PINS Bonusway privaatsuspoliitika

PRIVACY POLICY

The processing of personal data by PINS Bonusway will always be done according to the General Data Protection Regulation (GDPR).

1. Controller

Suomen Ostohyvitys Oy
Kalevankatu 30
00100 Helsinki
Finland
admin@bonusway.com

2. Data Protection Officer

Ville Laitinen
PINS Bonusway
Kalevankatu 30
00100 Helsinki
Finland
admin@bonusway.com

3. Cookies

The PINS Bonusway service uses cookies that are stored on a user's computer through their web browser. These cookies can be used to make the user experience of the service smooth, and to identify the specific browser and serve content that is specific to the user of the browser.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website.

The user may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of their browser, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time. This is possible in all popular internet browsers. If the user deactivates the setting of cookies in the their browser, not all functions of our website may be entirely usable.

4. General Data Collection

The PINS Bonusway service collects general data when a user's browser calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website, (4) the date and time of access to the service, (5) IP address and (6) any other similar data that may be used for your benefit in the event of attacks on our information technology systems.

When using these general data, PINS Bonusway does not draw any conclusions about user. Rather, this information is needed to ensure the long-term viability of our information technology systems and website technology, and provide authorities with the information necessary for criminal prosecution in case of a cyber-attack. The anonymous data of the server log files are stored separately from all personal data provided by a user.

5. Registration

The user has the possibility to register to the PINS Bonusway service with an include personal data. Which personal data are transmitted to PINS Bonusway is determined by the sign-ip form. The personal data entered by the user are collected and stored exclusively for internal use by PINS Bonusway. PINS Bonusway may transfer part of this information to one or more processors (e.g. a payments provider) that also uses personal data for an internal purpose which is attributable to PINS Bonusway.

By registering in the PINS Bonusway service, the IP address of the user and the date and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure PINS Bonusway. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of user, with the voluntary indication of personal data, is intended to enable PINS Bonusway to offer user contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of PINS Bonusway.

PINS Bonusway shall, at any time, provide information upon request to each user as to what personal data are stored about user. In addition, PINS Bonusway shall correct or erase personal data at the request or indication of user, insofar as there are no statutory storage obligations. A Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of PINS Bonusway’s employees are available to user in this respect as contact persons.

6. Newsletter Tracking

The newsletters of PINS Bonusway contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, PINS Bonusway may see if and when an e-mail was opened by a user, and which links in the e-mail were called up (clicked on) by users.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by PINS Bonusway in order to optimize the shipping of the newsletter, as well as to continuously adapt the content of future newsletters to the interests of user. These personal data will not be passed on to third parties. users are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by PINS Bonusway. PINS Bonusway automatically regards a withdrawal from the receipt of the newsletter as a revocation.

7. Contacting PINS Bonusway

If a user contacts PINS Bonusway by e-mail or via a form om the website, the personal data transmitted by user are automatically stored. Such personal data transmitted on a voluntary basis by a user to PINS Bonusway are stored for the purpose of processing or contacting user.

If a user contacts PINS Bonusway about a missing bonus, information about the purchase and the user may be shared with a third party, like a shop, to confirm the purchase exists and is not fraudulent.

8. Routine Erasure of Personal Data

PINS Bonusway shall process and store the personal data of user only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which PINS Bonusway is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely erased in accordance with legal requirements.

9. Rights of a User

9a. Right of Confirmation

Each user shall have the right granted by the European legislator to obtain from PINS Bonusway the confirmation as to whether or not personal data concerning him or her are being processed. If a user wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of PINS Bonusway.

9b. Right of Access

Each user shall have the right granted by the European legislator to obtain from PINS Bonusway free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant user access to the following information:

- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from PINS Bonusway rectification or erasure of personal data, or restriction of processing of personal data concerning user, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from user, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for user.

Furthermore, a user shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, a user shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a user wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of PINS Bonusway.

9c. Right to Rectification

Each user shall have the right granted by the European legislator to obtain from PINS Bonusway without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, user shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a user wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of PINS Bonusway.

