Privacy Policy

1. Who we are and how we process your personal data

Pin Vision is committed to the protection of personal data of its users. This document has been drawn up in accordance with art. 13 and art. 14 of EU Regulation 2016/679 (hereinafter: “Regulation”) to help you understand what is our policy concerning your personal data, and how we process them when you use our site or our apps: (hereinafter: “Site” or “App”).

The information and data provided by you or otherwise acquired during the use of Pin Vision’s services will be processed in compliance with the provisions of the law and with the security of personal data that inspire Pin Vision’s activity.

The data processing activities will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality.

Data controller

The data controller is Pin Vision s.r.l., located in Via Roma 6 – Pino Torinese (TO), (hereinafter “Pin Vision”) and can be reached at the following e-mail address: [email protected]

2. What data we collect and why

Data collected:

  • Registration data and use of the service
    • Data referring to your person (Name, surname, email address, telephone, Golf Club affiliation, date of birth) in order to register you to the Platform.These data (name, surname, Golf Club affiliation, “live” status on the App) are processed to send you notifications from the Golf Club you subscribed with. These notifications will be about game events or operational communications (such as starting times, playing field conditions, etc.)
    • Location Information: We collect accurate or approximate location information from your mobile device, if you give us your consent. Pin Vision collects this data when the app is running and until the user ends the training session (the app is either open in the foreground of the screen or is running in the background and there is an icon or notification) on the device. The GPS authorization is required for the provision of the service and for the calculation of the distance between the player and the golf hole.
    • Data concerning how our users interact with our services (such as time of access, application functionality or pages viewed, application crashes and other system activities, browser types). In some cases, we use cookies, pixels, tags and similar technologies that create and maintain unique identifiers for this purpose. To learn more about these technologies, please see our Cookie Policy and Section 7.

How we use your personal data

We process your personal data in order to:

  • a) Allow the provision of the Services requested by you (create and update user accounts, calculate the player’s position in the game areas, receive in-app notifications about the palying field, the Golf Club, the tournaments you entered);
  • b) Respond to requests for assistance or information;
  • c) Comply with any legal, accounting and tax obligations;
  • d) Perform statistics on the use of the Services to improve their functionality;
  • e) Send you emails about Pin Vision Services;
  • f) Send you marketing communications regarding new services offered by Pin Vision or our Partners (such as promotions by Golf Clubs). You will receive promotional communications regarding our Partners’ services but we do not sell or share your personal data with our Partners without your specific consent.

The lawful basis for the processing of personal data for the purposes set out above in letters a-b-d-e is art. 6(1)(b) of the Regulation as the processing is necessary for the provision of the Services or to answer data subjects requests. The provision of personal data for these purposes is optional but failure to do so would make it impossible to use the App.

The purpose referred to letter f is carried out on the basis of the specific consent provided during the registration. Marketing communications may concern new products offered by Pin Vision or products and services offered by our Partners. The user can always withdraw his consent through a specific link at the end of the emails.

3. Who we share data with

We will disclose your personal data if this is necessary to provide our services or if you have given your consent to do so. We may share your personal data with:

“Data Processors”: they help us to provide you the Services, they have a contractual relationship with Pin Vision that binds them to specific contractual obligations of confidentiality for personal data they process on our behalf:

  • i) persons, companies or professional firms that provide assistance and advice to PinVision in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services;
  • ii) persons with whom it is necessary to interact in order to provide the Services (for example, the hosting providers that provide the IT infrastructure and where we store your personal data);
  • iii) subjects delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks); the list of data processors who process data can be requested from the Data Controller by writing to the following address: [email protected]

4. Login functionalities

Google login

Pin Vision also allows you to log in with your Google account. If you choose to use Google social login, your Google account will be associated with the Pin Vision App. You can manage this anytime in your Google Account. Please see Google’s resources for more details on this. Pin Vision will exchange certain data with Google, such as device Data, your IP-address and information you provided to Google when creating an account with Google Inc. This may include a transfer of your personal data to Google servers located outside the European Union. It is your choice if and to what extent you use the Google login and what information you provide to Google.

Apple Sign in

If you choose to use this Apple service to sign in to Pin Vision, Pin Vision will exchange certain data with Apple, such as Device Data, your IP-address and information you provided to Apple when creating an account with Apple Inc.
This may include a transfer of your personal data to Apple servers located outside the European Union. It is your choice if and to what extent you use the Apple Sign-In service and what information you provide to Apple.

