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Privacy Policy

Last Updated: 01/04/2024

INTRODUCTION

This Privacy Policy describes the privacy practices for the publications, businesses, websites, mobile applications, crosswords, and other ancillary digital products, and related online services that we provide through the foregoing (collectively, “Products”) that are operated by Pleroma Media, Inc. and its affiliates (“Pleroma” “we”, “our” “us”),To the extent permitted by applicable law, by using the Products and providing us with Personal Information (defined below), you agree to the practices described in this Privacy Policy and to the updates to these policies posted here from time to time. If you are based in the European Economic Area (“EEA”) or the United Kingdom (“UK”), this Privacy Policy serves as notice of how we process your Personal Data (defined below) for which we are a controller. If we require your consent, we will request it formally, in adherence to applicable data protection laws.

To make sure you stay informed of all changes, you should check these policies periodically. Updates will be referenced by the “Last Updated” date shown above.

PERSONAL INFORMATION AND PERSONAL DATA DEFINITION

For purposes of this Privacy Policy, unless a different definition is noted in a particular instance, “Personal Information” (or “Personal Data” as used in the “Individuals in the European Area (EEA) or UK” section below) means any information that identifies, relates to, describes, references, or is reasonably capable of being associated with an identified or identifiable natural person.

Personal Information for purposes of this Policy does not include your name, photo and/or other information about you included in news or editorial content. 

PERSONAL INFORMATION WE COLLECT

We may collect the following types of Personal Information about you as described below:

(A) Personal Information you provide to us,

(B) Personal Information we may automatically collect, and

(C) Personal Information we may receive from third parties.

A. Personal Information You Provide to Us

In using our Products, you may provide us with Personal Information, which may include (the examples provided are illustrative and not intended to be exhaustive):

· Contact information such as name, email address, postal address and telephone number(s);

· Demographic information such as birth date or gender;

· Account information and log in credentials, including unique identifiers such as username and password;

· Payment and transaction information including credit or bank card information;

· Preferences for communications;

· Communications and opinions in chat rooms, message boards, forums, surveys, polls, and online forms;

· Access to your geo-location (including through our mobile app) or to other data held on social media platforms and other software (for example, access to your contacts, calendar or photos);

· Photos and/or videos; and

· Any additional information that we describe to you, when we collect your data with your consent.

You agree that you will provide to us only your own Personal Information, or the Personal Information of those whom you have the legal right to provide (such as in your capacity as a legal guardian). You agree to provide us with accurate Personal Information.

B. Personal Information We May Automatically Collect About You

Our Products may automatically collect certain Personal Information about you. This Personal Information may include the following (the examples provided are illustrative and not intended to be exhaustive). Any of this information may be combined with other Personal Information we may have or obtain about you from your use of our Products or from third parties as described below in “Personal Information We May Receive from Third Parties.”

· IP address, which is the number associated with the service through which you access the Internet, such as through your ISP (Internet service provider);

· Date and time of your visit, registration, login or use of our Products;

· Domain server from which you are using our Products;

· Type of computer, web browsers, search engine used, operating system, or platform you use;

· Your Social Media Platform login information

· Data identifying the web pages you visited prior to and after visiting or using our Products;

· Data identifying the videos that you view while using our Products;

· Your location data

· Your behavior, movement and activity on or within the Product;

· Your profile information

· Geo-location information through the use of any of our mobile applications;

· Your list of contacts, friends or followers

· Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and

· Certain Personal Information about your activities on the Social Media Platform

· Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.

· If you sign up for text messaging, cookies or other tracking devices may be used to personalize your experience (for example, to send you personalized text message offers).

C. Personal Information We May Receive from Third Parties

We may collect or receive additional Personal Information about you from third-party websites and apps, social media platforms and video viewing platforms, such as, but not limited, to Facebook, Twitter, TikTok, Instagram, SnapChat and YouTube (“Social Media Platforms”), third party data providers, and sources providing publicly-available Personal information (e.g., from the U.S. postal service) for the purposes described in “How We Use Personal Information” section below.

