Privacy Policy
EFFECTIVE DATE: June 15, 2023
SPECIAL NOTE: Please read “Does Pinna track my kids’ activity?” below for an overview of our information collection practices when an adult or child accesses the Kids Player. Please see “Children’s Privacy” for more information about how we collect, use, and disclose information that we may receive when a child is using the Kids Player. We encourage you to read our entire Privacy Policy.
Pinna LLC (“Pinna,” “we,” or “us”) is committed to bringing you services and communications tailored to your individual needs while respecting your privacy. This Privacy Policy describes how we collect, use, and disclose certain information.
We collect information from visitors to our website (www.pinna.fm), mobile applications (Apple | Android | Amazon), social media pages, and any other place that links to or posts this Privacy Policy. Collectively, these are our “Services.” In this Policy, when we refer to “Services” with respect to our website and app, we specifically mean the portion of the website and app that are targeted to adults and do not stream Content which is on the Kids Player.
We make podcasts, audiobooks, or other content (“Content”) available to you and your kids via the streaming media player on our website or app, which this Policy calls the “Kids Player.” It’s necessary to log in to your account to get access to the Kids Player. We collect less information on the Kids Player than we do on our Services to protect kids’ privacy – please read on for more information.
This Privacy Policy does not apply to non-Pinna websites and mobile applications that may link to the Services or be linked to from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.
Updates to this Policy: We may modify this Privacy Policy at any time by posting revisions to the Privacy Policy with an updated effective date or other appropriate notice. If any changes are made to the Privacy Policy that would affect information collected from or about children in a way that would require parental consent under COPPA, we will obtain such consent from a parent or legal guardian.
Data Controller: As it pertains to users of our Services or Kids Player located in the EU, the controller of your personal data is Pinna LLC, 115 Broadway, 5th Floor, New York, NY 10006 USA.
Please see section 9 pertaining to Your California Rights.
Does Pinna track my kids' or students' activity?
When you use our Services, including to listen to Content, we absolutely do not collect, or use, sell, or disclose your kid’s/student’s name, address, email, or any other information that would personally and directly identify him or her. In fact, we have no mechanism or business reason to collect that information in the Services or our Kids Player. There are circumstances, such as when we offer contests or rewards programs, where we will ask parents or teachers to provide their child’s or student’s information. If we collect that information, we treat it according to the privacy notice we provide at the time we request the child’s or student’s information.
Second, we collect analytics information automatically about our users’ devices that access the Kids Player. The third parties we use for this purpose are listed in our Privacy Policy. This information is, for example, IP address and browser type. Like most other internet-enabled businesses, we need analytics to effectively run our business; for example, it is important to know which shows are popular across our user base. If you allow your kids/students to use the Kids Player, we will gather information about that activity for our internal analytics. But the analytics information we collect does not allow us to personally identify you or your kid/student, and we do not use it for marketing purposes.
Thank you for reading. Our goal is to earn your trust and provide an exceptional service. Please don’t hesitate to contact us at contact@pinna.fm with any questions.
Information We Collect
a. Information We Collect from the Services
We collect the following types of information when you use the Services.
Personal Identifiers: name, e-mail address; correspondence and other information that you send to us; stories, comments, photos, and other information you post in our interactive online features. In limited circumstances when you contact us, we may ask for your postal address and/or telephone number. When you create an account, we collect email address, password, and communications preferences.
Commercial Information: payment information, such as credit card number and expiration date.
Geolocation: imprecise location (e.g., location derived from IP address).
Audio: when using the voice activated show experience, device microphones may capture audio information (e.g., a “yes” or “no” response), including users’ voices. This information will not be combined with other device information such that the user’s voice will be identifiable.
Electronic Network, Analytics, and Service Activity: browser type and operating system; Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area; search queries; other unique identifiers, including mobile device identification numbers; sites you visited before and after visiting the Services; pages you view and links you click on within the Services; information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded; and information stored in server logs.
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your preferences based on the surveys you take and the information we and our partners gather when you interact with our Services.
b. Information We Collect from the Kids Player
The information we collect when you access the Kids Player is limited to:
Electronic Network, Analytics, and Service Activity: browser type and operating system; Internet Protocol (IP) address; mobile device identification numbers; Content you view; and links you click on within the Kids Player.
Our iOS app does not collect mobile advertising identifiers, such as Apple’s IDFA.
