PLEASE READ THIS POLICY CAREFULLY BEFORE USING PINAKEN.COM SERVICES

Protecting your data, privacy and personal information is very important to M/s Sharp-N India
("us", "our" or "we"). It is vitally important to us that our customers feel secure when using the Services.

This policy (together with our terms of use at [Insert hyperlink of terms of use] and any other
documents referred to in it), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by M/s Sharp-N India. Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.

When visiting M/s Sharp-N India’s website at www.pinaken.com (our "Website"), using our
application (our "App") or using any of the services offered via the Website or the App (the
"Services"), you will be asked to indicate your acknowledgment of, and where applicable your consent to, the practices described in this policy.

Our Website contain links to third party websites. If you follow a link to any of those third
party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information.
Please check these policies before you submit any personal information to such third party websites.

INFORMATION WE MAY COLLECT

We may collect and process the following data about you:

 Information that you provide to us. You will be asked to provide us with your information when you:
o fill in forms on our Website or App, or correspond with us by phone, email or otherwise;
o register to use our Services, subscribe to our newsletter, promotional emails or
other marketing materials;

o use the Services;
o report a problem with our Services; or
o complete any surveys we ask you to fill in that we use for research purposes
(although you do not have to respond to these if you do not want to).
o
The information you will be asked to provide to us for these purposes will include your first
name, surname, email address, phone number, delivery address, or further information required
to verify your identity.
 Information we collect about you. With regard to each of your visits to our Website
or our App we may automatically collect the following information; however, this
information cannot be used to identify you:
o device-specific information, such as your hardware model, operating system
version, unique device identifiers, and mobile network information;
o technical information about your computer, including where available, your IP
address, operating system and browser type, for system administration and
analytical purposes;
o details of your visits to our Website and App, including the full Uniform
Resource Locators (URL) clickstream to, through and from our Website and
App (including date and time), length of visits to certain pages, and page
interaction information (such as scrolling, clicks, and mouse-overs); and
o information showing us from which app store you downloaded our App.
 Information we receive from other sources. When using our Services, we will be in
contact with third parties who may provide us with certain information about you in
order to enable your use of the Services.

