PODWAY PRIVACY POLICY

2.1 Website and Applications Usage

When you visit our website or applications, we use cookies and similar tracking technologies to collect information about your visit, such as the device or browser you use, your IP address, and how you navigate the site or app. This information may contain personal data.

• Website: We collect information to ensure a stable, secure, and user-friendly website, and to create statistics about site visitors.
• Applications: We collect information about user activity in the app to tailor marketing based on user behavior.

2.2 When You Create an Account and Use Our Service

Podway offers a service ("Service") through which you can listen to podcasts and audiobooks via a mobile application, or another provided interface (for example, a browser-based player). When you create a user account for Podway’s Service, you are asked to provide your name, contact details, email address, and a password of your choice. We collect this information to provide you with access to the Service and to secure your account with a personal password. We also receive information about your geographic location. If you wish to link the Podway Service to Facebook, Apple, or another similar third-party service that processes personal data, Podway may collect and process information you have authorized that third party to share. You can read more about the processing conditions in these third parties’ own privacy policies.

If you use a paid subscription (including a possible free trial), we also collect payment information so that we can provide you with access to the paid service you have subscribed to. Because Podway collaborates with external payment service providers that operate independently of Podway’s systems, Podway does not store complete payment data (such as full credit card numbers). Additionally, if the functionality is available, you may voluntarily provide information about your age, gender, and areas of interest. We use this information to recommend content you might find interesting. Providing this additional information is entirely optional.

We also collect information about which platform you used to download our application and the source of your subscription (e.g., our own channels, an app store, or a third-party product/service partner). We process this information to ensure you receive the subscription benefits to which you have signed up, to manage partner relationships, and to measure campaign success. Furthermore, we collect information about your use of the Service, such as the content you search for, listen to, or save to your library. This involves the processing of technical data (e.g., device-specific identifiers, device IP address). We collect this information to improve your user experience, to provide you with related recommendations, to analyze the use of the Service, and to ensure that content creators receive appropriate compensation.

Legal Bases for Processing Personal Data:

• Personal data necessary for providing the user service (e.g., your subscription details) or that you provide to receive the service: Under the GDPR, processing is necessary for the performance of a contract.
• Processing of personal data to analyze service usage and measure campaign success: Under the GDPR, we have a legitimate interest in developing and maintaining our service.

We only retain data for as long as it is necessary for us, and we have a legitimate purpose for keeping it. The data is deleted in accordance with applicable data protection legislation, and generally, it is deleted five (5) years after the end of the financial year during which you decide to discontinue your subscription to our Service. This is intended to facilitate a possible desire to restore the Service in the future. In certain specific situations, we may deviate from our general retention periods (e.g., in the event of complaints).

We disclose personal data related to accounting information to the competent authorities (such as tax authorities) for the fulfillment of statutory obligations (bookkeeping, etc.). We also disclose any necessary data to payment service providers with whom we collaborate. We disclose your personal data to our service providers, for example, those who maintain, develop, and support our IT systems or provide analytics services for our user service. Please see below for more information about the transfer of personal data to third countries.

2.3 When You Contact Us

When you contact us (e.g., by email or via the contact form on our website), your message may contain personal data, such as your contact details (name and email address) and other information you have provided. We process this personal data so that we can manage and respond to your inquiries. Under the GDPR, the legal basis for processing is our legitimate interest in handling general inquiries.

We only retain data for as long as it is necessary for us, and we have a legitimate purpose for keeping it. The data is deleted in accordance with applicable data protection legislation. As a rule, general inquiries (such as email queries) are deleted five (5) years after the end of the financial year during which your last inquiry was addressed/resolved. In certain specific situations, we may deviate from our general retention periods (e.g., in the event of complaints).

Additionally, we disclose any necessary data to payment service providers with whom we collaborate. We also disclose your personal data to our service providers who, for example, maintain, develop, and support our IT and CRM systems. Please see below for more information about the transfer of personal data to third countries.

