Data Protection and Privacy Policy

Data Protection and Privacy Policy

Data Protection and Privacy Policy

Effective Date: October 2024

Introduction

Easton Tech Ltd ("we", "us", "our") values your privacy and is dedicated to protecting your personal data. This Privacy and Cookies Policy outlines how we collect, use, and safeguard your information on our website, Playful Pineapple.

Core Principles

1. Transparency: We collect and use your data to enhance your experience, such as creating your profile and improving our services.
2. Security: Your data is securely handled and protected.
3. Control: You choose what communications you receive from us, with all notifications being opt-in only.
4. Data Erasure: When you delete your account, your data is irreversibly removed from our systems immediately.

Our Golden Rule 

Always be cautious with your personal information. Avoid sharing any content on Playful Pineapple or elsewhere online that you wouldn't want to be public or misused. This includes account details, photos, messages, etc. By using our site, you agree to follow this rule.

Purpose of this Policy 

This policy explains what personal information we collect and how we handle it. Please read it carefully and only use our services if you are comfortable with our practices.

Policy Updates 

We may update this policy from time to time. Continued use of our services after any changes indicates your acceptance of the new policy.

Data Collection

- Information You Provide: When you register or update your profile, you provide us with personal information, which may include sensitive data such as your name or alias, date of birth, height, body type, sexual orientation, ethnicity, hair colour, body alterations, habits, your base location, profile username, email address, a profile photo, a feature photo and your preferences.
- Automatically Collected Data: We collect data like IP addresses, browser types, device information, and activity logs including pages visited and interactions on our site.
- Verification Data: If you verify your age or perform certain actions, we may store a flag indicating you are over 18. This data is used to comply with legal requirements and is not publicly visible.
- Location Data: If you enable location-based features, we collect GPS data to show you relevant information about users near you. This can be disabled at any time.
- Service Provision: We process your data to fulfil our contractual obligations and provide you with our services.
- Consent: For sensitive data, we rely on your explicit consent, which you can withdraw at any time by deleting your account.
- Legitimate Interests: We use data to improve our services, understand usage patterns, and prevent fraud.

Cookies and Tracking Technologies

Our website uses cookies to enhance user experience and provide insights into site usage. Cookies can be session-based or persistent. Learn more about managing cookies at www.allaboutcookies.org.

Types of Cookies Used

- Session Cookies: Facilitate navigation through the site without re-authentication.
- Persistent Cookies: Save login details for faster access.
- Google Analytics Cookies: Help us analyse site traffic and usage patterns to improve our services.

By using our site, you agree to our use of cookies.

Use of Your Data 

- Service Delivery: Enable profile creation, send service notifications, process payments, and manage orders.
- Verification: Verify your age and other necessary information.
- Special Category Data: Display sensitive profile information to other users, if you choose to do so.
- Communication: Send you opt-in notifications for new messages or updates.
- Site Improvement: Track anonymised site usage and prevent fraud.

Data Retention

We retain your data as long as you have an active account. Upon account deletion, your data is permanently removed. We may also delete inactive accounts or those breaching our terms.

Sharing Your Data

- With Other Users: Information you post or make public on your profile is shared with other users. Viewing another user's profile may notify them unless you opt-out.
- Public Actions: Actions such as entering chat rooms or posting in forums may be visible to others.
- Law Enforcement and Legal Requirements: We may disclose data to authorities if required by law or to protect our rights.
- Third-Party Service Providers: We share data with partners for payment processing and other necessary services.
- Business Transactions: In the event of a sale or merger, your data may be transferred to the new owners.

Payment Information

Payment details are handled directly by our payment partner. We do not store this information. Our Payment partner may share data with credit reference and fraud prevention agencies.

Your Rights 

You have the right to access, rectify, delete, or restrict the use of your personal data. You can also object to data processing or request data portability, subject to legal requirements.

Contact and Complaints 

For privacy-related inquiries or complaints, contact us via the contact form. If you're unsatisfied with our response, you can lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.

Privacy Settings 

To delete your account and data, use the account deletion page.

