1. Introduction
Welcome to pinguin. We respect your privacy and are committed to protecting your personal data. This Privacy Policy governs how we collect, process, and share information when you access our website and services (the "Service").
2. Information We Collect
- Account Information: Email address, name, and location data required to manage your profile.
- User-Generated Content: Images, item descriptions, and communications submitted to the platform.
- Technical & Usage Data: IP addresses, browser types, and interaction data to maintain Service functionality.
3. Legal Basis and Use of Information
We process your data under the following legal bases:
- Contractual Necessity: To provide the Service, facilitate swaps, and manage your account.
- Legitimate Interest: To ensure platform security, prevent fraud, and improve user experience.
- Consent: For sending marketing communications (which may be withdrawn at any time).
4. Data Sharing and Third-Party Processors
We do not sell your personal data. Data is shared strictly in the following circumstances:
- Service Providers: With compliant third-party processors like Google Cloud / Firebase (for authentication, database, and media storage) and Web3Forms (for customer support).
- Other Users: Your contact information (email) is only revealed to another specific user upon the mutual acceptance of a swap request.
- Law Enforcement & Legal Requests: We may disclose your information if required to do so by law, or in the good-faith belief that such action is necessary to comply with legal obligations, protect the safety of users, or investigate fraud.
5. International Data Transfers
Because pinguin operates globally, your data may be transferred to, and processed in, countries outside of your residence. By using the Service, you consent to this transfer.
6. User Data Rights
Depending on your jurisdiction, you possess the right to:
- Access the personal data we hold about you.
- Rectify inaccurate or incomplete data.
- Erase your personal data (the "Right to be Forgotten").
- Restrict or Object to certain processing activities.
To exercise these rights, submit a request via our support form.
7. Data Retention
We retain your personal data only for as long as your account is active or as needed to provide you the Service. If you request account deletion, we will delete or anonymize your data, except where retention is required by law or for legitimate business resolution.
8. Children's Privacy
The Service is strictly restricted to individuals who are 18 years of age or older. We do not knowingly collect personal data from anyone under 18. If we become aware that a minor has provided us with personal data, we will terminate the account and delete the data immediately.
9. Changes to this Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Policy on this page and updating the "Last Updated" date.