of the Services.
PinsXP is the provider of the Services and, in most cases, the organisation responsible for deciding how and why your personal information is processed.
For most processing described in this Privacy Policy, PinsXP acts as the controller of your personal information.
In limited circumstances, such as where we process certain data solely on behalf of a business customer under a separate agreement, we may act as a processor or service provider for that specific activity.
PinsXP is based in 13730 W 85th Dr, Ste 201, Arvada, CO 80005-5960, United States.
For privacy questions, requests or complaints, you can contact us at: compliance@pinsxp.com. For general support, you can contact: support@pinsxp.com
PinsXP has not appointed a formal Data Protection Officer at this stage. We have designated a privacy contacts responsible for coordinating privacy compliance and responding to privacy-related requests.
Where PinsXP is required to appoint an EU representative, UK representative or other privacy representative, we will include their contact details in this Privacy Policy.
This Privacy Policy applies to the use of the Services by:
PinsXP is not intended for children or teenagers under 18. We do not knowingly allow users under 18 to create accounts or use the Services. If we become aware that someone under 18 has created an account, we may suspend or close the account and delete associated personal information, subject to any legal, safety, security or enforcement obligations.
We only collect, use, disclose, store or otherwise process personal information where we have a valid legal basis to do so.
Depending on the circumstances, we may process your personal information where: it is necessary to provide and operate the Services you request;
Where we rely on consent, you can withdraw your consent at any time through your device settings, in-app settings or by contacting us (compliance@pinsxp.com). Withdrawal of consent does not affect processing that occurred before consent was withdrawn.
Where we rely on legitimate interests, we only do so where we consider that those interests are not overridden by your rights, freedoms or interests.
We collect information directly from you, automatically when you use the Services and, in some cases, from third parties.
Depending on how you use PinsXP, this may include:
If you create or manage a business account, we may also collect:
When you use the Services, we may automatically collect:
PinsXP may use location information to support features such as local recommendations, and place-based posting.
We only collect precise location information if you grant permission through your device settings or in-app settings. Precise location is optional. You can use PinsXP without enabling precise location, although some location-based features may be limited or unavailable.
We may collect:
You can change location permissions at any time through your device settings and, where available, in-app settings.
We may receive information from:
Where we receive personal information from third parties, we use it only for the purposes described in this Privacy Policy.
PinsXP is not designed for users to provide sensitive information, such as health information, political opinions, religious beliefs, sexual orientation, biometric information or similar categories of information.
However, you may choose to include information in your profile, posts, images, videos, comments, reviews or other content that reveals sensitive information about you or others.
Please do not share sensitive information unless you are comfortable doing so and have the right to share it.
Where required by law, we will only process sensitive information with your explicit consent or another lawful basis.
We use personal information for the following purposes.
We use information to:
We use information to:
We use information to:
Where required by law, we will ask for consent before using non-essential analytics, tracking or similar technologies.
We use information to:
We may use information to:
We may use cookies, software development kits, local storage, device identifiers and similar technologies to operate, secure, analyse and improve the Services.
These technologies may support:
Where required by applicable law, we will ask for your consent before using non-essential analytics, personalisation or tracking technologies.
You may be able to manage certain choices through in-app settings, consent tools, device settings, browser settings or advertising ID controls.
PinsXP does not currently provide personalised recommendations based on behavioural profiling.
PinsXP may use limited information, such as your location settings, selected location, saved places or basic app activity, to support local discovery, search, maps and other user-requested features.
If we introduce personalised recommendations, behavioural profiling or personalised promotional features in the future, we will update this Privacy Policy and provide any required notice, consent or user controls.
We do not use automated decision-making that produces legal or similarly significant effects about you without human involvement, unless we tell you and have a lawful basis to do so.
PinsXP allows users to create, upload and share content. This may include text, images, reviews, comments, business materials and other content.
If you choose to post or share content publicly or with others, that content may be visible to other users and may remain visible if it has been saved, reshared, screenshotted or otherwise reproduced by others.
You are responsible for ensuring that you have the rights and permissions needed for any content you upload or share through the Services.
We may review, remove, restrict or investigate content where necessary to enforce our policies, respond to complaints, address intellectual property concerns or comply with legal obligations.
We may disclose personal information in the following circumstances.
We may share information with vendors and service providers that help us operate the Services, including providers of hosting, infrastructure, mapping, messaging, customer support, security, diagnostics, moderation, and verification.
These providers are authorised to process personal information only as necessary to provide services to us and subject to appropriate contractual restrictions.
