Privacy Policy

Tiny Podcast Company ("Tiny Podcast", “we” or “us”) is committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy statement is to inform you about our privacy practices, including how we collect, use and disclose your personal information.

"Personal information" means information about an identifiable individual, subject to more particular definitions under applicable law. This privacy statement relates to all of our activities, including our Castro podcast app (“Castro”) and website located at http://supertop.co/castro/ (“website”), unless we have provided you with a separate privacy statement for a particular product, service or activity. Castro and the website are collectively referred to as the “Services”.

Please review this privacy statement carefully. By submitting your personal information to us, or by registering for or using any of the Services, you consent to our collecting, using and disclosing your personal information as set out in this privacy statement, as revised from time to time.

What's In This Privacy Statement?

We collect, use and disclose your personal information with your consent or as permitted or required by law. For example, where we are not relying on your consent, under the General Data Protection Regulation (“GDPR”), the legal basis for our processing of personal information may be that the processing is necessary for providing our Services and that the processing is carried out in our legitimate interests, which are further explained below. How we obtain your consent (i.e. the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy statement.

Typically, we will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information in the “Contact Us” section below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this privacy statement.

Personal Information We Collect

The information we collect is generally in one or more of the following categories.

Castro

When you access or use Castro, we may collect the following information:

Website

When you visit our Website, we may collect the following information:

We may use your personal information for other purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

We do not use the information we collect to provide advertising of third party products and services or targeted advertising of Company products and services across third party websites or service offerings.

How We Use Your Personal Information

We may use your personal information and other information for the following purposes. In each case, we identify the grounds that we rely on to use your personal information:

We may use your personal information for other purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

We do not use the information we collect to provide advertising of third party products and services or targeted advertising of Company products and services across third party websites or service offerings.

How We May Share Your Personal Information

Although we try to avoid sharing your personal information with third parties where possible, we have set out below the instances in which such sharing may occur.

We rely on third party service providers to perform a variety of services on our behalf, such hosting, data storage and processing service providers, and analytics service providers.

If we provide your information to service providers, we take reasonable measures to ensure that the rules set forth in this privacy statement are complied with and these third parties provide sufficient guarantees to implement appropriate security measures. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain aggregated, anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

Opting Out of Communications

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below. We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

Retention of Personal Information

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. If you would like further information regarding the periods for which your personal information will be retained, please contact us as set forth in the “Contact Us” section below.

Information Security

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your personal information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below. If we learn of a security breach involving your personal information, we will inform you and the relevant authorities of the occurrence of the breach as required under applicable law.

Rights Regarding Your Personal Information

You may make a written request to review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.

Under the GDPR, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of personal information about you, under certain conditions; (v) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (vi) the right to data portability of personal information that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; and (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection.

We may require that you provide appropriate identification to fulfill your request. Any such identifying information will be used only for this purpose.

International Transfer and Storage of Information

Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this privacy Statement and, if applicable, we will comply with GDPR requirements providing adequate protection for the transfer of personal information from the EU/EEA to a third country.

Third Party Websites and Services

This privacy statement applies only to our products and services. This privacy statement does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

Children’s Information

We do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, you should not provide us with your personal information. If you are a parent or guardian and discover that your child under the age of 16 has provided personal information, then you may alert us as set forth in the “Contact Us” section below and request that we delete that child’s personal information from our systems.

Privacy Statement Updates

This privacy statement is current as of the “updated” date which appears at the top of this page. We may modify this privacy statement from time to time. When changes are made to this privacy statement they will become immediately effective when published in a revised privacy statement posted on our website unless otherwise noted. We may also communicate the changes through our services or by other means. By submitting your personal information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this privacy statement, you consent to our collecting, using and disclosing your personal information as set out in the revised privacy statement.

Contact Us

All comments, questions, concerns, requests or complaints regarding your personal information or our privacy practices (including with respect to any service providers outside of your country of residence) should be sent to our Privacy Officer at privacy@castro.fm.

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