RECURRENT VENTURES

PRIVACY POLICY

Last Updated and Effective Date: June 16, 2026

Introduction

Recurrent Ventures Inc. and its affiliates (“Recurrent,” “we,” “us,” or “our”) offer digital media services through our websites, mobile apps, and related online offerings (collectively, the “Sites”). This Privacy Policy (“Policy”) applies to our sites and services on which we display or post a direct link to this Policy and explains how we collect, use, and disclose personal information when you visit our Sites or otherwise interact with us.

Changes to this Policy

We may update this Policy from time to time. We will post the effective date at the top and, where required, provide additional notice of material changes. Please review this Policy periodically for updates.

1. Scope of This Policy

This Policy describes Recurrent’s practices for collecting, using, maintaining, protecting, and disclosing (“processing”) your personal data when you use our Services, including when you:

• Visit our Sites and any other sites or application that link to this Policy.
• Create and maintain an account with Recurrent.
• Make a payment through Recurrent.
• Make a purchase or other transaction with us.
• Subscribe to or engage with our newsletters or other electronic communications.
• Interact with our social media pages.
• Click on our ads posted on third party sites.
• Communicate with our service representatives or features (including via chat functions, email, text, or phone).
• Otherwise interact with us.

 

This Policy does not apply to:

• Third-Party Sites. Websites, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us.
• Personal Data of Candidates or Job Applicants. Our processing of the personal data of job applicants/candidates is not governed by this Policy. Such processing is described in our Applicant Privacy Notice.
• Personal Data of our Workforce. Any processing of your personal data as a member of our workforce (e.g., employee, intern, temporary worker, or independent contractor) is governed by the Workforce Privacy Notice which is provided to Workforce Members.
• Non-Personal Data. Our processing of information that cannot be linked to an identifiable or identified individual, including non-identifying aggregate information. We may process this data for any legitimate business purpose.

2. Personal Data We Collect

We may collect or receive the categories of personal data listed below, which may depend on the specific Sites you interact with, Services you may use, as well as your device and account settings. Not all categories of personal data will be collected or received about every individual.

• Personal Data You Give to Us

We collect the following categories personal data you provide to us, including the following:

• Your Personal Details like your first and last name, email address, phone number, physical address, job titles, and other contact information you provide.
• Account and Other Identifiers like, a username, screen name, handle, account ID, assigned user ID, customer number, or similar identifier that can be used to identify and user or account.
• User Content. For example, emails and text messages, photos, videos, audio recordings, customer support communications, comments/feedback, and any other content submitted by you.
• Survey data. We may contact some individuals to request participation in a survey or other general research. If you choose to take part in these, you may provide personal data, in or along with your survey responses, or in any other feedback or comments you give us.
• Contests, sweepstakes, and prize drawings data. If you take part in a contest, sweepstakes, or prize drawing, then you may provide personal data, feedback, or comments to enter, or as part of the contest, sweepstakes, or prize drawing. Participation in these programs is governed by the applicable terms and conditions (including the Official Rules for any sweepstakes or contest or the promotional terms for any short-term promotion), which will also describe the financial incentives (as defined under the CCPA) associated with the promotion and how to participate.
• Messages and email data. We collect information about you when you send, receive, open, read or otherwise engage with messages, email, or other communications in connection with our Services, including whether you have opened or acted on those communications.
• Social Media Content. For example, interactions with our social media pages and content you post on them. If you use a social media provider to register or login to your Recurrent account, we will receive your personal data from them.
• Other Personal Data You Provide. If you provide us personal data other than that described above, we will collect it and use it for the purposes for which you provide it or other consistent purposes.
• Inferences. In certain instances, we may infer personal data about you based on the information you have provided to us or that we have collected about you.
• Chat Modules. We may collect certain categories of personal data from you when you use our interactive chat module. By interacting with the chat box, you consent to our collection practices and understand and acknowledge that we may use this data to communicate with you about our products and services.
• Payment processing information. For example, the form of payment, payment card number and details, bank account number, payment service provider, and other payment information you provide.
  • Personal Data We Derive Through Your Use of Our Services

