PRIVACY POLICY

1. Data controller

Podimo acts as a data controller for the processing of your personal data in the following situations:

• when you visit our website or apps (cookies and similar tracking technologies),

• when you Create an account for our User Service and use our User Service,

• when you sign-up to and use our Creator Service

• when you communicate with us,

• when you are subject to direct marketing,

• if you participate in competitions administered by us

• If you visit our social media platforms (Facebook, Instagram, Twitter), and

• when you represent a supplier, vendor or other third party.

Below, you can read more about the various purposes of our processing of your personal data in the different situations. You can also see which data we process, what the legal basis for our processing is, for how long we store the personal data and who we share it with.

Further, in the section Your rights etc. you can read about your rights and how to contact us.

2. Personal data, purpose, and legal basis etc.

2.1 When you visit our website or apps (cookies and similar tracking technologies)

When you visit our website or apps, we use cookies and similar tracking technologies to collect data about your visits, including e.g. your navigation on the website or in the app, the type of browser or device you use and your IP address. These data may contain personal data. 

For the website, we collect the data in order to ensure a stable, secure and user-friendly experience on our website, as well as to keep statistics about our website visitors. In some cases, data is processed in order to target marketing based on the web browser behaviour. 

For the apps, we collect the data in order to target marketing based on the user behaviour.

The legal bases for our processing are:

• for necessary (technical) cookies on the website: article 6(1)(f) of the GDPR, as we are pursuing our legitimate interest in ensuring functionality and security of our website, and 

• for other cookies and similar technologies on the website and in the apps: article 6(1)(a) of the GDPR, as you have given your consent to e.g., targeted marketing.

We disclose information about your use of the website and apps to any third-party service providers that you have allowed to place cookies and/or similar tracking technologies when you use the website or apps. If you have given your consent, such third parties include: 

• Facebook Ireland Limited – see privacy notice here.

• Google LLC  – see privacy notice here. 

Personal data contained in cookies will be deleted in accordance with the lifetime/period for each specific cookie. Read more about our cookies, including their lifetime and the specific third-party providers (i.e. the recipients), in our Cookie Policy. You can read more about the processing of your personal data at the third-party provider's own privacy notices (see links above). 

2.2 When you create an account for our User Service and use our User Service

Podimo provides services to access podcasts and audiobooks via our mobile device application and any other means we may make available from time to time, e.g. web players (our “User Service”).

When you create an account to access our User Service, you will be asked to enter your name and contact information, email address and a password chosen by you. We collect such information from you in order to provide you access to our User Service and to make sure that your access account is secured by your own individual password. In addition, we will have access to information regarding your geographical location. 

If You choose to link the User Service to Facebook, Apple or a similar third-party service that manages personal data, Podimo may collect and process information that You give to the relevant third party permission to share with Podimo. You can read more about the processing of your personal data by the third party-providers at the third-party providers’ own privacy notices.

With regard to users with a paid subscription to our User Service (including those starting on a free trial basis, where offered), we will also be collecting payment information in order to provide you access to your subscription. However, as Podimo cooperates with third party payment service providers who operate independently in systems separated from Podimo, no complete payment data, such as complete credit card numbers, will be stored by Podimo. 

Further, where the option is available, you may choose to provide us with additional information about your age, gender and areas of interest. We collect such additional information from you in order to provide you with suggestions about content which could be of interest to you based on the information provided. However, such information is not required and fully optional.

We also collect information as to the platform from which you download our app and as to the source of your subscription, for example via our own channels, app stores, and in the event that you sign up to our User Service as part of a promotion or partnership with a third party brand, product or service We process this information to enable us to ensure that you receive the benefit of the subscription which you have signed up for, to administer our relationships with partners and to measure the success of campaigns. 

In addition, we will have access to information regarding how you engage with our User Service, including what content you have searched for, interacted with, listened to and saved to your library. This includes processing technical data (such as unique platform ID, device IP address). We collect such information from you in order to improve your use of our User Service, including to make suggestions for related content, to analyse engagement with our User Service and to ensure that we are able to properly remunerate content creators for consumption of their content.

Personal data processed: i) in order to deliver our User Service, including personal data that you choose to provide us with in order to receive our User Service; and ii) in order to ascertain the source of your app download / subscription, is based on article 6(1)(b) of the GDPR, as the information is necessary for the performance of a contract with you.

Personal data processed in order to analyse your use of our User Service and measure the success of campaigns is based on article 6(1)(f) of the GDPR, as we are pursuing our legitimate interests in operating and developing our User Service.

We only keep your data for as long as they are of relevance to us and we have a legitimate purpose for keeping them. Your data will therefore be deleted in accordance with applicable data protection legislation and as a general rule your data will be deleted 5 years after the end of the financial year in which you choose to unsubscribe from our User Service, in order to facilitate any decision by you to restore your subscription.

In specific situations, we may defer from our general retention periods (in case of e.g. complaints, objections or other specific situations).

