Privacy Policy

Whip Networks, Inc.

Business Services Privacy Policy

Updated and Effective Date: This business services privacy policy (“Business Privacy Policy”) is effective and was last updated as of May 2, 2024.

This Business Privacy Policy describes Whip Networks, Inc.’s (“WNI”) practices with regard to data we collect in connection with WhipMedia.com and our business-to-business services offered via our Content Value Management (“CVM”)/Whip Media FASTrack™ and Content Value Management Insights (“CVMi”)/Whip Media Fan Pulse platforms, or such other names for these services as we may apply, and any other service operated by WNI that posts a link to or otherwise incorporates this Business Privacy Policy (collectively, the “Business Services”). If the individual accessing or using the Business Services (“You”) is doing so as the authorized user of a company to which we are providing the Business Services under a contract, Your use may be subject to the terms of that contract. This Business Privacy Policy does not cover or affect the confidentiality, or our use, of our customers’ business content, data, or other proprietary information as defined in and governed by an applicable contract.

TABLE OF CONTENTS

The Information We Collect
How We Use Your Information
How We Share Your Information
Third Party Analytics Providers
Third Party Content and Links
Your Choices About the Information We Collect
Security of Your Information
General Audience Business Services
Changes to This Business Privacy Policy
Consent to International Transfer of Your Information
How Long We Retain Your Information
Contact Us
Additional Information for Users of WhipMedia.com
Notice to California Residents
Additional Information for European Union, European Economic Area, and United Kingdom Residents
Additional Information for Canadian Residents
Additional Information If You Are Located in Countries Outside the US, EU/EEA, UK, or Canada

1. The Information We Collect

The Business Services collect information from You when You use them. Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies You as a specific, identified individual to be personal information (such as Your name and email address), and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code (“hash”). We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification process satisfies legal requirements. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.

We collect information in the ways described below. Please also see the service-specific sections for WhipMedia.com for additional information on information that is collected by those Business Services.

Information You Submit. The information You submit to us will depend on the Service that You are using. For instance, some of our Business Services are account-based, and in order to create an account, You or Your employer will need to provide information such as Your contact information (Your name and e-mail address), a password, and Your employer. Some of our Business Services collect Your information about Your preferences and interests.
Information We Collect Automatically. The Business Services collect certain information whenever You visit them or otherwise interact with them (“Usage Information”). Usage Information may include the hardware model, browser, and operating system You are using, the URL or advertisement that referred You to the webpage You are visiting, all of the areas within the Business Services that You visit, Your time zone, and mobile network (if applicable), among other information. In addition, we automatically collect Your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone or other device You use to access our Business Services. We may be able to collect or infer Your approximate location based on Your IP address or similar information we collect. As You use the Business Services, we may also track how You interact with the Business Services.

The methods that may be used to collect Usage Information include the following:

Cookies and Local Storage small text files stored locally on Your device that help store user preferences. These technologies are able to store a unique identifier for a device to us to recognize the device whenever the device is used to visit the Business Services. These technologies may be used for many purposes by us, our service providers, and our third-party business partners, such as automatically collecting Usage Information, enabling features, serving advertisements to You online (in the case of WhipMedia.com), and remembering Your preferences. We may use cookies and other technologies to study traffic patterns on the Business Services, to study the effectiveness of our customer communications, and to personalize Your experience through the Business Services, such as to recognize You when You return to them. The information we store includes internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. If You do not want to accept cookies, You can block them by adjusting the settings on Your Internet browser. You can find more information about cookies and how they work at www.allaboutcookies.org

Web beacons (also known as clear GIFs and pixel tags) are small pieces of code used to collect usage analytics. They help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. When You ask us to send You information or a promotion or a newsletter, we will use web beacons to establish how many of the emails are actually opened. In general, any electronic image viewed as part of a web page, including an ad banner, can act as a web beacon.