When you visit or use Recurrent’s Sites, apps, emails, or other online services, we and our partners automatically collect certain information through cookies, pixels, tags, SDKs, local storage, APIs, and server logs. This information falls into the categories below.The information we collect using these technologies includes:

• Device & Browser Identifiers, such as persistent and session cookie IDs, mobile advertising IDs (e.g., AAID, IDFA), browser fingerprint signals (e.g., user agent, language, time zone, screen resolution), device type, operating system, browser type/version, network type and carrier, and hashed identifiers derived from contact information we already hold (e.g., hashed email for account recognition).
• Geolocation Data, such as approximate location inferred from IP address or general device settings (e.g., city/region, country) and, where you grant permission, precise location from GPS/BLE/Wi-Fi signals (e.g., coordinates). You can manage location permissions at the device or browser level.
• Browsing & Search History (on our Sites), such as pages and screens viewed, navigation paths and session length, on-site searches and query strings, referral/exit pages and URLs, timestamps, articles read and scroll depth, features used, and error pages encountered.
• Real-Time Interaction Data, such as mouse movements, clicks/taps, scrolling, zoom, hover, copy/paste events, as well as form engagement signals (e.g., field started/abandoned (but not form contents for payment or other sensitive fields). We implement masking for sensitive inputs.
• Site Log & Usage Data, such as server and application logs, IP address, request headers, device and session identifiers, performance metrics (load times, latency), crash and diagnostic reports, authentication and access logs, and configuration or feature flags active during a session.
• Advertising & Event Metrics, such as ad requests, auctions, bids, impressions, viewability, clicks, frequency caps, conversion events, campaign/UTM parameters, attribution touchpoints, audience segment membership, brand safety signals, and associated online identifiers (e.g., cookie/ad IDs). Used to deliver and measure ads, prevent invalid traffic, and, where permitted by your settings, perform cross-context behavioral advertising (a.k.a. “sharing”).
• Video Watching History (on our Sites), such as titles/content IDs watched, start/stop times, duration and completion, playback position, player events (mute, pause, skip), device/app used, referral source, and ad breaks shown and interactions.
• Inferences, such as predicted interests (e.g., technology, sports), content preferences (topics/authors), likelihood to subscribe or churn, engagement propensity, and estimated demographics or location tiers derived from other data points. You may have rights to access or opt out of certain inferences as described in our Privacy Rights section.
  • Personal Data We Collect From Others

We mostly collect personal data directly from you or based on your interaction with our Sites, but we may also obtain information about you from other sources. For example, we may collect and share information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers, publicly available sources, advertising networks, and third-party services that update, enrich, or supplement information we maintain about you. Additionally, if you create or log into your account through a social media site or third-party service (like Facebook or Google), we will have access to certain information from that service, such as your name, email address, and profile picture, in accordance with the authorization procedures determined by such social media site or third-party service.

Even if you aren’t a registered user of our Services, your information might still be collected. Some users may choose to share information about their contacts, including their name, email address, phone number, or other information. User may also post or comment with personal data about other users (though we discourage it).

The information we obtain from or share with such third-party sources may include:

• Your Personal Details like your name, email address, phone number, physical address, and similar contact information.
• Device & Browser Identifiers, such as mobile advertising IDs (e.g., AAID, IDFA), IP addresses, device type, operating system, browser type/version, location data, network type and carrier, and hashed identifiers derived from contact information we already hold (e.g., hashed email for account recognition).
• Website and Mobile Application Interaction Data, including pages and screens viewed, clicks, downloads, navigation paths and session length, searches and query strings, referral/exit pages and URLs, timestamps, articles read and scroll depth, features used, and error pages encountered.
• Advertising & Event Metrics, such as ad requests, auctions, bids, impressions, viewability, clicks, frequency caps, conversion events, campaign/UTM parameters, attribution touchpoints, audience segment membership, brand safety signals, and associated online identifiers (e.g., cookie/ad IDs). Used to deliver and measure ads, prevent invalid traffic, and, where permitted by your settings, facilitate cross-context behavioral advertising (a.k.a. “sharing”).
• Inferences, such as predicted interests, preferences, behaviors, and estimated demographic and occupational information derived from other information collected about you.