We disclose personal data included in our account records to the relevant public authorities, including the tax and customs authorities, in connection with our statutory bookkeeping etc. 

Further, we disclose your personal data to the service providers for the online payments company that we use. Finally, we make your personal data available to our group companies and processors who e.g. host, develop and support our IT systems and provide analytics services connected to our User Service. Please see below regarding transfer of your personal data to third countries.

2.3 When you sign up to and use our Creator Service

If you are a creator of content (e.g. a podcaster), you can create an account on Podimo Podcaster Studio in order to administer your relationship with us and to receive insights into the performance of your podcast(s) on our User Service (“Creator Service”).

When you sign up to the Creator Service, we will register your personal data in Podimo Podcaster Studio and our IT systems, including name, contact details, country of residence, log-on details and password, and bank account information. Further, we process information on revenue share/royalties (where applicable), and information relating to your podcast(s) which you have ‘submitted’ via Podimo Studio, such as ratings and completion rate. 

We process these personal data as part of our creator administration, including for the purpose of managing the creator relationship, for billing purposes, in order to deliver the services based on our contractual obligations with the creators and to make their podcasts available to the users. 

The legal basis for our processing is article 6(1)(b) of the GDPR, as the processing is necessary for the performance of our creator contracts, and article 6(1)(f) of the GDPR, as we are pursuing our legitimate interest in creator administrative tasks and communicating with the creators, as well as managing accounting and finance tasks. 

Personal data will generally be deleted 5 years after the end of the financial year in which the creator relationship has ended. 

In specific situations, we may defer from our general retention periods (in case of e.g. complaints, objections or other specific situations).

We disclose personal data included in our account records to the relevant public authorities, including the tax and customs authorities, in connection with our statutory bookkeeping etc. 

We may disclose your personal data to our relevant business partners, including external advisors. Further, we make your personal data available to our group companies and processors who e.g. host, develop and support our platforms. Please see below regarding transfer of your personal data to third countries.

2.4 Communications with us

When you communicate with us (e.g., via email or by our contact form on our websites) your communication will contain personal data, e.g., your contact details (including name and email address) and other personal data you may provide us with. 

We process these personal data for the purpose of managing and answering your inquiries. The legal basis for the processing is article 6(1)(f) of the GDPR, as we are pursuing our legitimate interests in managing general inquiries. 

We only keep your data for as long as they are of relevance to us and we have a legitimate purpose for keeping them. Your data will therefore be deleted in accordance with applicable data protection legislation. Personal data pertaining to our general communication with you (such as email inquiries) will be deleted 5 years after the end of the financial year where your last inquiry has been handled/concluded.

In specific situations, we may defer from our general retention periods (in case of e.g. complaints, objections or other specific situations).

Further, we disclose your personal data to the service providers for the online payments company that we use. Finally, we make your personal data available to our group companies and our processors who e.g. host, develop and support our IT and CRM systems.  Please see below regarding transfer of your personal data to third countries.

2.5 When you are subject to direct marketing

When you subscribe to the newsletter about or User Service or other marketing communications (e.g. for news / offers regarding an upcoming launch of our User Service in a new market or, if you are creator of content using Podimo Studio, our newsletter about our Creator Service), we register your name, email address and, in the case of users of our User Service, any preferences you may have given. The latter involves that we, based on your profile, including your geographical location and the preferred genres and themes of the content you listen to, are able to better target our marketing. Further, we process these personal data for the purpose of being able to send you targeted communications. 

The legal basis for our processing is the consent you have given in accordance with section 10 of the Danish Marketing Practices Act (markedsføringsloven).

We stress that you at any time have the right to object to our processing of your personal data concerning marketing, including our profiling related to such direct marketing. Further, you have the right to withdraw your consent at any time. See our contact information below under "Contact details". 

Personal data pertaining to our distribution of marketing communications will be deleted 2 years after our last marketing communication  has been distributed, unless you have withdrawn your consent (i.e., unsubscribed) before such time.

We make your personal data available to our group companies and  processors who e.g. host, develop and support our IT systems. Please see below regarding transfer of your personal data to third countries. 

2.6 If you participate in competitions administered by us

If you decide to participate in competitions, e.g. prize draws organised, administered by us, to which you are invited to participate via, e.g. our websites or apps or as part of direct marketing communications (per Section 2.5), we may ask you to provide personal data such as your name, email address and other contact information (if you have not already provided this to us under Sections 2.2 or 2.3 above). We may also collect other personal information required to provide you with any prize offered in the event you win the competition/prize draw.

We process these personal data for the purpose of administering the competition, including contacting winners. The legal basis for the processing is article 6(1)(f) of the GDPR, as we are pursuing our legitimate interests in pursuing and running promotional activities.

We only keep your data for as long as they are of relevance to us and we have a legitimate purpose for keeping them. Your data will therefore be deleted in accordance with applicable data protection legislation. Personal data pertaining to competition administration will be deleted 5 years after the end of the financial year in which the competition or prize draw concluded.

