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Privacy Policy

Last Updated: May 23, 2021

Your privacy is important to Wings Media, LLC (“Wings Media”, “we”, “us”, or “our”). This Privacy Notice (“ Notice”) describes how we treat personal information provided or collected on or through our PodopoloTM mobile application (“ App”), websites including www.podopolo.com, (collectively the “ Websites”), our trainings or events, and any other media platforms offered by Wings Media where this Notice is posted, including the Wings of Inspired Business Podcast and any other podcasts supported by PodopoloTM. The Websites, Apps, and such other media platforms are collectively referred to in this Notice as the “ Services”. The Services may include “gamified” features that facilitate audience engagement. This Notice also applies to personal information collected through such features.

INFORMATION WE COLLECT

When you use the Services, you may provide the following “Personal Information” to us: Name, email address, mailing address, and phone number. In general, you will know what Personal Information we collect because you will actively and voluntarily provide it to us. We may collect Personal Information from you automatically when you use the Services, such as your IP address, geolocation data, and other information about your device and web browser. When using the Services, you may be asked to provide payment card information to complete a purchase. Please note that we do not collect or store payment card information. We use a third-party service provider to process such transactions. Some of the information we collect does not identify you and is not considered Personal Information, such as information about how you interact with the Services and information about your device (“Non-Personal Information”).

HOW WE USE YOUR PERSONAL INFORMATION

We use your Personal Information to pursue our legitimate interests and administer the Services to you, including for the following purposes:

  • To personalize your experience when using the Services;
  • To process transactions and communicate with you about your orders;
  • To fulfill any requests you make through the Services;
  • To improve customer service;
  • To improve the Services;
  • To administer a contest, challenge, promotion, survey or other features offered through the Services;
  • To provide you information that may be of interest to you;
  • To send periodic emails to you about the Services or other information we think may be of interest to you; and
  • To send you periodic SMS texts messages (if you have opted in to receive text messages);

We may create anonymized data from Personal Information we collect by excluding information (such as your name) that makes the data personally identifiable to you. Such anonymized data is considered Non-Personal Information. We may use Non-Personal Information for any purpose, including to analyze requests and usage patterns so that we may enhance the content of our Services.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your Personal Information to others, including our affiliated entities and third-party service providers we use to support our business and provide the Services to you. When we disclose your Personal Information, we make sure such parties are contractually obligated to use Personal Information only for the purposes for which we disclose it to them. We may also disclose Personal Information in the event of a merger, divestiture, restructuring, or other sale or transfer of some or all of Wings Media’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which Personal Information is among the assets transferred. We may also disclose Personal Information if we believe in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Wings Media; (iii) to protect or defend the rights or property of Wings Media or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Notice, or our Terms of Use at https://podopolo.com/terms.

The Services may include social media type functions that allow you to post information or comments. Please note that such information and comments you post or submit will be publicly available for others to view.

YOUR CHOICES WITH RESPECT TO YOUR PERSONAL INFORMATION

You can login into your user account to update or correct your Personal Information at any time. If you do not want to receive emails or text messages from us, you may opt out of receiving such communications by following the instructions included in the email or text message. You can also opt out of receiving certain advertisements by adjusting your browser settings, as described in the Cookies section below. If you need assistance updating or correcting your Personal Information, or with opting out of communications from us, you can contact us as described below. If you wish to terminate your account with Podopolo, it is in your right to do so, verbally or in writing, and Podopolo will consider the removal of all personally identifiable information from our servers. You may request a copy of your personal data and we will respond to such request within 30 days. If you no longer wish for us to process your data to provide the best experience for you within our sites and services, you may submit a request to cease data processing. We will respond to such requests within 30 days.

COOKIES

A cookie is a small file placed on your computer by a website that uses the cookie to store information about your use of the website to help users navigate websites efficiently, as well as to provide information to the owner of the website. There are two general types of cookies: session cookies and persistent cookies. Session cookies are only used during a single session online and will be deleted once you leave a website. Persistent cookies have a longer life and will be retained by the website and used each time you visit a website. Both session and persistent cookies can be deleted by you at any time through your browser settings.

When you use the Services, we may place session and/or persistent cookies in order to improve your experience by recognizing you when you return to use the Services again, such as by assigning a session ID, and to deliver content specific to your interests. We may also allow our affiliates and third-party vendors to use cookies on our Services. Some of these parties may use cookies in ways that we do not. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you use the Services. In reference to the Podopolo website, cookies are opt-in. If you wish to use the Podopolo website without cookies (potentially hindering your experience while using the Podopolo website) you may do so by continuing to use the website without accepting cookies.

THIRD PARTY WEBSITES

You may find advertising or other content on our Services that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. Such external links and websites are operated by third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Services. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Once you have left our Services, we cannot be responsible for the protection and privacy of Personal Information you provide on other websites. Browsing and interaction on any other website, including websites which have a link to our Services, is subject to that website’s own terms and privacy policy. You should exercise caution and review the privacy policy of any website you visit.

ADVERTISEMENTS

Some content, applications, and features, including advertisements on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We reserve the right to share your personal identifiable information with third parties we trust to improve your user experience while using our sites, apps and services. Our third party partners are held to strict compliance in handling your personal identifiable information and cannot use it outside of the Podopolo sites, apps, and services. We never sell your personal identifiable information to third parties.

SECURITY MEASURES

We implement physical and technical safeguards to protect against unauthorized access to your Personal Information and to prevent unauthorized use, alteration, corruption, or disclosure of Personal Information. All personal identifiable information is encrypted, pseudonomized, or anonymized in transit and at rest on secure servers hosted with Amazon Web Services. Please note, however, that we cannot guarantee that your Personal Information will remain secure in all circumstances.

