Privacy Policy

Last updated: March 27, 2025

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use Piny (“the Service”) and tells You about Your privacy rights and how the law protects You.

We use Your personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words with initial letters capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

• Account means a unique account created for You to access our Service or parts of our Service.
• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to Pinegrow Pte. Ltd. as the legal entity that collects Consumers' personal information and determines the purposes and means of processing Consumers' personal information, or on behalf of which such information is collected.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Pinegrow Pte. Ltd., 30 Petain Road, Singapore. For the purpose of the GDPR, the Company is the Data Controller.
• Consumer, for the purpose of the CCPA, means a natural person who is a California resident.
• Cookies are small files placed on Your computer, mobile device, or any other device by a website, containing details of Your browsing history on that website among other uses.
• Country refers to Singapore.
• Data Controller, for the purposes of GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to Piny, including any related websites and services we operate or provide in connection with Piny.
• Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service. It may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of the Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers, and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used might include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide You with services available through the Service and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts.
• Cookies Policy / Notice Acceptance Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies identify if users have accepted the use of cookies on the Service.
• Functionality Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies allow Us to remember choices You make when You use the Service, such as remembering your login details or language preference.
• Tracking and Performance Cookies
  Type: Persistent Cookies
  Administered by: Third-Parties
  Purpose: These Cookies are used to track information about traffic and how users use the Service. The information gathered may directly or indirectly identify You as an individual visitor.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service: including monitoring the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service.
• For the performance of a contract: the development, compliance, and undertaking of any purchases or other contracts with Us.
• To contact You: by email or other electronic communication regarding updates or informative communications about the Service, when necessary.
• To provide You with news, special offers, and general information: about other goods and services unless You opt not to receive such information.
• To manage Your requests: to attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger or other business transfer in which Personal Data is among the assets transferred.
• For other purposes: such as data analysis, identifying usage trends, and improving Our Service.

We may share Your personal information in the following situations:

• With Service Providers: to monitor and analyze the use of our Service or to contact You.
• For business transfers: in connection with or during negotiations of any merger or sale of Company assets.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Service.

Transfer of Your Personal Data

Your information, including Personal Data, may be processed at the Company's operating offices and any other places where the parties involved in the processing are located. Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

Other Legal Requirements

The Company may disclose Your Personal Data in good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Analytics

We do not use Google Analytics. However, We may use a self-hosted or EU-hosted analytics tool such as PostHog. This tool helps Us understand how You use our Service so that We can improve the user experience. Data collected is processed in the EU where possible.

Email Marketing

We may use Your Personal Data to contact You with newsletters and other information that may be of interest to You. You can opt-out of receiving these communications by following the unsubscribe link or by contacting Us.

Payments

We may provide paid products and/or services within the Service. In such cases, We may use third-party services for payment processing (e.g., payment processors). We will not store or collect Your payment card details; that information is provided directly to the third-party payment processors.

CCPA and GDPR Compliance

We comply with the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR) to the extent they apply to Us. We do not sell personal data. If You are a California resident or reside in the EU, You may have certain rights regarding Your personal data, including the right to access, correct, or delete Your information, and the right to object to or restrict processing of Your data. Please contact Us if You wish to exercise any of these rights.

Children's Privacy

Our Service is not primarily directed to children under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, You can contact us:

• By email: info@pinegrow.com