9d. Right to be Forgotten

Each user shall have the right granted by the European legislator to obtain from PINS Bonusway the erasure of personal data concerning him or her without undue delay, and PINS Bonusway shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- User withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- User objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or user objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which PINS Bonusway is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a user wishes to request the erasure of personal data stored by PINS Bonusway, he or she may at any time contact our Data Protection Officer or another employee of PINS Bonusway. The Data Protection Officer of PINS Bonusway or another employee shall promptly ensure that the erasure request is complied with immediately.

Where PINS Bonusway has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, PINS Bonusway, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that user has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of PINS Bonusway or another employee will arrange the necessary measures in individual cases.

9e. Right of Restriction of Processing

Each user shall have the right granted by the European legislator to obtain from PINS Bonusway restriction of processing where one of the following applies:

- The accuracy of the personal data is contested by user, for a period enabling PINS Bonusway to verify the accuracy of the personal data.
- The processing is unlawful and user opposes the erasure of the personal data and requests instead the restriction of their use instead.
- PINS Bonusway no longer needs the personal data for the purposes of the processing, but they are required by user for the establishment, exercise or defence of legal claims.
- User has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of PINS Bonusway override those of user.

If one of the aforementioned conditions is met, and a user wishes to request the restriction of the processing of personal data stored by PINS Bonusway, he or she may at any time contact our Data Protection Officer or another employee of PINS Bonusway. The Data Protection Officer of PINS Bonusway or another employee will arrange the restriction of the processing.

9f. Right to Data Portability

Each user shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from PINS Bonusway to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in PINS Bonusway.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, user shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, user may at any time contact the Data Protection Officer designated by PINS Bonusway or another employee.

9g. Right to Object

Each user shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

PINS Bonusway shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of user, or for the establishment, exercise or defence of legal claims.

If PINS Bonusway processes personal data for direct marketing purposes, user shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If user objects to PINS Bonusway to the processing for direct marketing purposes, PINS Bonusway will no longer process the personal data for these purposes.

In addition, user has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by PINS Bonusway for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, user may directly contact the Data Protection Officer of PINS Bonusway or another employee. In addition, user is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

9h. Automated Individual Decision-making, Including Profiling

Each user shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between user and a data controller, or (2) is not authorised by Union or Member State law to which PINS Bonusway is subject and which also lays down suitable measures to safeguard user’s rights and freedoms and legitimate interests, or (3) is not based on user’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between user and a data controller, or (2) it is based on user’s explicit consent, PINS Bonusway shall implement suitable measures to safeguard user’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of PINS Bonusway, to express his or her point of view and contest the decision.

If user wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of PINS Bonusway or another employee of PINS Bonusway.

9i. Right to Withdraw Data Protection Consent

Each user shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If user wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of PINS Bonusway or another employee of PINS Bonusway.

10. Facebook

In its service, PINS Bonusway has integrated components of the enterprise Facebook.

Facebook is a social network. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States.

Through the integration between PINS Bonusway and Facebook, Facebook is able to receive information about a visit to our service by the user.

Facebook may place a cookie on the device of the user. The definition of cookies is explained above.

Facebook is enabled to analyze the use of our website. During the course of this technical procedure, the enterprise Facebook may gain knowledge of personal information, such as the IP address of user.

Personal data, including the IP address of the user, may be transmitted to Facebook in the United States of America. This personal data are stored by Facebook in the United States of America. Facebook may pass these personal data collected through the technical procedure to third parties.

User may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies, or choose to delete alreaded set cookies.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of user. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g. the Facebook blocker of the provider Webgraph, which may be obtained under http://webgraph.com/resources/facebookblocker/. These applications may be used by user to eliminate a data transmission to Facebook.

11. Google Analytics

In its service, PINS Bonusway has integrated the component of Google Analytics.

Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

Google may place a cookie on the device of the user. The definition of cookies is explained above.

Google is enabled to analyze the use of our website. During the course of this technical procedure, the enterprise Google may gain knowledge of personal information, such as the IP address of user.

Personal data, including the IP address of the user, may be transmitted to Facebook in the United States of America. This personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

User may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies, or choose to delete alreaded set cookies.
In addition, user has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, user must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of user is later deleted, formatted, or newly installed, then user must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by user or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

12. Google AdWords

In its service, PINS Bonusway has integrated the component of Google AdWords.

Google AdWords is a service for internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network.

