Privacy Policy

Effective: March 1, 2023

At Ponder, we are committed to protecting your privacy, and we have created this Privacy Policy as part of our Terms of Service to explain what information we collect, how your information is collected, and how we may use it on our Websites and Services that we operate.

Information We Collect

Information you provide to us: When you register for and use Ponder, you are providing us with information, which we collect. This information may include your name and email address.

Information from your use of Services: This information may include IP Address, location information, date and time, browser type, and any other action you might have taken to use and while using the Services.

How We Use Your Information

• To create your account.
• To provide customer support.
• To send you emails.
• To personalize your experience.
• To improve our Services and our products.
• To send you updates and alerts and to contact you about your account.
• To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.

How We Share and Disclose Your Personal Information

• To provide customer support.
• When we have your permission to share your information.
• When we have given you prior notice that the information will be shared.
• When we are required by law, or legal process to disclose that information – such as a court order or a subpoena. When we believe in our discretion, unless otherwise prohibited by law, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• To enforce our terms and conditions or to protect our operations or users.
• If a transfer of your information is required under the terms of a reorganization, merger, or sale of the company.
• When we determine that information is aggregate information or other information that does not identify you.

Public Information and Third Parties

Third Parties: We are not responsible and this Privacy Policy does not cover your use of any third-party widgets, features, or websites or links to third-party websites or services. We encourage you to read the privacy policy of any third-party site you visit or service you use carefully.

Security

We take precautions to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, while we strive to protect your personal information, we cannot and do not guarantee its absolute security.

California Consumer Privacy Act (CCPA)

If you are a California resident, please refer to the California Consumer Privacy Act (CCPA) Notice below for more information about our practices and requests you may make under the CCPA.

Updates to this Privacy Policy

We reserve the right to modify this privacy statement at any time. If we make material changes to this policy, we will email you.

Questions

If you have any questions regarding this Privacy Policy, please email us.

California Consumer Privacy Act (CCPA) Notice

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we created this notice to provide the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months.

We collected the following categories of Personal Information and disclosed such Personal Information to third parties, e.g. our service providers, for our operational business purposes:

• Identifiers, such as name and IP address;
• Personal information, as defined in the California safeguards law, such as your email address;
• Internet or network activity information, such as your interactions with our Websites and online Services; and
• Geolocation data, such as device location.

As described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services (e.g., create your account, provide customer support etc…), to accomplish our business purposes and objectives, including, for example, using Personal Information to better understand your needs and interests, communicate with you, personalize your experience, improve our Services and our products, send you updates and alerts, and to contact you about your account, transfer your information in the case of a sale, merger, consolidation, or acquisition, respond to subpoenas, court orders, or legal process, and establish or exercise our legal rights or defend against legal claims.

We have not “sold” Personal Information for purposes of the CCPA

For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

What you can request as a California resident under the CCPA

1. Disclosure to you of the following information covering the 12 months preceding your request
   • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   • The specific pieces of Personal Information we collected about you;
   • The business or commercial purpose for collecting (if applicable) Personal Information about you; and
   • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
2. Deletion of Personal Information we collected from you

To make a request for the disclosures or deletion described above, you can email us.

• Please indicate whether you are a site visitor; registered user; authorized agent; or client
• Please specify what type of request you are making
• Please state your full name and email
• Certify you are a resident of California and that all information is true and correct under penalty of perjury

Please note that in some instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident, where no data exists, and/or where we believe in good faith that the required information provided is incomplete or erroneous.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.