Personal Information we may access from Social Media Platforms may include, but is not limited to:

· Your Social Media Platform login information

· Your location data

· Your profile information

· Your list of contacts, friends or followers

· Certain information about your activities on the Social Media Platform such as without limitation the content you view, and products or services you purchase there

Please keep in mind that when you provide Personal Information to us via a third-party website or platform (for example, via our applications on a mobile device or by logging into any of our Products via a social media account), the Personal Information you provide to us may be separately collected by the third-party website or platform or the Social Media Platform. Please review the privacy policies of the applicable third-party or Social Media Platform for their privacy practices. Also, please be aware that if you are logged into your social media account when you are visiting our Products, the Social Media Platform you are logged into may track your activities on our Products.

HOW WE USE PERSONAL INFORMATION

A. Use and Purpose of Processing Your Personal Information

We use and process your Personal Information for the following types of purposes (the examples provided are illustrative and not intended to be exhaustive).

· To provide you with the Products, and other promotions, newsletters and information we think you may be interested in

· To respond to your inquiries and provide you with requested information and to provide other communications, including by email, chat or text messages, and including alerts, notification of promotions, contests, and events

· For marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and other third parties, provided that you have not already opted-out of receiving such communications

· For billing and payment processing

· To deliver personalized advertising and content, including textual and audio-visual ads and content

· To fulfill contracts we have with you

· To manage, improve and support our relationships with third-parties that we contract with in connection with our business, Products and services, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners

· To maintain, improve, customize, or administer the Products, perform business analyses, or other internal purposes to improve the quality of our business, Products and services, , resolve technical problems, or improve security or develop other products and services

· To comply with our Terms of Service and Terms of Use for various Products

· To perform analytics for business purposes and business intelligence, such as monitoring traffic to our Products, counting ad impressions, and auditing legal and regulatory compliance

· To maintain the safety, security, and integrity of our Products, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators

· To identify and repair errors in our Products’ functionality

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information we hold is among the assets transferred

· To comply with any applicable laws and regulations and respond to lawful requests; and/or

· For any other purposes disclosed to you at the time we collect your Personal Information and/or pursuant to your consent .

If we decide to use the Personal Information for materially different purposes, we will update this Privacy Policy.

B. Disclosing Your Personal Information to Other Parties

We may disclose your Personal Information to other parties, including:

· Our affiliates

· Service providers

· Advertisers, advertising technology companies, Social Media Platforms, analytics companies and other third parties with whom we have business relationships.

· Government regulators

· Our legal advisors and parties involved in a legal process.

· To an entity involved in the sale of our business

· Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or Services we provide to you

In order to provide advertisements and content that are more relevant to you, we and our advertising and content providers may collect certain types of Personal Information when you use our Products (such as, by way of example, your email, the IP address of your device, the identifier on your mobile device, or cookies stored on your device). We may combine this information with other information we have, or that we collect through other sources, and may share the information we collect with third parties to provide interest based or targeted advertising and content, including textual and/or audio-visual ads or content. In addition, our advertising partners and Social Media Platforms may use information received from us to combine it with other information they may have about you obtained through other sources or through your relationship with them.

If we decide to disclose Personal Information to additional categories of parties, we will update this Privacy Policy.

Do We Use "Cookies"?

Yes. Cookies, SDKs, tracking pixels and similar technologies are small files that a website or mobile application stores on your device that recognizes the user’s browser or device and captures and remembers certain information.

In general, we and our third-party providers, advertisers and marketing partners, use these technologies to optimize the functionality of the Products, to help us understand how the Products are used and to provide users with interest-based content and/or advertising, including textual and/or audio-visual ads or content based upon their browsing activities and interests.

If you sign up for text messaging, cookies or other tracking devices may be used to personalize your experience (for example, to send you personalized text message offers). 

In addition, you may opt out of certain interest-based advertising by using the following resources:

(a) You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.

(b) You may opt-out of receiving some permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/ or visiting About Ads at http://optout.aboutads.info.