 

3. How We Use Your Personal Data

We may use your personal data for a variety of reasons. Depending on how you interact with our Services, these include using personal data for:

• Provide the Services & Account Management
  To create and manage accounts and subscriptions; authenticate you; remember required preferences; provide access to paywalled content; save reading position and library items; provide customer support; and fulfill your requests.
• Transactions, Billing & Fulfillment
  To process payments and refunds; verify eligibility for promotions; verify customer information, issue invoices and receipts; and handle order fulfillment and subscription changes.
• Personalize Content & Experiences
  To tailor articles, newsletters, recommendations, and on-site features to your interests; remember non-essential preferences with your consent; and customize the user interface across sessions and devices.
• Advertising, Marketing & “Sharing” for Cross-Context Behavioral Advertising
  To deliver, measure, and improve advertising (including interest-based ads); manage frequency capping; perform attribution and audience matching; and create or use audience segments. Where required, we obtain consent for cookies/trackers and disclose when we share personal information with advertising partners for cross-context behavioral advertising. You can opt out of such sharing as described in Your Privacy Rights.
• Analytics, Measurement & Reporting
  To understand usage and performance (e.g., page views, scroll depth, referral sources, session length, conversions); run A/B tests; improve site reliability; audit interactions with the Sites, applications, or advertisements; and generate aggregated reports for internal decision-making.
• Security, Fraud Prevention & Integrity of the Service
  To protect accounts and our platforms; detect bots and deceptive or malicious activity; prevent unauthorized access or content scraping; debug and repair errors; and ensure network and information security.
• Communications
  To send transactional messages (e.g., receipts, service or policy updates, password resets), respond to inquiries, and—where permitted—send marketing or newsletter communications. You can opt out of marketing at any time.
• Research, Product Development & Quality Assurance
  To evaluate and develop new features; conduct user experience research; train and test systems (using privacy-preserving techniques where feasible); and improve the relevance of content and ads.
• Geolocation-Enabled Uses
  To localize content and pricing, enforce territorial rights, comply with regional requirements, and prevent fraud—using approximate location from IP and, if you grant permission, precise location.
• Video & Media Functionality
  To provide and personalize video playback; resume where you left off; manage ad breaks; measure viewership and quality of experience; and improve player performance.
• Inferences & Profiles
  To derive or update interest and preference profiles (e.g., topics you read, likelihood to subscribe or churn) for personalization, analytics, and advertising, subject to your rights to access, correct, delete, or opt out.
• Legal, Compliance & Protection
  To comply with laws and regulatory obligations; maintain records (including consent and rights-request logs); respond to lawful requests; enforce our terms; and establish, exercise, or defend legal claims.
• Corporate Transactions
  To support an actual or potential merger, acquisition, reorganization, or asset sale (subject to appropriate confidentiality and data protection safeguards).
• Aggregated/De-Identified Data
  To create aggregated or de-identified insights that do not identify you, which we may use for analytics, research, and improving our services. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
• Sensitive Personal Data (SPD)
  We do not use or disclose SPD beyond purposes permitted by applicable law (e.g., providing the services, ensuring security and integrity, preventing fraud, or as otherwise allowed). Where available, you may direct us to limit our use and disclosure of SPD.

We may combine and associate personal data collected or inferred about you from multiple online sources (including other companies and from other Sites you visit) to better achieve these purposes.

4. Our Sharing of Your Personal Data

We disclose personal data to the categories of recipients below for the purposes described in How We Use Your Personal Information, subject to applicable law and your choices. Where required, we put contracts in place that limit recipients’ use of personal data to specified business purposes and require appropriate privacy and security safeguards.

