Poppulo's Legal Terms
We may provide additional "just-in-time" disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.
1. The Scope of this Policy
Our Customers are solely responsible for establishing privacy policies for and ensuring compliance with all applicable laws and regulations, agreements or other obligations, relating to the processing of personal information of individuals who use the Customer Services. If you are an individual who uses a Customer’s instance of our Services, then the processing of your personal information will be subject to the Customer’s privacy practices, and you should contact that Customer for assistance with any requests or questions relating to the processing of your personal information.
2. The Personal Information We Collect
- Personal information you voluntarily provide to us. We collect information you provide to us in optional, voluntary submissions, such as in registration forms, user profiles, promotional sign ups, requests for customer service, blogs, forums, and resumes and curriculum vitae submissions. This information may include (i) first and last name; (ii) business contact information (company, email, phone, physical business address); (iii) personal contact information (email, cell phone); (iv) picture; (v) title; (vi) position; (vii) employer; (viii) ID data; (ix) professional life data; (x) personal life data (in the form of security questions and answers); (xi) connection data; (xii) localization data; (xiii) billing Information; (xiv) IP addresses; (xv) demographics; and/or (xvi) passwords or other online contact information.
3. How We Use Your Personal Information
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes. We may use the information you provide us in the following ways:
- Communication & Responding to Requests: We use your information to provide you with customer support, process transactions, respond to your requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and to connect you to the Services.
- Optimization: We use your information, including your personal information, behavioral metrics, and other non-personally identifiable information to operate, provide, improve, and maintain our Services, to develop new products and services, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.
- Advertising: We may use your information, including personal information, geo-location data, demographic data and marketing preferences to personalize and display advertisements and other content for you.
- Sharing & Communication Features: We may use your information, submitted directly or passively to us, to provide you with various ways to connect and share content (e.g., web content, user generated videos, text, drawings, screen and lecture captures, quizzing features, media, tools, services, and other products) with third parties either through our Services or through third party services (e.g., social networking services). For example, we may provide you with the opportunity to email content to another person, which requires us to use your email address and the email address of the recipient.
- Quality Control: We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services.
- Network & Information Security: We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.
- Health & Safety: We may process your personal information to protect the health and safety of our employees and visitors, our facilities and our property and other rights. If you visit one of our locations, to maintain security at such locations you may be photographed or videotaped.
- Facilitate Corporate Acquisitions, Mergers and Transactions: We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
- With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.
4. Legal Basis for Processing Your Personal Information
For individuals who are located in the European Economic Area, Switzerland or the United Kingdom (collectively, “Europe Residents”) at the time of data collection, our legal basis for processing your personal information under the applicable data protection laws will depend on the personal information at issue, the specific context in which the personal information is collected and the purposes for which it is used. We generally only process your personal information where we are legally required to; where processing is necessary to perform any contracts we entered with you or to take steps at your request prior to entering into a contract with you; where processing is in our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms; or where we have obtained your consent to do so. Below is a chart showing how we use your personal information, as described above in Section 3, with the corresponding legal bases for processing.
Purpose of Processing
Legal Basis for Processing
Network and Information Security
Based on our legal obligations.
Communication & Responding to Requests
Based on our contract with you or to take steps at your request prior to entering a contract.
Health & Safety
Facilitate Corporate Acquisitions, Mergers, and Transactions
Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom.
Responding to Requests
With Your Consent
Based on your consent.
5. Why We Share Your Personal Information
We take care to allow your personal information to be accessed only by those who really need access in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. We do not share your information with third parties except in the limited circumstances as described below.
- Interactive & Communications Features: If you use a forum, blog, channel, bulletin board, chat room, user commenting features, or other interactive sharing or social features that may be offered through any of our Sites and/or Services, you should be aware that any information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction, except to the extent limited access features are available, if any. To request removal of your information from our blog, sharing service or community forum, please reach out using the information provided in the “Contact Us” Section. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to do so and why.
- Professional Advisors: We may disclose your personal information with our professional advisors who provide legal, compliance, insurance, accounting, banking or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
- Change of Ownership: Your information may be disclosed as part of any bankruptcy, merger, sale, transfer of company assets, acquisition, or similar transaction. In the event of such a transaction in which your information would be transferred to a third party, we will make reasonable efforts to notify you. For example, we will post a notice of the transfer of your information on our Services and, if we have your email address, we will send notice of the transfer of your information to that email address.
- Vital Interests: We may disclose information to any party where we believe it necessary in order to protect the vital interests of any person.
- With Your Consent: We may disclose your personal information for any other purpose with your consent.
6. Cookies and Tracking Technology
We also use our types of tracking technologies, such as:
- Flash Locally Stored Objects (e.g. “Flash” cookies), which follow the same principle as normal standard cookies in that they allow information to be stored on a user’s machine
- Transparent GIF or web beacons, which can be used to deliver a cookie to your browser. They can also be used in email marketing to identify to the sender if an email has been opened.
