1. Introduction
At Pinkies Up Collection, we understand that your privacy is important. We respect and value the privacy of everyone who visits https://www.pinkiesupcollection.com (the “Site”) or uses any of our applications on their devices (“Apps”). We only collect and use your Data as described in this Privacy Policy (the “Policy”) and as permitted by Data Protection Legislation.
Please read this Policy carefully and ensure that you understand it. To navigate through our Privacy Notice just click on the links below. Capitalised terms used in this Policy are defined in the Glossary below.
Please note that our Site and Apps are not intended for use by individuals under 18 years old.
2.Who are we?
Our Site and Apps are owned and operated by Visatech Limited, a company registered in US. For the purposes of the Data Protection Legislation, we are the data controller which means that we are responsible for determining the purposes for which and means of how your Data is Processed.
If you have any concerns about how we Process or protect your Data or would like to contact us about any aspect of this Policy, please get in touch with us on info@pinkiesupcollection.com
This Policy should be read together with our Cookies Policy, and our Site and Apps terms of use. You can find most information in our FAQs.
3. How we use your Data
We use your Data for purposes related to membership enrollment and management, ambassador program activities, product sales, and related customer support, privacy compliance, and site operations. Specifically, we may use your Data to:
– Register you as a member or ambassador on the Site or Apps.
– Manage your membership or ambassador account, including verification of identity and eligibility, processing of orders, and handling payments.
– Communicate with you about your membership, ambassador activities, orders, promotions, updates to the Site or Apps, and changes to our terms, policies, or privacy notices.
– Process and fulfill product orders, including payment processing, shipping, returns, and customer service inquiries.
– Provide and personalize customer support, respond to inquiries, and manage feedback or complaints.
– Administer and improve our Site and Apps, products, services, and experiences (e.g., analytics to understand usage and engagement).
– Send marketing communications and manage marketing preferences, where permitted and as consented (e.g., newsletters, promotions, loyalty program information).
– Maintain security, prevent fraud, and ensure the integrity and safety of our Site and services.
– Comply with applicable legal and regulatory obligations, including privacy and data protection laws.
We will not share any of your Data with any other organisation or third parties for any purposes other than those described above, except as required to operate our services (e.g., payment processors, hosting providers) or as required by law, and with your consent.
4. Who do we share your Data with?
We may share your Data with third parties to support your needs, provide services, or comply with our legal obligations. We may also share Data when it is in the public interest, or in our legitimate interests or the legitimate interests of a third party, where appropriate and lawful.
Typically, the organisations we may share your Data with include:
– Members of the Pinkies Up Collection group for the purposes described in this policy.
– Third-party suppliers and service providers that help us operate (e.g., hosting providers, payment processors, order fulfillment, customer support software, data storage, analytics services). This may include partners that assist with membership management, ambassador program activities, and product sales.
– Identity verification, fraud prevention, and compliance providers (e.g., know-your-customer and anti-money-laundering services) to help verify eligibility and protect against misuse.
– Affiliate and partner platforms involved in marketing, referrals, or loyalty programs, subject to your marketing preferences and consent where required.
– Banks, payment card networks, and other financial institutions as necessary to process transactions and protect against fraud.
– Professional service providers such as auditors, legal and compliance advisors, who support our contractual and regulatory obligations.
– Other organisations or individuals as required by law or to protect the rights, property, or safety of Pinkies Up Collection, our members, staff, or the public.
Notes:
– If you have specific vendors or categories you routinely share data with (e.g., particular payment processors, shipping partners, email service providers), we can name them or describe them by category in this section.
– If you want to list recipients by name, please provide the exact entities and I will insert them.
– This section previously referenced gambling-related providers. It has been replaced with generic categories aligned to membership/ambassador activities and ecommerce.
5. How long do we retain your Data?
We will not keep your Data longer than is necessary for the purposes described in this policy, including to comply with legal obligations. The retention periods depend on the data type and the purposes for which we use it, such as membership management, ambassador activities, product sales, and customer support.
– Data categories and typical retention:
– Account and profile data (e.g., name, contact details, membership status): retained for the duration of your membership and for a period after termination to handle final inquiries and fulfill legal obligations.
– Transaction and order data: retained for as long as required to process orders, support customer service, and meet regulatory or tax requirements; after that, archived securely for a defined period.
– Communications and marketing preferences: retained for the duration of your consent or until you opt out, with periodic reviews to honor unsubscribe requests.
– Appeals, disputes, or fraud-related records: retained for as long as needed to resolve claims or comply with legal/regulatory requirements.
– Analytics and usage data: retained in anonymized or aggregated form for analytical purposes unless you request otherwise.
– Legal and regulatory requirements: we may be obligated to retain certain data longer (e.g., for KYC, anti-fraud, or financial reporting). In such cases, data will be kept securely for the minimum period required by law.
– Rights and deletion requests: you may request deletion of your personal data where permitted by law. Some data may be retained in archived form or kept to fulfill contractual or legal obligations (e.g., to prevent a repeat of fraud, to preserve evidence).
– Archiving and disposal: when data is no longer needed, we will securely delete or anonymize it in accordance with our data destruction policies.
6. Where do we transfer your Data?
We primarily store and process your data within the European Economic Area (EEA). If we transfer your Data outside the EEA, we will ensure a similar level of protection to safeguard your information in accordance with Data Protection Legislation. This may include:
– Transferring only to countries that have adequate data protection laws under Data Protection Legislation.
– Requiring recipients to enter into contractual protections that ensure data privacy (for example, standard contractual clauses).
– Where applicable, ensuring protections for transfers to the United States or other jurisdictions are aligned with recognized frameworks or approved mechanisms.
– Implementing any other measures required by Data Protection Legislation to protect your data during cross-border transfers.
Note: Insert the exact legal entity name where required in your final policy (e.g., Pinkies Up Collection, LLC).
7.Keeping your Data safe
We implement reasonable technical and administrative measures to protect your Data from unauthorized access, loss, or disclosure. While we strive to protect your information, no system is completely secure. When you use a password to access certain services, keep it confidential and do not share it. Please be aware that transmission over the Internet cannot be guaranteed as absolutely secure, and any such transmission is at your own risk.
8.Cookies
9. Marketing (preferences and communications)
10.Opting out
– Email marketing: to opt out of marketing emails, use the unsubscribe link in any email you receive or manage your preferences in the Account Details section of the Site or App.
– SMS marketing: to opt out of SMS messages, use the STOP code in any message you receive or manage your preferences in the Account Details section of the Site or App.
Please note it may take up to 28 days for your opt-out request to take effect. You may still receive transactional messages or important information about your membership, ambassador activities, or orders.
11. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in law, our data practices, or our business. All changes will be posted on this page (and, where appropriate, in the App). Each update will be effective from the date of publication. We recommend reviewing this Policy periodically to stay informed about how we protect your Data.
12. Questions and contact
If you have questions or comments about this Policy, want to know more about how we use your Data, or want to exercise your rights, please contact our Privacy team at info@pinkiesupcollection.com or via the contact form on https://www.pinkiesupcollection.com. If you prefer, you can also use any other contact points listed in the policy for a prompt response.
13. Complaints
If you have a concern about how we Process your Data, please contact us at info@pinkiesupcollection.com and we will aim to resolve it. If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority or supervisory authority.