We are glad to welcome you to the Pindify Marketplace, a service provided by Pindify, SA and its subsidiaries (“Pindify”, “we”, “our”, “us”).
Your privacy is important to us and the purpose of this Privacy Policy is to explain how we collect, store, use, disclose and otherwise process your personal information when you use Pindify.com or any other Pindify website (together the “Website”), our mobile and desktop applications (the “Apps”) and all related sites, players, widgets, tools, applications, data, software, APIs and other services provided by Pindify (the “Services”). Information relating to our use of cookies and similar technologies is set out in our Cookie Policy, which forms part of the Privacy Policy why, when we refer to the Privacy Policy, we refer both to the Privacy Policy and Cookie Policy Please note that this Privacy Policy only applies to the Website, the Apps and the Services (together the “Marketplace”). When using the Marketplace, you may find links to other websites, apps and services, or tools that enable you to share information with other websites, apps and services. Pindify is not responsible for the privacy practices of these other websites, apps and services and we recommend that you review the privacy policies of each of these websites, apps or services before connecting your Pindify account or sharing any personal data. If you do not agree to any of the provisions of this Privacy Policy, you should not use the Marketplace. If you have any questions or concerns about this Privacy Policy, you can contact us through the help function in the Marketplace or at dataprotection@pindify.com
When this policy mentions “Pindify,” “we,” “us,” or “our,” it refers to the Pindify entity that is responsible for your information under this Privacy Policy (the “Data Controller”).
Pindify, SA, with registered address at 43, Avenue J.F. Kennedy, L-1855 Luxembourg, is the Data Controller of your personal data provided to, or collected by or for, or processed in connection with, our Marketplace.
We may share your data within our corporate group of companies that are related by common ownership or control (“Pindify Group”).
Pindify is committed to putting users first and believes you should know what data we collect about you, why we collect it, and how we use and share it. This is why we have designed this Privacy Policy to give you simple, clear, accurate and actionable information about our privacy and data protection practices.
We believe users of the Marketplace should also have meaningful choices over the data we collect, use and share as described in this Privacy Policy and otherwise in the Marketplace.
All personal information we collect is related to our ability to provide the Marketplace and its features and received from various sources.
(i) Information you provide to us
We ask for and collect the below personal information when you use the Marketplace. The information is necessary for the adequate performance of the agreement between you and us and to allow us to comply with our legal obligations.
We process this information in light of our legitimate interest in improving the Marketplace and giving the Marketplace users the best experience, and where it is necessary for the adequate performance under the agreement between us and you. Without processing the information, we may not be able to provide you with all the requested services and features of the Marketplace.
Certain Services require that you register for an account and, by doing so, you provide us with certain information:
Account Information. When you register any kind of Pindify account, you will need to provide your e-mail address and choose a password. In addition, you will also need to provide your real name, billing information, and payment verification information.
Profile Information. You may choose, at your discretion, to provide additional information for your public profile on Pindify – for example, your real name, a user name (which may be your real name or a pseudonym), the city and country in which you live, a profile picture, profile header image or avatar, information about how you categorize yourself with respect to content (for example, whether you are a musician, a label or some other category of creator), details of your other websites and social media profiles, including links to those pages, your gender if you wish to provide it, and any additional information you provide as part of your public profile, such as your real name, and links to your website and other social media profiles (but not your email address), will be published on your profile page. This information will be publicly accessible and may be viewed by anyone accessing the Website, or using our API or other Services. Please bear this in mind when considering whether to provide any additional information about yourself
Communications. When you communicate with Pindify by email or through the Marketplace, or use the Marketplace to communicate with other Marketplace users, we collect information about your communication and any information you choose to provide.
Survey Information. If you participate in any survey, you may provide certain personal data as part of your response, unless you respond anonymously.
Information You Post. You may provide personal data when you upload content to the Marketplace, or when you post comments, or contribute to community discussions.
(ii) Information we collect automatically
There is certain information that we collect automatically as the result of your use of the Marketplace, or through the use of cookies and other web analytics services as described in our Cookie Policy
. This information generally includes:
Usage Information. We collect information about your interactions with the Marketplace, including the pages and providers that you visit and links you click on, streaming, uploading or recording tracks, connecting your Facebook or Google+ account , sharing content, following or unfollowing another Marketplace user, joining or leaving a group, posting a comment, performing a search, the time, frequency and duration of your visits to the Marketplace, and whether you interact with e-mail messages, for example, if you opened, clicked on, or forwarded the e-mail message.
Log Data. We automatically collect log information when you use the Marketplace. That information includes, among other things, details about how you have used the Marketplace (including links to third party sites or services), IP address, access times, your browser type and operating system, device information, device event information (e.g., crashes, browser type), and the page you have viewed or engaged with before or after using the Marketplace.