(c) You may opt-out of having your activity on our Products made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

(d) One of our providers, LiveRamp, Inc. collects certain Personal Information from you through our Products, such as your email (in hashed form), IP address or information about your browser or operating system. LiveRamp then returns to us an online identification code that is associated with your Personal Information, and that we may store in our first-party cookie for our own use in online and cross-channel advertising across our Products. It may also be shared with advertising companies to enable interest-based and targeted advertising. To opt out of this use by LiveRamp, please click here: https://optout.liveramp.com/opt_out.

Video Viewing Behavior

As described elsewhere in this privacy policy and for purposes of clarity, your video viewing activity, including information as to whether you requested or obtained specific video materials or services, may be collected and shared by Pleroma with third parties, including, without limitation, service providers with whom we partner to provide our Products to you, as well as our advertising, social media and other business partners. By using our Products where videos are displayed, you consent to the collection and sharing with third parties of your video viewing activity, if any, with each such consent being valid for two years from the date of such use or until you withdraw your consent.

THIRD PARTY LINKS

Our Products may contain links to other websites, applications or services that are not owned or controlled by us, including links to Social Media Platforms, or may redirect you off our Products to other locations for information or other services. This Privacy Policy only applies to information collected by our Products. We are not responsible for the privacy and security practices of other websites, applications or social media platforms or the information they may collect (which may include IP address or device identifiers). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other websites, applications, Social Media Platform or content do not constitute or imply an endorsement or recommendation by us of the linked website, application, Social Media Platform, and/or content.

Third Party User Identity Solutions

“When you visit or enter your email address (either to log in, to sign up for a newsletter, or otherwise) on our websites, we may share personal data or other information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, and/or information about your browser or operating system with Third Party User Identity Solutions (“User ID Solutions”), acting as controllers. These User ID Solutions use this information to create an ID for the purpose of recognising you on your devices. This ID does not contain any of your identifiable personal data. We may place this ID in our first-party cookie or use a User ID Solution cookie and allow it to be used for online and cross-channel advertising. This ID may be shared by us or on our behalf with our advertising partners and other third-party advertising companies globally for the purpose of enabling interest-based content and/or targeted advertising throughout your online experience (e.g. web, email, connected devices, in-app, etc).

The following Third Party User ID Solutions are deployed across the Company’s web properties:

SECURITY

We use commercially reasonable procedures and various technical, administrative and physical safeguards to help protect the confidentiality of your Personal Information. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features.

ACCESSING, CORRECTING, OR DELETING YOUR PERSONAL INFORMATION

As required by applicable laws, and subject to any permitted exceptions and limitations, we will comply with any verified consumer request you submit with respect to your Personal Information. Please submit a verifiable consumer request to us through the email address below.

Transfers

Your Personal Information may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside the United States, and may have different data protection laws than in the United States.

AGGREGATE AND DE-IDENTIFIED INFORMATION

We may aggregate and/or de-identify any information collected through the Products so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA) SWITZERLAND OR UK

This Section is included in this Privacy Policy to comply with the requirements of the General Data Protection Regulation (“GDPR”). It applies only to individuals visiting or using our Products from within the EEA, Switzerland or the UK and applies only (1) if we collect through the Products any Personal Data of those individuals or (2) if we track individuals in the EEA, Switzerland or the UK who access our Products.

Controller

Pleroma is the controller (as defined under the GDPR) for processing and using the Personal Data of individuals within the EEA, Switzerland or the UK that is collected through our Products. Please see the email below to find out how to contact us.

Rights of Individuals Based in the EEA

Subject to applicable law, you may be able to exercise any of the following rights in relation to your Personal Data:

· Right to know what information we have about you: This is known as the "right of access" and gives you the right to find out what, if any, Personal Data we have about you, how we process it, and to request a copy of the Personal Data.

· Right to correct your information: This is known as the "right of rectification" and gives you the right to ask that we correct or complete any Personal Data we have about you.

· Right to delete your information: This is known as the "right to erasure" or "right to be forgotten" and gives you the right to ask us to delete your Personal Data.

