What this policy covers

Welcome to oinkching.com(platform), OinkChing Inc.’s (“we,” or “us”) online platform. Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our Platform, and your choices about the collection and use of your information. If you do not want your information processed in accordance with this Privacy Policy in general or any part of it, you should not use our online or mobile Platforms.

Welcome, here is our policy on privacy. Our privacy policy, if you will.

Summary: This policy sets out how OinkChing collects and uses the information that we collect about you when you use the OinkChing Platforms. This policy also explains the choices that you can make about the way that we use your information.

1. Information we collect and its use

We collect the following types of information about you:

(a) Information you provide us directly

We may ask for certain information when you register for an OinkChing account or correspond with us (such as a username, your first and last names, birthdate, phone number, and e-mail address).

We also collect any messages and actions you perform through the Platform, and may collect information you provide in User Content you post to the platform or to messages to OinkChing Inc. We use this information to operate, maintain, and provide the features and functionality of the platform to you, to correspond with you, and to address any issues you raise about the platform.

If you don’t provide your personal information to us, you may not be able to access or use our Platform or your experience of using our Platform may not be as enjoyable.

(b) Information we receive from third parties

We may receive information about you from third parties. For example, if you access our websites or Platform through a third-party connection or log-in. That third party may pass certain information about your use of its Platform to OinkChing. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that Platform, any information that you have permitted the third party to share with us, and any information you have made public in connection with that Platform. You should always review, and if necessary, adjust your privacy settings on third-party websites and Platforms before linking or connecting them to this Platform.

(c) Information we collect from you automatically

We will directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Platform. These tools collect information sent by your browser or mobile device. This helps us optimize our platform.

(d) Cookies information and information taken from similar technologies

When you visit the Platform, we may send digital cookies to your computer that uniquely identifies your browser and lets OinkChing help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Platform.

You can control or reset your cookies and similar technologies through your web browser, which will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the platform may not function properly if the ability to accept cookies is disabled.

(e) Log file information

Log file information is automatically reported by your browser or mobile device each time you access the platform. When you use our platform, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Platform, domain names, landing pages, pages viewed, and other such information.

(f) Device identifiers

When you access the Platform by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by OinkChing. A device identifier may convey information to us about how you browse and use the Platform. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Platform. Some features of the Platform may not function properly if use or availability of device identifiers is impaired or disabled.

(g) Location data

We collect, within your profile, a physical home address in addition to utilizing web protocols to map where you are logging in from generally.

2. How we use your information

We use the information we collect about you for the purposes set out above which we have described in more detail below:

• OinkChing is always analyzing user information looking for ways to optimize our platform across location, browser, and time.
• OinkChing utilizes your data to help respond to your requests and communications.
• OinkChing also shares PII with your sponsoring financial institution.
• OinkChing also looks for opportunities where the consumer can benefit from the sharing of their data, ie sharing key data elements with a credit bureau to help with identity protection.
• OinkChing utilizes consumer data to help inform our strategy and marketing efforts.

Legal bases for processing information under the GDPR (for users in the EEA)

For OinkChing users in the European Economic Area (EEA) OinkChing processes your information in accordance with European laws and r(“we,” or “us” (“we,” or “us” regulations such as the General Data Protection Regulation (GDPR). The GDPR governs how OinkChing may process your information, and the rights that EEA users have in relation to it.

This means that OinkChing will collect and use your information only where:

• We need it to provide you the Platform and fulfil our obligations to you under our Terms of Platform.
• It is in our legitimate interests to do so. Our legitimate interests include providing a useful Platform, obtaining payment for our Platform (if applicable), sending you marketing and enhancing our Platform via research and development, data analytics, data labelling and machine learning. We do not rely on this lawful basis where our legitimate interest is overridden by your interest in protecting your data.
• You consent to us or have a reasonable expectation of us using your information in a certain way – for example, to hear about new features or offers.
• It is necessary for compliance with our legal obligations.

If you have consented to our use of your information you can withdraw that consent at any time in writing. Where we are using your information because of a legitimate interest to do so, you have the right to object to that use. However, if you do so it may mean that it is not possible for you to continue using the Platform.

3. Sharing your information

We will not rent or sell your information to third parties outside OinkChing and its group companies (including any parent, subsidiaries and affiliates) without your consent, except as noted in this section:

1. Who we share your information with

Your Sponsoring Financial Institution

Your Previous Sponsoring Institution

A National Credit Reporting Agency

(c) Sharing with other third parties

OinkChing will also share your information with third parties in certain circumstances, such as where:

• we are required to do so as a result of a court order, subpoena or other legal requirement;
• we believe that it is necessary to protect you or OinkChing or other people from harm, such as where we consider that there is a need to investigate or warn of potentially fraudulent, malicious or criminal activity or remove malicious content. For example, this may involve sharing details of an account or website engaged in phishing or a breach of our Terms of Use with take down Platforms, intelligence sharing Platforms, law enforcement bodies or on public websites;
• you have consented to our sharing it with a third party for a particular purpose;

OinkChing will also share your information with a third party in circumstances where we sell, divest or transfer OinkChing (including any shares in OinkChing), or any combination of its products, Platforms, assets and/or businesses to a third party. Information such as customer names and email addresses, User Content and other user information related to the Platform may be among the items sold or otherwise transferred in these types of transactions. We will also sell, assign or otherwise transfer such information in the event of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganisations, liquidations, similar transactions or proceedings involving all or a portion of OinkChing. You will be notified via email and/or a prominent notice on the Platform if such a transaction takes place and be given notice of any material changes to the way we handle your data under this policy.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

4. How we transfer, store and protect your data

Your information collected through the Platform will be stored and processed in the United States, and any other country in which OinkChing or its subsidiaries, affiliates or Platform providers maintain facilities. OinkChing transfers information that we collect about you, including personal information, to affiliated entities, and to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. As a result, we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which OinkChing or its parent, subsidiaries, affiliates or Platform providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

5. Cross-border transfers of information (for users in the EEA)

For Users in the EEA, where we transfer your information to a third party provider that is not located in the EEA, and is not subject to an adequacy decision by the EU Commission, we will require those third party providers to enter into an agreement that provides appropriate safeguards for your information, including by using the EU Model Clauses.