Log Data. We automatically collect log information when you use the Marketplace. That information includes, among other things, details about how you have used the Marketplace (including links to third party sites or services), IP address, access times, your browser type and operating system, device information, device event information (e.g., crashes, browser type), and the page you have viewed or engaged with before or after using the Marketplace.
Cookies. We use cookies and other similar technologies, such as pixels, local storage, and mobile device identifiers and may also allow our business partners to use these tracking technologies on the Marketplace, or engage others to track your behavior on our behalf. For more information on our use of these technologies, see our Cookie Policy
Location Data. When you use certain features of the Marketplace, we may collect data about your general location (e.g. your IP address). We use this data to provide you with location-based services (such as advertising and personalized content). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings.
Device Information. We collect information from and about the devices you use, including how you interact with the Marketplace and information about device itself, such as the hardware model, operating system, IP addresses, cookie information, device settings, mobile device and advertising identifiers, apps installed, browser type, language, battery level and time zone. This information allows us to recognize and associate your activity, and provide personalized content and advertising, consistently across all of your devices.
Pindify widget. Other websites may integrate Pindify widgets; when you visit a website with a Pindify widget embedded, we may receive certain information, including information about the website you visited. Pindify and the widget may be able to recognize you, and in some cases the widget may be used to show personalized content. We know when you interact with a widget, and websites containing the widgets may receive this information as well.
(iii) Information we obtain from third parties
We may also receive information about you from our service providers and business partners, including companies that assist with payment processing, analytics, data processing and management (e.g. to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you, including for Pindify products) account management, hosting, customer and technical support, and other services which we use to personalize your Pindify experience
We use the personal information we collect from you, including with the help of automated systems and decision making, for a range of different business purposes according to different legal bases of processing and subject to the choices you make in your settings of the Marketplace.
(i) Provide, improve and develop the Marketplace
To operate and maintain your Pindify account, and to provide you with access to and use of the Marketplace. Your email address and password are used to identify you when you log into the Marketplace. Your device-IDs are used to ensure that you are in control of the devices that have access to your subscription.
To identify you as the creator of the content that you upload, the comments that you post and/or the other contributions that you make to the Marketplace.
To provide creators with stats and insights about users’ listening behavior of their content, (i.e. streaming and downloading their content or following their profiles).
We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new features, and conduct audits and troubleshooting activities.
When purchasing an account, your name, address and payment verification information will be used to process your account subscription and renewals and to collect your payment.
Your email will be used to send you service updates and notifications about your account.
To communicate with you about any comment or enquiry you have submitted.
We use your age to enable age restrictions
We process this information in light of our legitimate interest in improving the Marketplace and giving our users the best experience, and where it is necessary for the adequate performance of the agreement with you.
(ii) Maintain a safe and secure environment
Detect and prevent fraud, spam, abuse, security incidents, and other suspicious activity.
Verify and authenticate your identity and prevent unauthorized or illegal activity.
Enhance the safety and security of our products and services.
Conduct security investigations and risk assessments.
To prevent or take action against activities that are, or may be, in breach of our terms of use, guidelines or applicable law.
To provide you with customer and technical support.
We process this information in light of our legitimate interest in improving the Marketplace and giving our users the best experience, and where it is necessary for the adequate performance of the agreement with you.
(iii) Personalize content, advertising and marketing
To improve your experience on the Marketplace by providing personalized content, recommendations, and features.
To customize the content and measure performance of any e-mail, push notification, or in-app message we may send to you.
Administer promotional activities or events sponsored or managed by Pindify or its partners.
Use automated systems and decision making to profile user characteristics and infer preferences based on information that you provide to us, your interactions with the Marketplace and content, your profile information, and information obtained from third parties.
To deliver targeted marketing for Pindify products on and off the Marketplace and measure the success of those campaigns.
Combine information we collect about you with information from business partners and use it to serve more relevant advertising.
We may use your data for other purposes, provided we disclose the purposes and use to you at the relevant time, and provided that you consent to the proposed use of your personal data.
This section describes how the information collected or generated through your use of the Marketplace may be shared by you or by us.
Through your profile. Any information in your Pindify profile will be accessible by other users of the Marketplace, who may view your profile information, listen to and comment on any of your content, add themselves to your list of followers, and send you messages. If you consume any content uploaded by a Pindify user, the fact that you have consumed the content will be shared, and that you are following that user, so that they can track the popularity of their content. Similarly, if you comment on any content on the Marketplace, your comments will be available to all users of the Marketplace.
Consent. We will disclose your information if you have agreed that we may do so. We will make this clear to you at the point at which we collect your information, including the purpose(s) for which we will use the data.
Service providers. We use a variety of third party service providers, some of who may be located outside of the European Economic Area (“EEA”), to provide services to us or to our users on our behalf. These service providers have access to your information solely to perform these tasks on our behalf, and are contractually bound to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us. We need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
Advertising. We share the data collected about you, generally in hashed, aggregated, or de-identified forms with advertisers and advertising service providers and business partners in order to serve ads based on your interests and measure the reach and effectiveness of those ads, including whether a user took an action (e.g. purchase a product). We may also share cookie data and device identifiers with service providers for data matching purposes, in order to improve ad targeting.
