Privacy Policy

Effective Date: February 9, 2021

About

PodLink, ("us", "we", and "the Company"), owned by In Defense of Growth Incorporated d/b/a Podsights, is committed to protecting the privacy and security of your Personal Information (defined below). This privacy policy (the "Policy") describes how we collect and use Personal Information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

This Policy describes the types of information we may collect from you or that you may provide when you visit the website https://pod.link/ (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

The Company is a "data controller" This means that we are responsible for deciding how we hold and use Personal Information about you. We are required under data protection laws to notify you of the information contained in this Policy.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes to the Policy is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

This policy applies to information we collect:

• On this Website, including that information which is voluntarily provided by you
• In email, text, and other electronic messages between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party, including our affiliates and subsidiaries; or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. To determine your privacy rights under any of the third-party services, please read their privacy policies.

Data Protection Principles

We will comply with data protection laws which require that the Personal Information we hold about you must be:

1. Usedlawfully,fairlyandinatransparentway.
2. Collectedonlyforvalidpurposesthatwehaveclearlyexplainedtoyouandnotusedinanywaythat isincompatiblewiththosepurposes.
3. Relevant to the purposes we have told you about and limited only to thosepurposes.
4. Accurateandkeptuptodate.
5. Keptonlyaslongasnecessaryforthepurposeswehavetoldyouabout.
6. Keptsecurely.

The Kind of Information We Hold About You

Personal data is any information about an individual from which that person can be identified (hereinafter "Personal Information"). Personal Information does not include deidentified, anonymous, or aggregated data.

Types of Personal Information We Collect and Why

• Identifiers, such as name, postal address, e-mail address, telephone number, billing information, IP address, information that is about you but individually does not identify you, such as location data and the date and time of your visit to the Website; and/or or any other identifier by which you may be contacted online or offline, when you interact with our Website in a number of ways, including: establishing an account; adding information to your account, creating address entries, emailing an item to yourself or someone else; contacting us with a comment or question; and signing up to receive emails about our products and services.

• Financial Information , such as information collected from you as needed to process payments, such as your credit or debit card number, expiration date, and card verification number, when you voluntarily provide us with this information. We use that information to fulfill your requests and to contact the account owner in the event of account difficulties.

• Network Activity Information , such as browsing history, time zone, search history, a consumer's interaction information, information about your internet connection, cookies installed on your device the equipment you use to access our Website, and usage details such as individual web pages or products that you view, what Websites or search terms referred you to the Website, and information about how you interact with our Website in order to see which areas of our Website are most visited and to improve the quality of your online experience by providing more of the most visited and desired features and services.

• Inferences drawn from any of these Personal Information categories reflecting your preferences, characteristics, psychological trends, predisposing, behaviors, attitudes, intelligence, abilities and/or aptitude to help the Company to perform the services.

How is your Personal Information collected?

We collect Personal Information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through and interact with the Website. Information collected automatically may include your search queries on the Website, records and copies of your correspondence (including email addresses) if you contact us, usage details, IP addresses, and information collected through cookies, and other tracking technologies.
• From third parties, for example, our business partners.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• The information we collect automatically may include Personal Information. This helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.
  • Screen for potential risk and fraud

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Log Files."Log files" track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

We do not collect Personal Information automatically, but we may tie this information to Personal Information about you that we collect from other sources or you provide to us.

How We Will Use Information About You

We use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Website and its contents to you.
• To provide you with information or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
• To notify you about changes to our Website or services we offer or provide though it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Change of Purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may also use your information to contact you about our services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located in your account settings. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this Policy:

• To our parent companies, subsidiaries, and affiliates, including our parent company Podsights.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use [INSERT AS LINK TO WEBSITE'S TERMS OF USE] and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our advisors and advisees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Sharing, Accessing, and Correcting Your Personal Information

We may have to share your data with third parties, including third-party service providers, where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We require third parties to respect the security of your data and to treat it in accordance with the law.

The following activities are carried out by third-party service providers: data analytics services, advertising services, payment processing services, hosting and backend infrastructure services, website traffic optimization and distribution.

We may use analytic services to monitor and analyze web traffic that can be used to keep track of user behavior. We, or our partners, may use Google Analytics to help us understand how our customers use the Website. Please view their Privacy Policy and Terms of Service to learn more about how Google Analytics uses your Personal Information. You can opt out of Google Analytics by clicking here.

We use Heroku, provided by Salesforce, as a hosting service with the purpose of hosting data and files that enable PodLink to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of PodLink. Please view their Privacy Policy and Terms of Service to learn more about how Heroku uses your Personal Information.

