Privacy Policy

1. Who processes your data

The controller is Michelangelo Lacatena, Via Lecce 17, 70042 Mola di Bari (BA), Italy, VAT number IT08519250727. To exercise your rights, or for any question about this notice: info@pinbloom.eu.

2. Two different roles

This distinction is the most important thing in the document, because it decides who answers for what.

• For your account data we are the controller. It is what you give us in order to have the service; we process it for our own purposes and under this notice.
• For the data you upload into the platform you are the controller and we are your processor. Your lists of people, the names printed on the pieces, your staff's email addresses — those are yours. We process them only to provide the service and on your instructions. Having a lawful basis to collect them, and telling the people they concern, is down to you.

3. What we hold, and why

Your account

Name, email address, password (kept only as a cryptographic hash, never in the clear), preferred language and the date your email was verified. It is what creates the account, signs you in and lets us write to you about the service. Lawful basis: performance of the contract (Art. 6(1)(b) GDPR). If you sign in with Google, we receive from Google your name, your already verified email address and an identifier of your Google account, which we keep to recognise you on later sign-ins. If you turn on two-factor authentication, we keep, encrypted, the key of your code generator and your recovery codes.

Your business details

Trading name, address, VAT number, email, phone, website and logo. We use them to print your identity on the pieces you generate. Lawful basis: performance of the contract.

Your staff

The email address and temporary sign-in code of whoever checks codes at the door, plus the time they last signed in. Signing in uses a six-digit code good for a few minutes: we hold no staff passwords. For this data you are the controller.

Scans

Every check leaves a record: which code, with what outcome, by which member of staff (name and email), for which event, and what they were shown on screen. It is an audit trail that exists so you can tell who did what — the reason there is no shared PIN here. For this data you are the controller.

The free trial

To stop the same person or the same company from having more than one trial, we keep a cryptographic fingerprint of your email address, written in a normalized form, and for company addresses the domain. We also keep a fingerprint of the IP address you sign up from. We keep neither the email address nor the IP in the clear. Lawful basis: our legitimate interest in preventing abuse of the free trial (Art. 6(1)(f) GDPR).

The codes you generate

Identifier, tag, status, expiry, time of use, and the free-form fields you choose to attach — including details of the person the code is for. What goes in is your choice: do not upload data you do not need, and above all not special categories such as health data.

Contact requests

If you write to us through the form on the public page: name, email, company (optional), estimated volume, billing type and your message. They reach our mailbox and are stored nowhere else; we keep them in our mail for as long as it takes to answer you and agree an offer. Lawful basis: pre-contractual steps you asked for (Art. 6(1)(b) GDPR).

Support tickets

The title and messages of the tickets you open from your account, with time and date, and the replies you receive. They let us answer you and rebuild the conversation if you write again. We keep them while the account exists: if you delete it, they are deleted with it. Lawful basis: performance of the contract (Art. 6(1)(b) GDPR).

Technical session data

IP address, browser identifier and the time of your last activity, kept to hold the session open and for security. Lawful basis: our legitimate interest in running and protecting the service (Art. 6(1)(f) GDPR).

4. Cookies

We set two cookies, both strictly necessary: the session cookie, which keeps you signed in and remembers the language you chose, and the one that protects forms against forged requests. They are not used to profile you and so need no consent. We set no third-party cookies and run no analytics.

The site's typefaces are served from our own servers too: opening these pages does not hand your IP address to any outside provider.

5. Who we share it with

We do not sell data and we pass it to nobody for their own purposes. It is handled on our behalf by the providers that make the service run:

• Paddle.com Market Ltd, which handles payments as Merchant of Record. Paddle is the counterparty to your purchase and processes payment and invoicing data as its own controller, under its own notice. We never see your card details.
• Contabo GmbH, which hosts the application, its databases and the files it generates on servers in the European Union.
• OneSignal, Inc., based in the United States, which delivers the service's emails. Data is transferred to the United States on the basis of OneSignal's participation in the EU-U.S. Data Privacy Framework.

6. How long we keep it

Account data stays for as long as the account exists. Codes and events stay until you delete them or close the account.

The scan record has a deadline of its own, because it carries the name and email of whoever did the checking: it stays readable for 90 days, then moves to a compressed archive, and is deleted outright after 180 days in all. That second deadline is what bounds how long those details are kept anywhere.

The fingerprint of the sign-up IP is deleted after 30 days. The fingerprints in the trial registry stay after the account is closed, because their purpose is to prevent a second trial. An account that had the trial and never chose a plan is deleted 12 months after the trial ended, with an email warning 14 days before.

Exports you request are deleted automatically after fourteen days. Tax documents are kept by Paddle for as long as the law requires it.

7. Your rights

You can ask us for access to your data, for it to be corrected, erased, restricted or ported, and you can object to processing based on legitimate interest (Arts. 15–22 GDPR). Write to info@pinbloom.eu and we answer within a month.

If you believe the processing breaks the law you can complain to the Italian data protection authority (garanteprivacy.it) or to the authority where you live.

If data about you was uploaded to Pinbloom by one of our customers — because they sent you a ticket, say — they are the controller: write to them, and if you write to us we will put you in touch.

8. Changes

If we change this notice we update the date at the top. Where a change materially affects the processing we tell you by email before it takes effect.