Version 03in force since September 3, 2026

Integration terms

The terms applying to anyone installing PINTRU on the pages of their own website: what the integration covers, how data protection roles are divided, the publisher's obligations, and the pages on which the integration must not operate.

A separate document from the terms of use

1. Scope and acceptance

These terms apply to anyone placing PINTRU's integration code — below, "the script" — in the pages of a website for which they are responsible (below, "the publisher").

The terms are deemed accepted upon installation of the script and remain in force for as long as it is present on the website's pages.

This document is separate from the terms of use, which apply to anyone using PINTRU to create content, and from the purchase terms, which apply to anyone subscribing to a paid plan. A publisher who is also in either of those positions is subject to the relevant document in each of them.

The processing of personal data carried out by PINTRU as controller is described in the privacy notice; what is stored on visitors' devices is described in the cookie policy.

2. What the integration does

By installing the script the publisher activates PINTRU for their visitors: on the pages that load it, existing content is displayed together with the tools to create more. This is a decision made by the publisher, on behalf of people who have not made it.

PINTRU does not interfere with the content the publisher transmits, nor with how that content is made available. The pin layer is added only within the browsing session of the person who asked to see it, exists solely in their browser, is not visible to other visitors of the website, is not stored by the annotated website, and ends when the tool is switched off. The website being visited is served by its own publisher and receives no information from PINTRU.

The available features, the content categories and the limits applied may change over time, including as the service and the plans offered evolve.

3. Data protection roles

Installing the script does not in itself give rise to any processing: the script stays inert until the publisher declares the visitor's consent, and without that declaration it stores nothing on the device and transmits no data. From the declaration onwards, data of the host website's visitors is collected in their browser and communicated to PINTRU. For this phase — collection through the script and communication to PINTRU — the publisher and PINTRU jointly determine the purposes and means of processing: the publisher decides to activate PINTRU, on which pages and on what terms; PINTRU determines which data the script collects and how it transmits it. For that phase the parties are joint controllers within the meaning of Article 26 of Regulation (EU) 2016/679 and govern their respective obligations by the arrangement set out in the following section.

For all processing subsequent to receipt of the data — storage, moderation, publication of content, security, abuse prevention, operation and improvement of the service, handling of data subjects' rights over platform content — PINTRU acts as an independent controller, under its own privacy notice, and the publisher neither takes part in it nor has access to it.

The publisher gives PINTRU no instructions regarding the processing described in the preceding paragraph and is not answerable for it.

4. Joint controllership arrangement

For the collection and communication phase described in the preceding section, the parties agree as follows, which constitutes the arrangement required by Article 26(1) of the Regulation. The essence of this arrangement is made available to data subjects by its publication on this page and by the reference contained in PINTRU's privacy notice, in fulfilment of Article 26(2).

4.1 Division of obligations

It is for the publisher: to provide their visitors with the information required by Articles 13 and 14 of the Regulation concerning the activation of PINTRU on their pages; to collect, where required, consent to the storing of information on the terminal equipment under Article 122 of the Italian Personal Data Protection Code, before the script stores a persistent identifier or transmits usage data; to keep proof of that consent and pass its receipt to the script; to allow visitors to withdraw consent; and to choose the pages on which the script is installed.

It is for PINTRU: to make its own privacy notice available, to which the publisher refers; to adopt the security measures required by Article 32; to limit collection to what is described in its own notice; to refrain from persistent writing and from transmitting usage data absent a declaration of consent; and to act on data subjects' requests concerning the data it holds.

4.2 Security and confidentiality

PINTRU adopts appropriate technical and organisational measures under Article 32 of the Regulation, described in the Security section of the notice, and ensures that persons authorised to process data are bound by a duty of confidentiality.

4.3 Providers used

For the processing for which it is responsible, PINTRU uses the providers listed in the table below. Changes are notified 30 days in advance to the email address associated with the integration; within that period the publisher may object on legitimate grounds and, where the objection is reasoned, discontinue the integration at no cost.

List updated on 3 September 2026.

4.4 Transfers outside the European Union

The infrastructure and the sending of communications remain within the European Union. The only non-EU destination is the United States of America, for the automated assessment of content intended for publication, on the basis of the standard contractual clauses adopted by the European Commission.

4.5 Mutual assistance

The parties assist each other, by appropriate measures and taking account of the nature of the processing, in acting on data subjects' requests and in complying with obligations relating to security, breach notification and impact assessment.

4.6 Personal data breaches

Each party informs the other of personal data breaches affecting the jointly controlled processing. Notification is given without undue delay and, where possible, within 48 hours of becoming aware of the breach, to the email address associated with the integration.

4.7 Audits

PINTRU makes available to the publisher the information necessary to demonstrate compliance with the obligations set out here. Audits may be requested once a year, with 30 days' notice and in a manner that does not compromise the security of other customers; the related costs are borne by the publisher requesting them, unless failures come to light.

4.8 Termination

Jointly controlled processing ends when the script is removed. Content published by visitors remains on the platform, being processed by PINTRU as an independent controller for its own purposes and in the interest of its authors and of other users; the publisher has no standing to ask for its deletion or its return, without prejudice to the ability to report individual unlawful content and to the objection to public annotation provided for by the terms of use. The rights of individual data subjects against each joint controller are unaffected.

