PRIVACY NOTICE
Last updated: 12 September 2024
This privacy notice explains how we, Pineamite Ltd, company number 15545604 (we, us, our, Pineamite) process your personal data in connection with our online services such as our website, app or when you otherwise engage with us online or offline.
If you have any questions about your data protection rights or if you do not understand anything explained in this policy, please contact us by email to legal@pineamite.com.
1. Who does this privacy policy apply to?
Pineamite processes personal data in relation to the following categories of individuals:
· the users of our app;
· our partners who access our web portal;
· bystanders who are caught in the user contributions posted to our app; and
· anyone else who interacts with us, for example, job applicants, when you call, email or visit us or otherwise interact with us.
This notice applies to you if you act in your personal capacity, for example, as our user, and if you act in your professional capacity, for example, as an employee or agent of our corporate partner.
2. What categories of personal data do we process?
“Personal data” generally means any information that identifies you or relates to you, except for anonymised information that cannot reasonably be linked back to you. The different categories of personal data listed in paragraph 3 below reflect our data processing activities.
3. Why do we process your information?
Below we explain what personal data is necessary for each purpose and the lawful basis for processing the personal data, which is a technical legal reason for processing under English law. Our processes and data collection are kept under review, and we will update this privacy notice should any personal data no longer be necessary for the given purpose.
Purpose and description |
Personal data |
Lawful basis for processing (UK individuals) |
To assist with your enquiries. |
· general details · account details · details of your query |
Necessary for our legitimate interest in responding to enquiries, complying with the law and best practices. |
To provide our online services to our users, such as our website or app. For example, when you visit our website, your browser will provide your IP address, browser type and other technical information to enable us to display our content in a compatible manner. |
· account details · device and browser details |
Necessary for our legitimate interest in providing our services to the public and our users, complying with the law and best practices. |
To send you service communications about matters relevant to your use of our services and your engagement with us, such as surveys or other forms of active engagement, availability of new services, changes in our terms, etc. |
· general details · account details |
Necessary for the performance of our contract with you or, as the case may be, necessary for our legitimate interest in facilitating our services and organising related activities. |
To process user contributions, for example, to amalgamate user videos into a live stream or watch later video of sporting events, to identify and digitally anonymise individuals in the footage, to comply with a request to be blurred, etc. |
· user contribution data |
Necessary for our legitimate interest in providing our live stream and content to our users, partners and the public and to comply with data rights requests. |
To understand our audiences and user profiles for product and service development, research, market intelligence, marketing, advertising, content personalisation and business administration, as described below. Depending on purpose, we use your profile information in anonymised or pseudonymised or, when it comes to marketing by say email, identifiable form, e.g. your email address. In some cases, this will include information observed or inferred from your activity or other information about you. |
· all information as is necessary and proportionate |
Necessary for our legitimate interest in understanding our typical user profiles and demographics, for service development, research, market intelligence, marketing, advertising, content personalisation and business administration.
Where required by law, we rely on your consent to deploy cookies or similar technologies on your device or to read information on your device except where necessary for essential services. |
To send you relevant marketing communications in accordance with the law about our existing and new services by email, text, push, post or other channels if you are our existing user or, where required by law, if you give consent. |
· general details · account details · preferences and interests · engagement information |
We rely on your consent if you sign up or on soft opt-in (presumed consent) if you are our existing user. You can unsubscribe at any time.
Where required by law, we rely on your consent to deploy cookies or similar technologies on your device or to read information on your device except where necessary for essential services. |
If you are partner, to manage our professional relationship with you using our record management systems and engagement tools, identifying opportunities, contacting you by phone and sending you marketing communications. |
· professional opportunity records |
Necessary for our legitimate interest in the proper administration of our organisation and services and necessary for compliance with our legal obligations or activities in the substantial public interest. |
To ensure proper administration of our organisation, including to: · keep appropriate records about how our services are used; · resolve complaints; · conduct troubleshooting; · conduct equality monitoring; · ensure the health & safety and make reasonable adjustments to accommodate special needs; · register interactions with our communications, such as emails; · enforce our terms; · debt collection; and · similar purposes |
· all information as is necessary and proportionate including special category personal data |
Necessary for our legitimate interest in the proper administration of our organisation and services and necessary for compliance with our legal obligations or activities in the substantial public interest. |
To engage our third party service providers who may process your personal data on our behalf to facilitate the provision of our services and the fulfilment of essential service functions which we cannot fulfil ourselves, such as web hosting, cloud storage, IT, analytics, payments, plugins, communications, accounting, security, and others as well as our advisors such as lawyers, accountants, insurers and others. |
· all information as is necessary and proportionate to enable the relevant service |
Some activities are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring the proper operation of our services. |
To assess your job application and for business administration purposes.
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· details of your query · public data
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Necessary for our legitimate interest in responding to your query and, as the case may be, necessary for taking steps prior to entering into a contract. Special categories data may be processed as is necessary in the context of employment and social security laws. |
To share information with our affiliated companies.
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· all information as is lawful, necessary and proportionate |
Necessary for our legitimate interest in using our group’s resources to organise, develop and deliver our services, run our organisation and decide on future strategies. |
To ensure the security of our systems and online services. For example, we may monitor our networks and online services for suspicious activities, test and audit our systems, ensure compliance with our terms and deploy appropriate security measures. |
· device and browser details · usage data |
Necessary for our legitimate interest in ensuring the security of our organisation, people and services and necessary for compliance with our legal obligations. |
To share data with another organisation in accordance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our organisation |
· all information as is lawful, necessary and proportionate |
Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations. |
To process and share information as is required for our compliance with the law or to establish, exercise or defend legal claims.
