Introduction

When we say “personal data,” we mean information that can identify you, such as your name, email, address, phone number, bank account details, payment information, support inquiries, community comments, etc. If you cannot be identified (for example, when personal data is aggregated and anonymized), this notice does not apply. See our Terms of Use for more information on how we handle other data. We may need to update this notice. When the change is significant, we will make sure to notify you – usually by sending you an email.

Pinomm.com collects only the strictly necessary personal data to provide you with its services.

Last updated: June 2024.

Who is the data controller?

“Bulsago Trade Solutions” Ltd., UIC: 207726639, with its headquarters and address of management at: Varna, “Primorski” district, “Sveti Georgi” Street No. 11, email: [email protected], website: www.pinomm.com, (hereinafter referred to as “We”), is the controller of your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), referred to as the “Regulation.”

Data Protection Principles

Security: We have taken all possible measures to protect personal data – both technical and programmatic. Management: We manage, store, and process your personal data responsibly.

How We Collect Your Data

When you visit our websites or use our services, we collect strictly necessary personal data to provide our services.

The ways we collect it can generally be categorized as follows:

Information you provide directly: When you visit or use certain parts of our websites and/or services, we may ask you to provide personal data. For example, we request your contact information when you sign up for a free trial, respond to a job offer or email quote, participate in community forums, join us on social media, participate in training and events, contact us with questions, or request support. If you do not want to provide us with personal data, you are not obliged to, but this may mean you cannot use some parts of our websites or services.

Information we collect automatically: We collect some information about you automatically when you visit our websites or use our services, such as your IP address and possibly device type. We also collect information when you navigate our websites and services, including which pages you viewed and what links you clicked. This information is helpful to us as it helps us understand better how you use our websites and services, so we can continue to provide the best possible experience (e.g., by personalizing the content you see). Some of this information is collected using cookies and similar tracking technologies.

Information we receive from third parties: Most of the information we collect, we collect directly from you. Sometimes we may collect personal data about you from other sources, such as publicly available materials. We use this information to supplement the personal data we already hold about you, to better inform, personalize, and improve our services, as well as to validate the personal data you provide.

When we collect personal data, we will process it only:

• To fulfill a contract with you, or
• When we have legitimate interests to process the personal data and they are not overridden by your rights, or
• In accordance with a legal obligation, or
• Where we have your consent.

If we do not collect your personal data, we may not be able to provide you with all our services and some features and functions of our websites may not be available to you.

If you are an individual who has no connection with us but believe that a subscriber of Pinomm.com has entered your personal data into our websites or services, you will need to contact Pinomm.com for any questions you have regarding your personal data (including where you want to access, correct, modify, or request the user to delete your personal data) at [email protected].

How We Use Your Data

We use your personal data to manage and provide our services to you.

We also use your personal data for other purposes, which may include the following:

To Communicate with You: This includes, but is not limited to:

• Providing information you have requested from us (such as training materials or training sessions) or information we are required to send to you
• Operational communications, such as changes to our websites and services, security updates, or assistance with using our websites and services
• Marketing communications (regarding Pinomm.com or other products or services we believe may interest you) in accordance with your marketing preferences
• Requesting feedback or inviting you to participate in any surveys we conduct (for which we may engage a third party to assist).

To Assist You: This may include assistance in resolving technical support issues or other issues related to the websites or services, whether via email or otherwise.

To Improve Our Websites and Services and Develop New Ones: For example, by tracking and monitoring the use of websites and services to continue improving them, or by performing technical analysis of our websites and services to optimize your user experience and provide more effective tools.

For Protection: To detect and prevent any fraudulent or malicious activity and ensure that everyone uses our websites and services fairly and in accordance with our terms of use.

To Offer You Additional Products and Services: In addition to sending marketing communications, we may also use your personal data to analyze your usage and make relevant and tailored offers to you.

To Analyze, Summarize, and Report: We may use the personal data we collect about you and other users of our websites and services (whether obtained directly or from third parties) to produce aggregated and anonymized analyses and reports that we may share publicly or with third parties.

How We May Share Your Data

There will be times when we need to share your personal data with third parties. We will disclose your personal data only to:

• Regulatory bodies, law enforcement agencies, government agencies, courts, or other third parties when we believe it is necessary to comply with applicable laws and regulations, or to exercise, establish, or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure.
• Third parties where we have your consent.

Security

Security is a priority for us when it comes to your personal data. We protect your personal data and have appropriate technical, software, and organizational measures in place to ensure this.

Storage

We store your personal data for the legally required periods or until we receive an explicit request from you to delete this data.

After this period, we will ensure it is deleted or anonymized.

Your Rights

These are your personal data, and you have certain rights related to them. When it comes to marketing communications, you can ask us not to send you such communications at any time – simply follow the unsubscribe instructions contained in the marketing communication, or make your request at [email protected]. You also have the right to:

• Know what personal data we hold about you and ensure it is accurate and up to date
• Request a copy of your personal data or ask us to restrict the processing of your personal data or delete it
• Object to the continuation of our processing of your personal data

You can exercise these rights at any time by making a request in free text and sending it to [email protected]. If you are not satisfied with how we process your personal data, please let us know by sending an email to [email protected]. You will receive a response from us within a reasonable timeframe.

How to Contact Us

If you have any questions, please contact us at [email protected].