We may share information with business partners or integrated services where necessary to deliver a feature you request, verify engagement, operate a business account feature or support the Services.
Where possible, reporting to business accounts is provided on an aggregated or de-identified basis.
We may disclose information where we believe it is reasonably necessary to:
We may disclose information in connection with an actual or proposed merger, acquisition, financing, restructuring, sale of assets or similar transaction, subject to appropriate safeguards.
You have rights in relation to your personal information. These rights may include the ability to:
You can exercise these rights by using available in-app settings or by contacting: compliance@pinsxp.com. We may need to verify your identity before responding to a request.
Some rights may be limited where we need to retain information for legal compliance, safety, fraud prevention, security, dispute resolution, platform integrity or enforcement of our Terms and policies.
If you are located in the European Union, you may also have the right to complain to your local data protection supervisory authority.
We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain safety and security, comply with legal obligations, resolve disputes, prevent fraud and enforce our agreements.
Retention periods may vary depending on the type of information and the reason it was collected. Examples include:
When you delete your account, we will delete or de-identify personal information associated with your account from active systems within a reasonable period, and from backups within a limited further period, unless retention is required for:
Some content, such as posts, comments, reviews, reports or content shared with others, may remain visible or be retained in a de-identified or limited form where necessary for service integrity, legal compliance or where other users have interacted with, saved, reshared, screenshotted or otherwise reproduced that content.
PinsXP is based in the United States and may process personal information in countries other than the country where you live, including where our service providers, hosting providers, support providers, analytics providers or other partners operate.
Your personal information may be transferred to countries that may not provide the same level of data protection as your home country.
Where required by applicable law, we use appropriate safeguards for international transfers, such as contractual protections.
You can contact us at compliance@pinsxp.com if you would like more information about the safeguards used for international transfers.
We use reasonable technical, organisational and administrative safeguards designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
These measures may include encryption in transit, access controls, monitoring and security review processes.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
If you believe your account or information has been compromised, please contact us at: compliance@pinsxp.com
If we become aware of a personal data breach or security incident affecting your personal information, we will assess the incident and take appropriate steps to contain it, investigate it and reduce potential harm.
Where required by applicable law, we will notify affected users, regulators or other relevant parties.
We may update this Privacy Policy from time to time.
If we make material changes, we will provide notice as required by law, such as by updating the effective date, posting a notice in the Services or sending a notification.
Your continued use of the Services after the updated Privacy Policy takes effect means you acknowledge the revised policy, to the extent permitted by law.
For privacy questions, rights requests, concerns or complaints, contact us at: compliance@pinsxp.com
For general support, including content reports, moderation concerns, account issues or technical support, contact us at: support@pinsxp.com or use our in-app reporting tools.
If you have a concern about how we collect, use, store or share your personal information, please contact us first so we can try to resolve it.
If you are located in the European Union, you have the right to lodge a complaint with your local data protection supervisory authority, including in the country where you live, work, or where you believe a data protection issue occurred. Relevant authorities may include the Garante in Italy, AEPD in Spain, CNIL in France, the competent federal or state supervisory authority in Germany, and the DPC in Ireland.
If you are located in the United Kingdom, you may lodge a complaint with the Information Commissioner’s Office (ICO).
If you are located in the United States, you may be able to contact the Federal Trade Commission (FTC), your state Attorney General, or another state privacy or consumer protection authority.
If you are located in another jurisdiction, you may also be able to contact another data protection authority or a specialist reporting body.
If you have concerns about content on PinsXP, a moderation decision, illegal content, account restrictions, advertising transparency, recommender systems, scams, fake profiles, fake reviews, business promotions or another platform safety issue, please contact us first through our in-app reporting tools or at support@pinsxp.com.
If you are located in the European Union and believe PinsXP has not complied with the Digital Services Act, you may lodge a complaint with the Digital Services Coordinator in the EU Member State where you are located or established. This may include AGCOM in Italy, CNMC in Spain, Arcom in France, BNetzA in Germany, or Coimisiún na Meán in Ireland.
If you are located in the United Kingdom, you may report certain online safety concerns to Ofcom. Ofcom does not usually decide individual complaints or order individual content removals, so you should normally report the issue to PinsXP first.
If you are located in another jurisdiction, you may also be able to contact another consumer protection authority, law enforcement, or a specialist reporting body.
PinsXP has appointed an EU representative who may be contacted about matters relating to our processing of personal information:
EU Representative: [insert name]
Address: [insert address]
Email: [insert email]