DATA RETENTION

We will retain your Personal Information only for the period necessary to accomplish the permitted purpose as outlined in this Notice, unless a longer retention period is required or permitted by applicable law. In accordance with the General Data Protection Regulation, we respect your right to erasure, or ‘right to be forgotten.’ Upon verbal or written request to have your data removed from all Podopolo sites and services, Podopolo has 30 days to respond to such request. Your right to erasure is not absolute and is only applicable in certain situations.

DATA BREACH

In the event of a data breach, we agree to provide accurate, timely, and transparent information to the best of our knowledge to all affected individuals and/or organizations. In accordance with the General Data Protection Regulation, we will provide notification of any data breach within 72 hours of discovery.

DATA PROTECTION OFFICER

In accordance with the General Data Protection Regulation, we have a Data Protection Officer (DPO) assigned to ensure all data and privacy regulatory compliance is met. To contact the DPO with questions, comments, or concerns please contact our toll-free number and ask for the DPO, or email dpo@podopolo.com.

CHILDREN

The site, app and services are not intended for children under 13 years of age. We do not knowingly collect Personal Information from children who are under the age of 13. If a child under 13 submits Personal Information to Wings Media without verifiable parental consent, and we learn about it, we will delete the Personal Information as soon as possible. If you believe that we might have Personal Information from a child under 13, please contact us as described below.

CALIFORNIA RESIDENTS

This section applies to California residents only and supplements the information contained in this Notice. The California Consumer Privacy Act 2018 (the “CCPA”) grants specific rights to California residents and requires that we make certain disclosures. If you are a California resident, you have the right to: (i) request that we delete Personal Information that we have collected about you; (ii) request that we disclose the Personal Information we have collected about you; (iii) request that we disclose whether we sell (or sold) your Personal Information; (iv) opt-out of the sale of your Personal Information (to extent we sell your Personal Information); and (v) not face discrimination for exercising your rights under the CCPA. With respect to the sale of Personal Information, the CCPA defines “sale” or “sell” broadly to cover scenarios that are traditionally not considered a sale of Personal Information. Accordingly, there may be instances where we sell (as that term is defined under the CCPA) Personal Information. To exercise your right to opt-out of such sale, you (or your authorized agent) may submit a request to us by visiting the following link: Support@Podopolo.com. To exercise other rights under the CCPA, you (or your authorized agent) may contact us by submitting a verifiable consumer request as described below. Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We collect the following categories of Personal Information directly from you and indirectly from you (e.g., by observing your actions on our website): (i) Identifiers, which includes the following specific pieces of Personal Information: name, email address, street address, and telephone number; (ii) Commercial Information, which includes the following specific pieces of Personal Information: products or services purchased or considered, or other purchasing or consuming history or tendency; (iii) Internet or other electronic network activity information, which includes the following specific pieces of Personal Information: browsing history, search history, and information regarding your interaction with the Services; and (iv) Geo Location Data, which includes information about the location of the device you use to connect to the Services.

The purposes for collecting and selling (as that term is defined by the CCPA) Personal Information, and how we use and share Personal Information, are those outlined in the “How We Use Your Personal Information” and “Disclosure of Your Personal Information” sections of this Notice.

In the preceding twelve months, we have:

  • Collected the following categories of Personal Information: Identifiers; Commercial Information; and Internet or other electronic network activity information.
  • “Sold” (as defined by the CCPA) the following categories of Personal Information: Identifiers, Commercial Information, Internet or other electronic network activity information, and Geo Location Data.
  • Disclosed for a business purpose the following categories of Personal Information: Identifiers, Commercial Information, Internet and other electronic network activity information, and Geo Location Data.
  • Collected Personal Information from the following categories of sources: directly from you and indirectly from you.
  • Shared Personal Information with the following categories of third parties: service providers that help facilitate our business, advertising networks, internet service providers, and data analytics providers.

California Civil Code Section 1798.83 permits users of the Services who are California residents to request certain information regarding our disclosure of Personal Information to third parties for direct marketing purposes. To make such a request, please contact us as described below.

USERS FROM OUTSIDE OF THE UNITED STATES

Wings Media is located, and the Services are hosted, in the United States. If you are using the Services from outside the United States, please be aware that any Personal Information we collect will be stored and processed in the United States where we locate and operate our servers and databases.

EUROPEAN ECONOMIC AREA INDIVIDUALS

If you are located in the European Economic Area (“EEA”), you have certain data subject rights that may be subject to limitations and/or restrictions. These rights include the right to request access to and rectification or erasure of your Personal Information, obtain restriction of processing or to object to processing of your Personal Information, ask for a copy of your Personal Information to be provided to you, or to a third party. If you wish to exercise any of these rights, please send us your request to the contact details provided below. Individuals in the EEA also have the right to lodge a complaint about the processing of their Personal Information with the appropriate Data Protection Authority.

DO NOT TRACK NOTICE DISCLOSURES

Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. This is different than blocking cookies as browsers with the “do not track” option selected may still accept cookies. We currently do not honor “do not track” signals. If we do so in the future, we will update this Notice accordingly.

CHANGES TO THIS NOTICE

We may update this Notice from time to time. When we do, we will post a notification on the main page of the Services and revise the “last updated” date at the top of this Notice. We encourage you to review this Notice frequently for any changes to stay informed about how we are helping to protect the Personal Information we collect.

CONTACT US

If you have questions, comments, or complaints about this Notice, you may contact us at: dpo@Podopolo.com