Privacy Policy

Pushkin Privacy Policy

ONLINE PRIVACY POLICY AGREEMENT

Last updated September 13, 2020 

Pushkin Industries, Inc., (Pushkin), is committed to keeping any and all personal information collected of those individuals that visit our website and make use of our online facilities and services accurate, confidential, secure and private. Our privacy policy has been designed and created to ensure those affiliated with Pushkin Industries, Inc. of our commitment and realization of our obligation not only to meet but to exceed most existing privacy standards.     

THEREFORE, this Privacy Policy Agreement shall apply to Pushkin Industries, Inc. , and thus it shall govern any and all data collection and usage thereof. Through the use of www.pushkin.fm you are herein consenting to the following data procedures expressed within this agreement.

Collection of Information

This website collects various types of information, such as:

  1. Information that you directly provide to us in order to create an account (e.g. your name, email address and state). 
  2. Billing information associated with the debit/credit card you use to make an online purchase direct from our site. If you make a payment through our service, your credit/debit card number will be stored by Stripe. For more information on Stripe’s data storage and privacy terms, please read their terms of service here and privacy policies here.
  3. Information automatically collected when visiting our website, which may include: 
    1. Cookies third party tracking technologies and server logs; 
    2. Identifiers such as an anonymized session identifier; 
    3. Your geographic location. We used this data to provide you with location-based services, such as advertising and personalized content. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings; 
    4. Website traffic volume, frequency of visits, and type and time of transactions you initiate through the website; 
    5. Your Internet Protocol (IP) address;
    6. the type and settings of the device, operating system, and browser used to access the Service; and 
    7. websites you visit before and after using the Services;
  4. We may use third party-vendors, identified below, to help deliver you content and process your payments.                     

Please rest assured that this site shall only collect personal information that you knowingly and willingly provide by way of creating an account, answering surveys, completing membership forms, and emails. It is the intent of this site to use personal information only for the purpose for which it was requested and any additional uses specifically provided on this site.                                                                       

Pushkin Industries, Inc. may have the occasion to collect anonymous demographic information, such as age, gender, household income, political affiliation, race and religion at a later time. 

It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent as a means to better understand the way in which other websites garner, make use of and share information collected.

Data Processors 

Pushkin Industries, Inc. uses the following data processors with respect to the personal information collected: 

  • Memberful: Memberful manages all website membership details including your sign up and account maintenance. You can find Memberful’s privacy policy here. 
  • Stripe: Stripe managed all payment processing. Your credit card payment details are managed by Stripe and not released to Pushkin Industries, Inc. You can find Stripe’s privacy policy here

Use of Information Collected

Pushkin Industries, Inc. may collect and may make use of personal information to assist in the operation of our website and to ensure delivery of the services you’ve paid for or requested. At times, we may find it necessary to use personally identifiable information as a means to keep you informed of other possible products and/or services that may be available to you from www.pushkin.fm; support the tracking and recovery of the services you purchase; respond to questions, comments or other requests and provide you with technical support; and notify you of technical updates or changes to our policies. Pushkin Industries, Inc.  may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future services that may be offered.

Pushkin Industries, Inc. does not now, nor will it in the future, sell, rent or lease any of our customer lists and/or names to any third parties.

Pushkin Industries, Inc. may disclose your personal information, without prior notice to you, only if required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to: 

·       Remain in conformance with any decrees, laws and/or statutes or in an effort to comply with any process which may be served upon Pushkin Industries, Inc. and/or our website;

·       Maintain, safeguard and/or preserve all the rights and/or property of Pushkin Industries, Inc.; and

·       Perform under demanding conditions in an effort to safeguard the personal safety of users of www.pushkin.fm and/or the general public.

We may share or disclose non-personal, generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. Pushkin Industries, Inc. will only provide those third parties with the information that they need to deliver services to Pushkin Industries, Inc and on Pushkin Industries, Inc’s behalf. 

How we protect your information

We adopt appropriate data collection, storage and processing practices, and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our website. Sensitive and private data exchange between the website and its users happens over an SSL secured communication channel and is encrypted and protected with digital signatures. If you have any questions about the security of personal information collected by Pushkin Industries, Inc., please contact: [email protected]

Security

Pushkin Industries, Inc. shall endeavor to use commercially reasonable efforts to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or modification of the user's personal information under our control. However, no method of transmission over the Internet or via a mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect information about you, we cannot guarantee absolute security.

Children Under Age of 13

Pushkin Industries, Inc. does not knowingly collect personal identifiable information from children under the age of thirteen (13) without verifiable parental consent. If it is determined that such information has been inadvertently collected on anyone under the age of thirteen (13), please contact us (see “Contact Information”) and we shall immediately take the necessary steps to ensure that such information is deleted from our system's database. Anyone under the age of thirteen (13) must seek and obtain parent or guardian permission to use this website.