We use similar tools to collect such information from mobile devices. In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

2. How We Use Your Information

We may use non-personal information for any purpose. We also use information that we collect, including personal information and Usage Information, to: (1) provide the services You request and allow You to participate in features we offer, or to provide related customer service; (2) recognize You across our sites and services; (3) process Your requests, questions, or feedback, including to provide You with technical support; (4) provide You with information, products, or services that You have requested or that we think may interest You; (5) investigate and prevent fraudulent transactions and other illegal activities or activities that violate our policies, which may include sharing information with other companies, lawyers, courts, or other government entities; (6) process Your registration, including verifying Your information is active and valid; (7) improve the Business Services and for internal business purposes; (8) contact You with regard to Your use of the Business Services and, in our discretion, changes to the Business Services’ policies; and (9) for purposes disclosed at the time You provide Your personal information or otherwise with Your consent.

Please also see the service-specific sections for WhipMedia.com for additional information on how we use Your information in connection with those Business Services.

3. How We Share Your Information

We may share non-personal information, such as aggregated statistics or de-identified data, for any purpose in our discretion. (For clarity, however, and as noted above, this Business Privacy Policy does not cover or affect our customers’ business content, data, or other proprietary information, and such information will be used only as set forth in the applicable contract.) In addition, we may share the information we have collected about You, including personal information and Usage Information, as disclosed at the time You provide us with Your information or with Your consent, and as described in this Business Privacy Policy, including as set forth below.

Please also see the service-specific sections for WhipMedia.com for additional information on how we share Your information in connection with those Business Services.

Your Employer. If You are accessing the Business Services as an authorized representative of a company, all Your activities are considered to be on behalf of that company, and the company will have access to information about Your activities and the information in Your account, if applicable.

Affiliated Third Parties for Their Business Purposes. We may share information with our subsidiaries and affiliated companies for business, analytical, and operational purposes.

Service Providers. We contract with certain companies to perform services on our behalf, including advertising, marketing assistance, e-mail delivery, hosting services, site maintenance and repair, security, quality assurance, customer service, surveys, and data research and analysis, and provide Your information to them in furtherance of such services.

In Connection with Business Transitions. In the event WNI undergoes a business transition, such as a merger with or acquisition by another company, or sale of all or a portion of its assets, we may transfer Your personal information and other information to the successor organization in connection with such transaction, including during the course of any due diligence. By providing Your personal information, You agree that we may transfer such information to the other entity in such a transaction without Your further consent.

For Administrative and Legal Reasons. We reserve the right to use or disclose any information as needed to satisfy any law, regulation, or legal request; to protect the integrity of the Business Services; to fulfill Your requests; to cooperate in a law enforcement investigation, an investigation on a public safety matter, or an investigation into claims of intellectual property infringement; to protect and defend the legal rights and/or property of WNI and any of our subsidiaries, affiliates, and shareholders, or the Business Services, any of their users, or any other party; or, in an emergency, to protect the health and safety of users or the general public.

4. Third Party Analytics Providers

We work with third party analytics providers to provide us with information regarding the use of some of the Business Services. We allow these companies to place tracking technologies like cookies and web tags on the Business Services, and they may otherwise collect or have access to Usage Information and other information about You. We may share information, typically information that has been aggregated or de-identified, Usage Information, and location information with analytics providers. Some of these parties may collect personal information over time when You visit the Business Services or other online websites and services.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Business Services and report on activities and trends. This service may also collect information about the use of other websites, apps, and online services. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

If You are a California resident, please see our Notice to California Residents regarding additional rights You have, including how to exercise Your “Do Not Sell or Share” right.

5. Third Party Content and Links

The Business Services may contain links to third party websites, services, applications, or content that You elect to access through our Business Services. When You navigate away from the Business Services to such third party sites or content, this Business Privacy Policy does not apply, and we are not responsible for the privacy practices of any third party.

6. Your Choices About the Information We Collect

You are responsible for maintaining the accuracy of the information You submit to us, such as Your contact information associated with Your account. If You have an account within the Business Services, You will have a profile section within Your account that allows You to update certain personal information You have provided. You may also contact us at legal@whipmedia.com if You have questions about or wish to modify certain information that we have collected from or about You. Note that some information may be controlled by Your employer and may not be able to be changed. In addition, when You modify Your personal information or change Your preferences, information that You remove may persist internally for our administrative purposes or within backup media.