· Right to change how we use your information: This is known as the "right to restrict processing" and gives you the right to ask us to change how we use your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us using it in a certain way.

· Right to move your information: This is known as the "right to data portability" and gives you the right to ask to receive your Personal Data from us in a structured, commonly used and machine-readable format or to have it transmitted to another controller.

· Right to stop us from using your information: This is known as the "right to object" and gives you the right to ask us to stop using your Personal Data when applicable.

· Rights relating to how we use your information to categorize you or make decisions about you: This is known as the "right in relation to automated decision-making and profiling": You have the right to be free from decisions we may make that are based solely on automated processing of your Personal Data, including profiling, if they produce a significant legal effect on you, unless such decision-making or profiling is necessary for entering into or performing a contract between you and us, or is made with your explicit consent.

· Right to withdraw consent: If we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. This will not affect our use of your data before we received notice that you wished to withdraw your consent.

· Right to file a complaint with the supervisory authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the supervisory authority that is authorized to hear those concerns in your jurisdiction, although we provide contact email below of this page with any concern as we would be happy to try and resolve it directly.

You may exercise your rights by contacting us as indicated under the Contact US section below.The requests above will be considered and responded to in the time period stated by applicable law. Certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests.

Legitimate Interests

“Legitimate interests” means the interests of our company in conducting and managing our organization. For example, and without limitation, we have a legitimate interest in processing your Personal Data to analyze how the Products are being used, to administer our contractual relationships, fulfil legal obligations, process employee data, prevent fraud or criminal activity or misuse of our products or services, ensure the security of our IT systems, architecture and networks, and meet our corporate and social responsibility objectives, and/or effectively and efficiently operate our business and provide you with the services offered through our Services, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests.

Data Transfers

Pleroma is based in the United States, and we use service providers (described above) based in the United States to operate our business and our relationship with you. When you use our Products, you acknowledge that your Personal Data may be transmitted, stored, processed by us and our service providers’ servers in the United States to provide you with the services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EEA we will take steps to ensure that your rights continue to be protected. We endeavor to apply suitable safeguards to protect the privacy and security of your Personal Data and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also enter into data processing agreements and model clauses with vendors as appropriate.

Data Retention

We will keep your Personal Data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy based on the context in which you provided it, or for the duration required by law, whichever is the longer.

CHILDREN’S ON-LINE PRIVACY INFORMATION

In general, the Products are not intended for use by children under the age of 13, or 16 where applicable, and the terms for certain Products may specify further age-related restrictions. In cases where certain Products are intended for use by children under the age of 13 (or 16 where applicable), we will post appropriate notices and take steps as required by applicable law to safeguard children’s data. In addition, we do not knowingly collect Personal Information from children under the age of 13 (or 16 where applicable) through form submissions on our Products, although certain third party sites that we link to may do so. These third-party sites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Products without their permission.

Involvement of parents: In accordance with the provisions of the Children’s Online Privacy Act, in the event that we do begin collecting any Personal Information or data from children under the age of 13 (or 16 where applicable), we will notify parents first, and will seek parental or guardian consent to collect, use and/or disclose certain Personal Information from children under the age of 13, or 16 where applicable. A parent may review and have deleted their child’s Personal Information, and may refuse to permit further collection or use of their child’s information by contacting us as noted at the end of this Privacy Policy. Parents may consent to our collection and use of their child’s Personal Information without consenting to the disclosure of that information to others.

If you have reason to believe that a child under the age of 13 (or 16) has provided Personal Information Contact Us below with sufficient detail to enable us to delete that information from our databases.