2.4 When You Receive Direct Marketing

If you have subscribed to our newsletter or other marketing communications (such as news/offers related to Podway’s Service in a new market), we register your name, email address, and any preferences you may have. If you use our user service, this includes information that allows us to better target marketing, such as your geographic location and preferred genres or topics. We process this data to send you targeted messages.

Legal Basis for Processing: You have given your consent. Please note that you may at any time object to the processing of your personal data for direct marketing purposes, including any related profiling. In addition, you have the right to withdraw your consent at any time (see our contact details below under “Contact”).

Personal data related to marketing communications is deleted two (2) years after the last marketing communication has been sent, unless the consent (unsubscribe) has been withdrawn earlier. We make your personal data available to our service providers who, for example, maintain, develop, and support our IT systems. Please see below for more information about the transfer of personal data to third countries.

2.5 If You Participate in Competitions We Organize

If you decide to participate in competitions or prize draws that we organize (e.g., via our website or applications, or in the context of direct marketing communications, see Section 2.4), we may ask you to provide personal data, such as your name, email address, and other contact details (if you have not already provided them under Sections 2.2 or 2.3). We may also collect additional information needed for awarding prizes, should you win a competition. We process this personal data to administer the competition, including contacting the winners. Under the GDPR, the legal basis for processing is our legitimate interest in organizing and managing competitions related to marketing.

We only retain data for as long as it is necessary for us, and we have a legitimate purpose for keeping it. As a rule, personal data related to competitions is deleted five (5) years after the end of the financial year during which the competition or prize draw is concluded. In certain specific situations, we may deviate from our general retention periods (e.g., in the event of complaints).

We make your personal data available to our service providers who, for example, maintain, develop, and support the IT and CRM systems used to administer the competition, or who are involved in organizing the competition. Please see below for more information about the transfer of personal data to third countries.

2.6 If You Visit Our Social Media Channels (Facebook, Instagram, YouTube, TikTok)

If you visit our pages or accounts on social media (e.g., Facebook, Instagram, YouTube, or TikTok), we may process personal data visible to us based on the channel’s settings. This may include information about your reactions to our content (such as likes, comments, or shares). We process this data to manage our social media channels and communicate with you on these platforms. Under the GDPR, the legal basis for processing is our legitimate interest in maintaining our social media channels and communicating through them.

We only retain data for as long as it is necessary for us, and we have a legitimate purpose for keeping it. Personal data collected in connection with our social media channels, which are under our control, is generally deleted five (5) years after the end of the financial year during which the personal data was collected. Please note that the social media platform provider (e.g., Facebook) also processes your personal data for its own purposes, such as creating targeted advertising. Detailed information about such processing can be found in the respective service provider’s own privacy policy.

2.7 When You Are or Represent a Supplier, Vendor, or Other Third Party

If you contact us (e.g., by email) as or on behalf of a supplier, vendor, or other third party, your message may contain personal data such as your contact details (name, email address), the name of your employer, or other information you provide. We may also receive this information from third parties (such as your employer). We process this personal data in order to manage our cooperative relationship, including any agreements, and to communicate with you or the company you represent. We may also process your data if you participate in meetings or events organized by Podway. Under the GDPR, the legal basis for this processing is our legitimate interest in managing business relationships and fulfilling any contractual obligations we have undertaken with you or the company you represent.

If you are not or do not represent a supplier, etc., general correspondence (e.g., email inquiries) is generally deleted five (5) years after the end of the financial year during which your last correspondence was handled/completed. If you are or represent a supplier, etc., personal data pertaining to our communication with you is generally deleted five (5) years after the end of the financial year during which the business relationship ended.

We disclose personal data contained in account information to the competent authorities, including for statutory bookkeeping requirements. We may also disclose your personal data to relevant partners, including external advisors. In addition, we make your personal data available to our service providers who, for example, maintain, develop, and support our IT systems. Please see below for more information about the transfer of personal data to third countries.