The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Policy:
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.
You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share and store it in a manner consistent with this Privacy Policy.
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.
You can enable or disable access to this information at any time, through Your Device settings.
The Company may use Personal Data for the following purposes:
We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.
We may share Your personal information in the following situations:
We keep Personal Data only for as long as we need it for the purposes set out in this Privacy Policy, then delete it. Where we cannot give a single fixed period, the criteria we apply are: how long your account stays open, how long we need the data to provide and secure the Service, how long the law requires us to keep it, and how long we may need it to resolve a dispute or enforce our agreements.
The periods we can state are:
If you choose to delete your account, Your Personal Data, including pins and location history, will be permanently purged from our active systems. Please note that some data may persist in encrypted backups for a limited period until superseded, in accordance with our standard data disaster recovery procedures.
Pin Drop is operated from the United Kingdom by Salucia Ltd. Our application infrastructure and primary database are hosted in the United States, and some of the providers listed on our subprocessors page process data outside the UK and the European Economic Area.
Where we transfer Personal Data outside the UK or the EEA, we rely on one of the following safeguards:
We do not rely on your consent as the safeguard for these transfers. We keep a record of which mechanism applies to each provider and will share it on request. Write to legal@pindrop.it.
We take all steps reasonably necessary to ensure your data is treated securely and in accordance with this Privacy Policy, and no transfer takes place to an organisation or a country without adequate controls in place.
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
The security of Your Personal 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.
The tools described below help Us run and improve the Service. Most are operated by third parties, who collect, store, use, process and transfer information about Your activity in accordance with their own Privacy Policies. Where a tool is run by Us rather than by a third party, that is stated.
We use a single analytics tool and We run it Ourselves. No usage data is sent to a third-party analytics provider.
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
We may provide paid products and/or services within the service. In that case, we may use third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors 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.
We may use third-party Service Providers to provide better improvement of our Service.
Salucia Ltd is established in the United Kingdom, so our processing is governed principally by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Where we offer the Service to people in the European Economic Area, the EU General Data Protection Regulation (EU GDPR) also applies. References to "GDPR" in this Privacy Policy mean both, as they apply to you. Our supervisory authority is the UK Information Commissioner’s Office (ICO).
We may process Personal Data under the following conditions:
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/pindrop, the Company and the operator of the social network Facebook are Joint Controllers.
The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php.
Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.
We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.
For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy.
This section applies only to residents of the State of California and supplements the rest of this Privacy Policy. References to the CCPA mean the California Consumer Privacy Act as amended by the California Privacy Rights Act (CPRA). Nothing in this section limits or replaces the rights described elsewhere in this Privacy Policy, which apply wherever you live.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
Under CCPA, personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for monetary or other valuable consideration.
We do not sell your personal information, and we have not sold personal information in the preceding twelve (12) months. We do not sell, rent, or lease your personal location data, photos, pin history, or any other personal information to data brokers, advertisers, or any other third parties for their own commercial purposes.
We may share Your personal information identified in the above categories with the following categories of third parties:
We do not sell the personal information of any consumer, including minors. Our Service is intended only for users aged 18 and over.
The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:
Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
We cannot respond to Your request or provide You with the required information if We cannot:
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.
We do not sell Your personal information and never have. We do not share it for cross-context behavioural advertising, nor do We use it to serve You targeted advertising.
We do not run advertising on the Service. None of the Service Providers listed in this Policy is an advertising partner. There is therefore no interest-based advertising for You to opt out of.
You still have the right under the CCPA to direct Us not to sell Your personal information. If You would like that recorded against Your account, contact Us at legal@pindrop.it.
You can stop the collection of location information from Your mobile device at any time by changing the location permissions for the Application in Your device settings.
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Our Service is not directed to, or intended for use by, anyone under the age of 18, and we do not knowingly collect personal information from anyone under 18. By creating an account or using the Service, you confirm that you are at least 18 years old.
If you are a parent or guardian and believe that someone under 18 has provided us with personal information, please contact us at legal@pindrop.it and we will take reasonable steps to delete that information from our systems.
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
If you are in Canada, our handling of your personal information is also subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where it applies, provincial privacy legislation. You have the right to access the personal information we hold about you, to ask us to correct it, and to withdraw consent where our processing relies on it. To exercise any of these rights, contact legal@pindrop.it. If you are not satisfied with our response you may complain to the Office of the Privacy Commissioner of Canada.
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
We will not share or sell your mobile information with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors who support our service, such as our messaging provider, is permitted so that we can deliver the messages you have asked for. Text messaging originator opt-in data and consent are not shared with any third party.
If you give us your mobile number in the app or on a call, we use it only to send you what you asked for, such as an app download link, a sign-in link or a link to book a call. Message frequency varies and depends on what you request. Reply STOP to any message to stop receiving them. Reply HELP for help, or email legal@pindrop.it.
An assistant answers our phone. When you call Pin Drop, your call is answered by an automated assistant rather than a person. We tell you this at the start of every call. You can ask to speak to someone at any point and we will arrange a call back.
We record calls. Calls are recorded and transcribed so that we have an accurate record of what you asked for, so the right person can follow it up and so we can improve how the line works. Before the conversation begins We tell you that the call is recorded and why. If you would rather not be recorded, email us at legal@pindrop.it instead.
What we collect on a call. Your name, your company, the email address or phone number you give us, what you were calling about and the recording and transcript of the call itself.
Why we are allowed to do this. We rely on our legitimate interest in running a support service, keeping accurate records of customer requests and improving the service. Where a call concerns a contract with us, we also rely on the performance of that contract.
How long we keep it. Recordings and transcripts are kept for 12 months and then deleted. Notes taken from a call may be kept longer as part of your customer record.
Who can see it. The Pin Drop team and the providers who run our telephone and assistant systems. These are listed on our subprocessor page. We do not sell call recordings or transcripts and we do not use them for marketing.
Your rights. You can ask for a copy of a recording, ask us to delete it or object to being recorded by emailing legal@pindrop.it.
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Salucia Ltd (“the Company”) is the Data Controller for the personal information collected through Pin Drop. Our registered address is 35 Ballards Lane, London, N3 1XW, United Kingdom. We are registered with the UK Information Commissioner’s Office (ICO) under registration number ZC033245.
If you have a concern about how we handle your personal data, contact us first at legal@pindrop.it. We respond to data protection requests within one month, as required by Article 12(3) of the UK GDPR. You also have the right to complain to the ICO at ico.org.uk, or to the supervisory authority where you live if you are in the EEA.
If you have any questions about this document, you can contact us:
You can also write to us at Salucia Ltd, 35 Ballards Lane, London, N3 1XW, United Kingdom.
Need a data processing agreement (DPA)? We have one ready to send. Email legal@pindrop.it and we will get it over to you. Every company that processes your data, what each one receives and where it is processed, is listed on our trust pages: pindrop.it/trust
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