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Privacy Policy

Version 2.0 (27.08.2021)

Pongfinity respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we collect, process and share your personal data when you visit or purchase our products from the Pongfinity Store (www.pongfinity.store), visit our website or communicate with us, including on social media, and will tell you about your privacy rights.

You might have heard about us from different channels, such as Fanjoy clothing collection and our Pongfinity –mobile games. Those are independent controllers from us, and you can read more about how those use your personal data from their own privacy policies. 

  1. WHO IS THE DATA CONTROLLER?
  2. INFORMATION WE COLLECT AND HOW WE COLLECT IT 
  3. THE PURPOSES AND THE LAWFUL BASIS
  4. SHARING OF INFORMATION COLLECTED
  5. TRANSFER TO THIRD COUNTRIES
  6. DATA RETENTION
  7. HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS
  8. OTHER INFORMATION
  9. CHANGES TO THIS PRIVACY POLICY

 

1. WHO IS THE DATA CONTROLLER?

The data controller for the processing described in this privacy policy is: 

Pongfinity Entertainment Oy

P.O. Box 162

00250 Helsinki, Finland


If you have questions regarding this privacy policy, please contact us by email at support@pongfinity.fi 


If you visit our pages, communicate, or otherwise interact with us on social media such as Facebook, Instagram, and YouTube, please make sure to consult the specific privacy policy presented on such social medias or platforms. You should be aware that sometimes we may be jointly responsible for the data processing with the publisher of the social media or platform in question.

 

2. INFORMATION WE COLLECT AND HOW WE COLLECT IT

In the following we will tell you which types of personal data we may collect about you and how we collect it. In section 3 we have in a table explained the purposes for which we process your personal data and the lawful basis we rely on.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

  1. Identity Data includes first and last name, and company information.
  2. Contact Data includes email, telephone number and address.
  3. Transaction Data includes details on products and services you have purchased from us (Pongfinity Store) and details about payments to and from you.
  4. Profile Data includes purchases or orders made by you, your interests, preferences, feedback, your participation in competitions, activity on our website and social media platforms such as Facebook, Instagram, and YouTube, and demographic data, such as origin, gender and age.
  5. Technical Data includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  6. Usage Data includes information about how you use and interact with our website, social medias such as Facebook, Instagram, and YouTube.
  7. Marketing and Communications Data includes your preferences in receiving marketing from us and our partners and your communication preferences

The information is collected directly from you when you visit our website or interact with us on social medias, purchase our products, request marketing from us or otherwise communicate with us.

As you interact with our website or services, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. We may also receive Technical Data about you if you visit other websites or social medias employing our cookies. We will only apply cookies – other than strictly necessary technical cookies - if you have provided your consent. Please see our [LINK: cookie policy] for further details.

 

3. THE PURPOSES AND THE LAWFUL BASIS

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. Where you have provided your consent cf. GDPR Article 6(1)(a).
  2. Where we need to perform a contract, we are about to enter into or have entered into with you cf. GDPR Article 6(1)(b).
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests cf. GDPR Article 6(1)(f).

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Purpose/Activity

Type of data

Legal basis for processing including basis of legitimate interests

To manage and perform the contract with you including:

  • to register you as new customer
  • to allow you to purchase our products
  • to provide you with invoices and/or order confirmations
  • to order and deliver our products to you
  • to manage and collect payments for our products
  • to entitle you to customer advantages, provide customer service and support, including administration of complaints
  • and generally, to comply with our obligations and exercise our rights under agreements entered into with you

(A) Identity

(B) Contact

(C) Transaction



Performance of a contract with you or to take steps at the request of you prior to entering a contract

Compliance with a legal obligation (bookkeeping, accounting and tax)

To analyse and improve our business procedures and practices

(A) Identity

(B) Contact

(C) Transaction

(D) Profile

(E) Technical

(F) Usage

Necessary for our legitimate interest to analyse and improve our business, including our products and services

To enable you to access and interact with our website

(E) Technical

Necessary for our legitimate interest to provide you access to our website.

In so far as you interact with us in context of the Store, also performance of a contract.  

To enable you to communicate with us on the website, in e-mail, via social medias or otherwise, and to allow you to participate in competitions

(A) Identity

(B) Contact

(D) Profile

(G) Marketing and Communications

Necessary for our legitimate interest to communicate with you and to enable you to participate in competitions at your own discretion

To send you newsletters or other marketing 

(B) Contact

(D) Profile

(G) Marketing and Communications

Necessary for our legitimate interests to send you relevant marketing.

We will only send you marketing by e-mail or other means of electronic communication if you have given us your consent or we are otherwise allowed to under the Act on Electronic Communications Services

To administer and protect our business and website (including troubleshooting, data analysis, testing and system maintenance) 

(A) Identity

(B) Contact

(C) Transaction

(D) Profile

(E) Technical

(F) Usage

Necessary for our legitimate interests for running our business, provision of administration and IT services, network security and to prevent fraud  

To use data analytics to improve our website, products, marketing, customer relationships and experiences

(D) Profile

(E) Technical

(F) Usage

Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to improve our marketing strategy. 

We will only apply cookies – other than strictly necessary technical cookies - if you have provided your consent. 

To deliver relevant and targeted marketing, advertisements, and website content, on our and third-party sites, to you and measure or understand the effectiveness of the advertising we serve to you

(A) Identity

(B) Contact

(D) Profile

(E) Technical

(G) Marketing and Communications

Necessary for our legitimate interests to decide our marketing strategy and to target our marketing communication to you to fit with your preferences

We will only process cookies – other than strictly necessary technical cookies - if you have provided your consent.

