PRIVACY POLICY

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Email addresses
• Names (optional, if provided for email personalization)
• Contact preferences

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services, primarily via Google Analytics.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies, primarily through Google Analytics, which helps us understand website traffic.

The information we collect includes:

• *Log and Usage Data.* Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services (e.g., pages viewed, time spent, features used, IP address).
• *Device Data.* We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services (e.g., browser type, hardware model, operating system).
• *Location Data.* We collect location data such as information about your device’s general location (e.g., based on your IP address).

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes:

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We process your information to provide you with the freebie downloads and email newsletters you requested.
• To send administrative information to you. We may process your information to send you details about our policies, service changes, and other similar, non-marketing information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your preferences. You can opt out of our marketing emails at any time.
• To identify usage trends. We use data collected via Google Analytics and our email provider (Kit) to understand how our Services are being used so we can improve them (e.g., seeing which blog posts are most popular).
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, or to fulfill our contractual obligations.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose (e.g., signing up for the email list). You can withdraw your consent at any time.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms (e.g., to analyze site usage for improvement).
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share information with essential third-party service providers necessary to operate the blog and send emails.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties‘) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties designed to help safeguard your personal information.

The categories of third parties we may share personal information with are as follows:

• Data Analytics Services (e.g., Google Analytics)
• Sales & Marketing Tools (e.g., Kit or other email providers)
• Website Hosting Service Providers (e.g., Hostinger)

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use cookies primarily for site functionality and analytics (Google Analytics).

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. These are used to maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and track site performance via Google Analytics.

For more specific information about how we use cookies, please see our dedicated Cookie Notice (Link Placeholder).

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own, based on where our service providers (like Google Analytics and Kit) are located.

Our servers are located in France, however, please be aware that your information may be transferred to, stored by, and processed by us and the third parties with whom we may share your personal information (see ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?‘ above), including facilities in the United States, Canada, and other countries where our service providers operate.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information where required.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice. For example, Google Analytics retains event-level data for up to 14 months based on default settings. Kit retains email subscriber data generally for as long as you remain subscribed and the account is active. When personal information is no longer needed, we securely delete or anonymize it.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet can be guaranteed to be 100% secure. Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at thepinsightsproject@gmail.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location (US state, EEA, UK, Canada, etc.), you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) to object to the processing of your personal information.

Withdrawing your consent: If we are relying on your consent (like for email marketing), you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the details below or by clicking the unsubscribe link in the emails we send.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists. However, we may still send you service-related messages.

If you have questions or comments about your privacy rights, you may email us at thepinsightsproject@gmail.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of certain US states (e.g., California, Virginia), you may have the right to request access to or deletion of your personal information.

If you are a resident of California, Colorado, Connecticut, Virginia, or other states with comprehensive privacy laws, you may have the right to request access to and receive details about the personal information we maintain about you, correct inaccuracies, or delete your personal information. Since we do not sell or engage in targeted advertising, many of the complex sections do not apply to us.

Categories of Personal Information We Collect

In the preceding twelve (12) months, we have collected the following categories of personal information:

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months (as defined under US state laws, meaning we do not use your data for cross-context behavioral advertising).

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at thepinsightsproject@gmail.com.

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand: We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020. This Privacy Notice satisfies the notice requirements defined in both Privacy Acts.

Republic of South Africa: If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the Information Regulator (South Africa).

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated ‘Last updated’ date at the top of this Privacy Notice. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at thepinsightsproject@gmail.com or contact us by post at:

The PinSights Project
[YOUR PHYSICAL ADDRESS HERE] (Please replace with a valid contact address)
Kenya

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please email us directly at thepinsightsproject@gmail.com.