Privacy and Cookie Policy



  1. About Arise Digital (PTY) Limited and this Privacy Policy

    Your privacy is important to us; this is why we created this Privacy Policy so that you are aware of what information is collected, how we use it, and who we share it with.

    This Privacy Policy covers our websites on the Podcastar.co.uk domain, our mobile, apps, Player, and our other websites, products, software, applications, content, data feeds and other services (“Service”) on which an authorized link to this Privacy Policy is posted. This Policy covers our practices regarding Arise Digital (PTY) Limited users of all ages. The Service is operated by Arise Digital (PTY) Limited.

    If you are an EEA resident, this whole Policy applies to you. However, EEA residents should see Section 15 below, which will inform you in detail about the personal information we process, how we process it, for which purposes we process it, with whom we share it, on what legal basis we process and transfer your personal information and which rights you have regarding the processing of your personal information.

    Arise Digital (PTY) Limited is also committed to protecting the privacy of our users.

    If you have any questions, comments, or concerns regarding this Privacy Policy and/or data practices, please contact us at the following support form, telephone number, or mailing address:

    Arise Digital (PTY) Limited
    Attn: Arise Digital (PTY) Limited Privacy Manager
    Email: director@arise-digital.com

    For users based in the European Economic Area or in the United Kingdom:

    If you are a user based in the European Economic Area or in the United Kingdom, you may also contact our Representative according to Articles 27 EU and UK GDPR:

    Email: director@arise-digital.com
    17 Venter Street, Dan Pienaarville, Krugersdorp, Gauteng 1739, South Africa

  2. Definitions

    "Personal Information" means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.

    "Processing" means any operation which is performed on personal information, such as collection, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.

    Any other capitalized term that is not defined in this Policy is defined and has the meaning set out in our Terms of Use.

  3. Information Collected on our Corporate Websites

    Please note that our Corporate Websites (which may include Embillservices.com, blog. Arise Digital (PTY) Limited.com, and their subdomains) are general audience websites. On these sites, we may provide information regarding the corporate side of Arise Digital (PTY) Limited, press information, career information, and other general audience information.

  4. Information You Provide when Setting Up an Account on Arise Digital (PTY) Limited

    Registered users
    All users must create an Account to access our services. To create an Arise Digital (PTY) Limited account, we will ask you to create a unique username and password (so you can log in to your account), and to provide other demographic information such as your age or date of birth, gender, regional location or language preference (so we can customize your experience on Arise Digital (PTY) Limited).

    Users are encouraged not to create a username that reflects their own name or other personal information. Users should also not pick a password that is easy to guess and should not share their password.

    Usernames are used for participating in Service features, and we do not use them to identify individual users outside of their activities on our Service. Usernames are shared with the parties listed in Section 7 below.

    Users may be asked to provide or may choose to add a mobile phone number and email address to their account for added verification and/or to enable certain features. The primary purpose for this is to provide account security, as this is the only way for Arise Digital (PTY) Limited to check the authenticity of an account owner.

    Additional Personal Information You Provide When Using Arise Digital (PTY) Limited Features

    In addition to account setup on Arise Digital (PTY) Limited, we may collect and process personal information from you directly if you use the following features and activities (as applicable):

    • When you make purchases on the Service. Users can purchase premium subscriptions, Premium memberships, etc., and may use a variety of payment methods. When making purchases, users may be required to enter billing information, including name, billing address, credit card or other payment information, and billing email. Your billing information, transaction details, and purchase history may also be retained and used by our payment processors to resolve subsequent billing disputes and inquiries.

    • When you post, share, or otherwise transmit comments or messages on Arise Digital (PTY) Limited via community features, such as public chat or private chat, forums, group walls, personal posts, etc. We may collect these comments and messages, and they may be monitored, filtered and moderated for purposes such as removal of profanity, personal information, and other inappropriate conversations. We may use pre-filtered chat, comments and messages for purposes such as training and improving our filter technology to increase the safety on our platform, except that we will not engage in these activities with private chat, comments, and messages of EEA users.

    • When you provide us with your phone number. If you choose to provide a phone number during registration, you may receive a verification SMS after sign-up to confirm your ownership of the number, which will allow you to log in via mobile. Your phone number may also be used to recover a lost or forgotten password.

    • When you contact or send communications to us. For example, when you contact customer support, report a problem, or submit questions, concerns, or comments regarding our Service or its content, we may collect contact information such as your mobile phone number email address and other important information about your inquiry or concern. This information is used to respond to your communications, fulfill your requests, or provide other customer support.