To the extent that we have referred to our legitimate interest as the legal basis for the processing of personal data specified above we have conducted a balancing test for those interests to ensure that our interest is not overridden by your interests or fundamental rights and freedoms. Please contact us by email at support@pongfinity.fi if you wish to receive more information on the balancing test.

 

4. SHARING OF INFORMATION COLLECTED

We may disclose personal data to third parties:

  • When it is necessary for the purposes listed in section 3. For example, our online store is powered by Shopify. You can read more about how Shopify uses your personal data here: https://www.shopify.com/legal/privacy
  • When running our business, we share information, including personal information, with our trusted third-party service providers that we use to provide services to us and process your data on our behalf and under our instruction, e.g. hosting of data and maintenance IT-systems, administration of sales on our website, communication, planning and displaying marketing, administration of our interests at social medias, customer support and service, payment processing, delivery of products to you, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for any other purpose than in connection with the services they provide to us. We have entered into data processing agreements with our data processors.
  • When required by law we may disclose your personal data to public authorities such as tax authorities and law enforcement authorities.
  • When it is necessary for our partners to ship products ordered by you. For example, we use a logistic company from Finland that helps us run the Pongfinity Store. We use FedEx, DHL, GLS and Posti to send products. 
  • When you make payments on our website, your payment is administered by a payment service provider acting as an independent controller 
  • At our website cookies may be set and data collected or transferred to third parties. Please make sure to consult our [LINK: cookie policy] and [LINK: cookie settings] available at the website to find information of these third parties and the purposes for which data is collected. We will only apply cookies – other than strictly necessary technical cookies - if you have provided your consent.
  • When we believe in good faith that disclosure is necessary to establish or exercise our legal rights or defend against legal claims, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • When we sell or are in the process of selling our company to a (prospective) buyer. We will minimize the personal data shared during the process and make sure that you are informed about the sharing and the potentially new and different privacy statement applicable to you. 

 

5. TRANSFER TO THIRD COUNTRIES

We will not transfer your personal data to recipients outside EU or EEA unless we have ensured compliance with GDPR Chapter V. 

Some of our third-party service providers are established outside the EEA, including in the US, so their processing of your personal data will involve a transfer of data outside the EEA. However, to ensure that your personal information receive an adequate level of protection we have ascertained that sufficient safety measures have been implemented to allow for the transfer, including where the European Commission have deemed the country to provide an adequate level of protection for personal data; or by use of specific contracts approved by the European Commission (Standard Contractual Clauses) which give personal data essentially equivalent protection as it has in Europe. 

If you require further information about on our current data processors established outside the EEA and the safety measures in place to allow for the transfer of personal data, you can request it from us – please send your request to us by email at support@pongfinity.fi.

 

6. DATA RETENTION

We retain the personal information we collect where we have an ongoing legitimate need to do so. When we have no ongoing legitimate need to process your personal information, we will either delete or anonymize it.

Identity, Contact and Transaction Data is saved to demonstrate the agreement we have/have had and for bookkeeping and tax purposes for 6 full fiscal years after the expiry of the year in which the transaction relates. 

Profile and Marketing and Communications Data will be retained up to two years after the latest use. If you have consented to receive marketing, we will retain proof of your consent for a maximum of 1 years after the last time we relied on your consent to send marketing. We will stop sending you e-marketing when you withdraw your consent.

Data may be retained for longer period if we are legally obliged to do so, or if retention is necessary to establish, exercise or defend legal claims.

 

7. HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS

You have certain choices available to you when it comes to your personal information. Below is a summary of those choices, how to exercise them and any limitations.

Under certain circumstances, you have the right to:

  • Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. 
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party (also known as data portability).
  • Where our processing is solely based on your specific consent you have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

If you wish to exercise any of the data protection rights that are available to you, such as request a report of your personal information that we store or remove your personal and other data from our store, then please send your request to us by email at support@pongfinity.fi and we will action your request in accordance with applicable data protection laws.

You have the right to complain to your local data protection authority if you are unhappy with our data protection practices. In Finland you can lodge a complaint with the Office of the Data Protection Ombudsman at https://tietosuoja.fi/en/notification-to-the-data-protection-ombudsman


8. OTHER INFORMATION

Pongfinity cooperates with the clothing store Fanjoy (https://fanjoy.co/collections/pongfinity), where you can buy merchandise. All data collection is completely managed by Fanjoy.

The Pongfinity mobile games are developed by Linnama Entertainment (https://linnamaentertainment.com) and Pongfinity does not have access to any data processed in the game. 

As you know, we are active on YouTube, Facebook, Instagram, TikTok and Twitter. 

YouTube’s privacy terms are here: Privacy Policy – Privacy & Terms – GoogleYouTube shares with us a lot of information, like for example how many videos are watched per persons, the comments left, how much time the average user spends on our channel and how much a user would watch on average of a video. 

Facebook’s terms can be found at these links: Facebook privacy explanation and Facebook terms. Facebook provides us with aggregated statists and insights that helps us to market better and reach more people. 

Instagram’s terms can be found at these links: Instagram terms and Instagram data policy. Instagram provides us with aggregated statistics and insights that helps us to market better and reach more people. 

TikTok’s terms can be found at these links: TikTok terms and TikTok privacy policy. TikTok provides us with aggregated statistics and insights that helps us to market better and reach more people.

Twitter’s terms can be found at these links: Twitter terms and Twitter privacy policy. TikTok provides us with aggregated statistics and insights that helps us to market better and reach more people.


9. CHANGES TO THIS PRIVACY POLICY

This privacy policy may be updated from time to time to reflect changing legal, regulatory, or operational requirements. We encourage you to periodically consult our website for the latest information on our privacy practices.