PRIVACY POLICY

Pinsl GmbH (“Pinsl,” “we,” “platform,” “site” or “us”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Information (as defined below) we collect, why we collect it, and how we use and disclose it.

 

Your privacy matters to us, so please do take the time to get to know and familiarize yourself with our policies and practices. Please understand that we reserve the right to change any of our policies and practices at any time, but you can always find the latest version of this Privacy Policy here on this page.

Responsible for data processing:

Pinsl GmbH
Marienstrasse 37
D-70178 Stuttgart
privacy@pinsl.com

If you believe that the processing of personal data concerning you violates data protection law, you always have the right to lodge a complaint with the competent supervisory authority. According to Art. 77 GDPR, without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority responsible for us is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Friedrichstrasse 219, D-10969 Berlin.

 

1 Collection of Personal Information

As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably identifiable individual.

 

The purpose of processing personal data on our website is in particular to operate a platform with information about our offers and about us, processing purchases as well as to provide customer support in this regard. The legal basis for the data processing in this regard is:

 

for the use of the website (Art. 6(1) sentence 1 b) General Data Protection Regulation (“GDPR”)),
for safeguarding our interest in improving the user experience, advertising and presenting our services or maintaining the security of use (Art. 6(1) sentence 1 f) GDPR),
for the use of the services offered on the website as well as for pre-contractual measures, in particular for inquiries, for example (Art. 6(1) sentence 1 b) GDPR),
for the fulfillment of a legal obligation to which we are subject (Art. 6 (1) sentence 1 c) GDPR).

 

With regard to your personal data, you have 'in particular the following rights:

  • Based on Information, Art. 15 GDPR and Correction, Art. 16 GDPR, You may submit a request that Pinsl disclose the personal data that we process about you and correct any inaccurate personal data.
  • Based on Deletion, Art. 17 GDPR, You may submit a request that Pinsl delete the personal data that we have about you.
  • Based on Restriction of processing, Art. 18 GDPR, You have the right to restrict or object to our processing of your personal data under certain circumstances.
  • Based on Portability, Art. 20 GDPR, You have the right to receive the personal data you have provided to us in an electronic format and to transmit that personal data to another data controller. 

You also have the right to object to the processing of personal data, Art. 21 GDPR
If you have given consent to the processing of personal data, you have the right of withdrawal, Art. 7 GDPR with effect for the future.

 

1.1 Direct collection of personal information

  • Identification Information such as name, email, phone number, postal address;
  • Commercial Activity such as trading activity, order activity, deposits, withdrawals, fiat and cryptocurrency account balances, token transfers;
  • Correspondence such as information you provide to us in correspondence, including account opening and customer support; and
  • Sensory Information such as images that you upload to your User Profile;

If you create a customer account with us, we will collect and store the data you enter during registration for pre-contractual services, for the fulfillment of the contract or for the purpose of customer care (e.g. to provide you with an overview of your previous orders with us or to be able to offer you the so-called memo function).

Insofar as you consent to this processing, Art. 6(1) sentence 1 a) GDPR is the legal basis for the processing. If the opening of the customer account also serves pre-contractual measures or the fulfillment of the contract, the legal basis for this processing is also Art. 6(1) sentence 1 b) GDPR. The consent given to us for the opening and maintenance of the customer account can be revoked at any time with effect for the future in accordance with Art. 7(3) GDPR. For this purpose, you only need to inform us of your revocation.

Further data will be collected when you are using the services offered by the platform, where we will collect and store data you enter during profile modification, purchasing and transferring NFTs and other activities.

The data collected in this respect will be deleted as soon as the processing is no longer necessary. However, we must observe retention periods under tax and commercial law.

 

1.2 Automatic collection of personal information

  • Online Identifiers such as IP address, domain name;
  • Device Information such as hardware, operating system, browser;
  • Usage Data such as system activity, internal and external information related to platform pages that you visit, clickstream information; and
  • Geolocation Data.

The temporary storage of the IP address by the system is necessary to enable delivery of the website to your terminal device. For this purpose, the IP address must remain stored for the duration of the session. This data is not merged with other data sources. The information is used exclusively to analyze and maintain the technical operation of the servers and the network. The legal basis for this is Art. 6(1) sentence 1 f) GDPR. 

 

2 Usage of personal information

We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to:

  1. Provide you with our Services. We use your Personal Information to provide you with our Services pursuant to the terms of our Terms of Use. For example, in order to facilitate fiat transfers out of your account, we need to know your financial information.
  2. Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations.
  3. Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
  4. Protect the security and integrity of our Services. We use your Personal Information, including information about your device and your activity on Pinsl to maintain the security of your account and the platform.
  5. Provide you with customer support. We process your Personal Information when you contact our support team with questions about or issues with your account.
  6. Market our products. We may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time.
  7. Other business purposes. We may use your Personal Information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.

 

3 Sharing of personal information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you:

 

3.1 Facebook 

We have integrated components of the social network Facebook on our website. Facebook is operated by Facebook Inc, Hacker Way, Menlo Park, CA 94025, U.S.A.. The responsible party for the processing of personal data, if the data subject does not live in the U.S. or Canada, is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. By calling up one of the subpages of our website on which we have integrated the Facebook component, the internet browser of the data subject is caused to download a representation of the corresponding Facebook components from Facebook. This informs Facebook that this subpage of our website has been accessed. An overview of all Facebook components can be found at https://developers.facebook.com/docs/plugins/?locale=de_DE

If the data subject is logged into Facebook, Facebook recognizes that the data subject is visiting the subpage of our website. This information is collected by Facebook and assigned to the Facebook account of the data subject. Transmission of this data can be prevented, for example, by the data subject logging out of their Facebook account and deleting the cookies before accessing our website. The data protection provisions of Facebook can be found at https://www.facebook.com/about/privacy

This also results in possible settings for the protection of privacy and the suppression of data transmission to Facebook.

