PRIVACY POLICY
Last updated: April 18, 2025
Pinkfong USA, Inc. (“Pinkfong”, “we”, “our”, or “us”) understands that privacy is important to our users. This U.S. Privacy Policy (the “Policy”) describes our practices regarding the collection, use, sharing and protection of your personal information for the website located at www.pinkfong.com/en and any other online services that specifically reference this Policy (the “U.S. Website”). It does not cover mobile applications, web applications, or other services and products offered by Pinkfong, its subsidiaries, or affiliates unless otherwise specified as part of those products and services.
This Policy tells you about the rights and choices you have with respect to your personal information, how you can assert those rights, and how you can contact us to get answers to your questions. The U.S. Website is directed towards visitors from the United States and some additional state-specific terms will only apply to individuals in those locations, or as otherwise required by applicable laws. If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, or another U.S. state that has similar comprehensive privacy legislation please see the section of our Policy titled Additional U.S. Privacy Rights.
For more information about how users with disabilities can access this Privacy Policy in an alternative format, please email us at privacy.us@pinkfong.com.
BY USING OR ACCESSING THE U.S. WEBSITE, YOU AGREE TO THIS POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE U.S. WEBSITE OR PROVIDE US WITH ANY PERSONAL INFORMATION.
PERSONAL INFORMATION WE COLLECT FROM YOU
We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been de-identified or that otherwise cannot be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws.
The following are the categories and types of personal information that we may collect from you, depending on how you interact with our U.S. Website:
HOW WE COLLECT YOUR PERSONAL INFORMATION
Personal Information You Provide
We collect personal information that you provide to us directly. This may include, but is not limited to:
Personal Information We Collect Automatically
When you visit our U.S. Website or interact with our advertisements, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.
“Cookies” are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the type of browser you are using, your Internet Protocol (IP) address, what pages on the U.S. Website you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data. We may also use cookies to customize your visit and for other purposes to make your visit more convenient or to enable us to enhance the U.S. Website.
As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a website's server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the U.S. Website. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our U.S. Website, how visitors navigate throughout the U.S. Website, and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our U.S Website.
We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Services. One such provider is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyze how users use the U.S. Website. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the U.S. Website, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings in your browser. By using the U.S. Website and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/. You may obtain additional information about Google Analytics by visiting the section titled "How Google uses information from sites or apps that use our services,” located at www.google.com/policies/privacy/partners/.
If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks in connection with our U.S. Website, we may collect information that you share with us on social media or that such platforms share with us. Please review the privacy policies and settings of the social media platforms and networks that you use for more information about their privacy practices.
We may obtain information about you from other sources, such as data analytics providers, marketing or advertising vendors, fraud prevention vendors, vendors that provide other services on our behalf, or publicly available sources.
HOW WE USE YOUR PERSONAL INFORMATION
We collect and use personal information for the following purposes:
We reserve the right to supplement your personal information with information we gather from other sources which may include online and offline sources. We may collect information that is not personal information (“non-personal information”), including anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal information does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal information with personal information. If we combine any non-personal information with personal information, the combined information will be treated by us as personal information to the extent that it is capable of personally identifying you. We reserve the right to develop and derive aggregate data (meaning information that relates to a group or category of individuals, from which individual identities have been removed) from personal information to enhance and maintain the U.S. Website, and such aggregate data will be treated as non-personal information.
HOW WE DISCLOSE OR SHARE YOUR PERSONAL INFORMATION
In addition to using your personal information ourselves for the reasons stated above (and as otherwise mentioned in this Policy), we may disclose your personal information to other affiliates and entities in the following instances:
We may share your personal information with third-party service providers who may use your information to provide us with services including, but not limited to: software, system, and platform support; cloud hosting services; data analytics; promotional events; and customer service. These service providers may have access to personal information that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.
We may share personal information with our corporate affiliates, parent companies, and subsidiaries where necessary to provide a service that you have requested, for internal marketing purposes in accordance with this Policy, or in other circumstances with your consent or as permitted or required by law.
We may share your personal information with third parties who partner with us to promote products and services, provide marketing and advertisements, conduct data analytics, or use the data for other commercial purposes. We do not control how these third parties use and share your personal information once they receive it. You will need to contact such third parties directly for information about their privacy practices or to exercise any rights you may have (including if you would like to opt-out of marketing messages).
We may be required to disclose or share personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or to combat fraud. We may also disclose or share personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe is necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We may share your personal information and other information with third parties in connection with 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 the assets transferred may include information about the users of our U.S. Website and related profile or accounts.
