Effective: May 25, 2018.
Updated: January 9, 2020
Information we collect
Information provided by the user
Customer service through the web form or sending email, we collect the messages with the information provided by the user to track the problem and improve future assistance as well as the email address and the name that appear in the email. Subscription to the newsletter, we collect the name and email address.
Information we collect automatically
When the user uses Pinkfire applications with Internet connection, we collect aggregated user data, which does not allow us to personally identify you. We also use other technologies and external analytical providers that help us collect this information, as specified in the Cookies.
When the user accesses our website we can collect and analyze the following information on your device: browser, ip address, mobile device id, browser language, operating system or usage and error records.
When the user uses the mobile applications we automatically receive certain information about the mobile device and the use of the application including the identifier of the mobile device such as the IDFA on the Apple devices, the operating system, the version, the IP, installed apps and other similar data, such as the time spent in the different sections of the application and the error log to solve them in future updates.
When installing the mobile applications, the user is requested to consent to granting access to the geolocation data of the mobile device. By accepting such permission, we collect information about your geo-location and use that information to personalize ads and other location-based features. The user can withdraw their consent at any time, deactivate the GPS or other localization mechanisms as long as the device allows it.
Use of the Information
Pinkifire’s Apps uses the personal data it collects as described in the previous article for the purposes and with the legal basis described below:
- Share usage data. With the explicit consent of the user both on our website and in the Pinkfire applications. We use this data to analyze the use of our apps and to better understand the user’s interaction in the different areas of the web and the apps, and certain user information such as the connection speed depending on the type of network and geographical location.
- Personalized Ads. If the user gives us their consent, we share certain information with the suppliers with whom we work to show personalized advertising that may be of interest to the user.
- Customer Service. According to the data provided by the user at the time of contact to answer their questions, provide assistance. We will communicate with the user through the email used at the time of contact.
- Newsletter and updates notifications. Only with the prior consent of the user, we may occasionally send them information about products, services, special promotions, contests, events, customer satisfaction surveys and opportunities to interact with Pinkfire. The user can subscribe to receive these emails and social media campaigns on our newsletter registration page. The user has the option to withdraw their consent for these types of communications at any time.
The legal basis for such processing of personal data is, therefore, the user’s consent (Article 6  [a] of the GDPR). The user must take into account that they are not legally obliged to provide us with their personal data. However, without their personal data, we will not be able to send them our newsletters or show customized advertising content as described above.
Exchange and divulgation of the information
Pinkfire does not share, sell, pass or disclose in any other way the user’s personal data to third parties, unless required by law in accordance with the art. 6 (1) (c) of the GDPR, unless it is necessary for the purpose of the contract in accordance with the art. 6 (1) (b) of the GDPR, and unless the user has given us their express consent to do so according to the art. 6 (1) (a) of the GDPR. The exchange of the user’s personal data with external service providers will be carried out in accordance with applicable data protection laws and will be limited to the extent necessary. These third parties are expressly prohibited from using the user’s personal data for any purpose other than those described here. The companies with which we share the aforementioned data are:
Consent of ”Personalized Ads”
Currently the applications do not show ads and therefore does not ask for permission to ”Personalize Ads” to the user. This section is kept here in case this circumstance changes in the future.
Consent of ”Share Usage Data”
Monedata (DATA PAYMENTS OÜ, Majaka tn 26, Tallinn, 11412, Estonia, firstname.lastname@example.org)
This app uses third-party addons that collect varied data, which may include device identifiers, location, mobile network coverage and performance, installed apps list and usage stats.
With the user’s consent, this data will be collected and shared with those third-parties for analysis and measurement purposes. The user can change his mind at any time by changing the consent.
Tutela Technologies Ltd. (1124 Vancouver St, Victoria, BC V8V 3W2, Canada, email@example.com)
Tutela Technologies Ltd. collects data relating to your use of our apps, wireless networks, and your device, in a pseudonymized manner, that may include (a combination of) Personal Data and/or Personal Information elements, such as
- Wireless network performance, usage, and identifiers, and
- other permission-based user information.
Pseudonymous data is shared with wireless service providers and other third parties who use it to analyze and communicate consumer mobile trends, understand drivers of churn/acquisition, and improve your wireless networks. Tutela is a world leader in improving networks based on your perspective of performance: blog.
Outside of GDPR participating countries, mobile advertiser ID may be shared for network marketing and advertising purposes in accordance with the Digital Advertising Alliance principles. No data is stored by Tutela for longer than 18 months.
For further information about Tutela’s data practices, including technical and organisational measures to ensure that personal data are not attributed to an identifiable natural person, please see the Privacy Charter. You have the right to opt-out of data sharing with Tutela. To do so, please utilize the opt-out measures provided in the privacy statement, contact firstname.lastname@example.org, visit Do Not Sell My Info in accordance with the California Consumer Privacy Act, or contact us at email@example.com.
