Penny Pinch Privacy Policy: Penny Pinch: Cashless Payments, Money Transfer & Discounts!

Introduction

Penny Pinch Inc. (hereinafter, “we”, “us”, or “our”) (Company No. 2019/C118) values privacy and we are committed to protecting all Personal Information (as defined below) kept by us, in accordance with the relevant laws (including the Personal Data Protection Act, 2010), this Privacy Notice and our Terms of Use. For the avoidance of doubt, unless the context requires otherwise, the words used in this Privacy Notice shall have the same meanings stipulated in the Terms of Use.

This Privacy Notice describes our practices regarding the Personal Information we collect through your download and use of the Penny Pinch smartphone and mobile device application (the “App”), and your use of or access to the https://mypennypinch.com website (the “Site”) (collectively, together with the App, the “Platform”) and all content, products, services and functionality available at or through the App and the Site (collectively, together with the Platform, the “Services”).

This Privacy Notice explains:

The type of Personal Information we collect and how we collect it.
How we use your Personal Information;
The parties that we disclose the Personal Information to; and
The choices we offer, including how to access and update your Personal Information.

In the event of any conflict between the English and other language versions, the English version shall prevail.

By using our Services, you agree to the terms of this Privacy Notice and you will be deemed to have consented to the collection, use and disclosure of your Personal Information in accordance with this Privacy Notice.

What Kind of Personal Information We Collect and How We Collect It

“Personal Information” means any information that relates to you or allows someone to identify you, including, for example, your name, address, telephone number, e-mail address, information about your transactions in relation to the Services such as reward points, reward points account balances, redemption history, and account activities as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Information”, means, data that is not associated with or linked to your Personal Information including, aggregated information. Anonymous Information does not, by itself, permit the identification of individual persons.

In order to enable us to provide you this Service we may need to and/or may be required to collect, record, hold, use, disclose and store (i.e. “process”) Personal Information and Anonymous Information, including, but not limited to:

(a) Information you provide to us through your relationship with us, including but not limited to, information provided by you when using the Services, when interacting with the Merchants, when taking part in customer surveys, competitions and promotions. Examples include:

Personal Information from you, such as your first and last name, profile picture, photos or avatar, gender, age, ethnicity, marital status, educational level, interests, hobbies, precise location-based information, e-mail and mailing addresses, phone numbers, device ID numbers, and passwords when you create an account for our Services (“Penny Pinch Account”), and any other information you directly give us through the Services (including, but not limited to messages that you send through the Services).
Information about your interactions with the Services including, your engagement with Merchants, and the products and services you have purchased.
Information you disclose through your interactions with the Merchants.
Information necessary to complete a transaction through the Services, including your name and shipping information where applicable.
Information from written communications when you provide us feedback or contact us e.g. your name and e-mail address, as well as any other content included in the e-mail, to send you a reply

b) Information collected by technology via the Platform.

For example:

Information from you, including your web browser type, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, user profiles, and/or a date/time stamp for your visit, and, with respect to your mobile phone, the unique device identifier, better known as the Android ID.
Information from third party service providers, with your consent, which may include your profile content or other types of personally identifiable information.
Cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Platform. Persistent Cookies can be removed by following web browser’s directions.
Information from corresponding technologies used in connection with mobile phones, including the Android ID, to record date, time, search and viewing information related to your mobile phone.
Information about how you use and interact with the Platform and the Services via third party analytics services such as Google Analytics (https://www.google.com/analytics) or Google AdSense (https://www.google.com/adsense). Such third party analytics services may use Cookies to gather information such as the pages you visited, your IP address, a date/time stamp for your visit and the sites that redirected you to the Platform.

(c) Information from third parties or other sources which you have given your consent to disclose information relating to you and/or where not otherwise restricted.

(d) Information collected from you about others in situations where you decide to invite a third party to create a Penny Pinch Account. We will collect your and the third party’s names and e-mail addresses to send an e-mail and follow up with the third party.