• Service Providers and Contractors
  Cloud computing, hosting, and storage; internet service providers, data backup and security providers; functionality and infrastructure providers; content delivery networks; payment processors; customer support and communications tools; email/SMS delivery; identity and access management; debugging and site reliability operations; survey and feedback tools.
• Analytics and Measurement Partners
  Providers that help us measure usage, performance, and audience (e.g., page views, session metrics, conversion and campaign reporting), including A/B testing and product analytics platforms.
• Advertising and Marketing Partners
  Ad networks, exchanges, demand- and supply-side platforms, affiliate marketing partners, data and link management, enrichment, and attribution partners that enable interest-based advertising, frequency capping, and campaign measurement. In some jurisdictions this activity may be considered “targeted advertising” or “cross-context behavioral advertising.”
  • California disclosure: We may share personal information (e.g., online identifiers and internet/network activity) for cross-context behavioral advertising. See Your Privacy Rights for how to opt out of “sharing.”
  • EEA/UK disclosure: Where ePrivacy/GDPR requires consent (e.g., for most non-essential cookies and similar tech), we obtain it before engaging these partners.
• Fraud Prevention, Security, and Integrity Vendors
  Services and providers that help detect bots, prevent unauthorized access or malice, mitigate payment fraud and abuse, and ensure network and information security.
• Affiliates
  Our corporate affiliates (entities under common ownership or control) that process personal data on our behalf or for compatible internal purposes consistent with this notice.
• Business Partners and Co-Branded Programs
  Partners involved in co-sponsored content, events, or promotions you choose to engage in; disclosures are limited to what is necessary to administer the program and as described at the point of collection.
• Social Media Platforms and Plug-ins
  If you choose to interact with social features (e.g., “Like,” “Share,” sign-in with a platform, or embed interactions), the relevant platform may receive information about that interaction pursuant to its own privacy policy.
• Professional Advisors
  Lawyers, auditors, bankers, accountants, insurers, and similar professionals under appropriate confidentiality obligations, for legitimate business purposes (e.g., audits, compliance, financing, protection of the rights, property, or safety of Recurrent, our users, or others).
• Legal and Compliance Disclosures
  Courts, regulators, law enforcement, and other authorities where we believe disclosure is necessary to comply with law or legal process; to enforce our terms; or to protect the rights, property, or safety of Recurrent, our users, or others.
• Corporate Transactions
  Actual or potential mergers, acquisitions, financing, reorganization, bankruptcy, receivership, or sale/transfer of all or part of our business or assets, subject to appropriate confidentiality and data-protection safeguards.
• User-Directed Disclosures
  Disclosures you instruct us to make, such as when you link or integrate third-party accounts, participate in public forums or comment sections, or share content externally. Information you post publicly may be visible to others.
• Aggregated or De-Identified Information
  We may share aggregated or de-identified insights that do not identify you. Where we de-identify data, we commit not to re-identify it except as permitted by law.
• Sensitive Personal Data (SPD)
  We do not disclose SPD beyond purposes permitted by applicable law (e.g., providing requested services, ensuring security and integrity, preventing fraud, or as otherwise allowed). Where available, you may direct us to limit our use and disclosure of SPD (see Your Privacy Rights).

5. Publicly Posted Content

Recurrent users may have the ability to post content to one or more Recurrent forums, such as chat rooms and bulletin boards. You should be aware that when you voluntarily disclose personal data in any forum, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal data you choose to submit in these instances. Please take care when using these features.  You may request and obtain removal of such posted content by contacting us at compliance@recurrent.io and specifically identifying the content to be removed.  Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the Recurrent forums.

6. Cookies & Other Tracking Technologies

Recurrent and our third-party partners use cookies and similar technologies to operate our services, remember your preferences, analyze traffic and engagement, and—where permitted—deliver and measure advertising. This section explains what we use, why we use it, and your choices.

What We Use: We and our partners may deploy: first- and third-party cookies; pixels/beacons/tags; local or session storage; SDKs & APIs (web/mobile); advertising identifiers (e.g., IDFA, AAID); and limited fingerprinting signals (e.g., user agent, language, screen size) in accordance with applicable law and your settings.

