Privacy Policy
This Privacy Policy explains how personal data is processed when you use PinLivo, the website pinlivo.com, and the PinLivo app.
1. Controller and contact
SIA Platinium
Meža prospekts 62-8
Jūrmala, LV-2010
Latvia
Registration No. 40203106117
Privacy requests: contact@platinium.tech
Product: PinLivo · pinlivo.com
No data protection officer has currently been appointed. Privacy requests are handled through the contact address above.
2. Data processed by PinLivo
| Category | Examples | Purpose |
|---|---|---|
| Contact data | mobile number, optional email address, display name | account, login, SMS verification, invitations |
| Account data | user ID, language, role, account status, session data | providing and securing the account |
| User content | encrypted chat messages, voluntarily uploaded files/images and encrypted metadata | chat and file exchange |
| Audio/video | real-time media streams; where enabled, audio/text for real-time language functions | calls, captions, translation and speech output |
| Device/push data | APNs/PushKit tokens, web-push endpoint, app version | notifications and incoming calls |
| Usage/metadata | room/participant identifiers, timestamps, call state, duration, language modes | operation, security, diagnostics and billing |
| Payment data | packages, credit, payment status, references, receipts, transaction details | payments and accounting |
| Security data | network address or derived technical values, rate-limit/security events | protection against abuse and attacks |
PinLivo currently does not access your address book, HealthKit or device location and does not use the IDFA for advertising or tracking.
3. Purposes and legal bases
- Art. 6(1)(b) GDPR: account, login, rooms, chat, audio/video calls, translation, credit, payments and support required to provide the service.
- Art. 6(1)(c) GDPR: legally required tax, commercial and payment records.
- Art. 6(1)(f) GDPR: IT security, fraud/abuse prevention, service stability, diagnostics and legal claims.
- Art. 6(1)(a) GDPR where required: optional permissions or features requiring consent. Camera, microphone and notification permissions can be withdrawn in device settings.
4. Chat, files and encryption
PinLivo encrypts chat messages and files on the client side. The server stores encrypted content and technically necessary metadata. Key and session mechanisms are designed to limit server access to plaintext communication content.
Even with end-to-end encryption, technical connection data such as room/participant identifiers, timestamps, data volumes and connection states must be processed.
5. Audio/video calls and LiveKit
For real-time audio and video, PinLivo uses its own media infrastructure at media.pinlivo.com based on LiveKit. Media is transported to establish the real-time connection. PinLivo does not currently record calls as permanently retrievable audio or video recordings.
6. Translation, speech recognition and speech output
PinLivo uses Microsoft Azure for certain translation and speech functions. Depending on the selected feature, text, speech or derived text may be sent to Microsoft as necessary for the requested real-time function.
The current configuration uses Azure Translator and real-time Azure Speech functions. According to Microsoft's published information, text translation data and input data for the real-time Speech functions used here are not retained as permanent customer recordings. PinLivo does not use custom speech models or voice recordings for training.
7. SMS verification and invitations
PinLivo uses seven communications GmbH & Co. KG, Kiel, Germany (seven.io) for SMS. The required mobile number and message content are transmitted to seven.io, especially for login/verification codes and user-initiated invitations. SMS is not used for behavioural advertising.
8. Push notifications and incoming iPhone calls
If notifications are enabled on an Apple device, PinLivo processes an APNs device token and, for incoming VoIP calls, a separate PushKit token. Tokens are stored encrypted and linked to the signed-in account. Required push data is sent to the Apple Push Notification service (APNs). Permissions can be disabled in iOS. Signing out revokes the current device registration; revoked tokens are deleted after the technical grace period.
9. Payments and Mollie
PinLivo supports different payment methods. Where online payment through Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, Netherlands is enabled and selected, payment processing is carried out through Mollie. Mollie is a regulated payment service provider and also processes transaction data under its own data-protection responsibilities.
PinLivo does not store full card details when they are entered only on Mollie's payment flow. PinLivo does retain transaction/reference data needed for orders, status, crediting and receipts. Mollie Privacy Policy
10. Hosting, server operation and technical logs
PinLivo uses hosting and infrastructure providers for web, database and server operation. Technically necessary connection data may be processed, including IP/network data, timestamps, requested resources and security events. PinLivo does not trust freely supplied forwarded headers as the source of the security address.
The PinLivo application uses no advertising or analytics cookies. A secure, technically necessary session cookie is used for login and security; it is not used for advertising or cross-site tracking. This public privacy page itself does not set a PinLivo session cookie.
11. Recipients and international transfers
Personal data is disclosed only where necessary for a feature, required by law, or otherwise supported by a legal basis. Recipients may include hosting/server providers, Microsoft Azure for optional translation/speech functions, seven.io for SMS, Apple for push delivery and, where used, Mollie for online payments.
Where processing takes place outside the EEA, transfers are handled in accordance with Arts. 44 et seq. GDPR, for example on the basis of an adequacy decision or appropriate safeguards such as EU Standard Contractual Clauses where applicable.
12. Retention and deletion
- Chat/file content: removed through the technical deletion process when a room closes or expires; it is not intended as a permanent message archive.
- Raw room, participant, call and media-event metadata: generally shredded within a technical grace period of up to 24 hours after closure/expiry unless already deleted.
- Completed direct-call metadata without a room: deleted after the 24-hour grace period.
- Push/VoIP tokens: retained while the device is registered; revoked tokens are deleted after the technical grace period.
- SMS invitation diagnostics: currently retained for up to 30 days.
- Aggregated diagnostics: may be retained for limited diagnostic periods, currently up to 62 days, without plaintext messages, room PINs or push tokens.
- Account/security data: while the account exists or as necessary for security, abuse prevention or unresolved matters.
- Payment, ledger and receipt records: according to applicable commercial, tax and payment-law retention obligations.
13. Data security
PinLivo uses technical and organisational safeguards including TLS/HTTPS, secure session cookies, hashing and encryption of sensitive tokens, access controls, rate limits, short-lived room/session data and client-side encryption for chat and files. No technical measure can guarantee absolute security.
14. Your privacy rights
Subject to the GDPR, you may have rights of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and objection to processing based on legitimate interests (Art. 21). Consent may be withdrawn at any time with future effect.
Privacy requests can be sent to contact@platinium.tech. Signed-in users can permanently delete their account directly under My account → Delete account. The active account, deletable personal data and associated user content are removed. Reasonable identity verification may be required for other privacy requests. Records subject to statutory retention duties cannot be deleted before those duties expire.
15. Right to lodge a complaint
You may lodge a complaint with a data-protection supervisory authority. For SIA Platinium in Latvia, this is in particular the Data State Inspectorate (Datu valsts inspekcija), Elijas iela 17, Riga, LV-1050, Latvia; pasts@dvi.gov.lv; dvi.gov.lv.
16. PinLivo app and Apple App Privacy
For the iOS app, Apple's App Privacy disclosures describe the data categories actually collected, including contact information, user/device identifiers, payment/purchase history, voluntary user content and operational usage/diagnostic data. They are not used for advertising or cross-app tracking.
PinLivo currently uses no ATT/IDFA tracking. Location, address book, HealthKit and advertising data are not collected by the PinLivo app. Real-time audio is not currently retained as a permanently retrievable recording.
17. Changes to this Privacy Policy
This policy will be updated when functions, providers, legal requirements or actual processing materially change. The version published at pinlivo.com/privacy/en/ is the current English version. Where a material change requires new consent, consent will be obtained before that processing.