If we send You marketing email communications, You will have the ability to opt-out using the mechanism provided in the emails. Please note that we reserve the right to send You certain non-marketing communications relating to Your account or use of the Business Services, such as administrative communications, service announcements, and other transactional emails.

If You are a resident of certain jurisdictions, you may have additional rights. Please see our Jurisdiction Specific Notices for more information.

7. Security of Your Information

We implement commercially reasonable measures to protect the security of Your information. However, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge You to take steps to keep Your personal information (including Your account password) safe and to log out of Your account after use.

8. General Audience Business Services

The Business Services are not intended for children Younger than the age of 18. We do not knowingly collect or solicit personal information from children Younger than the age of 18.

9. Changes to this Business Privacy Policy

It may be necessary from time to time for us to modify this Business Privacy Policy to reflect changes in the way we collect and use information or changes in privacy-related laws, regulations and industry standards. Accordingly, to the extent allowed by applicable law, we reserve the right to change this Business Privacy Policy at any time. We will inform You by posting a notice on the Business Services. We may also provide notice to You in other ways, such as through contact information You have provided. Your continued use of the Business Services after the effective date of the revised Business Privacy Policy will constitute Your consent to those changes to the fullest extent allowed by applicable law.

10. Consent to International Transfer of Your Information

We are a US-based company so if You are located outside of the United States, please be aware that the information that we collect from You will be transferred to, and stored at, a destination outside of Your country. By using the Business Services or providing us with any information, You fully understand and unambiguously consent to this transfer to, and processing, usage, sharing, and storage of Your information in the United States and other jurisdictions, which may have different or less protective privacy laws than those in Your country. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to the laws in those jurisdictions. Your information will also be disclosed to third parties as described in the “How We Share Your Information” section above.

11. How Long We Retain Your Information

We will retain Your information for so long as we are required in order to provide the Business Services to You, in accordance with our agreement with Your employer, or as required to fulfill our legal requirements and defend legal claims. After You have terminated Your use of the Business Services, we will store Your information in an aggregated and anonymized format.

12. Contact Us

If You have any questions, comments, or concerns regarding this Business Privacy Policy and/or our practices, please contact us at Whip Networks, Inc., 1841 Centinela Ave., Santa Monica, CA 90404, or at legal@whipmedia.com. When writing to us, please specify that You are writing about WNI’s Business Services Business Privacy Policy and practices.

13, Additional Information for Users of WhipMedia.com

If You are a user of WhipMedia.com, please know that in addition to information collection, uses, and sharing set forth above, the following are applicable to You and Your information:

Information We Collect.

1. Social Media Platforms. WhipMedia.com permits You to interact with social media platforms, including LinkedIn, Facebook, Twitter, and YouTube. When You interact with third party platforms through this Business Service, we will receive information about You. We may also receive information about You if other users of social media give us access to their profiles and You are one of their connections or “friends.” The information we collect is subject to this Business Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including, without limitation, whether the third party continues to share information with us, the types of information shared, and Your choices with regard to what is visible to others on that third-party website or service. We or the third party may allow You to disable or remove the application or feature, in which case we will no longer collect information about You through the application or feature, but we may retain the information previously collected.
  If You choose to post information to a third party platform, that information may be public and the third party may have access to information about You and Your use of Sites. You may also choose to participate in a way that connects that third-party service with our Sites, such as posting to one of our pages on a social media site. Doing so may allow us to collect (or the third party to share) information about You, including personal information, and the third party may allow us to re-post content related to us on our own services.In addition, these third parties may set their own cookies and collect information about Your use of WhipMedia.com, including Your IP address or other device identifiers, and which pages You visit on our site. Certain third party platforms may be able to collect certain information on Your visits to WhipMedia.com regardless of whether or not You affirmatively interact with the feature and whether or not You are logged into (or have) an account.
2. How We Use Your Information. If You use WhipMedia.com, we may also use information we collect to tailor content, recommendations, and offers we display to You elsewhere online.
3. Third Party Advertising Partners. With respect to our WhipMedia.com Business Service, we work with third party online advertising companies to serve our ads online and provide us with information about the effectiveness of our advertisements. We allow these companies to place tracking technologies like cookies and web tags on the WhipMedia.com, and they may otherwise collect or have access to Usage Information and other information about You. Some of these parties may collect personal information over time when You visit WhipMedia.com or other online websites and services. We may share information, typically information that has been aggregated or de-identified, Usage Information, and location information with third party advertising companies and other third parties for targeted advertising purposes.Some of the third parties we use to perform advertising services may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using Your hashed email address for interest-based advertising. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies. If You are a California resident, please see our “Notice to California Residents” section below regarding additional rights You have, including how to exercise Your “Do Not Sell” right.