In specific situations, we may defer from our general retention periods (in case of e.g. complaints, objections or other specific situations).

We make your personal data available to our group companies and processors who e.g. host, develop and support our IT and CRM systems used to administer the competition or who are co-organising the competition. Please see below regarding transfer of your personal data to third countries.

2.7 If you visit our social media platforms (Facebook, Instagram, Twitter, Youtube, Tik Tok).

If you visit our account on platforms at, e.g., Facebook, Instagram, Twitter, Youtube or TikTok we may process the personal data that you have available to us via the specific settings, your reactions on content, including likes and comments, and any sharing of our content etc.

We process these personal data for the purpose of managing our social media platforms and communicating with you through these platforms. The legal basis for the processing is article 6(1)(f) of the GDPR, as we are pursuing the above-mentioned legitimate interests. 

We only keep your data for as long as they are of relevance to us, and we have a legitimate purpose for keeping them. Your data will therefore be deleted in accordance with applicable data protection legislation. Personal data pertaining to our social media platforms, that we are in control of, will be deleted 5 years after the end of the financial year in which such personal data was collected.

Please note that when using our social media platforms, the provider (such as e.g., Facebook) will also process your personal data for its own purposes, including for targeted marketing purposes. You may find further information on these processing activities at the provider's own privacy notices.

2.8 When you are or represent a supplier, vendor or other third party

When you communicate with us (e.g., via email) as or on behalf of supplier, vendor or another third party, your communication may often contain personal data, e.g. your contact details (including name and email address), association with a certain company or other personal data you may provide us with. We may also receive such personal data from a third party, such as your employer. 

We process this personal data for the purpose of managing our relationship, including any contracts we conclude with you, and to communicate with you/the company you represent. Further, such personal data may be processed if you participate in events and meetings at or hosted by Podimo.

The legal basis for the processing is article 6(1)(f) of the GDPR, as we are pursuing our legitimate interests in managing business relationships and fulfilling any agreement we may have concluded with you or the company you represent. 

If you are not or do not represent a supplier etc., personal data pertaining to our general communication with you (such as email inquiries) will be deleted 5 years after the end of the financial year where your last inquiry has been handled/concluded. If you are or represent a supplier etc., personal data pertaining to our communication with you will generally be deleted 5 years after the end of the financial year in which the business relationship has ended.

We disclose personal data included in our account records to the relevant public authorities, including in connection with our statutory bookkeeping etc.

We may also disclose your personal data to our group companies and relevant business partners, including external advisors. Finally, we make your personal data available to our processors who e.g., host, develop and support our IT systems. Please see below regarding transfer of your personal data to third countries.

3. Transfer of your personal data to third countries

We transfer your personal data to countries outside the EU and EEA, when making data available to our processors in various third countries. 

The basis for such transfer is either:

• the Commission Decision of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council (“SCCs”), or

• an EU Commission adequacy decision based on article 45 of the GDPR (“Adequacy Decision”).

If you want additional information about our transfer of personal data outside the EU and EEA, including a copy of the relevant security measures, etc., you may make a request for such additional information by contacting us (see contact information below). 

4. Your rights etc.

You have special rights to help you control your personal data, and we wish to make it easy for you to exercise those rights:

• Right to withdraw consent 

Where you have given your consent for our processing of your personal data, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us, see below under "Contact". 

If you withdraw your consent, the withdrawal will not affect the lawfulness of processing that has already been carried out based on your consent. 

• Right of access

You have the right to have confirmed whether we collect or process your personal data, and, if so, you have the right to request a copy of your personal data in a digital format.

• Right of rectification

You have the right to require that we correct any inaccurate personal data concerning you, and that we complete incomplete personal data.

• Right of erasure

In certain circumstances, you have the right to request that we erase personal data concerning you; for example, if it is no longer necessary for the purposes for which it was originally collected.

• Right to restrict processing

In certain circumstances, you have the right to request that we restrict the processing of your personal data, e.g. if you believe that the personal data is not accurate or lawfully processed.

• Right to object to the processing

In certain circumstances, you have the right to request that we stop processing your personal data.

• Right to data portability

In certain circumstances, you have the right to receive the personal data you have provided us with in a structured, commonly used, machine readable format, and the right to have us transmit the data to another entity, where technically feasible.

5. Complaint to a supervisory authority 

If you want to lodge a complaint with a supervisory authority about our processing of your personal data, you can do so by contacting the Danish Data Protection Agency via their website, www.datatilsynet.dk.

You can read more about your rights in the Danish Data Protection Agency's guidelines on data subjects' rights, which is available at www.datatilsynet.dk (in Danish). 

Please contact us if you wish to exercise your rights. The relevant contact details are stated below.

6. Contact details

If you have any questions about how we process personal data, please contact us.

Podimo ApS  Gasværksvej 16, 4.  1656 Copenhagen V Denmark Company registration no.: 40447024  Email: hello@podimo.com

Last modified on 15 February 2022.