Effective Date: September 21, 2020
- 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.
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 Media LLC, 15 MetroTech, 8th Floor, Brooklyn, NY 11201 USA.
First and foremost, 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. The only information we need from you (the parent/teacher) is your contact and payment information to maintain the account.
Thank you for reading. Our goal is to earn your trust and provide an exceptional service. Please don’t hesitate to contact us at email@example.com 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).
- 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.
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.
Present in the Kids Player?
LiveRamp and Arbor
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, text 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.
We may share information that we collect via the Services or Kids Player with the parties listed below.
- Corporate Parents, Affiliates, and Subsidiaries. We may share your information with our corporate parents, subsidiaries, and other affiliated entities for a variety of purposes, including business, operational, and marketing purposes;
- Service Providers. We may share your information with our agents and service providers that perform certain functions or services on our behalf. These are:
- Billing, collection, and payment;
- Auditing and accounting;
- Professional services;
- Information technology support, including cloud storage, software-as-a-service, and business software; and
- Sending marketing emails.
- Third Parties. We may share your information with 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 share information about you with 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
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.
Our Kids Player does not enable children to upload information about themselves or otherwise communicate their information to anyone.
We may share 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.
Pinna Media LLC
Contact Person: Pinna
15 MetroTech, 8th Floor
Brooklyn, NY 11201
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 our California Consumer Privacy Act disclosure 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.
- Request the transfer of your information to another party.
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 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 text 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 by (i) for promotional emails, by clicking on the opt-out or “unsubscribe” link included in the commercial emails you receive or emailing us at firstname.lastname@example.org and (ii) for text messages, following the instructions provided in text messages from us to text the word “STOP”. 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: You may choose to activate a “do-not-track” signal via your browser. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, Pinna currently does not take action in response to these signals. For more information on “do-not-track,” visit http://www.allaboutdnt.com.
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
a. California Shine the Light
Pursuant to California’s “Shine The Light” law, California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year. You may request this disclosure information at email@example.com and indicate in the email subject line “California Shine The Light Request” so that we can process your request. Please include your mailing address, state of residence and email address with your request.
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 the categories of personal information we collect and the purposes for which we use personal information. The following table summarizes the categories of personal information we collect, the categories of sources of that information, and whether we disclose or sell that information to service providers or third parties, respectively. 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.
Category of Personal Information
Categories of Sources
Categories of Entities to which We Disclose Personal Information
Categories of Entities to which We Sell Personal Information
You; Pinna’s social media pages
Any type of service provider
Any type of service provider
Internet or Other Electronic Network Activity Information
You; Pinna’s analytics partners
Any type of service provider
Third parties (analytics and advertising partners)
Pinna’s analytics partners
Any type of service provider
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics
Any type of service provider
*Note on “Selling”: The CCPA defines “sale” and “personal information” broadly to include the information transfer between a website or app and third party tracking technologies. For this reason, Pinna “sells” 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.
Right to Opt Out of Sale of Personal Information to Third Parties
You have the right to opt out of any sale of your personal information by us to third parties. To opt-out of our sales of personal information, please see our Do Not Sell My Personal Information page.
Right to Know About Sources of Personal Information and Personal Information Disclosed or Sold
During the preceding 12 months, the categories of personal information we collected, the categories of sources of that information, and the entities to which we have disclosed or sold that information are described above.
Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. Service providers are restricted from using personal information for any purpose that is not related to our engagement.
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.
Right to 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 with whom we share it. You also have the right to request in certain circumstances that we delete personal information that we have collected directly from you. 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.
You may submit a request to exercise your rights to know/access or delete your personal information by emailing us at firstname.lastname@example.org.
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.
Verification Procedures: We must verify your identity for everyone’s protection, so we may require you to provide us with verification information prior to accessing any records containing personal information about you. We do this by:
- Asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email or telephone 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 use the information you provide for verification only for the purpose of verification. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
13. Contact Us
Pinna Media LLC
Contact Person: Pinna
15 MetroTech, 8th Floor
Brooklyn, NY 11201