We may “de-identify” information so that it cannot be linked back to an individual. For example, we may generate statistics about the general geographic regions from which users access our websites. We may use and disclose de-identified information for any purpose.
c. Our Sources of Information
We may collect information you provide directly via the Services. For example, we may ask you for contact information and account set-up information when you register with our Services, access various content or features, register for contests or sweepstakes, submit comments and other content, order products, or directly contact us with questions or feedback.
We may collect certain information automatically when you use the Services or Kids Player. For example, we collect information about your device when you browse our website and app or access Content via the Kids Player. We may use cookies, pixel tags, Local Shared Objects (sometimes referred to as “Flash Cookies”), and other technologies to automatically collect this information.
The types of cookies and tracking technologies our partners use can be categorized as:
Analytics: These technologies help us to understand how visitors interact with our Services and Kids Player by collecting and reporting information about how you and your device interact with the Services or Kids Player.
Advertising: These technologies allow us to serve relevant advertising to you on other websites or apps.
Below is a list of our tracking partners with links to more information about their use of your information and how to exercise your options regarding tracking. Please also see “Your Rights and Choices” below.
Google Analytics Google Privacy and Terms
MyFonts - Privacy Policy
AppsFlyer - Privacy Policy
Facebook - Privacy Policy / Opt-out
We may collect information about you from other sources, including service providers and third parties, and combine such information with information we have collected about you. For example, we may collect information that you make available to us on or through a social media platform (such as by clicking on a social media icon linked from our Services, interacting with our social media pages, or linking your Pinna account to a social media account), including your account ID or username and other information included in your posts.
2. Lawful Basis of Processing
Pinna processes Personal Information to: (i) deliver Services you request, (ii) consistent with your consent, (iii) for our legitimate business interests such securing and protecting the integrity of our Services, and Service development; and (iv) as permitted to meet applicable legal requirements.
3. Uses of Information
We may use information that we collect to:
- Deliver and improve our Content;
- Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
- Customize and personalize your use of the Services or Kids Player;
- Contact you via email, push message (subject to an opt-in by you) or otherwise about products, services, and events that we think might be of interest to you, unless you have opted out;
- Contact you with surveys, legal notices, and other information that may be relevant to your use of the Services;
- Maintain or administer the Services and Content, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;
- Publish stories, comments, and other information posted in our interactive online features;
- Process employment applications and inquiries;To show you relevant ads, and measure the effectiveness and reach of ads; and
- As otherwise described to you at the point of collection or pursuant to your consent.
4. Disclosure of Information
We may disclose information that we collect via the Services or Kids Player with the parties listed below.
Corporate Parents, Affiliates, and Subsidiaries. We may disclose your information to our corporate parents, subsidiaries, and other affiliated entities for a variety of purposes, including business, operational, and marketing purposes;
Service Providers. We may disclose your information to our agents and service providers that perform certain functions or services on our behalf. These include:
- Billing, collection, and payment;
- Auditing and accounting;
- Professional services;
- Analytics;
- Security;
- Information technology support, including cloud storage, software-as-a-service, and business software; and
- Sending marketing emails.
Third Parties. We may disclose your information to select advertising, marketing, and analytics partners so that they can provide you with advertisements that may be of interest to you. When you use the Kids Player, we limit the third parties that collect information from you to those that support analytics functions; none of those third parties collect information to serve advertising.
Other Parties When Required by Law or as Necessary to Protect the Services. We may disclose your information to third parties in order to protect the legal rights, safety, and security of Pinna, our corporate parents, affiliates, and subsidiaries, and the users of our Services or Kids Player; enforce our Terms of Service; prevent fraud (or for risk management purposes); and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required;
In Connection with a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction;
Other Parties with Your Consent. We may disclose information about you to third parties when you consent to such sharing, including when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool; and
5. Children’s Privacy
a. Services
Our Services (for example, the www.pinna.fm website and social media pages) are not directed to children under the age of 13 in the US or children under the age of 16 in the European Union (“EU”). Pinna does not knowingly collect any Personal Information on its Services from children under the age of 13 in the US or under the age of 16 in the EU.
b. Kids Player
When users interact with our Kids Player, we or partners operating on our behalf collect device identifiers (such as an IP address or unique device identifier) solely to support our internal operations, which are analyzing the Kids Player’s performance, personalizing Content recommendations based on user activity, and protecting the security or integrity of the Kids Player.
