GENERAL PRIVACY POLICY

  1. INTRODUCTION
    1. Pointy ("we", "us", "our") understands the importance of privacy to the people who visit our site or use any of our services. 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 experience while on Pointy.
    2. This General Privacy Policy (also “Policy” or “Privacy Policy”) outlines how we may collect, receive, process, store, use and disclose information about 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).
    3. 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 set the parameters of the legal relationship between Pointy and you. By using our services you consent to us interacting with your information in the ways described below.
    4. 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.
  2. APPLICATION OF THE POINTY PRIVACY POLICY
    1. This Policy applies to our Website and to the App and to any agreements wherein this Policy is expressly mentioned.
    2. This Policy does not apply to any website, mobile application, product or service of any third-party company even if same links to (or from) our website, mobile application, product or service.
    3. Your continued access of the Website or use of the App will signify your acceptance of this Policy. If you do not agree with this Policy you must not access the Website, download or use the App.
  3. DEFINITIONS
    1. Should you wish to understand more about your privacy rights and the legislative framework in relation to data protection we recommend that you visit the website of the Data Protection Commissioner, www.dataprotection.ie. For the purposes of this policy the following terms are defined:
    2. “aggregated information” and “anonymised information” means information:-
      1. wherein an individual living person cannot be identified; or
      2. which has been altered so that an individual living person cannot be identified.
      “disclose / disclosure” means the transfer of information by us to a third party.

      “personal information” means information relating to an individual living person who is or can be identified from that information, e.g. name, address and telephone number.

      “sensitive personal information” means any personal information to race, ethnicity, political affiliations, health or criminal record of the information subject. We do not require or collect any sensitive personal information from our visitors or users.

      “use” means, in the context of our use of your information, any and all actions undertaken by us internally in relation to that information. It is important that the difference between use and disclosure is understood.
  4. HOW WE OBTAIN INFORMATION ABOUT YOU
    1. We may collect and process the following information about you:
    2. Information you give to us

    3. 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. This information is personal information if you as an individual can be identified by that information.
    4. Information we collect about you

    5. 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. Below is a list of the types of information we may collect:
      1. technical information, including the Internet protocol (IP) address used to connect your device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
      2. information about your visit, including the full clickstream to, through and from our Website or App pages (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
      3. When you access the Website by or through a mobile device and for App use, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates, Bluetooth identifiers or similar information regarding the location of your mobile device. You may configure your device not to provide this information, however some features we provide, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

      Information we receive from other sources

    6. 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 third parties e.g. business partners, advertising networks, analytics providers, search information providers and credit reference agencies.
  5. COOKIES
    1. 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.
  6. HOW WE MAY USE INFORMATION
    1. We may use the information held about you in the following ways:
    2. Information you give to us

    3. We will use this information to:
      1. provide you the features and functions inherent in the Website and the App;
      2. carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
      3. provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. This information will be served to you during your visit to our Website or use of the App.
      4. notify you about changes to our service; and
      5. ensure that content from our Website and App is presented in the most effective manner for you and for your device.

      Information we collect about you

    4. We reserve the right to use this information for whatever reason, however in the main we will use this information:
      1. to administer our Website and App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      2. to improve our services to ensure that content is presented in the most effective manner for you and for your device;
      3. to allow you to participate in interactive features of our Service, when you choose to do so;
      4. as part of our efforts to keep our Website and App safe and secure;
      5. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
      6. to make suggestions and recommendations to you and other users about goods or services that may interest you or them.

      Information we receive from other sources

    5. We may combine this information with the information you give to us and the information we collect about you. We may use this information and the combined information for the purposes set out above.
  7. DISCLOSURE OF YOUR INFORMATION
    1. We do not disclose your personal information to advertisers. We may provide them with anonymised or aggregated information about our users. For example, we may inform them that 500 men aged under 30 have searched for a certain branded product in an area in a particular period.
    2. We may disclose your personal information with any member of our group, which means any subsidiaries, any ultimate holding companies and its subsidiaries and our assigns.
    3. We may disclose your personal information to third parties:
      1. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
      2. If Pointy or substantially all of its assets are acquired by a third party, personal data held by it about its users will be one of the transferred assets.
      3. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service of the Website or the terms of the End User Licence Agreement and any other agreements; or to protect the rights, property, or safety of Pointy, its users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    4. We may share your information with selected third parties including:
      1. Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
      2. Analytics and search engine providers that assist us in the improvement and optimisation of our Website.
  8. WHERE WE STORE THE INFORMATION
    1. The data 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. By submitting your personal data, you agree to this transfer, storing or processing. We will endeavour to ensure that your data is treated securely and in accordance with this Policy.
    2. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
    3. The security of information transmitted via the internet cannot be completely guaranteed. Although we implement technical safeguards to protect your personal data, we cannot guarantee the security of your data transmitted to our Website or App; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to prevent unauthorised access. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
  9. COMMUNICATIONS TO YOU
    1. We may use the information we collect or receive about you to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. We also use your information to send you Service-related emails (e.g., account verification, changes/updates to features of the service, technical and security notices). All these communications will be from Pointy to you.
  10. YOUR RIGHTS
    1. 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.
    2. 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.
    3. 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.
    4. 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.
    5. You have the right to access personal information held by us about you. We may charge you an administrative fee to provide you with this information however this fee will not be in excess of 6.35 Euro. We will endeavour to comply with your request in a timely manner.
  11. ACCESS TO THIRD PARTY WEBSITES OR SERVICES
    1. Our Website or App may, from time to time, contain links to and from Third-party Sites or Services (as defined in the End-User Licence Agreement – App User). Third-party Sites or Services are not under our control, and we are not responsible for and do not endorse their content or their privacy policies (if any). You will need to make your own independent judgement regarding your interaction with any Third-party Sites or Services. Please check these policies before you submit any personal information to these websites.
  12. CHANGES TO OUR PRIVACY POLICY
    1. Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.
  13. PERSONS AGED 13 to 17
    1. 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.
  14. CONTACT
    1. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@pointy.com.

Last Updated: 01-2016