We may share non-personal information with unaffiliated third parties, such as business and advertising partners, manufacturers, distributors, and retailers, to improve and enhance your experience using the U.S. Website, and for our own market research activities. We publicly commit to maintain and use the information in de-identified or aggregate form, and not to attempt to re-identify the information.
Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.
LINKS TO OTHER SITES
We may have links to other websites that we think may be of interest to you, such as providers of various products and services. We may also provide links that allow you to send or forward a post from our U.S. Website through or to third-party sites, or other means of electronic communication, such as an email or text messaging service. We do not endorse any other websites, providers, or services by providing such links, and this Policy applies only to your use of the U.S. Website. We are not responsible for the privacy policies of any other websites and services we link to, and you should read the privacy policies of each site you visit to determine what data that site may collect about you.
The U.S. Website may also integrate with social media services. We do not control such services and are not liable for how they operate. While we may provide you with the ability to use such services on the U.S. Website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly. You should be aware that any personal information which you voluntarily include and transmit online in a publicly accessible blog, forum, social network, or otherwise may be viewed and used by others. By using such features, you assume the risk that the personal information provided by you may be viewed and used by third parties.
INTEREST BASED ADVERTISING
We may ourselves, or with third-party vendors, use your information to deliver targeted advertising to you when you visit our U.S. Website or other websites. Cookies, clickstream data, and other similar technologies described below may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “targeted advertising,” “behavioral advertising,” or “cross-context behavioral advertising,” enables us and our vendors to know about your interests in connection with the delivery of a specific ad. We believe that such advertising is helpful because it allows you to see advertisements that are relevant to your interests.
If you would like to opt out of these interest-based advertisements, please follow the opt-out process described in the section titled Your Choices below.
We may use your information to help us, or our third-party vendors, determine if you have interacted with our U.S. Website across multiple devices and to match such devices. To accomplish this, we may rely on information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies, or we may use information we collect in conjunction with such third-party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated with each other, and may further provide services to our advertisers to better enable cross-device targeting and analysis. To opt-out of or restrict our use of certain cross-device data, please see the section titled Your Choices below.
HOW WE PROTECT YOUR PERSONAL INFORMATION
Personal information is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this Policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at privacy.us@pinkfong.com.
DATA RETENTION
We will retain your personal information for as long as your inquiry is active, as needed to provide you with the any requested services, and as necessary to comply with our legal obligations and to resolve disputes. We do not retain your personal information longer than as required or permitted under applicable law. Even if we delete some or all of your information, we may continue to retain and use anonymized data, or any other data that constitutes non-personal information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
YOUR CHOICES
Consistent with applicable law, you may exercise the choices described in this section regarding your personal information and communications preferences. You may also have certain additional rights available depending on laws in your state of residence, as described further below in this Policy.
We may send you marketing messages via email or SMS message. If you receive a message from us, you may unsubscribe from future messages in accordance with our standard unsubscribe process (such as by using the unsubscribe link included in an email or texting “STOP” in response to an SMS message), or by sending an unsubscribe request to us at privacy.us@pinkfong.com. We will acknowledge and process your request within the lawfully required time after receipt. Please note that if you opt-out in this manner, certain aspects of our services may no longer be available to you.
If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our U.S. Website or some of its functionality may be affected. Note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Be advised that cookie-based opt-outs are not effective on some mobile services.
You may opt out of receiving targeted ads from certain data and advertising partners that participate in certain industry self-regulatory programs. The DAA provides a website at www.aboutads.info/consumers with information about how to opt out of targeted advertising from some or all of the DAA’s participating companies. Additionally, the Network Advertising Initiative (“NAI”) offers a website at http://optout.networkadvertising.org/ where you can opt out of interest-based advertising from some or all of the NAI’s members. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. In the event that we perform cross-device matching (as described above), once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes, and we will not use data from another device for interest-based advertising purposes on the Opted-Out Device.
To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, visit the following links:
You can also install the DAA’s AppChoices app on your device to opt out of targeted advertising by certain providers, and to select system-level advertising preferences on your device (such as “Limit Ad Tracking” on Apple devices, or “Opt-out of Interest-based ads” on Android devices).
Finally, to learn more from the NAI about how to opt out of targeted advertising on mobile devices, you can also visit the following link: https://thenai.org/opt-out/mobile-opt-out/.
NEVADA PRIVACY RIGHTS
If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information that we have collected (or may collect) from you to data brokers or other third parties. You can exercise this right by emailing us at privacy.us@pinkfong.com with the subject line “Nevada Do Not Sell Request.”