Why We Use Them: Operate the Service (authentication, paywall/entitlements, security); Preferences & Features; Analytics & Performance (including A/B testing); Advertising & Marketing (including measurement, data enrichment, frequency capping, attribution, and, where permitted, “sharing” for cross-context behavioral advertising); and Email Measurement.

Your Choices & Controls

• Cookie Preferences Manager: Use our on-site Cookie Preferences tool to accept, reject, or fine-tune non-essential cookies/tracking by category at any time. Your selections apply to the browser/device where you set them.
• Third-Party Pixels and CookiesWhen you visit our website, log in, register or open an email, cookies, web beacons, and similar technologies may be used by us or our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or third-party partners or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of our and our third-party partners’ use of tracking by using our on-site Cookie Preferences tool. Additionally, you can opt out of receiving this advertising by our advertising partner, Retention.com, by visiting https://app.retention.com/optout.
• Browser & Device Controls: Most browsers allow you to block or delete cookies; mobile OS settings allow you to limit ad tracking or reset advertising IDs.
• Global Privacy Control (GPC): Where legally required, we recognize GPC signals as a request to opt out of “sharing” for cross-context behavioral advertising on that browser.
• Do Not Track (DNT): We currently do not respond to DNT signals, but we do honor legally required signals like GPC.
• Industry Opt-Outs: Additional advertising choices may be available at the DAA (http://optout.aboutads.info), NAI (http://optout.networkadvertising.org), and, for mobile apps, AppChoices (http://www.aboutads.info/appchoices). These controls are browser/app-specific and may rely on cookies.
• Email Pixels: You can disable images in your email client or unsubscribe to limit email-based tracking.

Note: Blocking or disabling cookies/trackers may impact site functionality (e.g., login, paywall access, saved preferences, and video playback).

7. Data Retention

We will retain your personal data only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal data and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Data Security

We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal data from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal data. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply common protections described in this policy.

9. International Data Transfers

We are located in the United States and may transfer personal data to countries outside your place of residence (including the U.S.) for processing, including to service providers. We require recipients to adhere to our privacy and security requirements and to applicable privacy laws. For transfers of personal data from the EEA/UK, we rely on appropriate safeguards such as the EU Standard Contractual Clauses and, where applicable, the UK Addendum/IDTA, and we implement additional measures where necessary.

10. Your Communications Preferences

Marketing emails and texts are optional. Service and transactional messages (e.g., receipts, subscription notices, password resets, important service or policy updates) are not marketing and you may continue to receive them even if you opt out.

• Email: Use the “Unsubscribe” or “Manage Preferences” link in any marketing email, or update preferences in your account/Email Preferences Center. If you cannot access these tools, contact us (see Contact Us) with the email address to remove. We process opt-outs promptly; allow up to 10 business days for all lists to update.
• Text/SMS Messages: Reply STOP to any Recurrent text to opt out of that specific program (you may receive a one-time confirmation; reply HELP for assistance). If you receive texts from multiple numbers, reply STOP to each. You may also disable SMS in your account (if available) or contact us with the number to remove. Message and data rates may apply; frequency varies; consent is not a condition of purchase.
• Push Notifications (Apps/Browser) — Manage push permissions in your device or browser settings. Email/SMS unsubscribes do not change push settings.
• Updating Contact Details — Keep your email address and mobile number current in your account settings or notify us via Contact Us so we can honor your preferences.

 

11. Your Privacy Rights

Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include the following:

• Access/Know. Request confirmation from us as to whether or not your personal data is being processed by us and, if so, access to such data and/or the more detailed circumstances of the data processing (e.g., the categories and specific pieces of personal data collected, the sources, purposes, and categories of recipients, and, where applicable, the categories of personal data “sold,” “shared,” or used for targeted advertising).
• Portability. The right to request that we provide a copy of the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and transfer this data to another controller without hindrance from us, where feasible.
• Rectification/Correction. Request that Recurrent correct any inaccurate personal data relating to you (subject to limitations).
• Deletion/Erasure. Request that your personal data be deleted without undue delay. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation or if the processing is necessary for the performance of a contract.
• Opt-Out of “Sale” of Personal Data. Request that we not “sell” your personal data as that term is defined by applicable U.S. state privacy laws. You may opt out of this activity by:
  • Visiting our Privacy Rights Request form and submitting a “Do Not Sell My Personal Information” request; and
  • Updating your cookie preferences here and opting out of “Sale”-related cookies (where applicable).