If we change our practices – for example, if we collected persistent identifiers for advertising purposes – we will first notify parents and (if necessary) obtain their verifiable consent for that new practice.
Apart from collecting limited audio information necessary for the functioning of our [voice activated show experience], our Kids Player does not enable children to upload information about themselves or otherwise communicate their information to anyone.
We may disclose information collected via the Kids Player when we believe in good faith that we are authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, to protect the integrity of our Services or Kids Player, or to protect the safety of our users.
c. More Information and Contact
Parents or teachers may contact us at any time using the contact information below. In any such request, please include the parent’s or teacher’s email address associated with the account. To protect children’s privacy and security, we will take reasonable steps to verify a parent’s identity before responding.
contact@pinna.fm
917-727-3649
Pinna LLC
Contact Person: Pinna
115 Broadway, 5th Floor
New York, NY 10006
We designed our Kids Player to address the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and other laws applicable to children’s data protection. To learn more about COPPA, you may consult this simple one-page informational guide from the kidSAFE Seal Program: http://www.kidsafeseal.com/knowaboutcoppa.html
6. Data Security
We implement technical and organizational measures designed to protect your information against accidental or intentional destruction or loss, and unauthorized disclosure or access.
You are responsible for maintaining the confidentiality of your account password and for any access to or use of the Services or Kids Player using your password, whether or not authorized by you. Please notify us immediately of any unauthorized use of your password or account or any other breach of security.
7. Data Storage and Retention
Your information is stored on our servers and on the servers of database management service providers that we have engaged which are located in the United States. We retain data for the duration of the relationship you have with us.
8. Accuracy of Personal Information
While we take various steps to ensure the accuracy and completeness of your information, we rely upon you to provide accurate and complete information when interacting with us.
9. Your Rights
California residents should reference Your California Consumer Privacy Rights section below.
Under certain circumstances, and as required by applicable law, you have the right to:
-Request access to your information. This enables you to receive a copy of the information we hold about you. Please note that your Account page allows you to access and update your information.
- Request correction of any incomplete or inaccurate information that we hold about you.
- Request erasure of your information. Please note that we may have a reason to deny your deletion request or delete data in a more limited way than you anticipated, e.g., because of a legal obligation to retain it.
- Object to processing of your information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your information to suspend the processing, for example if you want us to verify its accuracy or our reason for processing it.
- Opt-out of certain uses of your information, such as for targeted advertising.
- Request the transfer of your information to another party.If you want to exercise any of these rights, please contact us using the information in the “Contact Us” section of this Privacy Policy.
We will not charge a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive if permitted by applicable law. Alternatively, we may refuse to comply with the request in such circumstances. There may be requests that we are unable to process because of other legal requirements. If a request is denied, we will notify you of the reason.
If you are located in the EU, you have the right to lodge a complaint with an EU Supervisory Authority. However, if you have a complaint regarding the processing of your personal data we request that you first contact us and we will reply on a timely basis.
Special Information for Nevada Residents: Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. At this time, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us using the information below.
10. Options to Control Your Information
a. Your Account
You may update your contact information and payment details through your Account page.
b. Communications Preferences
You may choose to receive promotional communications (including emails and push messages), newsletters, and similar communications from us. We will not sell, rent, swap or authorize any third party to use your email address or phone number for their own commercial purposes without your permission. You may opt out of receiving certain promotional communications from us at any time (i) for promotional emails, by clicking on the opt-out or “unsubscribe” link included in the commercial emails you receive or emailing us at contact@pinna.fm and (ii) for push messages, following your device instructions to turn off notifications. Please note that your opt-out is limited to the email address or phone number used and will not affect subsequent subscriptions. Opt-out requests for email may take up to 10 business days to be effective. Your opt-out request will not apply to messages that you request or emails that are not commercial in nature.
c. Analytics and Advertising Tracking Technologies
On Our Services: You may control our use of tracking technologies by using our cookie management options menu, here, or by using the links we make available in the table listing our tracking partners above.
Global Opt-out: We adhere to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising (“DAA Principles”). You may use several opt-out mechanisms that advertisers make available to opt out of tracking on Pinna and third party websites. To exercise your opt-out choice, please visit:
The Digital Advertising Alliance’s websites: http://www.aboutads.info/choices, http://www.aboutads.info/appchoices, or https://youradchoices.com/.
The Network Advertising Initiative (“NAI”) website: http://www.networkadvertising.org/choices/.
