intData Processing Addendum
Last updated
This addendum forms part of the Operator App Terms between Distinctive Vending LLC ("Pinpoint Vending") and the operator, and governs personal information handled in connection with advertising on the operator's screens.
1. Definitions
- Personal information — information that identifies or could reasonably be linked to a particular person or household, as defined by applicable privacy law.
- Controller (or business) — the party that decides why and how personal information is processed.
- Processor (or service provider) — a party that processes personal information on a controller's behalf and on its instructions.
- Sub-processor — a third party engaged to process personal information in connection with the service.
- Applicable law — the CCPA as amended by the CPRA, other US state privacy laws where they apply, and the GDPR and UK GDPR where they apply.
2. Scope of processing
| Category | Examples | Purpose |
|---|---|---|
| Operator contact and account data | Email, account holder's first and last name, sign-in records, terms acceptance | Operating the account, paying the operator |
| Screen and location data | Venue name, address, coordinates, machine identifiers, photographs | Setting up advertising, registering screens with our advertising partner |
| Machine reports | Sent once a day: total ads played, app version, screen resolution, connection type, Wi-Fi strength, data used | Knowing when a screen has stopped working |
| Grow page requests | Name, email, phone, what was asked for, area, and the names, addresses and details of the account's screens | Following up on the request, through our sales system |
| Advertising requests | Ad unit identifier, user-agent and IP address of the machine | Serving ads and confirming they ran (section 3.3) |
| Payment data | Amounts earned and paid; bank and tax details held by Stripe | Paying the operator, tax reporting |
We do not measure the people around screens. None of our software counts or recognises people, or captures images or the identifiers of nearby phones.
3. Roles and responsibilities
Role allocation is the heart of this addendum, and it is not uniform across the service.
3.1 Where Pinpoint Vending is a processor
For personal information about other people that the operator chooses to put into the service — people shown in photographs or uploaded ads, and other people named in support messages — we act on the operator's instructions.
3.2 Where the operator is a controller
The operator is responsible for any notice or signage their venue requires, for their own obligations to their staff and visitors, for having the right to run advertising at the location, and for having the right to give us the material described in 3.1.
3.3 Where Pinpoint Vending is a controller
For the operator's own account, payment and contact information, Pinpoint Vending is a controller: it is our customer relationship, and the Privacy Supplement governs it.
For registering screens with advertising platforms, for advertising requests, and for any audience or location data about screens that we provide to anyone now or in future, Pinpoint Vending acts as a controller in its own right and decides the purposes and means. We are not acting on the operator's instructions when we do this, and the operator is not responsible for it. Section 2.5 of the Privacy Supplement describes what screens send. We do not sell personal information; section 5 describes the one way we share it, with our ad partner. This sharing is a condition of running screens through the app: an opt-out through the Do Not Sell or Share page takes the affected screens off advertising.
This is stated plainly because calling ourselves a mere processor for data we decide to send to advertisers would be inaccurate, and inaccuracy in this document is itself a legal exposure.
4. Sub-processors
The operator authorises these sub-processors. We remain responsible for their performance.
| Sub-processor | Service | Location | Data |
|---|---|---|---|
| Supabase | Database, authentication, sign-in emails, file storage | United States | Account, screen, machine report, earnings, upload and support data |
| Stripe | Payouts, identity and tax verification | United States | Name, email, bank and tax details, payment amounts |
| 4 Corners Media Group | Media partner: advertising demand and ad serving, through the advertising platforms it works with | [CONFIRM WITH 4 CORNERS MEDIA GROUP — not recorded anywhere in our code or contracts on file] | Screen name, address, coordinates and characteristics; machine IP address; blocked ad categories. It also holds each screen's advertising revenue and photographs given to its platforms. |
| [CONFIRM: hosting provider of our own sales system, crm.pinpoint-vending.com] | Running the system that handles Grow page requests | [CONFIRM] | Name, email, phone, the request, and details of the account's screens |
| Resend | Support-thread emails | [CONFIRM] | Email addresses on the account, and the thread's text |
| Optional sign-in; web fonts | United States | Email, name and profile picture where the operator chooses Google sign-in; IP address when a page loads | |
| Vercel | Hosting the app's web pages | United States | IP address and browser details, in server logs |
| esm.sh | Delivering a code library the app loads | [CONFIRM] | IP address and browser details |
| Komoot (Photon) | Address suggestions | Germany | Address text as typed, and IP address |
| OpenStreetMap Foundation | Geocoding a machine's address | [CONFIRM] | Machine address and IP address |
| ipwho.is | Approximate machine location from IP | [CONFIRM] | Machine IP address |
| GitHub | Machine software updates | United States | Machine IP address |
We do not provide screen, location or audience data to data buyers.
We will give the operator at least 30 days' notice before adding a sub-processor that handles their data. If the operator reasonably objects, they may close their account.
5. Security measures
- Row-level access rules in the database, so one operator's records are unreachable by another even if the application is at fault.
- Encryption in transit and at rest.
- Append-only financial records: entries are added and corrected, never silently altered.
- Bank account numbers and tax identifiers held by Stripe, never by us.
- Credentials kept as managed secrets, not in application code.
- Access to production data limited to staff who need it.
6. Data isolation
Each operator sees only their own screens, earnings and correspondence. Staff may access any account for support and operations. Aggregated statistics across screens may be used for pricing and reporting. We do not sell them; if we ever provide them to anyone, section 3.3 applies.
7. Assisting with individual rights
If an individual contacts the operator about information we hold, the operator should forward it to privacy@pinpoint-vending.com. We will help the operator respond within the time the law allows, and we will respond directly where we are the controller.
8. Security incidents
We will notify the operator without undue delay, and in any event within 72 hours of becoming aware of a breach affecting their personal information, with what we know, what we are doing, and what we recommend. We will cooperate with any notification the operator must make.
9. Audit
On reasonable written notice, and no more than once a year unless required by a regulator or following a breach, we will provide the information reasonably needed to demonstrate compliance with this addendum.
10. Retention, deletion and return
Retention periods are set out in the Privacy Supplement. On termination, the operator may export their earnings history. Within 90 days we will delete or de-identify personal information about other people in the operator's uploaded ads (section 3.1). Photographs and support messages follow the periods in the Privacy Supplement, including any other people they show or name. We may keep anything longer where tax, accounting or legal-hold reasons require it.
11. International transfers
Our systems are in the United States. Address suggestions come from Komoot in Germany, and other sub-processors in section 4 may process data elsewhere. The service is offered only for machines in the contiguous United States, so no personal data is transferred to us from the EEA, the United Kingdom or Switzerland. If that changes, this section will be replaced with the transfer mechanisms that apply.
12. CCPA and CPRA provisions
Where we act as a service provider (section 3.1), we will not retain, use or disclose the operator's personal information for any purpose other than performing the service, will not sell or share it, and will not combine it with information from other sources except as permitted. We certify that we understand these restrictions.
Where we act as a controller (section 3.3), those restrictions do not apply to that processing, and we take responsibility for it — including honouring opt-out requests.
13. Term, changes and governing law
This addendum lasts as long as we process personal information in connection with the operator's account. Sections 5, 8, 10 and 12 survive. It is governed by the laws of Delaware, interpreted so as to comply with applicable privacy law. Changes require written agreement, except changes we must make to comply with the law, which we will notify.
14. Contact
Privacy: privacy@pinpoint-vending.com
Legal: legal@pinpoint-vending.com
Security reports: hello@pinpoint-vending.com