How We Use Your Personal Information

a) For general use or collected by technology. In addition to the purposes stated above, we may use your Personal Information either to respond to requests that you make, or to aid us in serving you better, whether or not through technological means, for one or more of the following purposes:

to provide the Services.
to facilitate the creation of and secure your Penny Pinch Account on our network.
to identify you as a user in our system.
to provide improved administration of our Services.
to notify visitors about updates to our Services.
to promote our Services; or products, services and special offers of third parties whose products and services we think may be of interest to you.
to improve and customize the quality of experience when you interact with our Services.
to send you a welcome e-mail and to verify ownership of the e-mail address provided when your Penny Pinch Account was created.
to send you administrative e-mail notifications, such as security or support and maintenance advisories.
to respond to your inquiries related to employment opportunities or other requests.
to send offers and promotional materials related to our Services and for other marketing purposes.
to track user-specific information on what pages users access or visit.
to improve and customize the quality of experience when you interact with the Platform, and the Services.
for our day to day operations and administrative purposes including account management, billing and collection, audits, reporting and investigations.
for the purposes of enforcing or defending our legal rights and/or obtaining legal advice.
to assist in the prevention, detection or investigation of crime or possible criminal activities or for the administration of justice.
for security and internal audit purposes.
for such other purposes as may be directed or consented to by you; and
for all other purposes in relation to or incidental to the above.

(b) Creation of Anonymous Information. We may also anonymize or aggregate your Personal Information by excluding information (such as your name) that make the data personally identifiable to you. This Anonymous Information may be used to personalize the Services, including directing certain advertisements to make them more relevant to you or to analyze request and usage patterns so that we may enhance the content of the Services and improve the Platform navigation or for any related market research purposes, either internally or through third parties.

Disclosure of Your Personal Information

Subject to any laws (including regulations, guidelines and/or obligations) applicable to us and our Affiliates (as defined below) (whether in or outside St. Lucia), we may disclose your Personal Information as described below and elsewhere in this Privacy Notice:

(a) Third Party Service Providers. We may share your Personal Information with third party service providers who may be located within or outside St. Lucia (a) to provide you with the Services that we offer you through the Platform; (b) to conduct quality assurance testing; (c) to facilitate creation of accounts; (d) to provide technical support; and/or (e) to provide other services to us. These third party service providers are not required to use your Personal Information other than to provide the Services requested by us.

(b) Affiliates and Acquisitions. We may share some or all of your Personal Information with our joint venturers, or other companies under a common control (our “Affiliates”), in which case we will require our Affiliates to honor this Privacy Notice.

c) Social Networking Sites (SNS). The Services may, with your consent, automatically post, information on your SNS profile based on your most recent activities (e.g., you used a coupon to purchase tickets to the newest blockbuster movie). See the section on Third Party Websites below for more information.

(d) We Do Not Share Personal Information with Advertisers, but...we do, however, allow advertisers to request that their advertisements are directed at certain users (e.g., users in a certain geographic location, or age, gender and/or with certain interests). In the event that you interact with certain advertisements, the advertisers (or the company which the advertiser works with, for example, its advertising agency or an advertising network) may determine certain characteristics about you.

(e) Third Party directed or consented to by you. We may share your Personal Information with any persons directed by or consented to by you.

(f) Professional Advisors. We may share your Personal Information with our professional advisors including but not limited to legal advisors, tax advisors, financial advisors, auditors, insurance brokers etc.

(g) Other Disclosures. Regardless of any choices you make regarding your Personal Information, we may disclose Personal Information if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property or users of the Services; and/or (d) to investigate or assist us in preventing any violation or potential violation of the laws, this Privacy Notice, or the Terms of Use.

We may also be required to transfer your personal data outside of Malaysia for the purposes and to such third parties stated in this Notice.

Third Party Websites

When you click on a link or, in case of smartphone and mobile device, swipe left to connect to any other website or location, you will leave the Services and be redirected to another site and another entity may collect Personal Information or Anonymous Information from you. We have no control over, do not review, and cannot be responsible for, these external websites or their content. This Privacy Notice do not apply to these external websites or their content, or to any collection of data after you click on links or swipe left to connect to these external websites.