Additional information on browser/device-level opt-outs is available at http://optout.aboutads.info and http://optout.networkadvertising.org.

• Opt-Out of Targeted Advertising. Request that we not use your personal data from third parties, or disclose, disseminate, or transfer your personal data to a third party, for Recurrent’s targeted advertising or marketing purposes (also known as “cross-context behavioral advertising”). You may opt out of this activity by:
  • Visiting our Privacy Rights Request form and submitting an “Opt Out of Targeted Advertising” request; and
  • Updating your cookie preferences here and opting out of Targeted Advertising Cookies.

Additional information on how to opt out of targeted advertising in your browser on a specific device is available at http://optout.aboutads.info and http://optout.networkadvertising.org.

• Opt-Out of Certain Profiling. Request that we cease profiling your personal data in furtherance of decisions that produce legal or similarly significant effects concerning you, where this right is available under applicable U.S. state law.
• Restriction of Processing. Request that we restrict processing of your personal data under the conditions set out in the GDPR/UK GDPR. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
• Object to Processing. Object, on grounds relating to your particular situation, to our processing of personal data concerning you which is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) processed by us on the basis of our legitimate interests. In this case, where applicable, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise, or defend legal claims. You may also object at any time to processing for direct marketing.
• Revoke Consent. Withdraw your consent that you have previously provided for our collection, use, or disclosure of your personal data, subject to reasonable notice and any contractual or legal exceptions. Note that this will not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
• Automated Individual Decision-Making. Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Note that this right shall not apply if such a decision is necessary as part of a contract we have with or want to conclude with you, we have your consent, or we are permitted by law to engage in such automated decision-making. In these cases, we will implement measures to safeguard your rights and freedoms and legitimate interests, and you may contest the decision by contacting us as set forth in “Contact Us” section below.
• Limit Use and Disclosure of Certain Sensitive Personal Information (California). Direct us to limit our use and disclosure of certain sensitive personal data to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer, and as otherwise permitted by law. Recurrent does not use sensitive personal data beyond what is necessary to perform the Services or provide the goods that have been requested of us. Where available, you may exercise this option via your account settings, our cookie preferences tool, or by submitting a request through our Privacy Rights Request form.
• Non-Discrimination/Non-Retaliation. Not be denied goods or services, charged different prices or rates, or provided a different level or quality of goods or services for exercising your privacy rights, except as permitted by law (e.g., bona fide loyalty programs or financial incentives with appropriate disclosures and opt-in consent).
• Complaints. Lodge a complaint with a supervisory authority at any time if you are of the opinion that the processing of personal data relating to you violates applicable law.
  • If you are located in the EU or UK, you can lodge a complaint with a supervisory authority in particular in the Member State of your place of residence, your place of work, or the place of the alleged infringement. You may identify the applicable supervisory authority based on your location on the European Data Protection Board website or, if in the UK, the Information Commissioner’s Office.
  • If you are located in Canada, you can lodge a complaint by contacting us as set forth in the “Contact Us” section below. If you are not satisfied with RV’s response to your complaint, you can lodge a complaint with your provincial privacy regulator if you reside in the following provinces: the Commission d’accès à l’information in Quebec, the Office of the Information and Privacy Commissioner of Alberta, or the Office of the Information and Privacy Commissioner for British Columbia. Outside these three provinces, you may lodge a complaint with the Office of the Privacy Commissioner of Canada.
• Appeal. Appeal our refusal to take action on your request within the timeframe required by applicable law after you have received notice of the refusal. You may file an appeal by contacting us as described in the “Contact Us” section below. If your appeal is denied, you may have the right to contact your state Attorney General or relevant data protection authority.