For the avoidance of any doubt, any reference in this privacy policy to your data shall include
data about other individuals that you have provided us with.
HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE.
Use of personal information under EU data protection laws must be justified under one of a
number of legal "grounds" and we are required to set out the ground in respect of each use of
your personal data in this policy. These are the principal grounds that justify our use of your
information:
 Consent : where you have consented to our use of your information (you are providing
explicit, informed, freely given consent, in relation to any such use and may withdraw
your consent in the circumstance detailed below by notifying us);
 Contract performance : where your information is necessary to enter into or perform
our contract with you;
 Legal obligation : where we need to use your information to comply with our legal
obligations;
 Legitimate interests : where we use your information to achieve a legitimate interest
and our reasons for using it outweigh any prejudice to your data protection rights; and
 Legal claims : where your information if necessary for us to defend, prosecute or make
a claim against you or a third party.
We use information held about you (and information about others that you have provided us
with) in the following ways:
Types of Information
Collected
Uses of that Information Use Justification
Email address, first name,
surname, home address
To provide you with access to
our Website, App and any
other information which you
request from us, and to use
our Services.
Contract performance.
Email address, first name,
surname, home address,
product choices and
To provide you with the
Services.
Contract performance.
customization, phone call
recordings and Website
chat history
Email address, first name,
surname
For marketing our own
products and services that we
believe will be of interest to
you.
Legitimate interest (for
marketing our own similar
products and services and
any re-engagement
campaigns).
Email address, first name,
surname, home address,
product choices and
customization, phone call
recordings and Website
chat history
To identify more appropriate
products and services to
market to you.
Legitimate interest (to
tailor our services
appropriately). No
marketing of third party
products or services will be
conducted without your
consent.
Email address, first name,
surname, home address,
product choices and
customization, phone call
recordings and Website
chat history
To administer our Services
and for internal operations,
including research, data
analysis and data statistics,
and to create derived,
anonymised and aggregated
data to improve our Services.
Legitimate interest (to
administer and improve
our Services).
Email address To notify you about changes
to our Services.
Contract performance,
legitimate interests (to
update our Services from
time to time).
We will not sell your personal data (or any other data you provide us with) to third-parties,
however, we reserve the right to share any data, which has been anonymised and/or aggregated.
You acknowledge and accept that we own all right, title and interest in and to any derived data
or aggregated and/or anonymised data collected or created by us.
We do share information with a number of trusted partners including but not limited to Google,
Facebook, LinkedIn and Conversant to enable us to deliver targeted advertising to you. If you
would prefer to opt out of this, please click [here] where you can manage your privacy settings
at any time.
MARKETING
We may use information for marketing products and services to you in the following ways:
Type of marketing activity Use Justification
Newsletters and marketing emails relating to our own
similar services and products. Where required by law,
Legitimate interest (to market
our products and services - you
we will ask for your consent at the time we collect
your data to conduct any of these types of marketing.
have the right to unsubscribe at
any time).
We will provide an option to unsubscribe or opt-out of further communication on any electronic
marketing communication sent to you or you may opt out by contacting us.
WHERE WE STORE YOUR PERSONAL INFORMATION
The personal data that we collect from you (including email addresses that form part of our
prospective marketing database) is processed in the European Economic Area ("EEA") and
stored on Heroku and Amazon Web Services (Europe) Cloud Servers This data may however
be processed by staff operating outside of the EEA who work for us or for one of our business
partners or service providers. A full list of our third party sub-processors and details of their
privacy policies can be found [here]. Countries outside the EEA may not provide the same
level of adequate protection for the rights and freedoms of data subjects in relation to the
processing of personal data. In countries which do not provide appropriate safeguards, we shall
transfer your data subject only to your consent except for transfers to and from: (i) any country
with a valid adequacy decision from the European Commission; (ii) any country with which
we have ensured similar levels of safeguards have contractually been put in place (this may
include entering into standard contractual clauses); or (ii) any organization, including any of
our sub-processors, which ensures an adequate level of protection in accordance with
applicable data protection laws.
Your passwords are stored on M/s Sharp-N India’s servers in encrypted form. We do not
disclose your account details. It is your responsibility to keep your password secure.
Unfortunately, the transmission of information via the internet is not completely secure.
Although M/s Sharp-N India will do its best to protect your personal data, we cannot guarantee
the security of your data transmitted to our Website, any transmission is at your own risk. Once
we have received your information, we will use strict procedures and security features to try to
prevent any unauthorised access.
Please contact us if you would like further details on the specific safeguards applied to the
export of your personal information outside EEA.
DISCLOSURE OF YOUR INFORMATION
We may also disclose your personal information to third parties in the following circumstances:
Purpose of disclosure and third party(s) to which
disclosure might be made
Use Justification
We may disclose your personal information to our service
providers and business partners, including our
manufacturers (to assist us in performing any contract we
enter into with them or you, including providing the
Website and the Services it enables), analytics providers,
(to assist us in the improvement and optimisation of the
Website) and/or a member of our group, which means our
subsidiaries, our ultimate holding company and its
subsidiaries, as defined in section 1159 of the UK
Companies Act 2006. A list of such third parties can be
reviewed at [LINK].
Contract performance,
legitimate interest, (to allow
our service providers to
provide the necessary
services).
If we sell or buy any business or assets, we may disclose
your personal information to the prospective seller or
buyer of such business or assets.
Legitimate interest (to sell
our business or assets); and
where required by applicable
law, consent (for sensitive
personal data).
If M/s Sharp-N India or substantially all of its assets are
acquired by a third party, personal information about our
customers will be one of the transferred assets.
Legitimate interest (to sell
our Company or assets); and
where required by applicable
law, consent (for sensitive
personal data).
If we are under a duty to disclose or share your personal
data in order to comply with any legal obligation or to
protect the rights, property, or safety of M/s Sharp-N
