GENERAL PRIVACY POLICY

Last updated on 24th May 2018.

Pointy ("we", "us", "our") understands the importance of privacy to the people who visit our site. We want to provide a service that is unique, useful and makes peoples' lives a bit easier. When we collect information, we always have this goal in mind - to provide people with the best possible Pointy experience.

This General Privacy Policy (also "Policy" or "Privacy Policy") outlines how we may collect, receive, process, store, use and share personal information and non-personal information about prospective users, visitors to our website, including all subpages and successor pages ("Website") and users of the Pointy mobile application (“App” as defined in the End-User Licence Agreement – App User).

Retailers who avail of our Services should consult the Retailer Privacy Policy and the End User Licence Agreement.

Personal information is information relating to a living individual who is or can be directly identified from that information, e.g. name and email address, or indirectly from that information in conjunction with other information.

Please carefully read this Policy together with the Terms of Service (if you are visiting our Website) or the End-User Licence Agreement – App User (if you have downloaded or use the App) as these two documents outline how we process your information and the terms on which we make our Website and App available to you. If you do not agree with this Policy you must not access the Website, download or use the App.

Legal documents can be complex but should be comprehensible. We have tried to used plain and simple English when drafting this Policy. Should you have any queries about this Policy please contact us at privacy@pointy.com.

Pomo Search Limited trading as Pointy is the data controller responsible for your information when you visit our Website or use our App. Our contact details are available below.

  1. Personal information we collect and process
  2. Information you give to us

    You may give us information about you by filling in forms on our Website or App or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when searching for a product, participating in discussion boards or other social media functions on our Website or App and when you report a problem with any of our products. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photographs.

    Information we collect about you

    With regard to each of your visits to our Website or use of our App we may automatically collect certain information about you. This information is predominately not personal information in and of itself but may be personal information if it can be combined with other information to identify you. Below is a list of the types of information we may collect:

    Information we receive from other sources

    We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that information that it may be shared internally and combined with information collected on this Website or App. We may also receive information about you from public sources, for example telephone directories, DNS records, and public web pages which mention you. We may also receive non-public information about you from third parties, for example our affiliate program operators and from credit reference agencies.

  3. Purpose and basis of collecting your personal information
  4. We use your personal information for the purposes described below, except where restricted by law.

    We process your information where necessary to further our legitimate interests where those legitimate interests are not overridden by your rights or interests. In particular, the processing of your personal information is necessary for the operation, improvement and expansion of the Website and App that we provide to you at your request. It is also in our legitimate interests to use your personal information to communicate with you about our Services and to notify you of changes to the Services

    If you do not object to us using your personal information, we may provide you marketing for our Services. It is in our legitimate interests to promote and market our Services. An example of when we rely on this legal basis is when we use your email address or telephone number to contact you on and gauge your interest in new features or service offerings that we think you could benefit from.

  5. Purpose of collecting your non-personal information
  6. We will use this information:

  7. Sharing of your personal information
  8. Where necessary, and in accordance with the purposes set out in this Policy, we share your personal information with third parties. However we do not share your personal information to advertisers so that they can market their products directly to you.

    We use a number of external providers to assist us to run and manage our business. It is necessary in some cases to share your personal information with these external service providers to assist us to manage our business and to provide you access to the Website and the App. We also share your personal information with marketing companies and advertisers to assist us promote our Service, Website and App. Examples of the types of service providers that we share your personal information with include:-

    When we share your personal information to these service providers, we require those third parties to protect that personal information with appropriate security measures and prohibit or restrict them from using the personal information for their own purposes or from disclosing the personal information to others. For example the web chat provider we use on our website can only process your email address for the purpose of facilitating you communicating with Pointy using that said provider’s web chat solution. They are not permitted to use the information we provide them to contact you or share that information to another third party.

    To the extent that it would be necessary for our legitimate interests and those of our affiliates, we may share your information with any member of our group, which means any subsidiaries, any ultimate holding companies and its subsidiaries and our assigns, together with any contractors we use to provide access to the Website and App to you.

