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Privacy Policy

We at Poppulo and our subsidiaries and related companies, including Four Winds Interactive LLC (trading as Poppulo), E-Search DAC, and Smartspace Global Limited (collectively referred to as “Poppulo,” “we,” “our,” or “us”) take our responsibilities under applicable data protection law, including the EU General Data Protection Regulation and implementing legislation such as the Data Protection Act 2018, very seriously. We have established this Privacy Policy to explain and describe the personal information Poppulo collects, how we uses that information, and your options regarding the personal information we collect about you.

This Privacy Policy applies when you visit the Poppulo websites and related subdomains, (collectively, the “Sites”), and all our products, mobile applications, software, blogs, forums, channels, sharing, and quizzing services (collectively, along with “Sites”, the “Services”). This Privacy Policy also applies when a customer’s employees provides their personal information to use our Services, when you receive communication from us, register or attend our events or webinars, or contact us with questions about our products.

Please take a moment to read this Privacy Policy carefully. By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

We may change this Privacy Policy in response to changing legal, technical, and business developments. The most recent version of this Privacy Policy is reflected by the version date located at the top of this policy. If we make material changes to this Privacy Policy, we will take appropriate measures to inform you in a manner that is consistent with the significance of the changes we make and is in accordance with applicable law. Your continued use of our Services constitutes your acceptance and agreement to this Policy and any updates.

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.

If you have questions about our Services, your personal information or this Privacy Policy, you can reach us through the methods provided in the “Contact Us” Section at the end of this Privacy Policy.

1. The Scope of this Policy

This Privacy Policy applies when Poppulo is acting as a data controller, meaning that it controls the means and purpose of the processing of certain personal information. This Privacy Policy does not apply when Poppulo, acting at the direction of a customer in providing the Services, processes the personal information of our customer’s end users’ personal information (collectively referred to as “Customer Services”). Customers are the controllers of the Customer Services as they can (i) deploy content not provided by Poppulo, (ii) manage and develop their own internal or external communications via the Customer Services, and (iii) otherwise collect, use, share, or process personal information via our products and services.

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 is typically data that identifies an individual or relates to an identifiable individual. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy. As described below, this includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.

  • 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.
  • Personal information we collect automatically. We collect information about you and your use of and interactions with our Services, including information about where you are logging in from, whether you open the communications we send you, and how you use our Services. Please refer to the “Cookies and Tracking Technology” Section of this Privacy Policy to learn more about how we passively collect your information.
  • Personal information we collect from other sources. We may also personal information, from third party sources. If we directly combine information from third parties with personal information that we have collected, we will treat the combined information as personal information and handle it in accordance with this Privacy Policy.

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 bases 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 Bases for Processing

Network and Information Security

Based on our legal obligations.

Communication & Responding to Requests

Quality Control

Based on our contract with you or to take steps at your request prior to entering a contract.

Optimization

Advertising

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

Advertising

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.

  • With Our Service Providers: We may provide your information to third parties as is necessary in order to provide our Services. In some instances, these service providers collect your information on our behalf. All of our service providers are only allowed to process your information at our direction and in accordance with this Privacy Policy and must maintain the confidentiality, security, and integrity of your information.
  • Our Affiliates: We may share your information with our parent companies, subsidiaries and/or affiliates. This information may be shared and used to provide services and support, provide recommendations to optimize product and service use, to provide customers and prospective customers with information about the range of available products and services, and for the purposes otherwise described in this Privacy Policy.
  • 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.
  • To Comply with Our Legal Obligations:We may disclose your information if we have a good-faith belief that doing so is required by a subpoena, warrant, or other judicial or administrative order or otherwise required by national security, law enforcement requirements, statute, government regulation, or law. Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of our Terms of Use or End User License Agreements, or our other agreements; take precautions against liability; protect our rights, property, or safety, or those of a partner, any individual or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; or assist government regulatory agencies.
  • 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 may use cookies and similar technologies to collect personal information, or information that becomes personal information if we combine it with other information. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that advertisements you see online are more relevant to you and your interests. Other tracking technologies are used on our Services. These are primarily used to understand if customers or users are interacting with any marketing-type emails sent from our systems. You can find more information about cookies at: http://www.allaboutcookies.org.

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.

Using our cookie preference manager, you have the option to determine which cookies and tracking technologies we may use when you use the Sites and Services. You can also set or amend your web browser controls to accept or refuse cookies.. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. If you choose to reject cookies, your access to some functionality and areas of our Services may be restricted.

Performance/Analytical Cookies. We may use analytics tools and other third party technologies, such as Google Analytics, Pardot, ZoomInfo, Salesloft, and 6Sense to collect information in the form of various usage and user metrics when you use our Sites and/or Services. These tools and technologies collect and analyze certain types of information, including cookies, email, name, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information. For additional information on how these companies use data collected from our websites or applications, please visit their website privacy policy:

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.

We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

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.
  • Opt-out of Third Party Analytics. We use Google Analytics cookies to collect information about the user behavior on some of our online Properties. The information is used to collect data reports to improve the content and performance of our Sites. Google’s privacy policy is located at http://www.google.com/policies/privacy/partners/.
  • 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.

11. Children

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

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of this Privacy Policy.

The table below describes the categories of personal information we collect, disclose for a business purpose, and “share” (as that terms are defined by California law). We do not “sell” your personal information for money. For details regarding how we use personal information, please see the “Information We Collect” Section of the Privacy Policy. For information regarding how long we retain personal information, please refer to the “How We Protect and Retain Information” Section of the Privacy Policy.

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.

As provided in the “How We Share Your Information” Section in this Privacy Policy

Advertising networks

Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.

With Service Providers to process transactions as provided in the “How We Share Your Information” Section in this Privacy Policy

N/A

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 provided in the “How We Share Your Information” Section in this Privacy Policy

Advertising Networks

Geolocation data

With Service Providers as described in the “How We Share Your Information” Section

Advertising Networks

Professional or employment-related information

With Service Providers as described in the “How We Share Your Information” Section

N/A

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

If you have questions regarding this Privacy Policy or about the privacy practices of Poppulo, please contact us as noted below.

Email: privacy@poppulo.com

Phone: +353 21 242 7277

Mail:
Four Winds Interactive LLC Attn: Data Protection Officer
1221 Broadway
Denver, CO 80203
USA

Last updated: November 9, 2022

Contact us at legal@poppulo.com if you have further questions.