Huq Industries Limited (2nd Floor 58-64 City Rdt, London, EC1Y 2AL, UK, firstname.lastname@example.org)
To help us improve our service we collect the following information on an anonymous basis: Operating System, Date & time, Latitude, Longitude, Accuracy (GPS), SSID (network), BSSID (network), Internal MAC address (network), Bundle ID, Device Model, Device Manufacturer, Carrier Code (Android only), Carrier Name, Sim Code, Country, and Locale.
In addition to helping us to measure the usage of our app this anonymous information is shared with third parties for their business purposes, including the creation of reports, market research and trend analysis. One of these third parties is Huq, data shared does not contain information from which users can be identified and we will not provide additional information to such third parties that enables such third parties to identify you. You can find a full description of our data collection and use practices in our Privacy and Security Policy here.
You can find a full description of Huq and what it does with the information collected via our app here.
Google Ireland Limited (Gordon House Barrow Street, Dublin, Dublin 4, Ireland)
We use Google services to obtain analytical data to better understand the general behavior of our users. To capture analytical and statistical data about the use of the application, we use Firebase.
To share personal data for analysis you have to give your explicit consent at the start of the applications or modify it whenever you want from the menu of the app itself.
For more information visit https://firebase.google.com/support/privacy/
Other cases in which we can share data
We may be required to disclose user information to government officials and members of the security forces in response to a lawful request by a public authority or to comply with a legal obligation, including the requirements of law and order and law enforcement according to the art. 6 (1) (c) of the GDPR. We may also disclose user information in order to achieve our legitimate interests when applying or enforcing our terms and conditions or in response to claims, to protect our rights or the rights of third parties, to protect the safety of any person or prevent any illegal activity (including the purposes of protection against fraud and reduction of credit risk) in accordance with the art. 6 (1) (f) of the GDPR. If the user has any questions about the judicial weighing in relation to art. 6 (1) (f) of the GDPR, they must contact us through the contact information listed below.
The user is offered a series of options regarding the information we collect and use as indicated in this policy. Some of the options are:
- Marketing communications. If the user has given his consent through the web form to receive news, social network campaigns and promotional emails, they may opt to stop receiving them by following the instructions included in each message received or by writing an email to email@example.com.
- Renunciation of personalized online advertising. Through our applications for Android or iOS we include a system of voluntary acceptance to provide us with data to personalize the advertising of our apps. Not activating this permission does not mean that advertising will not be shown, but that the ads shown will not be personalized for you based on the information you provide.
- Renunciation to share data for analytics. Through the acceptance system integrated in our applications you can share or not share the data of use of the application for analytical purposes that help us to have information to develop our app more efficiently.
Information about user rights
The user has the following rights:
- Right of access (Article 15 of the GDPR): the user has the right to request a confirmation of whether or not their personal data are being processed and, as appropriate, to request access to personal data and information, such as the purpose of processing or the corresponding personal data categories.
- Right of rectification (Article 16 of the GDPR): the user has the right to request the correction of incorrect personal data.
- Right of suppression (Article 17 of the GDPR): the user has the right to request the deletion of personal data without undue delay under certain circumstances. For example, if their personal data is no longer necessary for the purposes for which it was collected or if they withdraw the consent on which the processing is based in accordance with art. 6 (1) (a) of the GDPR and if there is no other legal basis for its processing.
- Right to limitation of processing (Article 18 of the GDPR): the user has the right to ask us to limit the processing of their personal data in certain circumstances, for example, if they believe that the personal data we process about them is incorrect or illegal.
- Right to data portability (Article 20 of the GDPR): under certain circumstances, the user has the right to receive the personal data that they have given to us in a structured, commonly used and mechanical reading format, and to transmit them to another controller without obstacles or ask us to do it.
- Right of opposition (Article 21 of the GDPR):
The user has the right to object to the processing of their personal data in certain circumstances, in particular if we process their personal data based on the existence of a legitimate interest (Article 6 (1) (b) of the GDPR) or if we use their personal data for marketing purposes. The user can enforce these rights at any time by sending an email to correct or modify any information, or request what personal data (for example, name or email) we have stored, or enforce any of their rights as mentioned above by sending us an email to firstname.lastname@example.org.
Right to file claims to the Data Protection Authority
The user has the right to submit a claim to a supervisory authority, in particular in the Member State of the European Union in which they habitually reside or work, or in the place of the alleged infringement, if they consider that the processing of his personal data infringes the current legislation on data protection. The user can contact us at email@example.com so that we can provide them with detailed information on the contact details of the respective competent supervisory authorities.
Links to external websites
- Facebook (Facebook Ireland Limited 4 Grand Canal Square Grand Canal Harbour, Dublin, Ireland)
- Twitter (Twitter Inc 1355 Market St. 94103, San Francisco, CA, USA)
- Google+ (Google Ireland Limited Gordon House Barrow Street, Dublin, Dublin 4, Ireland)
What we do to protect the user’s personal data.
The security of the personal data of the users is very important for us. We have implemented the newest administrative, technical and physical security measures to protect them against unauthorized access, destruction or alteration of information. However, despite all our efforts, no security measure is completely impenetrable.
Pinkfire’s contact information