Our Onboarding process, Age Assurance and Verification

We have processes in place that are intended to ensure that all Users on the Website are at least 18 years of age. During onboarding, we will ask you to go through a third-party process to gain assurances of your age. This process involves our third-party provider collecting a short .gif "selfie" (that you provide to the third-party provider) and using digital technology to estimate your age, which may involve the use of Face Recognition Data.

If you go through the third-party age estimation process, we will only receive the results of the process (pass / fail, the reason for failing and a selfie image), to maintain a record of the age estimation process.

If you fail the third-party age estimation process (e.g. if you are over 18 years of age, but their technology has predicted that you look under 18 years of age), you will be unable to complete registration and will have the opportunity to request a Manual Check to be made by a member of our Support team. 

If a Manual Check is requested, a member of our Support team will be able to see the results of the process (pass / fail, the reason for failing and the selfie image) and will contact you via email to request a copy of your ID. You must provide a valid form of ID for all users who are attempting to sign up to the Website.

In the interest of user safety and security, Easton Tech Ltd may conduct necessary checks with national databases and law enforcement authorities to verify the information provided.

The use of face recognition technology by our third-party provider is an important technological measure used in our onboarding process for our Users. It is intended to ensure safety on the Website and our compliance with applicable laws.

We use third-party service providers to carry out age estimation, who carry out these services on our behalf, as data processors.

UK GDPR Compliance

The Personal Data communicated by the User to the Company and/or published by the User from the Service is subject to data processing and is stored and used by the Company, in the Company’s capacity as the controller, for the duration of the User’s registration on the Service for the following purposes:

- Allow the User to access the Service and, where applicable, certain features, use its various functionalities, and administer their account;
- Connect the User with other users, if necessary, based on the criteria defined by the User;
- Register and manage the User’s preferences;
- Communicate with the User to respond to their requests;
- Send the User, upon request, information messages and/or promotional offers;
- Measure the performance of the Service, such as the number of pages viewed or clicks, and establish statistics for internal use;
- Respond to disputes or requests from authorities;
- Comply with the legal obligations imposed on the Company;
- Address legitimate interests, particularly in the management of the Company’s activities.

These data processing activities are carried out by the Company in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).

The processing conducted by the Company for the purposes outlined above is necessary to:

- Fulfil its contractual obligations to the User, particularly with respect to providing the services expected from the Service;
- Comply with legal obligations;
- Respond to legitimate business interests.

The Personal Data of the User is not disclosed or transferred to third parties for commercial or promotional purposes without the User’s prior and explicit consent.

The User's data is stored on secure servers hosted by Amazon Web Services in Ireland and is not transferred outside the United Kingdom or European Economic Area (EEA) without appropriate safeguards in place.

The User can access their account at any time to modify or delete information and data concerning them. The information will then be automatically and permanently removed from the Company’s database.

If the User unsubscribes from the Service by closing their account, the Personal Data related to them will be deleted within 36 months of the day of unsubscription, solely to allow the Company to comply with potential legal requests from public or judicial authorities.

In accordance with the UK GDPR and the DPA 2018, the User has the following rights concerning their Personal Data:

- Access their data;
- Rectify inaccuracies;
- Erase or request deletion of all or part of their data;
- Object to the processing;
- Limit the processing of their data;
- Portability of their data.

The User can exercise these rights by sending a request via email to: Easton Tech Ltd / Data Protection Officer (DPO) contact@eastontechltd.com

For data processing activities based on the User's consent, the User also has the right to withdraw their consent at any time.

The exercise of these rights does not affect the legality of data processing carried out prior to the withdrawal of consent, nor the Company’s right to retain certain Personal Data in accordance with the above-mentioned legal principles.

Requests must be submitted in writing by the User, signed, and accompanied by a copy of an ID bearing the User’s signature. This information will be processed solely for identification purposes and will not be retained longer than necessary to respond to the request. The request must specify the email or postal address where the response should be sent. The Company will respond within one (1) month of receipt of the request.

The User also has the right to file a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection authority, through their website (www.ico.org.uk).

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