5. The publisher's obligations

The publisher undertakes to:

• inform their visitors of PINTRU's presence in their own privacy notice and cookie policy, stating the data processed and referring to PINTRU's documents;
• collect the consent of their visitors, where the applicable law requires it, before the script stores a persistent identifier on the device or transmits usage data;
• respect the visitor's decision: absent consent, or where it is withdrawn, not to declare it to the script;
• never declare a consent that was not collected, and to pass on the consent receipt where available;
• make available to their visitors the means to withdraw consent;
• not alter, obfuscate or reproduce the script, nor use it for purposes other than those provided for;
• comply with the law applicable to their own website, including the rules on data protection and on the protection of minors.

6. Pages on which the integration must not operate

PINTRU is intended for the public pages of a website. The publisher undertakes not to include the script, and to remove it where already present, on:

• payment and checkout pages, and forms relating to cards or other payment instruments;
• authentication pages: sign-in, registration, credential recovery, two-step verification;
• restricted areas in which the user consults or enters personal data of their own or of third parties: profiles, case files, documents, correspondence;
• pages processing special categories of data within the meaning of Article 9 of Regulation (EU) 2016/679, or data relating to criminal convictions and offences;
• pages specifically aimed at minors.

PINTRU adopts measures designed to prevent the integration from activating in such contexts even where the script has been included there by mistake, and extends them over time. The exclusions currently active operate on two levels: the service recognises from the address the typical paths of payment, sign-in, registration, credential recovery and personal areas, and does not activate on those pages; in addition the script examines the page and switches itself off when it finds a password field or a card details field. The check is repeated on the server. These measures are subsidiary in nature and do not replace the publisher's own decision as to the pages on which to install the script.

Activating the integration on pages of that kind justifies suspension under the section Duration and interruption.

7. Visitors' content

Content published by visitors through PINTRU belongs to its respective authors. The publisher is not answerable for it as such, but may report it using the tools provided; PINTRU reserves the right to remove content that breaches its terms.

Content intended to become visible to others is subject to the checks provided for by the terms of use, which apply also to content created on the publisher's website.

A publisher who considers content referring to one of their pages to be unlawful or damaging may report it to info@pintru.com. Reports relating to copyright follow the procedure in the Copyright section.

8. What PINTRU provides

• A script that is discreet by default: until consent is declared, no persistent identifier is stored on the visitor's device and no usage data is transmitted, and the service operates in temporary mode.
• A deferred activation snippet, made available to the publisher, which evaluates the visitor's decision and requests the service script only once consent has been obtained: until that moment no request is made to PINTRU's servers and no connection data, including the IP address, is communicated to it. The publisher remains free to install the script directly, including by making its loading conditional on their own consent collection tool.
• A mechanism for declaring consent and passing on its receipt, distinguishing documented consent from declared consent. Where the host website uses a tool compliant with an industry standard that the snippet can query, the visitor's decision is read from that tool and the receipt is compiled accordingly; failing that, consent is declared by the publisher.
• Management of content under the service's rules, including the checks that precede publication.

PINTRU does not warrant that using the script is in itself enough to make the publisher's website compliant: that assessment depends on the context, the audience and the law applicable to that website. Nor does PINTRU warrant that the service will be constantly available or free from errors, and it may suspend it for maintenance, security or causes beyond its control.

9. Updates to the integration code

The publisher uses the version of the script supplied by PINTRU and accepts that its technical behaviour may change for reasons of security, compliance or functionality, and that new features may be introduced or existing ones removed.

Changes that substantially affect the obligations set out in this document are notified by an appropriate means and with reasonable advance notice, where circumstances allow. Notice is at least 30 days, given to the email address associated with the integration.

These terms may be updated. The version in force is the one published on this page, with the date shown at the top. A publisher who does not wish to accept a change must remove the script from their pages.

10. Liability and indemnity

PINTRU is liable for damage caused by intent or gross negligence and for anything that cannot be excluded by law. To the extent permitted by the applicable law, PINTRU is not liable for content published by visitors, for the consequences of an untrue declaration of consent, for activation of the integration on the pages described in section 6, or for damage arising from use of the script that departs from these terms.

The publisher holds PINTRU harmless from third-party claims, including those of supervisory authorities, arising from failure to observe the obligations set out in the sections The publisher's obligations and Pages on which the integration must not operate. The integration is provided free of charge. Where such a limitation is permitted, PINTRU's total liability towards the publisher does not exceed the greater of any amount the publisher has paid in the 12 months preceding the event and the sum of five hundred euro. The limitation does not apply in cases of intent or gross negligence, nor in any other case where the law does not allow it.

11. Duration and interruption

These terms are effective for as long as the script is present on the publisher's pages. The publisher may discontinue the integration at any time by removing it; content already published by visitors remains on the platform under the service's general rules.

PINTRU may suspend or discontinue the integration on a website, with reasonable notice where possible and without notice in the event of abusive or unlawful use, of risk to users, of activation on the pages described in section 6, or of breach of the obligations set out here.

12. Final provisions

Partial invalidity. The invalidity or ineffectiveness of any single clause does not affect the remaining ones, which retain full effect.

Forbearance. Failure or delay in exercising a right does not constitute a waiver of it.

Assignment. PINTRU may assign the contract as part of a sale or contribution of the business or of the branch to which the service belongs, provided that this entails no reduction in the guarantees granted, with at least 30 days' notice. Anyone who does not wish to continue with the assignee may end the relationship and, if they hold a paid plan, obtain a refund of the portion relating to the unused period.

13. Contacts

For matters concerning the integration: info@pintru.com. For matters concerning personal data: info@pintru.com. The service's single electronic point of contact is stated in the terms of use.

PINTRU is provided by Thomas Casadei, a sole trader under Italian law; the full identifying details are stated in the terms of use.