We useCloudflare's to help with traffic optimization and distribution services. The way Cloudflare is integrated means that it filters all the traffic through PodLink, i.e., communication between PodLink and the User's browser, while also allowing analytical data from PodLink to be collected. Please view their Privacy Policy and Terms of Use to learn more about how Cloudfare uses your Personal Information.

On certain pages, we may share Personal Information with Podsights in order to measure podcasts. Please view their Privacy Policy and Terms of Service to learn more about how Podsights uses your Personal Information.

All our third-party service providers are required to take appropriate security measures to protect your Personal Information inlinewithourpolicies.Wedonotallowourthird-partyserviceproviderstouseyourPersonal Informationfortheirownpurposes. We only permit them to process your Personal Information for specified purposes and in accordance with ourinstructions.

European Privacy Rights

We collect various types of Personal Information about you as described in this Policy. If you are from the EEA, you may have broader rights to access and delete your personal data, to object to or restrict processing of your personal data, or request portability of your personal information.

To make such requests, you can send an email to privacy@pod.link or write to us at the mailing address in the "Contact Us" section below. You also have the right to complain to your local data protection authority at any time. If you wish to access, review, modify or delete any Personal Information we have, under applicable EEA law or otherwise, you should contact that us with your request.

We will consider and handle all requests in accordance with applicable laws. If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. To learn more about your European privacy rights, please visit: https://gdpr-info.eu/

Details about the right to object to processing

Where Personal Information is processed for a public interest, in the exercise of an official authority vested in the Company or for the purposes of the legitimate interests pursued by the Company, you may object to such processing by providing a ground related to their particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. Any requests to exercise your rights can be directed to the Company through the contact details provided in this "Contact Us" section at the bottom of this policy.

Transferring information outside the EU

We will transfer the Personal Information we collect about you to certain countries outside the EU, in order to perform our services for you. We will ensure that your Personal Information receives an adequate level of protection and is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK and EU supervisory authority for data protection issues, visit: https://ico.org.uk/for-organisations/report-a-breach/

Nevada Privacy Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@pod.link

California Privacy Rights

We collect various types of Personal Information about you as described in this Policy. If you are a California resident, you have certain rights with regard to your Personal Information. Consumers have a right to request disclosure of their Personal Information, and to receive additional details regarding the Personal Information a business collects and its use purposes, including any third parties with which it shares information. To make such requests in accordance with the California Consumer Privacy Act of 2018, you can send an email to privacy@pod.link or write to us at the mailing address in the "Contact Us" section below. To make a "Do Not Sell My Personal Information" request, reach out to privacy@pod.link. Please include your IP Address and the associated User Agent.To learn more about your California privacy rights, visit: oag.ca.gov/privacy/ccpa

Security

We have appropriate security measures to prevent your Personal Information from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

Wehaveputinplaceprocedurestodealwithanysuspecteddatasecuritybreachandwillnotifyyouandanyapplicableregulator ofasuspectedbreachwherewearelegallyrequiredtodoso.

Data Retention

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information,weconsidertheamount,nature,andsensitivityofthePersonal Information,thepotentialriskofharmfromunauthorized useordisclosureofyourPersonal Information,thepurposesforwhichweprocessyourPersonal Informationandwhetherwecanachievethose purposes through other means, and the applicable legalrequirements.

Rights of Access, Correction, Erasure, and Restriction

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your working relationship with us. You may send us an email at privacy@pod.link or write to us at the mailing address in the "Contact Us" section below to request access to, correct or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Under certain circumstances, by law you have the right to:

• RequestaccesstoyourPersonal Information(commonlyknownasa"datasubjectaccessrequest").
• Request correction of the Personal Information that we hold aboutyou.
• Request erasure of your Personal Information.
• ObjecttoprocessingofyourPersonal Information.
• Request the restriction of processing of your Personal Information.
• RequestthetransferofyourPersonal Informationtoanotherparty.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to privacy@pod.link.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@pod.link. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a service, experience, or other transactions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email stating your request to privacy@pod.link. For this opt-out to function, you must have your browser set to accept all browser cookies.
  • You can opt out of targeted advertising by Facebook by visiting https://www.facebook.com/settings/?tab=ads
  • You can opt out of targeted advertising by Google by visiting https://www.google.com/settings/ads/anonymous
  • Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal: http://optout.aboutads.info/.
• We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (" NAI") on the NAI's website.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@pod.link. California residents under 18 years of age may have additional rights regarding the collection and sale of their Personal Information. To learn more about your California privacy rights, visit oag.ca.gov/privacy/ccpa.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users' Personal Information, we will notify you through a notice on the Website home page. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

Contact Us

For further information about your rights, or if you have any questions about this Policy or how we handle your Personal Information, please contact the Company by e-mail at privacy@pod.link