Pin-Up Privacy Policy

Pin-Up provides this document to explain the collection, processing, protection, disclosure, and destruction of personal information related to its online services for Bangladesh users. The policy describes what data is collected, how it is used, and the safeguards applied. Use of data is based on user consent and the choices available in account settings. By using the websites and apps, each user accepts these terms and the stated practices.

Privacy and Data Protection

  • Categories of personal data collected:
    • Identification and contact: name, date of birth, address, email, phone.
    • Account details: username, profile settings, responsible play preferences.
    • Verification data: identity documents, proof of address, photos or video for KYC.
    • Transaction and payment information: deposits, withdrawals, method identifiers (tokenised), billing records.
    • Technical data: device identifiers, IP address, browser type, operating system, app version, log files.
    • Usage information: gameplay activity, session times, interaction data, preferences, communications with support.
    • Location data: approximate geolocation from IP as required for compliance and fraud prevention.
    • Cookies and similar technologies: details in the Cookies section of this policy.
  • Purposes for collection:
    • Provide and maintain services, create accounts, and verify user identity.
    • Process payments, withdrawals, and handle customer support.
    • Prevent fraud, ensure platform integrity, and support responsible play measures.
    • Meet regulatory and anti-money laundering obligations.
    • Improve online user experience, quality, and performance of services.
  • Security measures (technical and organizational):
    • Encryption in transit (TLS) and at rest for sensitive information.
    • Role-based access control, multi-factor authentication for staff systems, least-privilege policies.
    • Network segmentation, firewalls, intrusion detection, and continuous monitoring.
    • Vendor due diligence, confidentiality agreements, and regular security reviews.
    • Staff training, incident response procedures, and periodic audits.
    • Data minimization, purpose limitation, and retention schedules.
  • User rights (subject to verification and lawful exceptions):
    • Access: obtain a copy of personal data and information on processing.
    • Correction: update inaccurate or incomplete data.
    • Deletion: request erasure when data is no longer necessary or consent is withdrawn.
    • Restriction and objection: limit or object to certain processing.
    • Consent withdrawal: opt out of marketing and non-essential processing at any time.
  • Compliance statement for Bangladesh users:
    • Pin-Up complies with applicable laws of Bangladesh relating to information security and cybercrime, including the Cyber Security Act, 2023, and the Information and Communication Technology Act, 2006 (as amended).
    • Anti-money laundering: records are retained as required under the Money Laundering Prevention Act, 2012 (as amended) and relevant guidance of the Bangladesh Financial Intelligence Unit.
    • Pin-Up also follows internationally recognised data protection standards, including GDPR principles on lawfulness, fairness, transparency, purpose limitation, and data minimization.
  • Retention:
    • Personal data is kept only for as long as needed for the purposes set out in this policy or to meet legal requirements. Typical retention for KYC and transaction records is at least five years after account closure, subject to statutory obligations.
  • Contact for privacy requests:
    • Email: [email protected] (or the contact channel in the account).
    • Response time: Pin-Up aims to respond within 30 days, subject to identity verification.

Use of Collected Information

  • How information is used:
    • Account setup, verification (KYC), and eligibility checks.
    • Processing deposits, withdrawals, and managing transactional records.
    • Providing online services, customer support, and service notifications.
    • Preventing fraud, chargebacks, abuse, and enforcing platform rules.
    • Improving and personalizing user experience and content.
    • Analytics and statistics to monitor performance and reliability.
    • Compliance and reporting to regulators and relevant authorities.
    • Marketing communications based on user consent, including emails or on-site messages, and the ability to opt out at any time.
  • Lawful bases:
    • Contract: to deliver services requested by the user.
    • Legal obligation: anti-money laundering, sanctions screening, accounting.
    • Legitimate interests: security, fraud prevention, product improvement.
    • Consent: marketing, certain cookies, and optional features.
  • Transparency commitment:
    • Processing is conducted for specified purposes, using the minimum personal data necessary, and in a manner that maintains confidentiality and integrity.