    • When you use or interact with third-party plug-ins that may be available on the Service. This includes third-party social media widgets, share buttons, and/or login mechanisms. These features may include social plugins from Google, Facebook, Twitter or other platforms and may be subject to the privacy policies of these other companies as posted on their respective websites. When you use these features, certain information from your social media accounts may be accessed by or shared with Arise Digital (PTY) Limited, and likewise, certain information about your use of Arise Digital (PTY) Limited may be posted to your profile on those platforms.

    • When you participate in contests, competitions, sweepstakes, giveaways, prize draws or other promotions that we may run or sponsor on our Service. These promotions may involve the collection and use of certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion. In some jurisdictions, we are required to publicly share information of winners.

    • When you respond to or participate in voluntary research or demographic surveys or studies. These surveys may collect information about your likes and dislikes, general hobbies and interests, and other lifestyle information or preferences. These surveys may ask for personal information.

    • When you request or agree to location-based services from Arise Digital (PTY) Limited, which may be available to our users. With your consent, we may collect or track real-time or precise geolocation information to provide services such as tagging, check-in and content delivery, or geo-based advertising, or other services that are dependent on knowing where you are. This information may be collected in combination with an identifier associated with your device to enable us to recognize your mobile browser or device when you return to the Service. You can always stop the collection of location information by updating your device settings, stopping to use the Service, or uninstalling our mobile applications.

    • When you subscribe to other features or activities. We may offer other features or activities on our Services from time to time, and you may be able to submit or upload personal information in connection with such features. The data being collected for such features and their intended uses will be evident at the time of data collection.

    • When you browse, navigate, or otherwise interact with the Service. We collect information from your device when you visit our websites, as outlined in the “Cookies and Similar Technologies” section below.

    You are under no obligation to provide personal information to Arise Digital (PTY) Limited when requested. However, if you choose to withhold any requested information, we may not be able to provide you with certain services and features.

    In addition to the specific uses above, any information that you provide or that we collect on the Service may be generally used for the following purposes:

    • To operate, maintain, and improve the Service;

    • To give you access to the Service and related features or restrict your access;

    • To personalize the Service or content on the Service, as well as make it more user-friendly;

    • To allow you to manage your Arise Digital (PTY) Limited account or account information, update your account settings, and (where applicable) make purchases or subscribe to services;

    • To communicate with you about the Service (product changes, feature updates, etc.);

    • To provide technical support or customer service;

    • To deliver advertising for our Services that may be relevant to your interests;

    • To detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;

    • To research technological development and demonstration;

    • To identify and repair errors that impair existing intended functionality;

    • To audit interactions, transactions, and other compliance activities; and

    • To protect the integrity, safety, or security of the Service or our users, comply with legal obligations, or enforce compliance with our Terms of Service or other restrictions placed on your use of the Service.

  5. Cookies and Similar Technologies

    Like most websites, we use cookies and other standard Internet technologies to help us improve our Service.

    Cookies
    A cookie is a small text file that is placed on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, for example so you don’t have to re-enter them whenever you come back to the website or browse from one page to another.

    A cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:

    • Session cookie which is erased when the user closes the browser; or

    • Persistent cookie which remains on the user’s computer/device for a pre-defined period of time.

    As for the domain to which it belongs, there are either:

    • First-party cookies which are set by the web server of the visited page and share the same domain (in this case Podcastar.co.uk domain); or

    • Third-party cookies stored by a different domain to the visited page’s domain. This can happen when the webpage references a file, such as JavaScript, located outside its domain

    Pixel Tags/Web Beacons
    A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about visitors’ engagement on that web page. The use of a pixel allows us to record, for example, that a visitor has visited a particular web page or clicked on a particular advertisement.

    How we use cookies
    When you visit or access the Service, we may – by means of cookies, beacons, tags, scripts, and/or other similar technologies – automatically collect technical information about the devices and software you use to access the Service, such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Service, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, and other similar technical information. These same technologies (or a combination of them) may also be used to help us:

    • Capture and store users’ preferences, account settings, and certain login information (for convenience, user verification, and account security);

    • Compile statistics and analytics about your use of and interaction with the Service, including details about how and where our Service is downloaded from or accessed, how often a user visits or uses the Service, the date and time of user visits to, and actions on, the Service, which areas of the Service are visited and for how long, information regarding in-service activities, and other similar traffic, usage, and trend data;

    • Mobile analytic tools to allow us to better understand the functionality of our mobile software on your device and gain insights about how mobile software is used;

    • Gather important functionality, testing, and performance data about our Service, including performance data related to our mobile application, the Arise Digital (PTY) Limited Player, and Arise Digital (PTY) Limited Studio, such as networking activity, CPU load, and resource usage, among other relevant data;

    • Moderate user behavior on the Service, such as protecting against payment fraud and other inappropriate activities;

    • Gather demographic information about our user base; and

    • Perform other similar functions

    We will not use cookies or similar technologies other than for the purposes stated in this Privacy Policy.