    We may share your information to third parties:

    To the extent that it would be necessary for our legitimate interests and those of third parties, we may also share your information to third parties

  9. Security
  10. All the information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access a private section of the Website or the App, you are responsible for keeping this password confidential. We ask you not to share user passwords with anyone.

    The security of information transmitted via the internet cannot be completely guaranteed. Although we implement appropriate technical and organisational safeguards to protect your information, we cannot guarantee the security of your information transmitted to our Website or App; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to prevent unauthorised access.

  11. Data transfers
  12. The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. The privacy protections in these countries may not be equivalent to those in the EEA. We will only transfer personal information outside of the EEA where permitted to do so by law. These transfers are necessary for the management of the Pointy’s business operations. Pointy relies on the European Commission’s adequacy decisions on certain countries to transfer your information from the EEA.

  13. Your rights
  14. You have the following rights regarding the processing of your personal information:

    If you do not want to receive emails containing newsletters, promotions and special offers from us you have the right to opt-out and unsubscribe from these mailings.

    If you are a visitor to the Website and you no longer wish for us to interact with your information in the ways outlined in this Policy you should leave the Website immediately or change the settings of your web browser to ensure that same align to your needs.

    If you are an App user and you no longer wish for us to interact with your information in the ways outlined in this Policy you should cease using the App and delete it from your device(s). Please note that any information you have already provided to us or that we have collected from you or that we have received from third parties about you, may have already been processed by us.

    Following termination or deletion of the App from your device or your departure from the Website, we may retain any content, information or data generated by your use of the service for a commercially reasonable time.

    These rights may be restricted in certain circumstances, for instance where your information may be needed to comply with our legal obligations or for the defence or exercise of legal claims.

    Any information you have already provided to us or that we have collected from you or that we have received from third parties about you, may have already been used by us as outlined in this Policy. Our information retention policy is described below.

    You can exercise these rights by contacting us using the contact details listed at the end of the Policy.

    In circumstances where you are not satisfied with our use of your personal information or you are not satisfied with how we have responded to your request to exercise your rights, you have the right to lodge a complaint with the Irish Data Protection Commission, www.dataprotection.ie, (who is Pointy’s lead supervisory authority) or your local supervisory authority in the country in which you reside, whichever is more convenient. The Office of the Data Protection Commission can be contacted at info@dataprotection.ie or LoCall 1890 25 22 31.

  15. Retention
  16. We will retain your personal information for as long as is necessary for the purposes set out in this Policy or as needed for us to provide the Website or App. We will retain and use your personal information to the extent necessary to comply with our legal obligations, to resolve disputes and to enforce our agreements.

  17. Cookies
  18. We use cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

  19. Do Not Track & Website Analytics
  20. Some internet browsers allow users to flag their preference in relation to online tracking by websites visited by the user. This feature is typically referred to as “Do Not Track”. Currently we do not look for or respond to Do Not Track preferences made by visitors to our website.

    We work with various reputable third party services to help analyze and optimize our website, for example Google Analytics, Facebook and Adroll. We carefully vet companies with which we work, however we have no direct control over how these third parties track users to or from our website.

  21. Access To Third Party Websites
  22. Our Service may, from time to time, contain links to and from third-party sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

  23. Persons aged 13 to 17
  24. We recommend that young people aged 13 to 17 ask their parents or legal guardians for permission before using or accessing our Website or downloading our App, registering as a user or sending any information about themselves to anyone over the internet.

  25. Changes to This Policy
  26. This Policy may be updated from time to time. Any changes we may make to our Policy in the future will be posted on this page and we will notify you of any material changes by email or by prominently posting a notice of such changes.

  27. Contact Information
  28. Questions, comments and requests regarding this Retailer Privacy Policy are welcomed and should be addressed to us by email at privacy@pointy.com or you can write to us at 1 Stokes Place, St. Stephen’s Green, Dublin 2, D02 DE03, Ireland.

Last Updated: 2018-05-24