Access to Information

  • How users can exercise their rights:
    • Access and update: use account settings or contact [email protected].
    • Correction: provide supporting information to amend inaccurate records.
    • Deletion: request erasure of personal data that is no longer necessary or where consent is withdrawn, except where retention is required by law.
    • Export: request a machine-readable copy of certain data, subject to technical feasibility.
  • Procedure:
    • Pin-Up may request identity verification before processing a request.
    • A response will be provided within a reasonable time, typically within 30 days.
    • Some data cannot be deleted immediately due to financial, AML, dispute resolution, or audit requirements.
  • Consent to checks and payment processing:
    • By using Pin-Up, the user consents to identity, age, sanctions, and risk checks to protect the platform and users.
    • The user also consents to the processing of payment information by authorised payment service providers and card schemes to complete transactions and prevent fraud.

Protection of Children’s Privacy

  • Pin-Up services are intended for persons aged 18 and above. Accounts for users under 18 are prohibited.
  • The operator cannot verify age without documents. Identity evidence may be requested during verification or at any time if misuse is suspected.
  • If a parent or guardian believes a minor has provided personal information, contact [email protected]. Pin-Up will delete the account and associated personal data where required by law.
  • Any report of underage activity may result in preservation of limited information for investigation and compliance purposes.

International Data Transfers

  • Personal data may be stored or processed outside Bangladesh in jurisdictions where Pin-Up or its partners operate data centres or provide services.
  • By using the websites or services, the user consents to such cross-border transfers and processing.
  • Safeguards include contractual commitments, confidentiality obligations, and data security controls aligned to international standards. Where applicable, standard contractual clauses or similar mechanisms are used to protect the information.
  • All partners handling personal data are required to maintain confidentiality and use the information only for the documented purposes.

Use of Cookies

  • Definition: Cookies are small text files placed on a device by websites or apps to store information about the user’s session and preferences.
  • Purposes of use:
    • Statistics and analytics to understand usage and improve services.
    • Behaviour analysis to prevent fraud and maintain security.
    • Personalization of content, language, and settings.
    • Site improvement through performance measurement and error diagnostics.
  • Categories:
    • Essential cookies: required for core functions like authentication and security.
    • Preference cookies: remember settings such as language or region.
    • Analytics cookies: measure usage and performance.
    • Marketing cookies: subject to consent and user controls.
  • Retention and control:
    • Standard retention period for non-essential cookies is 1 year.
    • Users can manage cookie preferences through browser or device settings and in on-site controls where available. Blocking some cookies may affect certain features of the services.

Acceptance of Privacy Policy

  • Use of Pin-Up services constitutes full acceptance of this Privacy Policy and any related documents referenced here.
  • The current version posted on the websites prevails over prior versions.
  • Material changes are indicated by an updated “Last updated” date. Continued use after changes indicates acceptance of the revised document.

Third-Party Privacy Practices

  • Sharing of personal data may occur in these situations:
    • Legal and regulatory: responses to lawful requests, compliance reports, sanctions screening.
    • Dispute resolution: banks, payment networks, chargeback handlers, arbitration bodies, courts.
    • Service provision under agreements: KYC/AML providers, payment processors, cloud hosting, analytics, customer support tools, fraud detection vendors.
  • Scope and purpose:
    • Third parties receive only the information required to deliver contracted services or meet legal obligations, and must not use it for unrelated purposes.
    • A list of principal processors and categories of recipients is maintained on the websites. If a specific party is not listed, users will be informed of the purpose and scope before sharing where practicable.
  • Consent:
    • Providing personal information to Pin-Up constitutes consent to share it with third parties for the purposes stated in this policy, subject to user choices and applicable law.
  • Responsibility:
    • Third parties operate under their own privacy policies. Users should review those documents to understand how information is processed by each provider.

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