 

3.2 Instagram

We have integrated components of the social network Instagram on our website. Instagram is operated by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. This may include, for example, content such as images, videos or texts and buttons where users can indicate their like, subscribe to the account of the author of the content or our posts. Instagram uses cookies to analyze user behavior. If the users are members of the Instagram platform, Instagram can assign the call of the aforementioned content and functions to the users' profiles there. Instagram's privacy policy can be found at: http://instagram.com/about/legal/privacy/

 

3.3 Twitter

We have integrated components of the social network Twitter on our website. Twitter is operated by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. This may include, for example, content such as images, videos or texts and buttons that allow users to indicate their liking, to subscribe to the account of the author of the content or to subscribe to our posts. If the users are members of the Twitter platform, Twitter can assign the call of the aforementioned content and functions to the profiles of the users there. Twitter is certified under the Privacy Shield agreement and guarantees to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active) Information on individualization and data protection can be found here: https://twitter.com/de/privacy

 

3.4 LinkedIn 

We have integrated components of the social network LinkedIn on our website. LinkedIn is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. When a user accesses a web page on this site that features one of these buttons, the browser establishes a direct connection with LinkedIn’s servers as soon as the LinkedIn button is pressed. Thanks to the integration of the plugin, LinkedIn knows that you have accessed the relevant page of our platform. If you are logged in to LinkedIn, LinkedIn can recognize you based on your LinkedIn account and record your visit. For the information on the purpose and scope of data collection and processing and usage by LinkedIn, as well as your rights in this respect and settings options for protecting your privacy please see the data protection information of LinkedIn.

You can find the privacy policy of LinkedIn under https://www.linkedin.com/legal/privacy-policy LinkedIn is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active ).

 

3.5 Pinterest

We have integrated components of the social network Pinterest on our website. Pinterest is a service of Pinterest Inc., 651 Brannan Street, San Francisco, CA, 94107, USA. 

We do not have access to this user data. Access is only available to Pinterest. Pinterest Inc. is certified under the Privacy Shield and committed to comply with European privacy standards. https://www.privacyshield.gov/participant?id=a2zt00000008VVzAAM&status=Active The Pinterest privacy policy can be found here: https://policy.pinterest.com/de/privacy-policy

 

3.6 Google

We have integrated both Google social login and Google Analytics on our website, services of Google LLC, 1600 Amphitheatre Pkwy, Mountain View, California 94043, USA. Google LLC uses cookies and analyzes from which website our website was visited, which of our subpages were visited and the length of stay. The information generated by the cookie is usually transferred to a Google LLC server in the USA and stored there. Google LLC is certified under the Privacy Shield agreement and thus guarantees compliance with European data protection law. https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Google LLC evaluates the use of our online offers on our behalf, and pseudonymous usage profiles can be created. Google Analytics is only used by us with activated IP anonymization. The IP address of the user is shortened by Google LLC within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google LLC server in the USA and shortened there. The IP address is not merged with other data from Google. The storage of cookies can be prevented by a corresponding setting of the internet browser. Furthermore, the collection and processing of this data can be prevented by an internet browser add-on available here: http://tools.google.com/dlpage/gaoptout?hl=de

Further information and the privacy policy of Google LLC as well as setting and objection options, can be found here https://policies.google.com/privacy?hl=de&gl=de

 

3.7 Amazon AWS

Pinsl uses the services of Amazon Web Services (AWS) SARL 38 avenue John F. Kennedy, L-1855 Luxembourg;

(https://aws.amazon.com/compliance/gdpr-center) for hosting its software. The data centers used are ISO/IEC 27001 certified and thus meet our high requirements for the physical security of our customers’ data.

 

4 Transfer of personal information

Pinsl and their partners operate with systems based in the United States. As a result, we may transfer personal data from Europe to third countries outside of Europe, including the United States, under the following conditions:

  • Contractual Obligation. Where transfers are necessary to satisfy our obligation to you under our Terms of Use, including to provide you with our Services and customer support services, and to optimize and enhance Pinsl; and
  • Consent: where you have consented to the transfer of your personal data to a third country.

Where transfers to a third country are based on your consent, you may withdraw your consent at any time. Please understand, however, that our services may not be available if we are unable to transfer personal data to third countries.

When we transfer personal data to third countries, we endeavor to ensure adequate safeguards are implemented, for example through the use of standard contractual clauses or Privacy Shield certification.

 

5 Usage of Cookies

Our automatic collection of Personal Information may involve the use of cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit Pinsl. We use Cookies to help us recognize you as a customer, collect information about your use of Pinsl to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (ii) assess and improve our services and advertising campaigns.

You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note that if you reject cookies, you will not be able to use some or all of Pinsl. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use Pinsl.

The legal basis for this processing is Art. 6(1) sentence 1 b) GDPR, insofar as these cookies data are processed for contract initiation or contract execution.

If the processing does not serve the purpose of initiating or executing a contract, our legitimate interest lies in improving the functionality of our website. The legal basis is then Art. 6(1) sentence 1 f) GDPR.

For technically unnecessary cookies or marketing cookies, etc., we require your consent. If you have given us your consent to the use of cookies on the basis of a notice ("cookie banner") the legality of the use is additionally based on Art. 6(1) sentence 1 a) GDPR.

 

6 Usage of Automatic Decision Making

We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data. Services that include elements of automated decision-making include:

  • Temporary denylist of IP addresses associated with repeated failed This denylist persists for a small number of hours.
  • Temporary denylist of credit cards associated with denylisted IP This denylist persists for a small number of days.

You have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

Our partners may engage in automated decision-making for purposes of fraud detection and prevention.