1. INTRODUCTION

PinSpace SRL ("PinSpace," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect information in relation to our social networking service PinSpace (the "Service"), and your choices about the collection and use of your information.

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, do not use our Service.

Our company details:
PinSpace SRL
Registered address: Jud. Suceava, Municipiul Suceava, Strada LAZĂR VICOL, Nr. 15, Bl. E37, Scara A, Ap. 47
EUID: ROONRC.J2025045812003
Contact: support@pinspace.com

2. INFORMATION WE COLLECT

We collect information you provide directly to us, information we collect automatically when you use our Service, and information from other sources.

2.1 Information You Provide to Us
- **Account Information**: Username, email address, password, and date of birth (to verify age)
- **Profile Information**: Profile picture, bio, and any other information you choose to add
- **Content**: Photos, videos, links, text, and other content you share in your collections
- **Communications**: Messages you send through our Service, feedback, and correspondence with us
- **Collections and Subscriptions**: Information about collections you create and subscribe to

2.2 Information We Collect Automatically
- **Usage Information**: How you interact with our Service, including collections viewed, content shared, searches performed, and features used
- **Device Information**: Hardware model, operating system, unique device identifiers, mobile network information, IP address, browser type, and app version
- **Location Information**: General location derived from IP address
- **Log Information**: Server logs that may include IP address, access times, app features accessed, and system activity
- **Cookies and Similar Technologies**: We use cookies, web beacons, and similar technologies to collect information about your browsing activities

2.3 Information From Other Sources
- **Other Users**: Other users may provide information about you when they share content featuring you or mention you
- **Social Media Platforms**: If you choose to link your account with other platforms
- **Third-Party Services**: Information from services you connect to share content to PinSpace

3. HOW WE USE YOUR INFORMATION

We use the information we collect to:

3.1 Provide and Improve Our Service
- Operate and maintain your account
- Enable you to create and manage collections
- Facilitate subscriptions and notifications
- Process and deliver content sharing
- Personalize your experience
- Develop new features and improve existing ones

3.2 Communicate With You
- Send you Service-related notifications
- Respond to your comments, questions, and requests
- Send you technical notices and security alerts
- Provide customer support

3.3 Ensure Safety and Security
- Detect and prevent fraud, spam, and abuse
- Verify accounts and activity
- Monitor and analyze trends and usage
- Comply with legal obligations
- Enforce our Terms of Use and other policies

3.4 Legal Basis for Processing (GDPR)
We process your personal data based on:
- **Consent**: For certain types of processing, such as marketing communications
- **Contract**: To provide you with the Service under our Terms of Use
- **Legitimate Interests**: To improve our Service, ensure security, and operate our business
- **Legal Obligations**: To comply with applicable laws and regulations

4. HOW WE SHARE YOUR INFORMATION

4.1 Information Shared on the Service
- **Public Content**: Collections and content you make public can be viewed by anyone
- **Subscribers**: Users who subscribe to your collections receive notifications when you add content
- **Username and Profile**: Always public and viewable by anyone

4.2 Information Shared with Third Parties
We may share your information with:
- **Service Providers**: Companies that provide services on our behalf (hosting, analytics, customer support)
- **Legal Requirements**: When required by law or to respond to legal process
- **Protection of Rights**: To protect the rights, property, or safety of PinSpace, our users, or the public
- **Business Transfers**: In connection with any merger, sale of company assets, or acquisition
- **Aggregated Information**: Non-identifiable aggregated data for analytics and research

4.3 We Do Not Sell Your Personal Information
We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

5. DATA RETENTION

We retain your information for as long as your account is active or as needed to provide you with our Service. We will retain and use your information as necessary to:
- Comply with our legal obligations
- Resolve disputes
- Enforce our agreements
- Maintain security and prevent fraud

When you delete your account, we delete your personal information, though some information may persist in encrypted backups for a limited period. Content you shared that was re-shared by others may remain visible.

6. YOUR RIGHTS AND CHOICES

6.1 Your GDPR Rights
As an EU resident, you have the right to:
- **Access**: Request a copy of your personal data
- **Rectification**: Correct inaccurate or incomplete data
- **Erasure**: Request deletion of your personal data
- **Restriction**: Request restriction of processing
- **Portability**: Receive your data in a structured format
- **Object**: Object to certain types of processing
- **Withdraw Consent**: Where processing is based on consent

To exercise these rights, contact us at support@pinspace.com.

6.2 Account Information
You can update your account information at any time through your account settings.

6.3 Communication Preferences
You can opt out of non-essential communications through your account settings or by following unsubscribe instructions in emails.

6.4 Cookies
Most browsers allow you to refuse cookies. Note that some features of our Service may not function properly without cookies.

7. CHILDREN'S PRIVACY

Our Service is not intended for children under 13. We do not knowingly collect personal information from children under 13. If we discover we have collected information from a child under 13, we will delete it immediately.

For users between 13 and 18, we provide age-appropriate experiences and encourage parental involvement.

8. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws than your country.

We take appropriate safeguards to ensure your personal information remains protected, including:
- Standard Contractual Clauses approved by the European Commission
- Ensuring recipients are in countries with adequate data protection laws
- Other lawful safeguards under GDPR

9. SECURITY

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These include:
- Encryption of data in transit and at rest
- Regular security assessments
- Access controls and authentication
- Security training for our staff

However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

10. THIRD-PARTY LINKS

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any material changes by:
- Posting the new Privacy Policy on this page
- Updating the "Last Updated" date
- Sending you an email notification
- Providing notice through the Service

Your continued use of our Service after changes constitutes acceptance of the updated Privacy Policy.

12. DATA PROTECTION OFFICER

For privacy-related inquiries, you can contact our Data Protection Officer at:
Email: dpo@pinspace.com
Address: PinSpace SRL, Jud. Suceava, Municipiul Suceava, Strada LAZĂR VICOL, Nr. 15, Bl. E37, Scara A, Ap. 47

13. SUPERVISORY AUTHORITY

You have the right to lodge a complaint with a supervisory authority, in particular:
- In Romania: National Supervisory Authority for Personal Data Processing (ANSPDCP)
- In your EU member state of residence, place of work, or place of alleged infringement

14. CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

PinSpace SRL
Email: support@pinspace.com
Data Protection Officer: dpo@pinspace.com
Address: Jud. Suceava, Municipiul Suceava, Strada LAZĂR VICOL, Nr. 15, Bl. E37, Scara A, Ap. 47
EUID: ROONRC.J2025045812003

15. COOKIE POLICY

15.1 What Are Cookies
Cookies are small text files placed on your device when you visit our Service. We use cookies and similar technologies to:
- Keep you logged in
- Remember your preferences
- Understand how you use our Service
- Improve our Service
- Deliver relevant content

15.2 Types of Cookies We Use
- **Essential Cookies**: Required for the Service to function properly
- **Functional Cookies**: Remember your preferences and personalize your experience
- **Analytics Cookies**: Help us understand how users interact with our Service
- **Performance Cookies**: Help us improve the performance of our Service

15.3 Managing Cookies
You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of our Service.

16. LEGAL BASIS SUMMARY

Here's how we process your data under GDPR:
- **Based on Contract**: Account creation, content sharing, collection management
- **Based on Legitimate Interests**: Service improvement, security, fraud prevention
- **Based on Consent**: Marketing communications, certain cookies
- **Based on Legal Obligation**: Compliance with laws, responding to legal requests

By using PinSpace, you acknowledge that you have read and understood this Privacy Policy.