6. Keeping your information safe

OinkChing cares about the security of your information, and uses appropriate safeguards to preserve the integrity and security of all information collected through the Platform. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from OinkChing, at all times. However, OinkChing cannot ensure or warrant the security of any information you transmit to OinkChing or guarantee that information on the Platform may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and Platforms that you add to the OinkChing Platform, such as social networks. OinkChing is not responsible for the functionality or security measures of any third party.

7. Compromise of information

In the event that any information under our control is compromised as a result of a breach of security, OinkChing will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

8. Your choices about your information

(a) You control your account information and settings

You may update your account information by logging into your account and changing your profile settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests.

(b) Opting out of collection of your information

Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents OinkChing or its business partners from tracking your browser’s activities in relation to the Platform, and for use in targeted advertising activities by OinkChing, including via third parties’ websites. However, doing so may disable many of the features available through the Platform.

If you want us to stop collecting information about you, there may be some settings you can adjust in your browser or device.

(c) Rights in respect of your Information

The laws of some countries grant particular rights in respect of personal information. In certain circumstances, users in the EEA have the right to:

• Request a copy of your information;
• Request that we correct inaccuracies relating to your information;
• Request that your information be deleted or that we restrict access to it;
• Request a structured electronic version of your information; and
• Object to our use of your information.

You can request deletion of your account via your account settings page. You also have the right to object to our processing of personal data about you in order to send you marketing and we will stop processing data for that purpose.

In some circumstances OinkChing will not be able to comply with a request that you make in respect of your personal data. If we are unable to remove any of your information, we will let you know why. For example, we may not be able to provide a copy of your information where it infringes on the rights of another User. For our Community, we will remove your profile information where possible, but this may have been indexed by search engines or copied by other Users or included in the body of posts. We may also be required to retain certain information that you ask us to delete for various reasons, such as where there is a legal requirement to do so. In some cases, you may have shared your information with third parties, such as by publishing a design on a third party’s website. In that case OinkChing will not be able to delete the information, and you will need to contact that third party directly.

If we are unable to resolve your request, or if you are concerned about a potential violation, you also have the option to report the issue or make a complaint to the data protection authority in your jurisdiction. Where you have provided your consent to certain processing and no longer want us to use your information for that purpose, you may withdraw your consent to this use, although this will not affect the lawfulness of processing based on consent before its withdrawal.

9. How long we keep your information

Following termination or deactivation of your User account, OinkChing will retain your profile information and User Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, OinkChing will retain your information for the purpose of complying with its legal and audit obligations, and for backup and archival purposes.

10. Children’s privacy and OinkChing for Education

Children under the age of 14 are not permitted to sign up themselves for OinkChing Platform.

OinkChing does not knowingly collect or solicit personal information from children under the age of 13 and the Platform, Community and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at ted@oinkching.com.

OinkChing for Education: Children under the age of 13 may use our under the supervision of their parental guardian. We will only collect student data where such collection is authorized by a parental guardian. We will share student data with our third party Platform providers solely to the extent necessary for them to perform a business or technology support function for us. This may include data processing, account management or the provision of usage analytics.

If the parental guardian of a user who is under 13 deletes their account, we will be de-activating the user id of that individual who is under 13.

11. Links to other websites and Platforms

We are not responsible for the practices employed by websites or Platforms linked to or from the Platform, including the information or content contained therein. Please remember that when you use a link to go from the Platform to another website, our Privacy Policy does not apply to third-party websites or Platforms. Your browsing and interaction on any third-party website or Platform, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies. In addition, you acknowledge that we are not responsible for and we do not exercise control over any third-parties that you authorize to access your User Content. If you are using a third-party website or Platform (like Facebook) and you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Platform.

12. California users’ Privacy Rights

Californian users of OinkChing have additional rights afforded to them under the California Consumer Privacy Act (CCPA).

Categories of personal information collected by OinkChing

For more details about the personal information OinkChing has collected in the past year, please see section 1 “Information we collect and its use”. For details on how we use that information, and who we share it with, please see section 2 “How we use your information” and section 3 “Sharing your information”.

OinkChing does not “sell” (as defined in the CCPA) the personal information of OinkChing users.

Making a request in relation to your personal information

The CCPA gives California consumers various rights with respect to the personal information we collect, including the right to (subject to certain limitations):

• Request to access the personal information OinkChing has about you; and
• Request that OinkChing delete all your personal information.

California users may make a request by contacting us at ted@oinkching.com. We will authenticate your request using the email address associated with your OinkChing account and if necessary, proof of residency

13. Changes to this Policy

We may update this policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this policy, we will revise the “Last Updated” date at the top of this policy. If we make any material changes to the way we collect, use, store and/or share your personal information, we will notify you with a notice on our website and/by sending an email to the email address associated with your OinkChing account. We recommend that you check this page from time to time to inform yourself of any changes.

14. How to contact us

If you have any questions about this Privacy Policy or the Platform, or wish to make a complaint please contact us at:

• Email: ted@oinkching.com
• Write: PO Box 1175, 257 Lawrence St. NE, Marietta, GA 30060-9998