CROSS-BORDER DATA TRANSFERS
By submitting your personal information to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Be advised that we may be required to disclose your personal information in response to lawful requests by public authorities in the United States, including to meet national security or law enforcement requirements.
CHILDREN’S PRIVACY
Our U.S. Website and any related promotional activities are intended for visitors ages 18 and over, and we do not knowingly collect personal information from minors under the age of 18. When we become aware that personal information (or other information that is protected under applicable law) from a child under 13 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal information from or about a child under 13, please contact us by using the information the section below titled Contacting Us.
CHANGES TO THIS POLICY
We reserve the right, at our discretion, to change, modify, add, or remove portions from this Policy at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the U.S. website for the latest information on our privacy practices. Your continued use of the US Website following the posting of any changes to this privacy policy means you accept such changes.
CONTACTING US
If you have any questions about our privacy or security practices, please send us an email at privacy.us@pinkfong.com. You can also write to us at the following address:
Attn: Legal Team
1925 Century Park East
Suite 1700
Los Angeles, CA 90067
ADDITIONAL U.S. STATE PRIVACY RIGHTS
If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, or another U.S. state that has similar comprehensive privacy legislation (collectively, “Covered States”), you may have specific rights regarding your personal information under: the California Consumer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Texas Data Privacy and Security Act, Oregon Consumer Privacy Act, Montana Consumer Data Privacy Act, Iowa Consumer Data Protection Act, Delaware Personal Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Data Privacy Act, New Jersey Data Privacy Act, and similar laws in other U.S. states (collectively, "State Privacy Laws"). This section describes the rights that consumers of Covered States have and explains how to exercise those rights. To be clear, these rights are granted only to the extent that you are considered a consumer of Covered State and we are acting as a “controller” or “business” (as applicable) under State Privacy Laws with respect to your personal information.
The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in the terms of the Privacy Policy above.
Information We Collect; How We Collect It; How We Use It
General information regarding our collection, use, and disclosure of personal information is set forth in the Privacy Policy above.
In the past 12 months, we have collected categories of personal information described in the section of the Privacy Policy above titled Personal Information We Collect From You, and we have collected this information from the sources described in the section titled How We Collect Your Personal Information. Depending on your level of interaction with us, we may not have collected your personal information from all of the categories listed in the Privacy Policy above. We collect and use your personal information for the business or commercial purposes described in the section titled How We Use Your Personal Information, and retain it pursuant to the section titled Data Retention.
We may disclose the following categories of personal information for business or commercial purposes to service providers who perform business services for us; and to third parties, such as advertising networks, analytics providers, and social media networks:
Rights to Your Information
In addition to the rights set forth in our Privacy Policy, State Privacy Laws may, depending on your state of residence, provide you with the following rights:
To our knowledge, we do not sell or share for targeted advertising the personal information of minors under 18 years of age.
How to Exercise Your Rights; Verifying Your Identity
To exercise any of your privacy rights, or if you have any questions about your privacy rights, you may contact us by:
After submitting a request, we will take steps to verify your identity in order for us to properly respond and confirm that it is not a fraudulent request. In order to verify your identity, we will ask, at a minimum, that you provide your name, email address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.
Only you (or for California residents, an agent legally authorized to act on your behalf) may make a verifiable request related to your personal information. If you are making a request as the authorized agent of a California consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal information, we may ask you to submit reliable proof of your identity.
Response Time; Your Right to Appeal
We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, State Privacy Laws allow us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.
If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If you have this appeal right, within 60 days (45 days for residents of Colorado) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.
Notice of Financial Incentive
We may offer you financial incentives, including discounts, coupons, gift cards, or other rewards, for sharing personal information through programs that we may provide from time to time (collectively, our “Programs”). For example, we may offer you free products or discount codes for your participation in surveys or sweepstakes, for making reviews on our products, as part of invitations to events, or in relation to other offers. When we offer our Programs to you, we believe that the value of the different pricing or services you receive exceeds the cost of providing your personal information. Your participation in these Programs is completely optional and subject to the terms provided to you at the time you sign up.
You may withdraw from participation in a Program at any time by contacting us using the designated method set forth in the applicable Program rules. Visit the terms and conditions of each Program to view full details, including how to join. You may also withdraw from or opt out of our Programs at any time by contacting us at privacy.us@pinkfong.com.
California “Shine the Light”
In addition to the above rights, under California Civil Code Section 1798.83 (“Shine the Light”), California residents may have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at privacy.us@pinkfong.com. If you do not want your personal information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at privacy.us@pinkfong.com.