Please note opting out through these mechanisms does not opt You out of being served advertising. You will continue to receive non-targeted ads while online or on Your Device.

JURISDICTION SPECIFIC RIGHTS

14. Notice to California Residents

This California Privacy Notice is effective as of May 2, 2024.

This notice supplements our Business Services Business Privacy Policy and applies only to California consumers who are users of the Business Services. Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the California Consumer Privacy Act, the California Privacy Rights Act, and any implementing regulations adopted thereunder (collectively, the “CCPA”), unless otherwise defined.

Exercising Your Rights

The CCPA provides California users with the right to request (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you (“Right to Know“); and (2) that we delete the Personal Information we collected about you (“Right to Delete“), (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”), (4) to opt-out from the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”), (5) to opt-out from the sale of their Personal Information (“Right to Opt-Out of Sale”), and (6) that we limit the use or disclosure of your Sensitive Personal Information (SPI) to purposes set forth under the CCPA, including what is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services (“Right to Limit Use and Disclosure of SPI”), all subject to meanings and exceptions set forth in the CCPA. More information on how to exercise these rights is below.

Please note that our business activities do not use personal information in a manner that triggers the Right to Limit Use and Disclosure of SPI.

California users have the right to not receive discriminatory treatment for exercising CCPA rights. We will not discriminate against you for exercising your CCPA rights.

Verifying Requests: Please note that we will take reasonable steps to verify your identity in order to fulfill your request. In addition to your username and email address, we may ask for additional information, such as your transactions with us (e.g., a series or movie you have marked as a favorite). In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request. When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with information, beyond the above, in order to verify your identity and fulfill your request.

Agents: If you are an authorized representative submitting a request on a user’s behalf, please submit the request per the instructions below We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, You may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill the request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request. If you have questions about any of these rights, please contact us at legal@whipmedia.com.

Submitting Your Requests

If you are a California Consumer and would like to exercise your rights please email us at legal@whipmedia.com or mail us your request at Whip Networks, Inc., 1841 Centinela Ave., Santa Monica, CA 90404. Your request must include your username (if you have one) and email address; please also include any additional information that you have submitted to us that may help us verify you as set forth below.

Other Important Information

Requests to Know: In order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that You are the consumer whose Personal Information is the subject of the request.

Requests to Delete: To ensure that we do not delete Your personal information in response to a fraudulent request, once You submit the request, we may follow up to confirm that You want Your information to be deleted.

Do Not Sell or Share for Cross-Context Behavioral Advertising: As required under CCPA, WNI provides a right to users of these Business Services who are California consumers to request to opt-out of the sale of Personal Information, where applicable. WNI does not sell personal information for monetary compensation, but as described above, certain third-party advertising partners and analytics companies may collect data from visitors to certain Business Services, and these may be considered “sales” or “sharing” under the CCPA. In these cases, there will be a “do not sell or share my personal information” link available within the Business Service; click that link to access the service’s cookie manager and set Your preferences.

Note that these are cookie-based opt-outs. You will need to indicate Your opt-out choices at each of our Business Services separately, and if You disable Your cookies or upgrade Your browser after opting out, or if You use different computers or browsers, You will need to indicate Your opt-out choices across those other computers and browsers.