The operating company of the Google AdWords component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

Google may place a cookie on the device of the user. The definition of cookies is explained above.

Google is enabled to analyze the use of our website. During the course of this technical procedure, the enterprise Google may gain knowledge of personal information, such as the IP address of user.

Personal data, including the IP address of the user, may be transmitted to Facebook in the United States of America. This personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

User has a possibility of objecting to the interest based advertisement of Google. Therefore, user must access from each of the browsers in use the link www.google.com/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

13. AppsFlyer

In its service, PINS Bonusway has integrated the component of AppsFlyer.

AppsFlyer is a mobile analytics service. Mobile analytics is the collection, gathering, and analysis of data about the behavior of visitors to mobile applications.

The operating company of the AppsFlyer component is AppsFlyer Ltd., 100 1st Street, 25th floor, San Francisco, CA 94105, United States

AppsFlyer is enabled to analyze the use of our mobile application. During the course of this technical procedure, the enterprise AppsFlyer may gain knowledge of personal information, such as the IP address of user.

Personal data, including the IP address of the user, may be transmitted to AppsFlyer in the EU. This personal data are stored by AppsFlyer in the EU. AppsFlyer may pass these personal data collected through the technical procedure to third parties.

Further information and the applicable data protection provisions of AppsFlyer may be retrieved under https://www.appsflyer.com/gdpr/dpa.pdf.

14. OneSignal

In its service, PINS Bonusway has integrated the component of OneSignal.

OneSignal is a push notification service. Push notifications allow PINS Bonusway to contact the users of the PINS Bonusway mobile application with messages regarding security and offers relevant to them.

The operating company of the OneSignal component is Onesignal Inc., 411 Borel Ave, Suite 512, San Mateo, CA 94402, United States

OneSignal is enabled to send push notifications to the users of the PINS Bonusway mobile application. During the course of this technical procedure, the enterprise OneSignal will gain knowledge of personal information, such as the IP address of the user.

Personal data, including the IP address of the user, may be transmitted to OneSignal in the United States. This personal data are stored by OneSignal in the United States. OneSignal may pass these personal data collected through the technical procedure to third parties.

Push notifications are only sent if the user has given explicit consent for that.

15. Twilio

In its service, PINS Bonusway has integrated the component of Twilio.

Twilio is a messaging service. It allows PINS Bonusway to secure its users accounts by using SMS/voice as a second factor of authenticaion.

The operating company of the Twilio component is Twilio, Inc., 375 Beale Street, Suite 300 San Francisco, CA 94105, United States

Twilio is enabled to send SMS messages to the users of the PINS Bonusway service. During the course of this technical procedure, the enterprise Twilio will gain knowledge of personal information, such as the mobile phone number of the user.

Personal data, including the mobile phone number of the user, may be transmitted to Twilio in the United States and the EU. This personal data are stored by Twilio in the United States and the EU. Twilio may pass these personal data collected through the technical procedure to third parties.

No messages are sent to the user should the choose not to enter their phone number in the system.

16. Dialog Insight

In its service, PINS Bonusway has integrated the component of Dialog Insight.

Dialog Insight is an email delivery service.

The operating company of the Dialog Insight component is Dialog Insight, 4535 Wilfrid-Hamel Blvd, Suite 210, Quebec G1P 2J7s, Canada

Dialog Insight is enabled to send email messages to the users of the PINS Bonusway service. During the course of this technical procedure, the enterprise Dialog Insight will gain knowledge of personal information, such as the email address of the user.

Personal data, including the email address of the user, may be transmitted to Dialog Insight in Canada. This personal data are stored by Dialog Insight in Canada. Dialog Insight may pass these personal data collected through the technical procedure to third parties.

Emails are only sent if the user has given explicit consent for that.

15. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which user is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of user or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of user which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if user is a client of PINS Bonusway (Recital 47 Sentence 2 GDPR).

16. The legitimate interests pursued by PINS Bonusway or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

17. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

18. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of user to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that user provides us with personal data, which must subsequently be processed by us. user is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with user could not be concluded. Before personal data is provided by user, user must contact our Data Protection Officer. Our Data Protection Officer clarifies to user whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

19. Existence of automated decision-making

We do not use automatic decision-making.