Wurl Privacy Notice

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Wurl Privacy Notice

Last Updated: January 31, 2025

This Privacy Notice is designed to help you understand how WURL, LLC and WURL NETWORK UK, LTD (“Wurl”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.

For information on our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”), please see Section 8 – Supplemental CCPA Privacy Notice.]

SCOPE
PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR PERSONAL INFORMATION
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
INTERNATIONAL DATA TRANSFERS
RETENTION OF PERSONAL INFORMATION
SUPPLEMENTAL CCPA PRIVACY NOTICE
CHILDREN’S INFORMATION
OTHER PROVISIONS
CONTACT US

1. SCOPE

This Privacy Notice applies to personal information processed by us, including on our websites and other online or offline offerings. To make this Privacy Notice easier to read, our websites and other offerings are collectively called the “Services.”

An Important Note: This Privacy Notice does not apply to any of the personal information that we process on behalf of our customers through their use of Wurl’s Services (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to our customer.

In addition, this Privacy Notice does not apply to any of the personal information that we process about viewers of content through our AdPool, ContentDiscovery, and WurlBits and/or TVBits Services. For details about the personal information Wurl processes via its AdPool, ContentDiscovery, and WurlBits and/or TVBits Services please visit the Wurl Advertising and Media Services Privacy Notice.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

Account Creation. We may collect information when you create an account, such as name, email address, and details about your employer.
Your Communications with Us. We may collect personal information, such as email address, phone number, mailing address, or the contents of your communications when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us. We may also record calls that you participate in 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 and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
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 our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services:

Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag 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.

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 website 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 individuals use our Services (see Analytics below);
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 websites. Some of the advertising Technologies we use include:
- Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
- Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
- Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.

C. Personal Information Collected from Other Sources

We may obtain information about you from other sources, including through 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.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your personal information to fulfill our contract with you and provide you with our Services, such as:

Managing your information and accounts;
Providing access to certain areas, functionalities, and features of our Services;
Answering requests for customer or technical support;
Communicating with you about your account, activities on our Services, and policy changes;
Processing your financial information and other payment methods for products or Services purchased;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.

B. Administrative Purposes

We use your personal information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions and other compliance activities;
Enforcing our agreements and policies; and
Complying with our legal obligations.

C. Marketing and Advertising 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.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based,” “personalized advertising,” or “targeted advertising,” including through cross-device tracking.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

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.
De-identified and Aggregated Information. We may use personal information and other information 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.
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. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
Our Customers (Authorized Users Only). In cases where you use our Services as an authorized user of our customer, that customer may access information associated with your use of the Services including usage data and the contents of the communications and files associated with your account. Your personal information may also be subject to the customer’s privacy policy. We are not responsible for the customer’s processing of your personal information.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
Affiliates. We may share your personal information with our company affiliates.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us”

B. 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.

C. 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, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email and Telephone 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 our Services or updates to our Terms or this Privacy Notice).

We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.

“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. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for 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 and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

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

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Confirm Whether We Are Processing Your Personal Information (the right to know);
Request Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion of your personal information;
Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws) or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);
Request Restriction of or Object to our processing of your personal information; and
Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

To the extent Wurl’s use of retargeting pixels on its website is considered “targeted advertising”, you may opt out of such processing by installing the Ghostery ad-blocker browser plug-in and blocking our use of advertising cookies via that tool or by otherwise configuring your Internet browser to prohibit advertising cookies from being set.

To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

6. INTERNATIONAL DATA TRANSFERS

All personal 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 personal information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice 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.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. SUPPLEMENTAL CCPA PRIVACY NOTICE

This Supplemental CCPA Privacy Notice supplements our Privacy Notice and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).

NOTICE AT COLLECTION

At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below.