There are two types of cookies: session cookies and persistent cookies. Session cookies are stored in temporary memory, not retained after an end-user's browsing session ends and do not obtain information from the end-user's device. Persistent cookies persist on the end-user's device in the browser's subfolder and are activated again once you visit the site that created the particular cookie and remains for the duration period set within the cookie's file.
We may use the following types of cookies used on our Sites have been categorized based on the categories found in the ICC UK Cookie guide. A list of all the cookies used on our Sites by category is set out below.
- Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the Site and/or Services will not work. These cookies do not store any personally identifiable information.
- Functional Cookies: These cookies enable the Sites and/or Services to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
- Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Sites and Services. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and we will not be able to monitor its performance.
- Social Media Cookies: These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.
- Targeting Cookies: These cookies may be set though our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not directly store personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Do Not Track. Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our online Properties do not currently process or respond to "DNT" signals. We take privacy seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
7. How We Protect and Retain Information
No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create a trial account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your trial account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or trial account.
8. Your Choices
If you reside in certain jurisdictions, you may have the right to exercise certain of the choices and rights available to you under applicable law. If any of the rights listed below are not provided under the law for your jurisdiction, we have the absolute discretion in providing you with those rights.
Your personal information rights are not absolute. Depending upon the applicable law, access to your rights may be denied: (a) when denial of access is required or authorized by law; (b) when we are unable to verify your identity; (c) when granting access would have a negative impact on another’s privacy; (d) to protect our rights and properties; (e) where the request is frivolous or vexatious, or for other reasons. We will not discriminate against individuals who exercise their privacy rights under applicable law.
- Access To Your Personal Information: You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
- Changes To Your Personal Information: We rely on you to update and correct your personal information. You may ask us to correct information that is inaccurate or incomplete by contacting us via the emails or addresses provided in the “Contact Us” Section. Note that we may keep historical information in our backup files as permitted by law.
- Deletion of Your Personal Information: You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
- Objection to Certain Processing: You may object to our use or disclosure of your personal information by contacting us at the address provided in the “Contact Us” Section.
- Automated Individual Decision-Making. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws. We do not engage in any automated processing that has a legal effect on you.
- Revocation Of Consent: Where we process your personal information based upon consent, in certain circumstances you may revoke consent. Please note, if you revoke your consent for the processing of personal information then we may no longer be able to provide you services
- Opt-out of Targeted Advertising: You may opt-out of online tracking based targeted advertising (e.g., cookies) by using our cookies preferences manager, contacting us via the email addresses provided in the “Contact Us” section.
- Promotional Emails: You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
Submitting Requests. You may exercise the rights described above through our online portal or by contacting us as indicated in the “Contact Us” Section. Please note that to protect your privacy and security, we must be able to verify your identity before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable law. We may conduct the verification process by email or phone, and we may ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship with us. You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so.
If you disagree with how we handled a request, you may appeal our decision by contacting us with the subject line “Appeal.” If you are located in the European Economia Area (EEA), Switzerland or the United Kingdom, you have the right to lodge a complaint with your national data protection authority or equivalent regulatory body.
9. Transfer of Personal Information to Other Countries
To facilitate our global operations, we may transfer, store, and process your personal information with our affiliates, third party-partner and services providers based throughout the world. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. Before we share your information with any third party, we will enter into a written agreement that the third party provides at least the same level of protection for the personal information as required under applicable data protection laws.
In relation to personal information transferred out of the EEA, Switzerland or the UK, we rely primarily on the European Commission’s Standard Contractual Clauses and UK ICO’s International Data Transfer Agreement to facilitate the international and onward transfer of personal information collected in the EEA, Switzerland and the UK (collectively “EEA Personal Information”), to the extent the recipients of the EEA Personal Information are located in a country that the EEA, UK or Switzerland considers to not provide an adequate level of data protection. This includes transfers from our EU-based operating entities to our US-based operating entities. We may also rely on an adequacy decision of the European Commission confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.
10. Third-Party Applications/Websites
For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.
Our Sites and Services are not intended for children under the age of 16 and we do not knowingly collect personal information from children under age 16. Children under the age of 16 should not provide their personal information to us. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Services without parental permission. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Services, please contact us, and we will use commercially reasonable efforts to delete that information.
12. Additional Information for California Residents
Category of Personal Information
Category of Recipients
Disclosures for a Business Purpose
Sharing for Cross-Context Behavioral Advertising
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.
Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
With Service Providers as described in the “How We Share Your Information” Section
Professional or employment-related information
With Service Providers as described in the “How We Share Your Information” Section
California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): precise geolocation and contents of consumer’s mail, email, and text messages. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with the Sites and Services. Note that we do not use such information to infer characteristics about you, but only use such information for purposes that are identified within the California Privacy Rights Act Section 1798.121.
California Shine the Light: If you would like information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the “Contact Us” Section bellow.
13. Contact Us
Phone: +353 21 242 7277
Four Winds Interactive LLC Attn: Data Protection Officer
Denver, CO 80203
Last updated: November 9, 2022
Contact us at firstname.lastname@example.org if you have further questions.