India, our customers, or others. This includes exchanging
information with other companies and organisations for
the purposes of fraud protection.
Legal obligation, vital
interest.
Fraud Prevention and other checks. We and other
organisations may also access and use your personal
information to conduct credit checks and checks to
prevent fraud. If false or accurate information is provided
and fraud is identified or suspected, details may be passed
to fraud prevent agencies.
Legitimate interest (to assist
with the prevention of fraud
and to assess your risk
profile).
We may disclose your personal information to third
parties, the court service and/or regulators or law
enforcement agencies in connection with proceedings or
investigations anywhere in the world where compelled to
do so. Where permitted, we will direct any such request
to you or notify you before responding unless to do so
would prejudice the prevention or detection of a crime.
Legal obligation (to
cooperate with law
enforcement and regulatory
authorities).
HOW LONG WE RETAIN YOUR PERSONAL DATA
We will hold the above information for as long as is necessary in order to provide you with the
Services, deal with any specific issues that may raise, or otherwise as is required by law or any
relevant regulatory body. Once your account is terminated or deactivated, we shall delete the
personal data relating to your account within 30 days. If your account is inactive for 18 months,
we may contact you to assess whether you want to continue to use the Services. Some personal
data may need to be retained for longer than this to ensure M/s Sharp-N India can comply with
applicable laws and internal compliance procedures, including retaining your email address for
marketing communication suppression if you have opted not to receive any further marketing.
We restrict access to your personal information to those persons who need to use it for the
relevant purpose(s). Our retention periods are based on business needs and your information
that is no longer needed is either irreversibly anonymized (and the anonymized information
may be retained) or securely destroyed.
YOUR RIGHTS
Under the General Data Protection Regulation (EU) 2016/679, you have various rights in
relation to your personal data. All of these rights can be exercised by contacting us
at customercare@pinaken.com
You have the following rights in relation to your personal data:
Right Details
Right of
Access
The data subject shall have the right to obtain from the controller
confirmation as to whether or not personal data concerning him or her
are being processed, and, where that is the case, a copy of the personal
data undergoing processing.
Right to
Rectification
We will use reasonable endeavors to ensure that your personal
information is accurate. In order to assist us with this, you should notify
us of any changes to the personal information that you have provided
to us by sending us a request to rectify your personal data where you
believe the personal data we have is inaccurate or incomplete.
Right to
erasure / 'Right
to be forgotten'
Asking us to delete all of your personal data will result in M/s Sharp-N
India deleting your personal data without undue delay (unless there is
a legitimate and legal reason why M/s Sharp-N India is unable to delete
certain of your personal data, in which case we will inform you of this
in writing).
Right to
restriction of
processing
You have the right to ask us to stop processing your personal data at
any time.
Right to data
portability
You have the right to request that M/s Sharp-N India provides you with
a copy of all of your personal data and to transmit your personal data to
another data controller in a structured, commonly used and machinereadable format, where it is technically feasible for us to do so.
Right to
complain
You have the right to lodge a complaint to a supervisory authority such
as the Information Commissioner's Office in the UK (see
[www.ico.org.uk](http://www.ico.org.uk)). Although we encourage
our customers to engage with us in the event they have any concerns or
complaints.
M/s Sharp-N India will not ordinarily charge you in respect of any requests we receive to
exercise any of your rights detailed above; however, if you make excessive, repetitive or
manifestly unfounded requests, we may charge you an administration fee in order to process
such requests or refuse to act on such requests. Where we are required to provide a copy of the
personal data undergoing processing this will be free of charge; however, any further copies
requested may be subject to reasonable fees based on administrative costs.
Asking us to stop processing your personal data or deleting your personal data will likely mean
that you are no longer able to use M/s Sharp-N India’s Services, or at least those aspects of the
Services which require the processing of the types of personal data you have asked us to delete,
which may result in you no longer being able to use the Services.
Where you request M/s Sharp-N India to rectify or erase your personal data or restrict any
processing of such personal data, M/s Sharp-N India may notify third parties to whom such
personal data has been disclosed of such request.
CHANGES TO THIS POLICY
Any changes we make to our privacy policy in the future will be posted on this page, and where
appropriate, notified to you by email or notifications via the App. We therefore encourage you
to review it from time to time to stay informed of how we are processing your information.
CONTACT
Questions, comments and requests regarding this privacy policy are welcome and should be
addressed to customercare@pinaken.com.
For the purpose of the relevant data protection legislation, the data controller is M/s Sharp-N
India with registered address at A-60 Sector 8, Noida, Uttar Pradesh 201301.
Our data compliance officer is Mr. Manish Goyal admin@pinaken.in
COOKIES
M/s Sharp-N India uses cookies to distinguish you from other users. This helps us provide you
with a good experience when you use our Website, and also allows us to improve our Services.
Please note that it is possible to disable cookies being stored on your computer by changing
your browser settings. However, our Website may not perform properly or some features may
not be available to you if you disable cookies.
For detailed information on the cookies we use and the purposes for which we use them see
our Cookie policy here.
THIRD PARTY COOKIE INTEGRATION
We may use third party companies to provide advertising services and/or to collect certain
information when you visit and interact with our website. These third-party companies may
collect and use non-personally identifiable information (e.g., click stream information, browser
type, time and date, subject of advertisements clicked or scrolled over) during your visit to this
website [and/or other websites] in order to provide advertisements about goods and services
likely to be of greater interest to you. These third-party companies may use cookies and other
technologies to recognise your browser to collect and record information about your web
surfing activity including your activities on this website. You may visit the European
Interactive Digital Advertising Alliance at http://youronlinechoices.eu/ to learn more about
interest-based advertising, or to opt out of receiving advertisements tailored to your interests
on your browser, from their respective members and participants.
FIRST PARTY COOKIE INTEGRATION
We may also use technologies, such as our own cookies, to provide you with relevant online
display advertising tailored to your interests. Our marketing partner, Conversant, assists us in
managing these technologies. To opt out of our cookies used for this online advertising or to
submit a data subject request specific to these technologies, click here.