Recurrent will honor the privacy rights afforded to individuals in accordance with applicable law and will not discriminate against individuals for exercising their privacy choices under the law.

Exercising Your Privacy Rights

To exercise the above privacy rights, please visit our Privacy Rights Request form or contact as described in the “Contact Us” section below.

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in this section. We will process the agent’s request consistent with applicable law. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity and/or confirm that you provided the agent permission to submit the request. If you use an authorized agent to submit a request to exercise your rights, please have the authorized agent take the following steps in addition to the steps described above:

• E-mail a copy of your signed written declaration authorizing the authorized agent to act on your behalf to compliance@recurrent.io; and
• Provide any information we request in our response to your email to verify your identity. The information requested will depend on your prior interactions with us and the sensitivity of the personal data at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

If we cannot comply with a request or cannot fulfill a request within the standard timeframe, we will generally provide you with the reason for this. We may request specific information from you to help us confirm your identity and your rights. Applicable laws may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will generally inform you of the reasons why, subject to any legal or regulatory exceptions.

12. Children’s Privacy

Our Services are not intended for persons under 16 years of age. We do not knowingly collect or process the personal data of individuals under the age of 16. If we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us their Personal Data, please contact us at compliance@recurrent.io.

13. Jurisdiction-Specific Privacy Disclosures
    • Members of the European Economic Area and the United Kingdom

Our Legal Grounds for Processing Your Personal Data

Recurrent processes personal data that is subject to this Policy for different purposes, dependent on the specific use-case, as described in “Scope of this Policy”. These purposes include where you have provided consent, where such processing is necessary for the performance of a contract that we have with you, to comply with our legal obligations, or for our legitimate business interests. We process personal data only to the extent that we are legally permitted to do so.

Under European data protection laws, Recurrent is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.

• We process personal data based on your consent where required by law. This includes (for example):
  • placing or reading non-essential cookies or similar technologies;
  • serving targeted/interest-based advertisements, including using online identifiers and cross-site tracking;
  • “selling” or otherwise disclosing personal data to third parties for their own advertising, marketing, analytics, or data enrichment purposes; and
  • sending certain types of electronic marketing (where a separate opt-in is required)

You may withdraw your consent at any time as described in the “Your Privacy Rights” and “Cookies & Similar Technologies” sections. Withdrawal does not affect the lawfulness of processing before withdrawal.

• Performance of a Contract. We process personal data as necessary to enter into or perform a contract with you, including to:
  • create and manage your account or subscription;
  • provide access to our online magazines and other digital content (including paywall and entitlement checks);
  • deliver customer support and service communications;
  • process payments, billing, and fulfill transactions; and
  • personalize features that are strictly necessary to provide the service you request (e.g., remembering your reading position or saved preferences essential to the service).
• Compliance with Legal Obligations. We process personal data to comply with laws to which we are subject, such as:
  • tax, accounting, and invoicing requirements;
  • responding to lawful requests and orders from public authorities;
  • maintaining records necessary to demonstrate compliance (e.g., consent records, consumer-request logs); and
  • honoring consumer protection and privacy law obligations (e.g., responding to rights requests within statutory deadlines).
• Legitimate Interests. We process personal data where necessary for our legitimate interests (or those of a third party) and where these are not overridden by your interests or fundamental rights and freedoms. Our legitimate interests include:
  • operating, securing, and improving our websites, apps, and Services (including fraud prevention, abuse and bot detection, and network/information security);
  • measuring and understanding service performance (including first-party, privacy-preserving analytics that do not rely on non-essential cookies or cross-site tracking);
  • sending certain types of electronic marketing in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications;
  • contextual advertising that does not use tracking technologies requiring consent;
  • internal reporting, quality assurance, product development, and debugging;
  • enforcing our terms, protecting our rights, and establishing, exercising, or defending legal claims; and
  • business administration (e.g., mergers, acquisitions, or corporate reorganization).

Where ePrivacy laws require consent (e.g., for most targeted advertising and non-essential cookies), we will seek consent rather than rely on legitimate interests. We document our balancing assessments and you have the right to object to processing based on legitimate interests (see “Your Privacy Rights”).