Personal Information Collected. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Shared” for a list of personal information which may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you.
Uses of Personal Information. See the section of this Supplemental CCPA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information.
Is Personal Information “Shared” for “Cross-Context Behavioral Advertising”? Yes. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Shared” for more details. If we have previously “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “share” that personal information if collected from you. See the section of this Supplemental CCPA Privacy Notice titled “Right to Opt Out of ‘Sharing’ of Personal Information for ‘Cross-Context Behavioral Advertising’ for instructions on how to opt-out of these activities.
How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Notice and our Privacy Notice. Importantly, the section of our Privacy Notice titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA.

CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources.

OVERVIEW OF PERSONAL INFORMATION COLLECTED, DISCLOSED, AND/OR SHARED

The CCPA provides California residents with the right to know what categories of personal information Wurl has collected about them, whether Wurl disclosed that personal information for a business purpose (e.g., to a service provider), and whether Wurl “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by Wurl	Category of Third Parties To Whom Personal Information is Disclosed to for a Business Purpose	Category of Third Parties Personal Information To Whom Personal Information is Shared
Identifiers	Service providers	Advertising partners
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Service providers	N/A
Protected classification characteristics under California or federal law	Service providers	N/A
Commercial information	Service providers	N/A
Internet or other electronic network activity	Service providers	Advertising partners
Professional or employment-related information	Service providers	N/A
Inferences drawn from other personal information to create a profile about a consumer	Service providers	Advertising partners
Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	Service providers	N/A

USES OF PERSONAL INFORMATION

We may use and disclose the personal information that we collect for the following business and commercial purposes:

Providing the Services as further described in our Privacy Notice;
Processing for administrative purposes as further described in our Privacy Notice;
Processing for marketing purposes as further described in our Privacy Notice;
Processing with your consent or direction as further described in our Privacy Notice;
Processing to carry out automated decision making as further described in our Privacy Notice;

The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth in “Personal Information We Collect”, “How We Use Your Personal Information”, and “How We Disclose Your Personal Information” above, respectively. We will retain personal information in accordance with the time periods set forth in “Retention of Personal Information.”

The CCPA defines “share” to mean disclosing a consumer’s personal data for cross-context behavioral advertising, also known as tailored advertising. Tailored advertising is when we use information about your use of the Services to tailor ads to be more relevant to you.

Additional Privacy Rights for California Residents

Opting Out of “Sharing” for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the “sharing” of personal information for “cross-context behavioral advertising.” To the extent Wurl’s processing of personal information is considered “sharing”, California residents may exercise these rights by installing the Ghostery ad-blocker browser plug-in and blocking our use of advertising cookies via that tool or by otherwise configuring their Internet browser to prohibit advertising cookies from being set.

You may also manage your consent preferences related to the “sharing” of personal information for “cross-context behavioral advertising” by navigating to the “Your Privacy Choices” button located at the bottom of Wurl’s website.

Disclosure Regarding Individuals Under the Age of 16. Wurl does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Wurl does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

Disclosure Regarding Sensitive Personal Information. Wurl only uses and discloses sensitive personal information for the purposes set forth in Section 7027(m) of the CCPA regulations.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

9. CHILDREN’S INFORMATION

The Services are not directed to children under 16 (or other age as required by local law outside of the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

10. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may 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.

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

11. CONTACT US

Wurl is the controller of personal information that is processed under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Wurl, LLC.
1100 Page Mill Rd
Palo Alto, CA 94304
United States of America

[email protected]

EU and UK Privacy Representatives

We have appointed Prighter Group as our privacy representatives in the EU and UK. You can contact us through our privacy representatives at the following addresses:

For residents of the EU:
PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG
c/o Wurl, LLC
Schellinggasse 3/10
1010 Vienna
Austria

For residents of the UK:
PrighterUK-Rep by Prighter Ltd.
c/o Wurl, LLC
20 Mortlake Mortlake High Street
London, SW14 8JN
United Kingdom

Additional information regarding our privacy representatives can be found at the following links:

https://prighter.com/q/18612339371

https://prighter.com/q/17903445896