Do Not Track

Some browsers incorporate a ‘Do Not Track’ (DNT) feature that, when turned on, signals to websites and online services that you do not wish to be tracked. Because there is not yet an accepted standard for how to respond to browser DNT signals, we do not currently respond to them.

Users Younger than Age 16. WNI does not knowingly sell Personal Information of minors Younger than 16 years of age.

Data Retention

[We have adopted retention language from the Whip Media privacy policy. Please review retention criteria and confirm this accurately reflects your data retention policy.]

Notice of Financial Incentive

[We do not believe you engage in any loyalty programs or provide coupons or similar incentives on Whip Media website. Please confirm.]

Personal Information WNI Collects

We collect certain types of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). The Personal Information we collect about You will depend on how You use the Business Services or otherwise interact with us. Accordingly, we may not collect all of the below information about You.

In addition to the below, we may collect and/or use additional types of information, and will do so after providing notice to You and obtaining Your consent to the extent such notice and consent is required by the CCPA.

[Please review the below chart for accuracy. Note that the definition of “Share” under the update law is: “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.” This definition includes targeted advertising but let’s discuss if Whip Media anticipates whether any other business practices could fall within this definition.]

Category of Personal Information Collected	Business or Commercial Purpose(s) for which Information is Collected	Categories of Sources from Which Collected	Categories of Third Parties with whom Information is Shared/Disclosed for Business Purpose	Categories of Third Parties to Whom This Type of Personal Information Is Sold or Shared
A. Identifiers Examples: name, email address, and device identifiers	To provide the Business Services to You and allow You to participate in the features the Business Services offers To help us to improve the Business Services and to serve You better To send you communications For legal, regulatory, administrative, and internal business purposes To protect against misuse of the Business Services, fraud, or criminal activity To detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Business Services For other purposes described to You at the time of collection or otherwise consistent with this Privacy Policy	You Third party service providers and business partners Cookies and other tracking technologies	Other Users Service Providers Third parties whose features are integrated with the Business Services, such as social media companies Third party advertising and analytics companies Third parties who may acquire Your information in connection with a merger, acquisition or other ownership transition Third parties or affiliated companies when You request that we share Your information with them Other third parties (including government entities) to comply with laws, regulations, or legal requests or to protect or defend our rights or the rights of any third party Third parties when You agree to or request that we share Your information with them.	Third party advertising, analytics, and similar marketing partners may have access to this data, including in order to better service you relevant advertisements, and this may be considered a “sale” or “share” under the CCPA in certain circumstances.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Examples: name, email address, phone number	To provide the Business Services to You and allow You to participate in the features the Business Services offer To help us to improve the Business Services and to serve You better To send you communications For legal, regulatory, administrative, and internal business purposes To protect against misuse of the Business Services, fraud, or criminal activity To detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Business Services For other purposes described to You at the time of collection or otherwise consistent with this Privacy Policy	You Other Users Third party service providers and business partners Cookies and other tracking technologies	Other Users Service Providers Third parties whose features are integrated with the Business Services, such as social media companies Third party advertising and analytics companies Third parties who may acquire Your information in connection with a merger, acquisition or other ownership transition Third parties or affiliated companies when You request that we share Your information with them Other third parties (including government entities) to comply with laws, regulations, or legal requests or to protect or defend our rights or the rights of any third party Third parties when You agree to or request that we share Your information with them.	Third party advertising, analytics, and similar marketing partners may have access to this data, including in order to better service you relevant advertisements, and this may be considered a “sale” or “share” under the CCPA in certain circumstances.
C. Commercial information Examples: products or services obtained or considered; purchasing or consuming history or tendency	To provide the Business Services to You and allow You to participate in the features the Business Services offer To help us improve the Business Services and to serve You better For legal, regulatory, administrative, and internal business purposes To protect against misuse of the Business Services, fraud, or criminal activity To detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Business Services For other purposes described to You at the time of collection or otherwise consistent with this Privacy Policy	You Third party service providers and business partners	Other Users Service Providers Third parties whose features are integrated with the Business Services, such as social media companies Third party advertising and analytics companies Third parties who may acquire Your information in connection with a merger, acquisition or other ownership transition Third parties or affiliated companies when You request that we share Your information with them Other third parties (including government entities) to comply with laws, regulations, or legal requests or to protect or defend our rights or the rights of any third party Third parties when You agree to or request that we share Your information with them.	Third party advertising, analytics, and similar marketing partners may have access to this data, including in order to better service you relevant advertisements, and this may be considered a “sale” or “share” under the CCPA in certain circumstances.