5. How long we store your data

Pin Vision stores personal data about your user profile, game history and other personal information as long as you maintain your account and as long as necessary to comply with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.

6. Data subjects rights

Under art. 15 and following of the Regulation you have the:

  • a) Right to access – the right to request
    • (i) copies of the information we hold about you at any time, or
    • (ii) that we modify, update or delete such information.

If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is manifestly unfounded or excessive. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

  • a) Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
  • b) Right to erase – the right to request that we delete or remove your Data from our systems.
  • c) Right to restrict our use of your Data – the right to limit the way in which we can use it.
  • d) Right to data portability – the right to request that we move, copy or transfer your Data.
  • e) Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

For information about managing your personal data, for any doubts or request concerning them please submit a request to us at [email protected].

7. Tracking e Analyses on Pin Vision Website and App

By using our website through the cookie banner opt-in, you consent that Pin Vision uses cookies and third-party services, and collects your usage data under a unique identifier, for the purposes of tracking, analysis, and improvement of our website.

You may withdraw your consent to non-essential tracking and analysis at any time. When visiting our website, you can decline the use of non-essential cookies in the pop-up notification. For more information on cookies in our website, please refer to the Cookie page here.

For the purpose of tracking the performance of our services and to improve Pin Vision, we use the following third party services:


Pin Vision uses a suite of performance analysis and monitoring tools called Firebase, which is provided by Google LLC. Firebase allows us to monitor the overall performance and stability of our apps, implement internal version control, identify bugs and prioritize fixes. For this purpose Firebase collects your IP address, device identifier, as well as event and usage data related to your use of Pin Vision. This data will be transferred to and stored on a server in the EU and operated by Google LLC.

It is not possible to opt-out of Firebase as it is an essential tool that we require in order to provide a functioning Pin Vision app to you.


Pin Vision uses an in-app performance and analysis service by Adjust (Adjust is a mobile marketing vendor), a Berlin-based company that helps us understand where our users are coming from, which age group they are from and how they are interacting with our app, so that we can optimize our ad campaigns. Mainly, we use this service to answer this question: “Did this user on this device install the application in response to a specific advertising campaign performed by Pin Vision?”

What data is collected and sent to Adjust?

When you download our App for the first time, it sends an anonymous “attribution” request to the adjust servers. This request describes how the application was downloaded, for example, whether it was downloaded directly via the App Store or through a marketing campaign link. The data includes an advertising ID (Apple IDFA on iOS and your Google Play Services ID on Android), IP address, and timestamp.

Occasionally the app send adjust anonymous summaries about how often the app has been in active use recently and what features of the app are being used. These are anonymous reports that contain, for example, how many times the search, browse and erase button are pressed.

Moreover, Adjust receives data such as country, language/locale, operating system and app version.

You can find more information on Adjust Technology here:

If you would like to opt out of the Adjust Technology tracking, please open the following page:, please choose the device you would like to turn off and enter your device identifier. We will then immediately remove the tracking from apps using our technology. If you have any questions regarding this opt-out, please send an e-mail to [email protected] or [email protected] and Adjust will get back to you as soon as possible.


Pin Vision uses Sentry, a performance analysis and monitoring tool for the Pin Vision App, which is provided by Functional Software, Inc. a company seated in the USA. Sentry allows us to monitor the overall performance and stability of our apps, identify bugs and prioritize fixes. For this purpose Sentry collects your IP address, device identifier, as well as event and usage data related to your use of Pin Vision. This data will be transferred to and stored on a server operated by Functional Software, Inc.

It is not possible to opt-out of this as Sentry is an essential tool that we require in order to provide a functioning Pin Vision app to you.

Google Analytics

Google Analytics uses cookies which are stored on your computer and which enable an analysis of your usage of the website. The information generated by the cookie concerning your usage of this website (including the abbreviated IP address) is generally transferred to a Google server and stored there. Pin Vision uses Google Analytics exclusively with the extension “_anonymizeIp()” which ensures anonymization of the IP address by abbreviation and excludes direct reference to persons.. Google will use this information on our behalf to evaluate your usage of the website to compile reports concerning the website activities and to render other services to us, which are associated with the website usage and the internet usage. The IP address transmitted by your browser in the context of Google Analytics is not associated with other Google data.

If you do not agree with the use of Google Analytics, the cookie settings in your browser can be adapted accordingly or the functions deactivated via

You can find additional information concerning Google’s data protection provisions using the internet addresses below:

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