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· all information as is lawful, necessary and proportionate |
Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims, or, where necessary and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws. |
We will update you about any new purposes of processing of your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.
4. Who else gets to see your data?
Where necessary, proportionate and lawful in connection with the purposes set out above, we will share your personal data with third parties, including with:
· our third parties that provide services or advice to us;
· our marketing, advertising and analytics partners;
· third parties who provide additional services, features or content to you, such as social media plugins;
· with your consent, our partners who may request information about your contribution;
· our affiliated companies;
· persons or authorities where we are compelled by law, responsible practices or for legal claims;
· the relevant entity in case of a merger, acquisition or collaboration; and
· other third parties where you have provided your consent.
5. Third parties may process your personal data
Some of the third parties who we share your personal data with process your personal data for their own purposes. You should check the privacy statements of these third parties and we are not responsible for how they may process your personal data. Some of our third party service providers may use your anonymised personal data for business administration and product development purposes.
6. How long is your personal data kept?
We will keep your personal data for as long as is necessary for the purposes listed above or longer, as may be required by law. You may contact us for further details or request deletion of your personal data at any time.
The table below illustrates what general retention periods may apply to specific categories of personal data. However, the periods may vary depending on circumstances in accordance with the law.
Category of personal data |
Retention period |
account details and general details |
3 years from collection or following account closure |
device and browser details, engagement information, preferences and interests, third party data, usage data |
6 years from collection |
professional opportunity records |
6 years from collection |
User contribution data |
2 years from collection |
Special category personal data |
Generally not retained or only kept for the duration of the relevant event. |
We will delete or anonymise your personal data upon or before the expiry of the retention period.
7. How do we secure your personal data?
We maintain appropriate organisational and technological safeguards consistent with best international standards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of the personal data we hold.
We also seek to ensure our third-party service providers do the same. We only appoint service providers under appropriate contract who provide sufficient guarantees about data security in accordance with applicable law.
We will endeavour to use the least amount of personal data as is required for each purpose. We will employ pseudonymisation and anonymisation techniques, where appropriate.
Where appropriate, we apply security measures such as encryption or hashing when sharing your personal data with third parties.
Our staff will access your personal data on a “need to know” basis.
8. Where is your personal data processed?
Your personal data will generally be held in the United Kingdom.
However, your personal data may be transferred where necessary to work with service providers or partners in countries different to your country of residence. Each recipient is subject to appropriate safeguards such as due diligence and the standard contractual clauses or similar contractual provisions for international transfers of personal data.
9. Categories of personal data
Category of personal data |
Description |
account details |
Username, password, and similar information. |
details of your query |
Information in your query, complaint, job application or other communication. |
device and browser details |
Information automatically provided by your device and browser including mobile device ID, internet protocol (IP) address, cookie ID, online identifiers, operating system, browser type, language, time zone setting, location and date and time of access. |
engagement information |
Information about your engagement with our emails and other communications or with our content on the Internet including open rates, click rates, view rates, active time spent, survey data, feedback data and similar information. |
general details |
Your name, date of birth, address, email, telephone number and similar information. |
preferences and interests |
Information about your preferences and interests known, observed or inferred from various sources. |
professional opportunity records |
Your personal and professional details as business customer, prospecting information and other opportunity records. |
public data |
Publicly available information about you. |
special categories data |
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. |
third party data |
Information provided by third parties about your interaction with our posts and content and ‘likes’ on social media platforms, and your preferences and interests received from our advertising and analytics partners, references from your previous employer, referees, membership organisations and other third parties. |
usage data |
Information about how you navigate and engage with our online services, features including online activity data such as downloads, clickstream data with URLs visited previously, log data, page interaction, such as scrolling, clicks, and mouse-overs, methods used to browse away from our website, information in security logs and similar information. |
user contribution data |
Image, video and sound recorded in the user’s footage. |
10. Opt-out
If you would like us to stop sending you marketing communications and to process your personal data for direct marketing purposes, please contact us.
You can request to stop receiving our marketing communications at any time by clicking on the unsubscribe link at the bottom of each marketing message and we will add you to a suppression list or otherwise arrange that you no longer receive marketing communications.
11. Your data protection rights
Upon providing a proof of your identity, where appropriate, we will endeavour to respond to your request relating to your:
· Right to information about matters set out in this privacy policy. You may also contact us for further details about our data retention policy and international data transfers.
· Right to make an access request to receive a copy of your personal data held by us.
· Right to rectification of any inaccurate or incomplete personal data.
· Right to withdraw consent previously provided.
· Right to object to our processing of personal data based on our legitimate interests such as processing for direct marketing purposes.
· Right to erasure of personal data that is no longer needed, for example, if you object to our profiling for advertising or personalisation purposes and also request erasure.
· Restriction on the processing of personal data, for example, where necessary while we deal with your enquiry.
· Right to human intervention in respect of any automated decision-making without human involvement that significantly affected you.
· Right to data portability from one service provider to another, where applicable.
· Right to lodge a complaint with the Information Commissioner’s Office.
All requests will be processed without undue delay and no later than within one month. If we cannot process your request within this period, we shall explain why and process it without undue delay.
12. Updates
If we make any changes to our privacy policy, you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.
If you do not agree with the changes, please do not continue to use our online services. Of course, if any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.