By using the Services, you will also be able to connect with third party services and your SNS. By logging-in to your SNS from our Platform, your SNS will provide us a token that allows them to recognize us when we ask, on your behalf, for access to your account information or to post information on your SNS profile. You will be able to revoke our access to any of your SNS at any time by amending the appropriate settings from within your account settings on your applicable SNS, though such revocation may limit the Services we are able to provide you. In addition, when you engage in certain activities within the Services, those activities may be automatically posted to your SNS profile. You will be able to disable this functionality at any time by logging into your SNS profile and selecting the option to disable this feature.

Your Choices

General
You have certain choices about personal information stored in our Platform. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.

Email Communications
If you receive an advertising or marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving such emails.

Your Privacy Rights:
In accordance with applicable law, you may have the right to:

Access Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update personal information stored for your account, or for data we do not control, we may refer you to the controller who is able to make the correction.
Request deletion of your personal information, subject to certain exceptions prescribed by law. Subject to applicable law, you may request that Penny Pinch delete information stored about you that is stored in our systems. However, if your data has been extracted from an external cloud-based service provider (e.g., G Suite, Office 365, Slack, etc.), the data will still be present in the cloud-based service provider’s system. To have this data deleted, contact the cloud-based service provider who hosts the data.
Request restriction of or object to processing of your personal information, if applicable, where such requests are permitted by law.

If you would like to exercise any of these rights, please log into your account, or contact us as detailed below. We will process such requests without undue delay and in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.

You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We do not discriminate based on the exercise of any privacy rights that you might have.

Your Rights to Access and Correct Your Personal Information

(a) Choices. We offer you choices regarding the collection, use, and sharing of your Personal Information. Nevertheless, should you decline to provide any Personal Information that is essential to us to enable us to process your application/request (for example for the registration), we may not be able to process your application/request or provide you with this Service.

We will periodically send you free newsletters and e-mails that promote the use of the Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the “unsubscribe” instructions provided in the e-mail you receive, by terminating your Penny Pinch Account or by contacting us directly (please see contact information below).
Despite your indicated e-mail preferences, you may not opt-out of communication related to the terms and conditions of the Services, including any updates to our Terms of Use or Privacy Notice unless you deactivate the use of the Services.

(b) Changes to Personal Information. You may have access to or change your Personal Information in our possession or control through your profile within your Penny Pinch Account. Any request of access to correct Personal Information may be subjected to a fee and to the provisions of the applicable laws. We reserve the right to decline requests that jeopardize the security and privacy of the personal information of others as well as requests that are impractical or not made in good faith. Additionally, it is important to note that system-recorded Personal Information is not editable. When we delete any information, it will be deleted from the active database, but may remain in our archives. To the extent permitted by law, we may also retain your information for fraud prevention or similar purposes required by laws.

What If Personal Information Provided by You Is Incomplete?

Where indicated (for example, during first-time sign-in for a Penny Pinch Account), it is obligatory to provide your Personal Information to us in order to enable us to process your application for a Penny Pinch Account, or for us to provide you with our Services. Should you decline to provide such obligatory Personal Information, we may not be able to process your application and/or provide you with our Services.

Disclaimer

The accuracy and completeness of your personal data depends on the information you provide. We assume that the information you have provided is accurate, up to date and complete unless you inform us otherwise.

Revisions to Privacy Notice

We may review and update this Privacy Notice from time to time to reflect changes in the laws, in our business practices, procedures and structure, and the community’s changing privacy expectations. The latest version of the Privacy Notice will be made available on the Platform.

Where we consider, at our sole discretion, that the revisions made on the Privacy Notice are substantive, notice of such revisions will be provided on the Platform or by such other means of communication deemed suitable by us, for example, by sending you an e-mail to the last e-mail address you provided to us. Please always note that you are responsible for updating your Personal Information and to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.

If you do not agree to the changes in our use of your Personal Information, you must notify us immediately and deactivate your Penny Pinch Account with us. Continued use of our Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Should you have any query in relation to this Privacy Notice or how we handle your Personal Information, kindly contact us at:
Penny Pinch Inc.
Suite 13, JQ Charles Rodney Bay Mall
Rodney Bay, Gros Islet
St. Lucia
support@mypennypinch.com