Data Controller
VIREON LIMITED Unit 2A, 17/F, Glenealy Tower, No. 1 Glenealy, Central, Hong Kong S.A.R.
Business Registration: 79593076
01Who we are
PinCraft is an online education product operated by VIREON LIMITED, a company registered in Hong Kong (Business Registration Number 79593076). When we refer to "we", "us", or "our" in this policy, we mean VIREON LIMITED. When we refer to "you" or "your", we mean any person who visits our website, signs up for our newsletter, or purchases our courses.
This Privacy Policy explains how we collect, use, store, and protect your personal data when you interact with PinCraft.
02What data we collect
We collect only the data we actually need. This falls into three categories:
Information you give us directly
- Your name and email address, when you sign up for a course or newsletter
- Your billing information, when you make a purchase (processed by our payment provider, not stored by us)
- Any information you share when you email us, message us, or join our community
Information collected automatically
- Standard server logs (IP address, browser type, pages visited, referring page, timestamp)
- Cookies and similar technologies for analytics and to remember your preferences
- Aggregate usage data showing how visitors move through the site
Information from third parties
- Payment confirmation data from our payment processor (transaction ID, amount, status)
- Email delivery and engagement data from our email service provider
03How we use your data
We use your data only for these specific purposes:
- To deliver the product you purchased, including granting access to the course materials, community, and any updates
- To process payments and refunds, via our payment processor
- To send transactional emails, such as receipts, course access details, and important service updates
- To send marketing emails, only if you have explicitly opted in. You can unsubscribe at any time from any email we send
- To provide customer support, when you contact us
- To improve our products, by analyzing aggregate, anonymized usage data
- To meet legal obligations, such as tax records and responding to lawful requests from authorities
04Legal basis for processing (GDPR)
If you are located in the European Economic Area or the United Kingdom, the lawful bases we rely on to process your personal data are:
- Contract: to fulfill the purchase agreement between us when you buy a course
- Legitimate interest: to run our business, analyze aggregate traffic, prevent fraud, and improve our products
- Consent: for marketing emails, non-essential cookies, and any data use that requires your explicit opt-in
- Legal obligation: for tax, accounting, and regulatory compliance
05Who we share your data with
We do not sell your personal data. We never have, and we never will. We share your data only with the following service providers, and only as needed to operate our business:
- Payment processors (such as Stripe, Whop, or similar), who handle the financial transaction directly
- Email service providers, who deliver our transactional and marketing emails
- Hosting and analytics providers, who host our website and provide aggregate traffic data
- Course delivery platforms, which grant you access to the course materials you purchased
- Legal and regulatory authorities, only when required by law
Each of these providers is required to protect your data and use it only for the specific purpose we engaged them for.
06Cookies and tracking
We use a small number of cookies and similar technologies. These fall into two groups:
- Essential cookies, required for the site to work (such as remembering you are logged in)
- Analytics cookies, which help us understand how visitors use the site in aggregate. We do not use these for advertising or to build profiles of individual users
You can disable cookies in your browser at any time. Disabling essential cookies may prevent parts of the site from working correctly.
07How long we keep your data
We keep your personal data only as long as we need it, or as long as required by law. In practice:
- Customer records: kept for the lifetime of your account, plus 7 years for accounting and tax purposes
- Email subscribers: kept until you unsubscribe, after which we retain only the unsubscribe record
- Support emails: kept for up to 2 years after the last interaction
- Server logs: kept for up to 90 days
08Your rights
You have the following rights regarding your personal data:
- Access: ask us what data we hold about you
- Correction: ask us to correct data that is wrong or outdated
- Deletion: ask us to delete your data (subject to legal retention obligations)
- Restriction: ask us to limit how we use your data
- Portability: ask for a copy of your data in a portable format
- Objection: object to processing based on legitimate interest
- Withdraw consent: at any time, for any processing based on consent
- Lodge a complaint: with your local data protection authority
To exercise any of these rights, email us at support@pincraft.com. We will respond within 30 days.
09How we protect your data
We use standard industry practices to protect your data, including encrypted connections (HTTPS), encrypted databases, restricted internal access, and reputable service providers. No system is perfectly secure, but we take reasonable steps to keep your data safe.
In the unlikely event of a data breach affecting your personal data, we will notify affected users without undue delay, in accordance with applicable law.
10International data transfers
VIREON LIMITED is based in Hong Kong. Some of our service providers may be located in other countries, including the United States, the European Union, and the United Kingdom. When your data is transferred outside your home jurisdiction, we rely on appropriate safeguards (such as standard contractual clauses) to ensure your data remains protected.
11Children's data
PinCraft is not directed to children under 16. We do not knowingly collect personal data from anyone under 16. If you believe we have collected data from a child, please contact us and we will delete it promptly.
12Changes to this policy
We may update this Privacy Policy from time to time, to reflect changes in our practices or in the law. When we make material changes, we will update the "last updated" date at the top of this page and, where appropriate, notify you by email or via a notice on the site.
13Contact us
If you have any questions about this Privacy Policy, or about how we handle your personal data, please contact us:
VIREON LIMITED
Unit 2A, 17/F, Glenealy Tower, No. 1 Glenealy, Central, Hong Kong S.A.R.
Email: support@pincraft.com
Business Registration: 79593076