The European Interactive Digital Advertising Alliance (“EDAA”) opt-out page: https://www.youronlinechoices.com/uk/protecting-your-privacy.
Please be aware that, even if you exercise an opt-out choice through these mechanisms, you may continue to receive ads. Pinna is not responsible for effectiveness of, or third parties’ compliance with, these programs.
Do Not Track: Pinna responds to the Global Privacy Control signal for U.S. residents. However, we do not respond to “Do Not Track” signals because there is no formal “Do Not Track” standard. Please go here to learn more about enabling the Global Privacy Control: https://globalprivacycontrol.org/#download.
11. International Transfers of Personal Information
Please be aware that the information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store personal data in the United States.
12. Your California Privacy Rights California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.
Notice at Collection Regarding the Categories of Personal Information Collected
You have the right to receive notice of certain information about our data collection, use, and disclosure. The following table summarizes the categories of personal information we collect, the categories of sources of that information, whether we disclose, sell or share that information to service providers or third parties, respectively, and the criteria we use to determine the retention period of such information. The categories we use to describe personal information are those enumerated in the CCPA, and additional information about the specific types of personal information we collect are described above in “Information We Collect.” We collect this personal information for the purposes described in the “Uses of Information” section above.Personal Identifiers - Sources: You, Pinna’s social media pages; Entities to which we disclose: Any type of service provider; Not sold or shared
Commercial Information - Sources: You; Entities to which we disclose: Any type of service provider ; Not sold or shared
Internet or Other Electronic Network Activity Information - Sources: You, Pinna’s analytics partners; Entities to which we disclose: Any type of service provider; Shared with: Third parties (necessary analytics and advertising partners)
Geolocation - Sources: Pinna’s analytics partners; Entities to which we disclose: Any type of service provider; Not sold or shared
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics - Sources: You; Entities to which we disclose: Any type of service provider; Not sold or shared
We determine the retention period for each category of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.
Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement.
Entities to whom we “sell” or with whom we “share” personal information are third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us. A business “shares” personal information when it discloses personal information to a company for purposes of cross-context behavioral advertising.
*Note on “Selling”: The CCPA defines “sale," "sharing," and “personal information” broadly to include the information transfer between a website or app and third party tracking technologies. For this reason, Pinna “sells” and "shares" personal information; however, Pinna limits its and its tracking partners’ collection and use of that information consistent with its disclosures above, including “Children’s Privacy.” Furthermore, the partners we use for analytics on the Kids Player are under “service provider” obligations.
Your Rights Under the CCPA
Opt out of sale or sharing of personal information: You have the right to opt out of our sale or sharing of your personal information to third parties. To exercise this right, please see our Do Not Sell or Share My Personal Information page. Your right to opt out does not apply to our disclosure of personal information to service providers.
Entities to whom we “sell” information are third parties. Under the CCPA, a business “sells” personal information when it discloses it to a company for monetary or other benefit. A company may be considered a third party either because the purpose for its sharing of personal information is not for an enumerated business purpose under California law, or because its contract does not restrict it from using personal Information for other purposes.
Know and Request Access to and Deletion of Personal Information. You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share or disclose it. You also have the right to request in certain circumstances that we correct personal information that we have collected about you and to delete personal information that we have collected directly from you. Please contact us as explained in section 13 to exercise these rights.
You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf through these means.
- Having you submit your request through your account page, which will automatically verify your identity and will result in faster processing of your request.
13. Contact information, submitting requests, and our response procedures
a. Contact Information
Please contact us if you have questions or wish to take any action with respect to information to which this Privacy Policy applies.
contact@pinna.fm
Pinna LLC
Contact Person: Pinna
115 Broadway, 5th Floor
New York, NY 10006
917-727-3649
b. General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Realm of Possibility Holdings Corp. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
- by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
- by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
c. UK General Data Protection Regulation (GDPR) - UK Representative
Pursuant to Article 27 of the UK GDPR, Realm of Possibility Holdings Corp. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
- by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
- by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
d. Making a request to exercise your rights
Submitting requests: You may request to exercise your rights by submitting the form Do Not Sell or Share My Personal Information or making a request using the contact information above.
If you are a resident of California, you may, under certain circumstances, authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf.
We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Verification Procedures: We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously and confirm your request using the email account stated in the request; or having you submit your request through your account page, which will automatically verify your identity and will result in faster processing of your request.
We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.