OWNED AND OPERATED BY COMPANY: PASSPLANE (PTY) LTD

 REGISTRATION NO: 2018/550208/07

1.     WHO IS PIN-PIN?

Pin-Pin exists to help build a community of people who wish to connect with groups and individuals internationally who are aligned with their interests and hobbies.

This Privacy Policy describes how Passplane (Pty) Ltd and its affiliates (“we,” “us,” or “Pin-Pin”), process personal information in relation to your use of the Pin-Pin Platform. Depending on where you live and what you are doing on the Pin-Pin Platform, the supplemental privacy pages listed below may apply to you. Please follow the links and review the supplemental information describing how we process personal information for those regions and services.

2.     DEFINITIONS

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).

3.     PERSONAL INFORMATION WE COLLECT

3.1 Information needed to use the Pin-Pin Platform.

We collect personal information about you when you use the Pin-Pin Platform. Without it, we may not be able to provide all services requested. This information includes:

• Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, interests and profile photo, some of which will depend on the features you use.
• Identity Verification and Payment Information. Such as your ID number or other verification information, bank account or payment account information. ​​If you are not a Pin-Pin user, we may receive payment information relating to you, such as when a Pin-Pin user provides your payment card to complete a payment. If a copy of your ID is provided to us, we may scan, use, and store information contained in your ID to verify your identity.

3.2 Information you choose to give us.

You can choose to provide us with additional personal information. This information may include:

• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
• Information About Others. Such as a payment instrument belonging to another person. By providing us with personal information about others, you certify that you have permission to provide that information to Pin-Pin for the purposes described in this Privacy Policy, have shared the Pin-Pin Privacy Policy with them, and they have read and understood that it applies to them.
• Address Book Contact Information. Address book contacts you import or enter manually.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us.

3.3 Information Automatically Collected by Using the Pin-Pin Platform and our Payment Services.

When you use the Pin-Pin Platform and Payment Services, we automatically collect personal information. This information may include:

• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for Listings, connections you have made, and other actions on the Pin-Pin Platform.
• Log Data and Device Information. Such as details about how you’ve used the Pin-Pin Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Pin-Pin Platform. We may collect this information even if you haven’t created a Pin-Pin account or logged in.
• Cookies and Similar Technologies as described below:

We may use small computer files that are transferred to your computer’s hard drive that contain information such as user ID, user preferences, lists of pages visited and activities conducted while browsing the Site (“Cookies”) to help us improve our Site by tracking your navigation habits and to store some of your preferences. Generally, we use Cookies to customize your experience on our Site and to store your password so you do not have to re-enter it each time you visit the Site. Cookies do not allow our site to gain access to other information on your computer. At your option, expense and responsibility, you may block Cookies or delete Cookies from your hard drive. However, by disabling Cookies, you may not have access to the entire set of features of the Site.

In addition, our business partners may use Cookies to provide us with anonymous data and information regarding the use of our Services. Specifically, some of our business partners use Cookies to show Pin-Pin ads on other sites on the internet as a result of you using the Services. Such Cookies do not contain any Personal Information. You may opt out of receiving Cookies placed by such third party vendors by visiting the Network Advertising Initiative opt out page.

Other Cookies used by our business partners may collect other non-personally identifying information, such as the computer’s IP address, type of operating system, type of internet browsing software, what web pages were viewed at what time, the geographic location of your internet service provider and demographic information, such as gender and age range. This information is used to provide Pin-Pin with more information about our users’ demographics and internet behaviours.

We do not link the information stored in these Cookies directly to any of your Personal Information you submit while on the Site.

• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, and other related transaction details.

3.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:

• Third-Party Services. If you link, connect, or login to the Pin-Pin Platform with a third party service (e.g. Google, Facebook, WeChat), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals. If you are invited to the Pin-Pin Platform, the person who invited you can submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Pin-Pin Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to, health information related to contagious diseases.

4.     HOW WE USE INFORMATION WE COLLECT

4.1 Provide, Improve, and Develop the Pin-Pin Platform

Such as to:

• enable you to access the Pin-Pin Platform and make and receive payments,
• enable you to communicate with other Members,
• process your request,
• perform analytics, debug and conduct research,
• provide customer service, training,
• send you messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information, such as your friends or acquaintances, we may process this information: (i) to facilitate your referral invitations, (ii) for fraud detection and prevention, and (iii) to facilitate your requests or for any other purpose you authorize,
• personalize and customize your experience based on your interactions with the Pin-Pin Platform, your search and activity history, your profile information and preferences, and other content you submit, and
• enable your use of our enterprise products.

4.2 Create and Maintain a Trusted and Safer Environment.

Including to:

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• conduct checks against databases and other information sources, including background or police checks,
• comply with our legal obligations, protect the health and well-being of our users, Practitioners, Practitioners’ employees, and members of the public,
• enforce our agreements with third parties,
• comply with law, respond to legal requests, prevent harm, and protect our rights,
• enforce our terms and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the Pin-Pin Platform, your profile information and other content you submit to Pin-Pin, and information obtained from third parties. In limited cases, automated processes, which analyze your account and activities on the Pin-Pin platform as well as information in relation to activities on and off the Pin-Pin platform that can be associated with you, could restrict or suspend access to the Pin-Pin Platform if such processes detect activity that may pose a safety or other risk to Pin-Pin, our community, or third parties. If you would like to challenge decisions based on automated processes, please contact us via the Contact Information section below.

4.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

For example to:

• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Pin-Pin or its third-party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.