    Third party advertising and ad networks
    Arise Digital (PTY) Limited partners with third-party advertisers, ad server companies, and ad networks (“third-party advertising companies”) to promote our Service. If you respond to one of our advertisements and visit or register to use our Service, we or our service providers may provide these third-party advertising companies with identifiers from your device or computer, such as an IP address or device ID, to help us analyze our user acquisition efforts.

    NOTE: In order to disable advertising-related tracking at your request, companies may need to set an opt-out cookie on your browser. Sometimes a browser’s configuration may prevent companies from setting such cookies, for example, if your browser is set to block all third-party cookies by default. Therefore, you may need to change your browser settings to accept cookies in order to fully disable advertising-related tracking.

    Your choices
    Most web and mobile device browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set.

    Some browser manufacturers provide comprehensive help relating to cookie management in their products. Please see below for more information:

    You can also learn more about cookies by visiting https://www.allaboutcookies.org/, which includes additional useful information on cookies and how to block or delete cookies that are already on your computer.

    Please note, however, that by blocking or deleting cookies used on the Service, you may not be able to take full advantage of the Service and you may not be able to log on to the Service.

  6. Information Sharing

    Please note that Arise Digital (PTY) Limited has not and does not sell personal information about you to third-party companies for their independent purposes. Arise Digital (PTY) Limited may disclose your information for a business purpose as set forth below.

    Agents and contractors
    Arise Digital (PTY) Limited may share users’ information, including personal information including but not limited to billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Arise Digital (PTY) Limited’s behalf. These providers may operate or support certain functions of the Service. Below is an illustrative list of functions for which we may use third-party service providers and the names of the providers we may use to perform these functions:

    • Analytics services (e.g., Google LLC, comScore, Flurry Analytics);

    • User Acquisition services (e.g., AppsFlyer);

    • Community filtering and moderation services (e.g., CommunitySift);

    • Customer support services (e.g., Zendesk);

    • Surveys and promotions (e.g., Reach3);

    • Billing services and payment gateway providers (e.g.,Worldpay, PayPal, Google, Apple, Amazon, Windows Store, Mobivate); and

    • Hosting and content delivery network services (e.g., AWS, Equinix, CenturyLink).

    These agents and contractors are only allowed to use the personal information shared with them for the specific tasks they’ve been hired to do and consistent with this Privacy Policy, and for no other purposes, and they are not permitted to sell the personal information shared with them. Arise Digital (PTY) Limited takes steps to ensure that all service providers with access to personal information are capable of protecting the information we share with them.

    Legal disclosures
    We may disclose personal information about you as required or permitted by law and/or comply with a judicial proceeding, court order, or legal process served on our Service. To the extent permitted by applicable law, we also may disclose personal information about you in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services), or if we believe in good faith that such disclosure may prevent a crime, facilitate an investigation related to public safety or protect the safety of a child using our Service, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights.

    Business transfers
    Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. Where required by applicable law, we will inform you of such disclosure and obtain your consent.

    De-identified information
    We share aggregated, automatically-collected, or otherwise de-identified personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users' interests, habits and usage patterns for certain programs, content, services, advertisements, promotions and/or functionality available through the Services.

  7. Security and Data Retention

    Security
    The security of your personal information is important to us. We have security measures in place to attempt to protect the personal or other sensitive information submitted to us against the loss, misuse and alteration of personal information under our control. While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use reasonable efforts to prevent it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

    When using the Services or providing personal information to us, we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of an incident that may qualify as a breach under applicable law, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

    Retention
    Arise Digital (PTY) Limited may retain users’ account data internally for the following purposes:

    • Billing information and transaction histories are retained to resolve subsequent billing disputes and inquiries;

    • Publicly shared content

    • User account history is retained to support subsequent customer service inquiries and to provide, improve and develop the Services;

    • To promote safety and security on and for the Services; and

    • To resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with our legal obligations.

    We may retain your information for as long as is necessary and relevant to your use of the Service and our operations, which may include retaining your information beyond the end of your use of the Service.

  8. External links

    Our Service may, from time to time, contain links to external sites or applications. We are not responsible for the privacy policies or the content of such sites or applications. To make clear when you are linking to a third-party site or application, we may display a warning message informing you when you are leaving our Service.