D. Internet or other similar network activity Examples: login information, areas of the Business Services You visit, and devices used to access the Business Services	To provide the Business Services to You and allow You to participate in the features the Business Services offer To communicate with you To help us improve the Business Services and to serve You better For legal, regulatory, administrative, and internal business purposes To protect against misuse of the Business Services, fraud, or criminal activity To detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Business Services For other purposes described to You at the time of collection or otherwise consistent with this Privacy Policy	Cookies and other tracking technologies Third party service providers and business partners	Other Users Service Providers Third parties whose features are integrated with the Business Services, such as social media companies Third party advertising and analytics companies Third parties who may acquire Your information in connection with a merger, acquisition or other ownership transition Third parties or affiliated companies when You request that we share Your information with them Other third parties (including government entities) to comply with laws, regulations, or legal requests or to protect or defend our rights or the rights of any third party Third parties when You agree to or request that we share Your information with them.	Third party advertising, analytics, and similar marketing partners may have access to this data, including in order to better service you relevant advertisements, and this may be considered a “sale” or “share” under the CCPA in certain circumstances.
E. Inferences drawn from other personal information Examples: Preferences, characteristics, predispositions, behaviors	To provide the Business Services to You and allow You to participate in the features the Business Services offer To help us improve the Business Services and to serve You better To send you communications For legal, regulatory, administrative, and internal business purposes To protect against misuse of the Business Services, fraud, or criminal activity To detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Business Services For other purposes described to You at the time of collection or otherwise consistent with this Privacy Policy	You Third party service providers Cookies and tracking technologies Third party social media companies Third party business partners such as data analytics providers, data brokers, advertising networks, or joint marketing partners	Other Users Service Providers Third parties whose features are integrated with the Business Services, such as social media companies Third party advertising and analytics companies Third parties who may acquire Your information in connection with a merger, acquisition or other ownership transition Third parties or affiliated companies when You request that we share Your information with them Other third parties (including government entities) to comply with laws, regulations, or legal requests or to protect or defend our rights or the rights of any third party Third parties when You agree to or request that we share Your information with them.	Third party advertising, analytics, and similar marketing partners may have access to this data, including in order to better service you relevant advertisements, and this may be considered a “sale” or “share” under the CCPA in certain circumstances.

15. Additional Information for European Union, European Economic Area, and United Kingdom Residents

Legal Basis for Processing

We will only collect, store, or otherwise process Personal Information collected from you in the EU/EEA or the UK in the following situations:

When we have your consent to do so. You can withdraw your consent at any time as described below or directly through the Business Services.

When we need to use your Personal Data to perform our responsibilities under our contract with you (e.g. providing the Business Services you have requested).

When we or a third party have a legitimate interest in processing your Personal Data. For example, we may process your Personal Data to communicate with you about our Business Services, to provide, secure, and improve our Business Services, and, in certain circumstances, to deliver advertising to you. You have the right to object to our processing of your Personal Data that is based on our legitimate interests.

When we are required by law to process the Personal Data.

EU/EEA/UK Data Subject Rights

The GDPR (EU General Data Protection Regulation) provides certain rights for EU/EEA residents. Residents of the United Kingdom have similar rights under the UK GDPR and Data Privacy Act. You can access information about you and update or correct it. In some cases, you can also ask us to erase it, restrict or stop processing, or provide data in a “portable” form, if feasible. You may withdraw consent (“opt-out”) if you have previously consented to any particular use of your information, such as receiving emails or text messages. For all requests, contact legal@whipmedia.com. You may also decline to share certain Personal Data with us, in which case we may not be able to provide some or all of the features and functionality of our Business Services.