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES, INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE, WILL WE OR OUR SUBSIDIARIES, PARENT COMPANIES OR AFFILIATES BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES THAT RESULT FROM OUR USE OFPERSONAL INFORMATION, EVEN IF WE ARE ADVISED BEFOREHAND OF THE POSSIBILITY OF SUCH DAMAGES, AND THE MAXIMUM AMOUNT OF DAMAGES FOR WHICH WE WILL BE LIABLE UNDER THIS AGREEMENT WILL BE THE GREATER OF THE FEES YOU PAID FOR ANY PRODUCT IN CONNECTION WITH WHICH YOU PROVIDED YOUR PERSONAL INFORMATION, OR $100. (BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN CATEGORIES OF DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. IN SUCH JURISDICTIONS, OUR LIABILITY AND THE LIABILITY OF OUR SUBSIDIARIES, PARENT COMPANIES AND AFFILIATES, IS LIMITED TO THE FULLEST EXTENT PERMITTED BY SUCH LAW.) YOU SPECIFICALLY ACKNOWLEDGE AND AGREE THAT WE ARE NOT LIABLE FOR ANY DEFAMATORY, THREATENING, OFFENSIVE OR ILLEGAL CONDUCT OF ANY USER OF OUR PRODUCTS.

INDEMNIFICATION

You agree to indemnify and hold harmless us, our affiliates, and each of our and their respective directors, officers, managers, employees, shareholders, agents, representatives and licensors, from and against any and all losses, expenses, damages and costs, including reasonable attorneys' fees, that arise out of your provision of any inaccurate or unauthorized Personal Information to us or your violation of this Agreement or any rights of another. We reserve the right to take over the exclusive defense of any claim for which we are entitled to indemnification under this section. In such event, you agree to provide us with such cooperation as is reasonably requested by us.

WAIVER OF CLASS ACTION CLAIMS

You and Pleroma agree that each party may bring disputes against the other party only in an individual capacity, and not as a plaintiff or class member in any purported class or representative proceeding, including, without limitation, a federal or state class action lawsuit. However, nothing in this section limits your right or Pleroma’s right to bring a lawsuit against each other as an individual plaintiff. This provision applies to the maximum extent permitted by applicable law to all claims that arise under, in connection with, or relate to this Privacy Policy or the Personal Information you provide to us (whether your own or any other Personal Information you provide), Personal Information that is automatically collected by us and/or obtained by us from third parties; that arose under, in connection with, or relate to any previous privacy policy in effect or that otherwise arose before these terms went into effect; or that may arise in connection with or after or otherwise relate to your Personal Information (or any other Personal Information you provide to us) after termination of any business relationship we may have with you, including cancellation or deletion of your accounts if applicable.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on our Products and update the notice’s “Last Updated” date. Where permitted by applicable law, your continued use of our Website and/or Services following the posting of changes constitutes your acceptance of such changes.

OTHER

This Privacy Policy, any terms of use or terms of service posted on or in or linked to from our Products or described on any form through which you registered or subscribed to a Product, as well as other policies referenced herein or therein constitutes the entire agreement (“Agreement”) between us and you with respect to the subject matter contained in this Agreement and supersedes all previous and contemporaneous agreements, proposals and communications, written or oral.

You also may be subject to additional terms and conditions that may apply when you use the products or services of a third party that are provided through the Digital Products. In the event of any conflict between any such third-party terms and conditions and this Privacy Policy (as it relates to Personal Information or Personal Data), this Privacy Policy will govern.

This Agreement will be governed by and construed in accordance with the laws of the State of New York, without giving effect to any principles of conflicts of law.

This Agreement is personal to you and you may not assign it to anyone. We may assign this Agreement and all rights and obligations hereunder at any time. If any provision of this Agreement is found to be unlawful, void, or for any reason unenforceable, then that provision will be deemed severable from this agreement and will not affect the validity and enforceability of any remaining provisions. This Agreement is not intended to benefit any third party, and does not create any third party beneficiaries. Accordingly, this Agreement may only be invoked or enforced by you or us.

You agree that regardless of any statute or law to the contrary, any claim or cause of action that you may have arisen out of or related to use of the Products or this Agreement must be filed by you within one year after such claim or cause of action arose or be forever barred.

CONTACT US

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information described here, your choices and rights regarding such use, or you wish to exercise your rights, please contact us as provided below.

· Email us : info@pleromamedia.com

· Write us at: Pleroma Media Inc., 33 Whitehall St, Fl 7, NY 10004 Attn: Privacy Officer