  9. Accessing and Updating Your Personal Information

    If personal information about you changes, or if you no longer desire to use our Service, you may correct, update, amend, or deactivate your account under your account settings or by contacting Arise Digital (PTY) Limited using the personal information set out above in Sec. 1. We will respond to your request within a reasonable timeframe.

    Storage and International Transfer of Your Personal Information

    Arise Digital (PTY) Limited is based South Africa. Your personal information which we collect are sent to and stored on secure servers located in the United States. Such storage is necessary in order to process the information.

    Arise Digital (PTY) Limited operates globally and we may transfer the personal information that we collect from you to our other offices and/or to the third parties mentioned in the circumstances described above (see“Information Sharing”), which may be situated outside of your regional location, and may be processed by staff operating outside your regional location. In particular, information provided to us or collected by us likely will be transferred to and processed in the United Kingdom by us or our agents and contractors. The data protection laws of the United Kingdom or other countries may not be as comprehensive or equivalent to those in your regional location of residence. Wherever we transfer your personal information, we will take reasonable steps to ensure that your privacy rights continue to be protected.

  10. Additional Information for EEA Residents

    In the course of visiting our websites and apps, and/or using our services and products, we may process the following personal information:

    • Login information, which may include your IP address, device type, name, date and time of your visit, information on your browser version, information on your operating system, including language settings, MAC addresses, and User ID. We will process this information to provide you with the websites, apps and our online services. The legal basis for this processing activity is Article sec. 1 sent. 1 lit. b (“performance of a contract”) and lit. f (“legitimate interest”) GDPR. It is our legitimate interest to guarantee the websites’ stability and security.

    • Account information, e.g. information such as your name, username, login and password details, location information, user-generated content, contact details and other personal information that are used for participating in the Service feature we are offering. We process this information to provide our Services to you. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).

    • Email addresses you provided us with for added verification and/or to enable certain features. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) and f (“legitimate interest”) GDPR. Arise Digital (PTY) Limited has a legitimate interest of providing a safe and secure Platform.

    • Billing and payment information, when you participate in premium subscriptions, including your name, billing address, mobile phone number, credit card or other payment information and billing information. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”). We may also retain transactions details and purchase and payment history. The legal basis for processing this personal information is our legitimate interest in being able to resolve subsequent billing disputes and inquiries, Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

    • Information relating to contacting our customer service, e.g. when you report a problem, submit questions, concerns or comments. We may process your mobile phone number, email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulfill your requests, or provide other customer support. This processing activity is based on your consent according to Article 6 sec. 1 sent. 1 lit. a GDPR and/or Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”), depending on the initial purpose for contacting our customer support.

    • Comments or messages you post or transmit on Arise Digital (PTY) Limited via public chats, forums, group walls, personal post, etc. We process this information to monitor, filter and moderate this information for the purposes of being able to remove profanity, personal information, and other inappropriate conversations. Additionally, we may use pre-filtered comments and messages for other purposes such as training and improving our filter technology. The legal basis for this processing activity is Arise Digital (PTY) Limited’s legitimate interest in being able to defend ourselves from possible liability claims that may arise from unlawful comments posted by you, Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”). Please note that any personal information submitted by you in forums and similar means offered by us is available to anyone who has access to this forum including other users. The personal information posted by you can be read, collected or used by other users of these forums and could be used to send unsolicited messages.

    • Information relating to your use of or interaction with third party plug-ins, e.g. social plugins from Google, Facebook or Twitter. When you use these features, certain information from your social media accounts may be accessed by or shared with Arise Digital (PTY) Limited, and likewise, certain information about your use of Arise Digital (PTY) Limited may be posted to your profile on those platforms. The legal bases for this processing activity are Article 6 sec. 1 sent. 1 lit. a (“consent”) and f (“legitimate interest”) GDPR. We have a legitimate interest to improve your website experience and to optimize our service.

    • Information processed to enable advertising. To market our services, inter alia, via social media platforms in order to bring new users to our websites and to maintain and increase our user base, we may process personal information such as IP addresses, information on users’ browser or operating system, including language settings, location information and user names or user IDs. The legal basis for the processing of this data is Arise Digital (PTY) Limited’s legitimate interest in maintaining our user base, bringing new users to our websites and informing (potential) users about interesting events, Art. 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

    • Information relating to the use of location-based service. In order to provide Services such as tagging, check-in and content delivery, or other services that require knowing where you are, we may process your location information. This processing is based on Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”) and/or Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”) and represents our legitimate interest to improve your website experience and to optimize our services. Please note that you can always stop the collection of location information by updating your device settings, stopping to use the Service, or un-installing our mobile applications.

    • Information relating to your participation in contest, competitions, sweepstakes, giveaways, prize draws or other promotions that we may run on our Service or sponsor from time to time. We may process certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).

