Privacy Policy

Effective Date: May 26, 2020

  Vurbl Media, Inc. (“Vurbl,” “we,” “us,” and “our”) provides a platform that allows our users to create and publish audio content (“Creators”) and listen to audio content (“Users”).  Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use, and share your personal information and to assist you in exercising the privacy rights available to you.

SCOPE

  This Privacy Policy applies to personal information processed by us in our business, including on our websites, mobile applications, and related online and offline offerings (collectively, the “Services”).

  1. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with our Services.  

Information You Provide to Us

Creator Registration. When you create an account and register as a Creator, we collect personal information such as your name, email address, date of birth, username, password, RSS feed information, social media information such as YouTube channels, who you follow or subscribe to, content you may interact with, your interests, and other information.

User Registration. When you create an account and register as a User, we collect personal information such as your name, email address, date of birth, username, password, your interests, and other information.

Your Communications with Us.  We collect personal information from you such as your email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

Surveys.  We may contact you to participate in surveys.  If you decide to participate, you may be asked to provide certain information which may include personal information.

Interactive Features. We may offer interactive features such as forums, blogs, commenting functionalities, and social media pages.  Additionally, you may choose to share information through the audio content that you create and publish on our Services or through your station bio. Any content you provide on the public sections of these channels will be considered “public” and is not subject to the privacy protections referenced herein. 

Registration for Sweepstakes or Contests. The Creators may run sweepstakes and contests on podcasts or other audio content published on our Services.  Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law.  In some jurisdictions, it may be required that information about winners be shared publicly.

Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Vurbl and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.  

Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with Vurbl.

Information Collected Automatically

Automatic Data Collection. We may collect certain information automatically when you use the Services.  This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of  your IP address), Internet service provider, mobile carrier, pages that you visit before, during and after using the Services, information about your searches on the Services, information about the links you click, information about how you interact with the Services, including the content you listen to and frequency and duration of your activities, and other information about how you use the Services. We may also combine your information with information that other people provide when they use our Services, including information about you when they tag you.

Cookies, Pixel Tags/Web Beacons, and Analytics Information.  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.  Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies.  Cookies are small text files placed in device browsers to store their preferences.  Most browsers allow you to block and delete cookies.  However, if you do that, the Services may not work properly.
  • 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 users’ engagement on the Services.  The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Analytics.  We may use Google Analytics and other service providers to collect analytics information on our Services.  For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/.  You can opt out of Google Analytics’ collection and processing of data generated by your use of our website by going to http://tools.google.com/dlpage/gaoptout.

Information Collected from Third Parties

Information from Other Sources. We may collect information about you from other sources, including from third party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

2. HOW WE USE YOUR INFORMATION

We use your personal information for a variety of business purposes, including:

To Provide the Services or Information Requested, such as:

  • Fulfilling our contract with you; 
  • Processing your payment card and/or other financial information for transactions;
  • Providing you with suggestions for content we think you may enjoy; 
  • Responding to questions, comments, and other requests;
  • Providing access to certain areas, functionalities, and features of our Services; and
  • Answering requests for customer or technical support.

Administrative Purposes, such as:

  • Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Measuring interest and engagement in our Services;
  • Improving the Services; 
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Carrying out audits;
  • Communicating with you about your account, activities on our Services and Privacy Policy changes;
  • Preventing and prosecuting potentially prohibited or illegal activities;
  • Enforcing our agreements; and
  • Complying with our legal obligations.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below. 

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

  Use De-identified and Aggregated Information.  We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Share Content with Friends or Colleagues.  Our Services may offer various tools and functionalities.  For example, we may allow you to provide information about your friends through our referral services.  Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

  How We Use Automatic Collection Technologies.  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services.  Our uses of these Technologies fall into the following general categories: 

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance Related.  We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
  • Functionality Related.  We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services.  This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising or Targeting Related.  We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps.  For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop.  To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

3. DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

  Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: the provision of the Services; the provision of information, products, and other services you have requested; marketing and advertising; payment and transaction processing; customer service activities; and the provision of IT and related services.

Creators and Other Vurbl Users. When you use the Services, certain personal information, may be shared with Creators and other Users you interact with. Please be aware that Vurbl has little or no control over how individuals may use the information you share.

Business Partners.  We may provide personal information to business partners with whom we jointly offer products or services.  In such cases, our business partner’s name will appear along with ours.

Affiliates.  We may share personal information with our affiliated companies.

Content Distribution. When you create and publish audio content using our Services, we may distribute this content to our other websites and platforms.

Advertising Partners.  Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile advertising identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others.  We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers.  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

4. INTERNATIONAL DATA TRANSFERS 

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. 

5. YOUR CHOICES 

General. You may have certain choices about your personal information.  

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails.  Note that you will continue to receive transaction-related emails regarding products or Services you have requested.  We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Service or this Privacy Policy).

Mobile Devices. We may send you push notifications through our mobile application.  You may at any time opt- out from receiving these types of communications by changing the settings on your mobile device.  We may also collect precise location information if you use our mobile applications.  You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, for some devices you may use your device’s platform controls in your settings to exercise choice (e.g., Android, iOS, and others).

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.  

We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request.

If you are a California resident, you have the right not to receive discriminatory treatment by Vurbl for the exercise of your rights conferred by the California Consumer Privacy Act. 

6. DATA RETENTION 

We store the personal information we receive as described in this Privacy Policy for as long  as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

7. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Unfortunately, no system 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 unauthorized disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.

8. THIRD PARTY WEBSITES/APPLICATIONS 

The Services contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third party websites or applications is at your own risk.

9. CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.  If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below.  If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account

10. OTHER PROVISIONS

CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018provides California residents with the right to know what categories of personal information Vurbl has collected about them and whether Vurbl disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal InformationCollected by Vurbl?Disclosed by Vurbl for a Business Purpose?
IdentifiersYesYes
Personal information categories listed in Cal. Civ. Code § 1798.80(e)Yes Yes 
Characteristics of protected classifications under California or federal lawNoNo 
Commercial informationNoYes 
Biometric informationNoNo
Internet activity or electronic network activity informationYesYes
Geolocation dataYesYes
Audio, electronic, visual, thermal, olfactory, or similar informationYesYes 
Professional or employment-related informationYesYes 
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))NoNo
Inferences drawn from other personal information to create a profileYesYes 

SUPERVISORY AUTHORITY

  If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

11. CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion.  If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.  You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

12. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Vurbl Media, Inc.

2633 Lincoln Blvd. #835, Santa Monica, CA 90405

legal@vurbl.com