You may make some changes to your information via your profile or settings sections, as described in the “Your Choices About the Information We Collect” section, above.

We will reply to your data subject requests within 30 days. We will verify your identity and/or requests by requesting your user ID and/or email address, and information about your transactions with us (e.g., your last login date. If we cannot fulfill your request within 30 days, we will inform you when we will be able to do so. We will also provide an explanation if we do not fully comply with your request. When technically feasible, at your request, we will provide your Personal Data to you or transmit it directly to another controller.

Inquiries and Complaints

Please first contact us as set forth below. EU/EEA and UK residents have the right to make a complaint to Your national data protection supervisory authority if You do not believe we have resolved Your concern.

Contact Us

For all EU/EEA and UK Data Subject Rights requests, please put the statement “Your EU/EEA/UK Data Subject Rights” in the subject field of Your request. Please provide Your contact information in Your request and clearly indicate that You are requesting information with respect to our Business Services, and identify the Business Service(s) You use.

Email: legal@whipmedia.com

European/UK residents also may learn more about interest-based advertisements from participating third parties at the European Interactive Digital Advertising Alliance page at www.youronlinechoices.eu.

16. Additional Information for Canadian Residents

We make reasonable efforts to notify You of the purposes for which personal information will be used or disclosed and if the initial purpose changes. Please note, You may withdraw consent at any time (subject to legal or contractual restrictions and reasonable notice). Subject to certain limits set out in the applicable laws, Canadian residents also have the right to request access to the personal information that WNI collects and to update or correct personal information if it is inaccurate.

If You are a Canadian resident and would like to submit a request to access Your personal information or to withdraw consent to the processing of Your personal data, You must submit Your request by sending an email to legal@whipmedia.com. You may also use this contact to submit any requests for information on WNI’s privacy practices or to submit a complaint regarding our practices.

Your request or complaint must include Your full name, street address, city, province, postal code, and an email address so that we are able to contact You if needed regarding this request.

We cannot properly process requests or complaints that do not come through the designated request mechanism or do not contain sufficient information to allow us to process Your request. You may also be required to take reasonable steps as we determine from time to time in order to verify Your identity and/or the authenticity of the request. Once Your request is processed, absent exemptions, we will provide You with details regarding what personal information we have, how it is used, and with which third parties it is shared.

Canadian residents may have additional rights under Canadian law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and successor legislation. Please see the website of the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) for further information.

Canadian residents also may learn more about interest-based advertisements from participating third parties in Canada at the Canadian DAA choice page at http://Youradchoices.ca/choices. [Please make this a link]

You and we confirm that it is our wish that this Business Privacy Policy, the Terms of Service, and all other related policies be drawn up in English.

17. Additional Information if You Are Located in Countries Outside the US, EU/EEA, UK, or Canada

In certain jurisdictions with relevant data protection laws, including (without limitation) Argentina, Australia, Brazil, Canada, China, Hong Kong, India, Japan, Malaysia, Mexico, Philippines, Singapore, South Africa, Switzerland, and Taiwan, we may require your consent or authorization to use or share your Personal Data for the purposes described in this Business Privacy Policy. By providing your Personal Data to us, you expressly provide such consent or authorization to the extent it is required.

In addition, you may have additional privacy rights under the law of your country of residence, typically including the rights to access, correct, delete, or object to further processing of your Personal Data. We handle requests to exercise such rights similarly to requests from EU residents under the EU GDPR, as described above.

Other Whip Media products privacy policies:

For TV Time, please visit below:

https://www.tvtime.com/privacy

For TheTVDB, please visit below:

https://www.thetvdb.com/privacy-policy

If you feel that we are not abiding by this privacy policy, you should contact us immediately via telephone at +1.310.998.1976 or via info@whipmedia.com.

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