Privacy Policy

1. Introduction
This privacy policy governs the way in which this website collects, uses, maintains and discloses information collected from users (each, a User, you or them) of the website https://www.pinyly.com (Site). This privacy policy applies to the Site and all services offered through the Site or by Khmaussie Limited (we, us or our). Please read this policy prior to using the Site. By using the Site, you confirm you agree to the terms of this policy.

This privacy policy aims to give you information on how we collect and process your personal data through your use of the Site, including any data you may provide through the Site when you fill in our contact form, sign up to receive information from us or purchase a product or service.

The Site is not intended for children under 13 years of age. By providing us with your data, you warrant to us that you are over 13 years of age. We do not knowingly collect personal information from children under 13 years of age and if we learn that we have received personal information from a child under 13 without verification of parental consent, that data will be deleted.

2. Personal data
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:

Communication Data - any communication you send us through our contact form, by email, text, social media messaging, social media posting or any other form. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims.

Customer Data - data relating to any purchases of our services such as your name, title, billing address, address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the services you have purchased and to keep records of such transactions. We do this to perform the contract between you and us and/or to take steps at your request to enter into such a contract.

User Data - data about how you use our Site and any services together with any data that you post for publication on Site or through other online services. We process this data to operate our Site and ensure relevant content is provided to you, to ensure the security of our Site, to maintain back- ups of our Site and/or databases and to enable publication and administration of our Site, other online services and business. We do this to enable us to properly administer our Site and operate our business.

Technical Data - data about your use of our Site and services such as your IP address, your login data, details about your browser, length of visit to pages on our Site, page views and navigation paths, details about the number of times you use our Site, time zone settings and other technology or the devices you use to access our Site. The source of this data is from our analytics tracking system. We process this data to analyse your use of our Site and services, to administer and protect our business and Site, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. We do this to properly administer our Site and our business and to grow our business and to decide our marketing strategy.

Marketing Data - data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to participate in our promotions, to deliver relevant content and advertisements to you and measure or understand the effectiveness of this advertising. We do this to study how customers use our services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant content and advertisements to you and to measure or understand the effectiveness of the advertising we use. We do this to grow our business and to send other marketing communications to you. We do this with your consent or for legitimate interests to grow our business. Users may, however, visit our Site anonymously. Users can always refuse to supply personal data, except that it may prevent them from engaging in certain Site related activities.

3. Disclosures of your personal data
We may have to share your personal data with:

  • Service providers who provide IT and system administration services

  • Professional advisers including lawyers, bankers, financial advisers, tax agents, auditors and insurers

  • Government bodies that require us to report processing activities

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

4. International transfers
We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the European Economic Area (EEA), we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

  • We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or

  • Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

5. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes and if these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being clients.

In some cases we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates, advisors and advertisers for the purposes outlined above.

6. How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

7. Third party links and websites
The Site may include links to third-party websites, plug-ins and applications. We do not control the content or links that appear on these sites and are not responsible for any loss incurred by a User in accessing any of these. Using any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.

8. Web browser cookies
The Site may use 'cookies' to enhance a User’s experience. A User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Users may choose to set their web browser to refuse cookies, or to alert them when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

9. Changes to this privacy policy
We may update this privacy policy at any time. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

10. Your acceptance of these terms
By using this Site, you accept the terms of this privacy policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Questions
If you have any questions about our privacy policy, please contact us or email info@pinyly.com.

Last updated 15 September 2022