Privacy Policy

1. Who we are and how we process your personal data

Pin Vision is committed to the protection of personal data of its users. This document has been drawn up in accordance with art. 13 and art. 14 of EU Regulation 2016/679 (hereinafter: “Regulation”) to help you understand what is our policy concerning your personal data, and how we process them when you use our site or our apps: (hereinafter: “Site” or “App”). 

The information and data provided by you or otherwise acquired during the use of Pin Vision’s services will be processed in compliance with the provisions of the law and with the security of personal data that inspire Pin Vision’s activity. 

The data processing activities will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality. 

Data controller

The data controller is Pin Vision s.r.l., located in Via Roma 6 – Pino Torinese (TO), (hereinafter “Pin Vision”) and can be reached at the following e-mail address: [email protected].

2. What data we collect and why

Data collected:

  • Registration data and use of the service 

    Data referring to your person (Name, surname, email address, telephone, Golf Club affiliation, date of birth) in order to register you to the Platform. 

    Location Information: We collect accurate or approximate location information from your mobile device, if you give us your consent. Pin Vision collects this data when the app is running and until the user ends the training session (the app is either open in the foreground of the screen or is running in the background and there is an icon or notification) on the device. The GPS authorization is required for the provision of the service and for the calculation of the distance between the player and the golf hole. 

    We collect data about how users interact with our services (such as time of access, application functionality or pages viewed, application crashes and other system activities, browser types). In some cases, we use cookies, pixels, tags and similar technologies that create and maintain unique identifiers for this purpose. To learn more about these technologies, please see our Cookie Policy

  • Browsing Data on the Site or App 

    In some cases, we use cookies, pixels, tags and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Policy

How we use your personal data

We process your personal data in order to:

  1. Allow the provision of the Services requested by you (create and update user accounts, calculate the player’s position in the game areas); 
  2. Respond to requests for assistance or information; 
  3. Comply with any legal, accounting and tax obligations; 
  4. Perform statistics on the use of the Services to improve their functionality; 
  5. Send you emails about Pin Vision Services; 
  6. Send you marketing communications regarding new services offered by Pin Vision or our Partners (such as promotions by Golf Clubs). You will receive promotional communications regarding our Partners’ services but we do not sell or share your personal data with our Partners without your specific consent. 

The lawful basis for the processing of personal data for the purposes set out above in letters a-b-d-e is art. 6(1)(b) of the Regulation as the processing is necessary for the provision of the Services or to answer data subjects requests. The provision of personal data for these purposes is optional but failure to do so would make it impossible to use the App. 

The purpose referred to letter f is carried out on the basis of the specific consent provided during the registration. Marketing communications may concern new products offered by Pin Vision or products and services offered by our Partners. The user can always withdraw his consent through a specific link at the end of the emails. 

3. Who we share data with

We will disclose your personal data if this is necessary to provide our services or if you have given your consent to do so. We may share your personal data with: 

“Data Processors”: they help us to provide you the Services, they have a contractual relationship with Pin Vision that binds them to specific contractual obligations of confidentiality for personal data they process on our behalf: 

  1. persons, companies or professional firms that provide assistance and advice to PinVision in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services; 
  2. persons with whom it is necessary to interact in order to provide the Services (for example, the hosting providers that provide the IT infrastructure and where we store your personal data);
  3. subjects delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks); the list of data processors who process data can be requested from the Data Controller by writing to the following address: [email protected]
4. How long we store your data

Pin Vision stores personal data about your user profile, game history and other personal information as long as you maintain your account and as long as necessary to comply with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.

5. Data subjects rights

Under art. 15 and following of the Regulation you have the: 

    1. Right to access – the right to request 
      • (i) copies of the information we hold about you at any time, or 
      • (ii) that we modify, update or delete such information.

If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is manifestly unfounded or excessive. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

  1. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete. 
  2. Right to erase – the right to request that we delete or remove your Data from our systems.
  3. Right to restrict our use of your Data – the right to limit the way in which we can use it. 
  4. Right to data portability – the right to request that we move, copy or transfer your Data. 
  5. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests. 

For information about managing your personal data, for any doubts or request concerning them please submit a request to us at [email protected].