Social media. For users outside of the EU/EEA, where permissible under applicable law, we may share your e-mail address with Facebook in order to target you with ads for Pindify products on Facebook and on third party websites and applications on Facebook. We also allow Facebook and other social media platforms to collect information through cookies and similar technologies like pixels in order to serve ads for Pindify on those third party websites and apps and drive users to our Marketplace. In order to measure the effectiveness of and optimize these marketing campaigns, these technologies track activity taken across devices after a user sees a Pindify ad, in order to determine performance metrics like sign ups, visits to the Marketplace, and purchases. We undertake these activities based on our legitimate interest in acquiring new customers and offering products we think you may be interested in. Any questions regarding how these social media platform service provider processes your personal data should be directed to such third party platform.
Aggregated data. We may also share aggregated information (information about our users that we render in such a way that it no longer identifies or references an individual user) and other pseudononimized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
Compliance with laws. We may disclose your information to courts, law enforcement agencies, and governmental authorities to (i) comply with our legal obligations, (ii) comply with legal process and to respond to claims asserted against Pindify, (iii) respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) enforce and administer our Terms of Use and other agreements with users, or (v) protect the rights, property or personal safety of Pindify, its employees, and members of the public.
Protecting our rights. We may disclose your information if we feel this is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors, officers, or shareholders, and/or to ensure the safety and security of the Marketplace and/or the Pindify community.
To our affiliates. To enable and support us in providing the Marketplace and Services, we may share your information, including personal information, within the Pindify Group. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Marketplace globally.
Change of control. We may also share your personal data as part of a sale, merger or change in control of Pindify, or in preparation for any of these events. Any other entity that buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
As further described in our Cookie Policy
we use cookies and similar technologies (e.g., pixels, local storage, and device identifiers) to recognize you and/or your device(s) on and off the Marketplace, and across devices and devices. To the extent allowed by your settings or your device, we also allow third parties to use cookies as described in our Cookie Policy
in order to track user behavior on and off the Marketplace in order to show you ads based on your interests and preferences. You can control cookies through your browser and other tools as described in theCookie Policy
, as well as through your settings.
Pindify maintains technical, administrative, and physical safeguards that are designed to prevent unauthorized access, use or disclosure of personal information we collect or store. We regularly monitor our systems for possible vulnerabilities and attacks. However, it is not possible to guarantee the security of information transmitted over the Internet. You use the Marketplace and provide us with information at your own discretion and risk.
Pindify operates globally and may share your information internally within the Pindify Group, and third parties for the purposes described in this Privacy Policy. Information collected within the EEA may, for example, be transferred to countries outside of the EEA for the purposes as described in this Privacy Policy. We utilize appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, or another legally approved mechanism, to ensure the lawful transfer of your personal data outside of the EEA.
We do not knowingly collect any personal information from any person who is under the age of 18 or 13, as the case may be, or allow them to register an account. If the processing of personal information concerns a child under the age of 18 (or such other lower age determined by the local laws where you live), consent must be given by an authorized person with parental responsibility for the child.
We do our best to give you as much choice as possible regarding the amount of information you provide to us and the control you have over that information. You may manage the content and information you share when you use Pindify through your account settings. You may also use the mobile or platform device settings for certain limitations. This also applies to your web browser, specifically to control cookies etc.
In some jurisdictions, including the EU/EEA, you may exercise any of the rights described in this section through the Help Center. Please note that we may ask you to verify your identity before taking further action on your request.
Data access and portability. You may be entitled to request copies of your personal information processed by us. This includes a right to request copies of personal information you have provided to us in machine-readable format.
Change or correct data. Where you cannot update data yourself through your Pindify account, you have the right to ask us to correct change, update or rectify any of your information.
Data retention and deletion. We generally retain data for as long as your Pindify account is in existence or as needed to provide the Marketplace. However, specific retention times can vary based on context of the processing we perform and on our legal obligations. You have the right to ask us to delete all or some of the personal data we hold about you. We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, or where we have a legitimate interest in doing so (e.g. to prevent fraud and abuse and maintain and enhance security).
Restriction of processing. Under certain circumstances, you may have the right to limit the ways in which we use your personal information.
Withdrawing consent. Where you provide consent to the processing of your personal information by Pindify, you may withdraw your consent at any time by changing your account settings or by sending a communication to Pindify specifying the specific consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
You have the right to lodge complaints about the data processing activities carried out by Pindify before a competent data protection authority.
If you have questions or complaints about our practices or this Privacy Policy, please do not hesitate to contact us ondataprivacy@pindify.com
We may update this Privacy Policy from time to time in our sole discretion. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Marketplace. Please be sure to periodically check this page to ensure that you are aware of any changes to this Privacy Policy.
Last updated: 25 May 2018