4.4 Provide Payment services.

Personal information is used to enable, or authorize third parties to use, Payment Services such as to:

• detect and prevent money laundering, fraud, abuse, and security incidents,
• conduct security investigations and risk assessments,
• comply with legal obligations (such as anti-money laundering regulations),
• enforce the payment terms,
• with your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences, and
• provide and improve Payment Services.

5.     SHARING & DISCLOSURE

5.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Pin-Pin account or participating in promotional activities by Pin-Pin partners or third parties.

Where permissible under applicable law, we may use certain information about you such as your email address, de-identify it, and share it with social media platforms to generate leads, drive traffic to Pin-Pin, or otherwise promote our products and services.

5.2 Sharing Between Members.

To help facilitate messaging or other interactions between Members, we may need to share certain information such as:

• When a chat request is made, or a dispute is submitted, certain information may be shared between Users(s), including profile, name, cancellation history, review information, dispute outcome (when applicable), and other information you choose to share and submit. When a chat is started, additional information is shared to assist with facilitating the chat, like profile photo and profile information as previously shared.
• When you as a user invite another Member to chat with you, you authorize that person to access your public information and Member Content, including, but not limited to, certain information like your full name, city, country, birthday, interests.

5.3 Information You Publish in Profiles, Listings, and other Public Information.

You can make certain information publicly visible to others, such as:

• Your public profile page, which includes your profile photo, first name (or initials where applicable), description, birthday, interests, city and country.
• Listing pages that include information such as the Listing’s approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
• Reviews, ratings, and other public feedback.
• Content in a community or discussion forum, blog, or social media post.

We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms, and apps.

Information you share publicly on the Pin-Pin Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.

5.4 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request (such as a subpoena or court order) or to respond to claims asserted against Pin-Pin, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our agreements with Members, including our Terms and Policies, or (v) protect the rights, property or personal safety of Pin-Pin, its employees, its Members, or members of the public. For example, if permitted due to the foregoing circumstances, Practitioner tax information may be shared with tax authorities or other governmental agencies.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Pin-Pin, our Members, or expose Pin-Pin to a claim of obstruction of justice.

Where legally required or permissible according to applicable law, we may disclose Practitioners’ and/or Users’ information to tax authorities for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations. Relevant tax obligations include Pin-Pin’s tax obligations on its service fees, its facilitation of taxes on accommodations and withholding taxes, and Practitioners’ individual tax obligations. Information that may be disclosed includes, but is not limited to, Practitioner and User names, listing addresses, Practitioner addresses, tax/business identification number(s), date of birth, and/or contact information, property parcel identification numbers, payout information, transaction dates and amounts, to the extent any of this information is known by Pin-Pin.

5.5 Service Providers.

We share personal information with affiliated and unaffiliated service providers to help us run our business and for their compliance purposes, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Pin-Pin Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or similar claims. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

5.6 Business Transfers.

If Pin-Pin undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

5.7 Corporate Affiliates.

To support us in providing, integrating, promoting and improving the Pin-Pin Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:

• Sharing with Passplane (Pty) Ltd. Even if your country of residence is not South Africa, your information will be shared with Passplane (Pty) Ltd which provides the technical infrastructure for the Pin-Pin Platform.
• Sharing with Passplane Payments. In order to facilitate payments on or through the Pin-Pin Platform, certain information as described in our Payment Terms will be shared with the relevant Pin-Pin Payments gateway.

6.     OTHER IMPORTANT INFORMATION

6.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Pin-Pin Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

6.2 Linking Third-Party Accounts.

You can link your Pin-Pin account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

• some of the information provided to us from linking accounts may be published on your public profile,
• your activities on the Pin-Pin Platform may be displayed to your Friends on the Pin-Pin Platform and/or that third-party service,
• a link to your public profile on that third-party service may be included in your Pin-Pin public profile,
• other Pin-Pin users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
• other Pin-Pin users may be able to see any schools, hometowns, or other groups you have in common with them as listed on your linked social networking service,
• information you provide to us from the linking of your accounts may be stored, processed, and transmitted for fraud prevention and risk assessment purposes, and
• publication and display of information that you provide to the Pin-Pin Platform through this linkage is subject to your settings and authorizations on the Pin-Pin Platform and the third-party service.

6.3 Third-Party Partners & Integrations.

Parts of Pin-Pin may link to third-party services, not owned or controlled by Pin-Pin, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy. Pin-Pin does not own or control these third parties and when you interact with them you are providing your information to them.

7.     YOUR RIGHTS

You can exercise any of the rights described in this section consistent with applicable law. As a registered user of the Services, you can modify some of the Personal Information you have included in your profile or change your username by logging in and accessing your account. Upon your request, Pin-Pin will use commercially reasonable efforts to delete your account and the Personal Information in your profile; however, it may be impossible to remove your account without some residual information being retained by Pin-Pin.  Registered users who wish to close their account should email: [email protected]

7.1 Managing Your Information.

You can access and update some of your personal information through your Account settings. If you connected your Pin-Pin Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

7.2 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

7.3 Data Erasure.

In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

• We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend an Pin-Pin Account for fraud or safety reasons, we may retain information from that Pin-Pin Account to prevent that Member from opening a new Pin-Pin Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Pin-Pin and Pin-Pin Payments may keep information for tax, legal reporting, and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Pin-Pin, even after your Pin-Pin Account is cancelled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
• Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

8.     SECURITY

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.

9.     CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Pin-Pin Platform will be subject to the revised Privacy Policy.

10.   CONTACT INFORMATION AND RESPONSIBLE PIN-PIN ENTITIES

For questions or complaints about this Privacy Policy or Pin-Pin’s handling of personal information contact Passplane (Pty) Ltd, Unit 101A Horizon Bay, Tableview, Cape Town, 7441, South Africa