PINOGI SOFTWARE OÜ
Privacy Policy
Last updated: 11 November 2026
This policy explains how Pinogi Software OÜ handles personal data in connection with pinogi.com and messages sent to our corporate email address. It does not cover the PinPassport app or its separate website, which have their own privacy information.
1. Who is responsible?
Pinogi Software OÜ · 17644500
Harju maakond, Tallinn, Kesklinna linnaosa, Viru väljak 2, 10111, Estonia
info@pinogi.com
We are the controller for the personal data described in this policy. You can contact us at the address or email above about your data or your rights.
2. Visiting this website
Delivering a web page involves processing technical information such as your IP address, the requested page or file, request time, browser information and response status. Hosting systems may record this information in access, error or security logs. We use technical information to deliver the site, investigate faults and protect it against misuse. Our legal basis is our legitimate interest in operating a reliable and secure website (GDPR Article 6(1)(f)).
3. When you contact us
If you email us, we process your email address, any name you provide, your message, attachments and related correspondence to answer your inquiry and manage the conversation. General inquiries are handled on the basis of our legitimate interest in communicating with people who contact us (Article 6(1)(f)). Where an inquiry concerns entering into or performing a contract with you, Article 6(1)(b) applies. Processing required by a legal obligation is based on Article 6(1)(c).
Contacting us is optional. We need a return address and enough information to understand your request to respond. Please do not send identity documents, payment details or sensitive personal information unless specifically needed for your request.
4. Cookies, analytics and language selection
The website code does not set cookies, save preferences in browser storage or include analytics, advertising pixels or third-party embedded content. Language selection works through English and Turkish page addresses and is not stored as a preference. Fonts and visual assets are served from this website. Selecting an email link opens your email application; the site itself has no contact form.
5. Who can receive data?
Access is limited to people who need the data to handle your request or operate the website, and to service providers supporting website hosting, email delivery and IT security. Providers acting on our behalf must process data under appropriate contractual instructions. We may also disclose information to professional advisers or competent authorities when necessary to meet legal obligations or establish, exercise or defend legal claims. We do not sell personal data.
6. International processing
Service-provider processing locations depend on the hosting and email services used. If personal data is transferred outside the European Economic Area, applicable GDPR transfer requirements must be met, for example through an adequacy decision or appropriate safeguards such as standard contractual clauses, together with any required supplementary measures. Contact us for information about the providers, processing locations and safeguards applicable to your data, or to request a copy of relevant safeguards.
7. How long is data kept?
Retention depends on why the information is needed. Technical records are retained for the time needed to operate the service, diagnose faults and investigate security incidents, taking account of the hosting system’s log and backup cycles. Correspondence is retained while an inquiry or related business relationship remains active and, where necessary, for applicable legal retention or limitation periods. When deciding whether continued retention is necessary, we consider unresolved requests, outstanding obligations and actual or reasonably anticipated disputes. Information that is no longer needed is deleted or anonymised, subject to applicable backup cycles. You can ask us for the retention information applicable to your data.
8. Your rights
Subject to the conditions in applicable law, you can request access to your personal data, correction, erasure or restriction of processing. You may object to processing based on legitimate interests. Data portability applies where processing is automated and based on consent or a contract. If we rely on consent for any additional processing, you can withdraw it without affecting the lawfulness of earlier processing.
Send requests to info@pinogi.com. We may ask for proportionate information to verify your identity. We normally respond within one month; if a lawful extension is needed, we will explain it within that month. You may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or another competent supervisory authority, including in the EU country where you live or work.
9. Automated decisions and external links
This corporate website does not use personal data for profiling or automated decisions that have legal or similarly significant effects. Following a product link takes you to a separate website. Its data practices are explained in its own privacy notice; statements about the PinPassport app do not describe data processing on this corporate website.
10. Changes to this policy
We update this policy when the website or our processing practices change. The date above identifies the latest version. Where legally required, we will provide additional notice of material changes.