PRIVACY_POLICY

1. What Personal Data Do We Collect?

We may collect and process various types of personal data about you, depending on how you interact with our Services. This may include:

• Identity Data: Username, display name, account ID, date of birth (optional for age verification)
• Contact Data: Email address, mobile number (for account recovery/notifications)
• Technical Data: IP address, 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 our Services
• Usage Data: Information about how you use our Services, products, and features (e.g., in-app interactions, feature usage)
• Profile Data: Your username and password, in-app activity, competitive performance (e.g., skill level, territorial claims), preferences, feedback, and survey responses
• Marketing and Communications Data: Marketing preferences, notification preferences, and your communication preferences
• Financial Data: Payment details (processed securely by third-party payment providers)
• Content Data: Any content you create, upload, or share through our Services, such as messages, photos, or videos (e.g., skate clips, spot updates, comments)

We collect this data through direct interactions (e.g., when you register for an account, contact us), automated technologies (e.g., cookies, analytics), and third parties (e.g., analytics providers, advertising networks).

2. How Do We Use Your Personal Data?

We use your personal data for various purposes, including:

• To provide and maintain our Services, including to monitor the usage of our Services.
• To manage your account: to manage your registration as a user of the Services. The Personal Data you provide can give you access to different functionalities of the Services that are available to you as a registered user.
• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Services.
• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• To manage your requests: To attend and manage your requests to us.
• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

3. Legal Basis for Processing Your Personal Data

We will only process your personal data when we have a lawful basis to do so. The legal bases we rely on include:

• Consent: Where you have given us clear consent for us to process your personal data for a specific purpose.
• Contract: Where our use of your personal data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
• Legal Obligation: Where our use of your personal data is necessary for us to comply with the law (not including contractual obligations).
• Legitimate Interests: Where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party, provided your interests and fundamental rights do not override those interests. We will always conduct a Legitimate Interests Assessment (LIA) to ensure this balance.

4. Specific Data Handling for Pushinn Pro

4.1. Location Data

Pushinn Pro is a location-based application that relies on precise geographical data to function.

• What we collect: We collect your precise GPS location data (latitude and longitude) when you use the app. This includes active collection when the app is in use and, with your consent, background collection when the app is closed, to provide continuous features like territorial tracking.
• How we use it: Your location data is essential for:
  • Territorial Claiming & Battle Mechanics: To determine your presence within specific municipal boroughs and at skate spots for battle participation, claiming territory, and tracking "Solo Impact" activities.
  • Spot Intelligence: To verify your proximity to a spot when contributing "Live Spot Intel" (e.g., reporting spot conditions).
  • Personalized Maps: To show you relevant spots and user activity near your current location.
• Sharing: We may share aggregated or anonymized location data with third parties for analytics, research, and business development. Precise, non-anonymized location data may be shared with other users or business partners only with your explicit consent (e.g., to show your presence at a public spot, or for a brand activation you participate in).
• Consent: You will be prompted for your explicit consent to collect precise location data, including background collection. You can withdraw this consent at any time through your device settings, though this may limit app functionality.

4.2. User-Generated Content (UGC)

Pushinn Pro relies on user-generated content to build its "Grind Archive" and power competitive features.

• What we collect: This includes skate clips, photos, text comments, spot reports, and any other media or data you create or upload through the app.
• How we use it: UGC is used to:
  • Populate The Grind Archive: Creating an immutable ledger of tricks and spot history.
  • Facilitate Street Battles: Displaying your performance to rivals and the community.
  • Provide Live Spot Intel: Sharing real-time conditions with other users.
  • Moderation: To ensure compliance with our Terms of Service and community guidelines.
• Sharing & Public Display: By uploading UGC, you acknowledge and agree that some content (e.g., skate clips, public comments) may be publicly displayed within the app and on our website. You control the privacy settings for certain types of content within the app.

4.3. Competitive & Profile Data

Your activity within Pushinn Pro generates unique competitive data central to the app's experience.

• What we collect: This includes your "Triple-Score" metrics (Player Score, Map Score, Ranking Score), territorial claims, battle history, "Solo Impact" contributions, and interactions with other users/crews.
• How we use it: This data is used for:
  • Leaderboards & Rankings: Displaying your standing within boroughs and globally.
  • Skill Verification: Assisting in the "Tribal Verification" process.
  • Scouting Dashboard: Providing anonymized (or consented, non-anonymized) insights to verified business partners (e.g., brands scouting talent).
  • Feature Optimization: Improving battle mechanics and territorial dynamics.
• Sharing: Your competitive profile data may be displayed publicly within the app to other users and, with your explicit consent, shared with verified business partners (e.g., for sponsorship opportunities).

5. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention period will vary depending on the type of data and the purpose for which it was collected. For example, we typically retain account data for 7 years after account closure (for legal and accounting purposes), or as required by law.

6. Sharing Your Personal Data

We may share your personal data with the following categories of recipients:

• Service Providers: Third-party vendors and service providers who perform services on our behalf, such as hosting, data analysis, payment processing, customer service, and marketing assistance. These service providers are contractually bound to protect your data and only use it for the purposes for which it was disclosed.
• Business Partners: With our business partners to offer you certain products, services, or promotions.
• Affiliates: With our affiliates, in which case we will require those affiliates to honour this Privacy Policy.
• For Business Transfers: 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.
• Law Enforcement and Legal Obligations: When required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
• With Your Consent: We may disclose your personal data for any other purpose with your consent.

We ensure that any international transfers of personal data comply with UK GDPR requirements, typically through the use of Standard Contractual Clauses or other approved mechanisms.

7. Your Data Protection Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights regarding your personal data:

• The right to be informed: You have the right to be informed about how your personal data is collected and used.
• The right of access: You have the right to request copies of your personal data.
• The right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The right to erasure (the 'right to be forgotten'): You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

To exercise any of these rights, please contact us using the details provided in Section 9. We will respond to your request within one month.

8. Cookies and Tracking Technologies

Our Services may use cookies and similar tracking technologies (like web beacons and pixels) to track the activity on our Services and store certain information. Tracking technologies are used to collect and track information and to improve and analyze our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Services.

We will obtain your explicit consent for the use of non-essential cookies and provide you with clear information about the types of cookies used and how you can manage your preferences, in compliance with the Privacy and Electronic Communications Regulations (PECR).

9. Contact Details

If you have any questions about this Privacy Policy or our data protection practices, please contact us:

• Data Controller: Pushinn Labs LTD
• Registered Office: 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX
• Contact Email: [email protected]

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

11. Complaints

If you have any concerns about our use of your personal data, you can make a complaint to us at [email protected]. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.