    • Cookies. We will use certain cookies only if you have previously consented to such use. When you visit our website with an EEA IP address, a cookie banner will appear asking you for your consent. You can manage your choice by clicking on “manage cookie preferences” in the cookie banner. We will save your choices in the form of a cookie. This cookie has a limited effective period of one year. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”). In addition, you can also manage cookies using your browser settings. For further information on cookies and similar technologies see Section 7 above.

    Please note that we do not use your personal information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

    Data sharing
    Arise Digital (PTY) Limited may share users’ information, including personal information like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Arise Digital (PTY) Limited’s behalf.

    These providers may operate or support certain functions of the Service. Below is an illustrative list of functions for which we may use third party service providers and the names of the providers we may use to perform these functions:

    • Analytics services (e.g., Google LLC, comScore, Flurry Analytics);

    • User Acquisition services (e.g., AppsFlyer);

    • Community filtering and moderation services (e.g., CommunitySift);

    • Customer support services (e.g., Zendesk);

    • Surveys and promotions (e.g., Reach3);

    • Billing services and payment gateway providers (e.g., Worldpay, PayPal, Google, Apple, Amazon, Windows Store, Mobivate); and

    • Hosting and content delivery network services (e.g., AWS, Equinix, CenturyLink)

    The legal basis for this data transfer and processing activity is Article 28 of GDPR in conjunction with the data processing agreements we concluded with respective third-party agents. These agents and contractors are only allowed to use the information shared with them only for the specific tasks they’ve been hired to do and consistent with this Privacy Policy, and for no other purposes. Arise Digital (PTY) Limited takes steps to ensure that all service providers with access to personal information are capable of protecting the information we share with them.

    Legal disclosure
    We may disclose personal information about you, including the content of your communications on the Service, to comply with legal process, including court orders, served on our Service. In addition, we also may disclose personal information about you, including content, in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services), or if such disclosure may (i) prevent the instigation of a crime, (ii) facilitate an investigation related to public safety or protect the safety of a child using our Service, (iii) protect the security or integrity of our Service, or (iv) enable us to take precautions against liability or to protect our rights. The legal basis for such disclosure is Article 6 sec. 1 sent. 1 lit. c (“compliance with legal obligation”) in compliance with the respective EEA or Member State law and lit. f (“legitimate interest”) GDPR. It is our legitimate interest to comply with the legal requirements of English law.

    Storage and international transfer of your personal information
    Arise Digital (PTY) Limited is based South Africa. Your personal information that we collect is sent to and stored on secure servers located in the United States. Such storage is necessary in order to process the information.

    Some of our agents and third-party service providers are located outside the European Economic Area, e.g. the United States. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your regional location of residence. Wherever we transfer your personal information, we will take reasonable steps to ensure that your privacy rights continue to be protected, e.g. conclude the EU Standard Contractual Clauses with third parties.

    Your rights
    If you are a user based in the European Economic Area, you may be entitled to exercise some or all of the following rights:

    • Require (i) information whether your personal information is retained and (ii) access to or duplicates of your personal information retained, including the purposes of the processing, the categories of personal information concerned, and the data recipients as well as potential retention periods;

    • Request rectification, removal or restriction of your personal information, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;

    • Refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal information at any time;

    • Object, on grounds relating to your particular situation, to processing of your personal information, in case such processing is either based on our or a third party’s legitimate interests or on a performance of a task carried out in the public interest. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal information or present you our compelling legitimate grounds for an ongoing processing;

    • Object to the use of your personal information for direct marketing at any time;

    • Take legal actions in relation to any potential breach of your rights regarding the processing of your personal information, as well as to lodge complaints before the competent data protection regulators; and/or

    • Require (i) to receive the personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side. Where technically feasible you shall have the right to have the personal information transmitted directly from us to another controller.

    You may (i) exercise the rights referred to above, (ii) pose any questions, or (iii) make any complaints regarding our data processing by contacting us under the contact details set out above in Sec. 1.

  11. Privacy Policy Changes and Updates

    We may update this Privacy Policy to reflect changes to our information practices at any time, so please review it frequently. If we update this Policy, changes will be reflected on this page and we will update the “Last Updated” date posted below. If we make any material changes to this Privacy Policy, we will attempt to notify you by email (by sending an email to the email address specified in your account, if an email account is associated with your account), or by means of a prominent notice on this website prior to the change becoming effective. We will obtain prior parental consent if any changes we make to this Policy affect users under the age of 13 in a way that requires such consent under COPPA or the age of 16 in a way that requires such consent under the European General Data Protection Regulation.

Last Updated: January 10, 2023