• Residents of the State of California

We disclose categories of personal information as detailed in the table below and elsewhere in this Policy, including for business purposes to service providers/contractors and for “sharing” (cross-context behavioral advertising), subject to your right to opt out.

Category	Example	Collected	Disclosed for a Business Purpose	Shared for Cross-Context Behavioral Advertising
Identifiers	Name, alias, postal address, email address, phone number, IP address, device IDs, account username	Yes	Yes	Yes
Personal information under Cal. Civ. Code § 1798.80(e)	A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, financial information, medical information, or health insurance information. Some personal data included in this category may overlap with other categories.	Yes	Yes	Yes
Protected classification characteristics (under California or federal law)	Age (40 years or older), citizenship, marital status	Yes	Yes	No
Commercial information	Subscription history, transaction records, purchase/upgrade details	Yes	Yes	No
Biometric information	Voiceprints, facial geometry	No	No	No
Internet or other electronic network activity	Browsing history on Recurrent Sites, referral URLs, ad interactions, cookie data, page views	Yes	Yes	Yes
Geolocation data	Approximate location derived from IP address	Yes	Yes	Yes
Sensory data	Customer support call recordings (if you contact us by phone)	Yes	Yes	No
Professional or employment-related information	Company/role for B2B contacts (if provided)	Yes	Yes	No
Non-public education information (FERPA)	Student records	No	No	No
Inferences drawn to create a profile	Preferences, content interests, propensity to subscribe	Yes	Yes	Yes
Sensitive personal data (as defined by CPRA)	Account log-in with password; payment card with security code (processed by processor); contents of messages sent to support	Yes	Yes	No

• Sources of Personal Data. We collect personal data directly from you (e.g., account registration, subscriptions, customer support), automatically from your device and browser (e.g., cookies, pixels, SDKs, log files), and from service providers/contractors and partners (e.g., payment processors, fraud prevention, analytics, advertising partners), as well as from third-party data providers and publicly available sources. For more information, please review “Personal Data We Collect”.
• Uses of Personal Data. We use personal data to: provide and maintain accounts and subscriptions; authenticate you and process payments; deliver, personalize, and improve our online magazines and digital content; provide customer support and communicate with you; perform debugging, audit, security, and fraud prevention; measure and understand service performance and audience; conduct internal research and development; comply with law; and, where applicable, serve targeted ads and perform cross-context behavioral advertising (“sharing”) consistent with your choices. For more information, please review “How We Use Your Personal Data”.
• Disclosure of Personal Data. We disclose personal data to service providers and contractors for operational purposes (e.g., cloud hosting, payment processing, customer support, security, analytics), as further described in “Our Sharing of Your Personal Data”.
• Opt-Out of Sale/Sharing. Recurrent “sells” and “shares” certain personal information (e.g., online identifiers, internet/network activity, inferences) for advertising/marketing. You may opt out at any time via the “Do Not Sell or Share My Personal Information” link or by using a supported Global Privacy Control We do not sell or share personal information of consumers we know are under 16.
• Other Disclosures. We may disclose personal data to affiliates, professional advisors, law enforcement or regulators (pursuant to legal process), and in connection with corporate transactions (e.g., merger, acquisition, or asset sale).

Additional California Specific Disclosures

If you are a California resident, you can make certain requests regarding your personal data, and we will fulfill each request to the extent required by law. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.

As stated in more detail below, you can request that we:

• Provide you with access to a copy of and certain details regarding the personal data we have about you.
• Delete your personal data.
• Stop selling your personal data or sharing your personal data for cross-context behavioral advertising.
• Correct your inaccurate personal data.
• Limit the use or disclosure of your SPD.

You may exercise any of these privacy rights by going to the footer of our website or settings section of our app and selecting the ‘Do Not Sell or Share My Personal Information” link, or calling 305-918-1013 opt. 4.

Contact Us

 

If you have questions or comments about this Policy or complaints about our privacy practices, please contact us at: compliance@recurrent.io.