Unsubscribe or Opt-Out

All users and/or visitors to our website have the option to discontinue receiving communication from us and/or reserve the right to discontinue receiving communications by way of email or newsletters. To discontinue or unsubscribe to our website please send an email that you wish to unsubscribe to [email protected] If you wish to unsubscribe or opt-out from any third party websites, you must go to that specific website to unsubscribe and/or opt-out. Please note that once we have removed your personal data as described in this Privacy Policy, we may send you a final confirmation email to let you know that such removal process has been completed.  

  1. To control cookies, you can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. 
  2. Please note that if you choose to block cookies, doing so may impair the service or prevent certain elements of it from functioning. 

“Do Not Track” Signals 

Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. This service does not alter its practices when it receives a “Do Not Track” from a visitor’s browser. 

Links to Other Web Sites

Our privacy policy contains links to our affiliate Data Processors. Pushkin Industries, Inc. does not claim nor accept responsibility for any privacy policies, practices and/or procedures of other such Data Processors. Therefore, we encourage all users and visitors to be aware when they leave our website and to read the privacy statements of each and every Data Processors that collects personally identifiable information. The aforementioned Privacy Policy Agreement applies only and solely to the information collected by our website.

Data Retention and Account Termination

You can close your account here by contacting us at [email protected]  Once your account is closed, no further data will be collected, but we may retain information about you for the purposes authorized under this Privacy Policy, unless prohibited by law. Please note that we may automatically collect information about you through cookies, pixels or the other tracking technologies described in this Privacy Policy if you revisit the Service after you have closed your account. To prevent this, you will need to adjust your browser settings before revisiting the Service.

You can update or correct personal information (e.g., your name, email address and state) by accessing your account. You can also access or rectify your information by reaching out to us at [email protected]. You can delete your information by sending an email to [email protected] with your first name, last name, and the respective email addresses you would like for us to delete.

Please note that we have the right to reject deletion requests that are unduly burdensome or repetitive or that cannot be honored in light of legal obligations or ongoing disputes, or where retention is necessary to enforce our agreements or protect our or another party’s rights, property, safety, or security. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the service or to comply with legal obligations. The time-period for which we keep information varies according to the information’s use. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need. Please also note that even after you have deleted your account, other content associated with your use of the service may still be accessible and viewable in accordance with applicable law and our Terms of Service.

Location of Data and Transfers of Information

The Pushkin Industries, Inc. website is owned and operated by Pushkin Industries, Inc, which is located in the United States. If you are located outside of the United States, please note that personal data will be processed to and/or accessed in the United States. 

EEA Users

Pushkin Industries, Inc. endeavors to comply with European privacy laws such as the General Data Protection Regulation (GDPR). Pushkin Industries, Inc may act, depending on the circumstances, as a “Controller” of personal data (as defined in the GDPR). We act as the Controller of information that we ask you to provide to create an account and information that we automatically collect when you use the service. 

EEA users have the right to request access to personal data, as well as to seek to update, delete or correct their personal data. You can usually do this using the settings and tools provided in your account. If you cannot use the settings and tools, contact us for additional access and assistance.

Your California Privacy Rights.

We recognize the need to provide further privacy protections with respect to personal data we may collect from California residents. For California residents, we will employ different data practices as necessary to comply with applicable law. For additional information about our practices regarding personal data and privacy-related choices specific to California residents, please read our Privacy Notice for California Residents below. 

Changes to Privacy Policy Agreement

Pushkin Industries, Inc. reserves the right to update and/or change the terms of our privacy policy, and as such we will post those change to our website homepage at www.pushkin.fm, so that our users and/or visitors are always aware of the type of information we collect, how it will be used, and under what circumstances, if any, we may disclose such information. If at any point in time Pushkin Industries, Inc. decides to make use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected, the user or users shall be promptly notified by email. Users at that time shall have the option as to whether or not to permit the use of their information in this separate manner. 

Acceptance of Terms

Through the use of this website, you are hereby accepting the terms and conditions stipulated within the aforementioned Privacy Policy Agreement. If you are not in agreement with our terms and conditions, then you should refrain from further use of our sites. In addition, your continued use of our website following the posting of any updates or changes to our terms and conditions shall mean that you are in agreement and acceptance of such changes.

How to Contact Us

If you have any questions or concerns regarding the Privacy Policy Agreement related to our website, please feel free to contact us at the following email, telephone number or mailing address.

Email: [email protected]

Mailing Address:

    Pushkin Industries, Inc.

    5-9 Union Square West

     New York, NY 10003

Privacy Notice for California Residents

Effective Date: September 15, 2020

  1. General

This Privacy Notice for California Residents supplements the information contained in Pushkin Industries, Inc.’s Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. Any other defined terms have the meaning ascribed to them in our Privacy Policy.

  1. Information We Collect

Our websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Pushkin Industries, Inc.’s websites have or will collect the following categories of personal information from its consumers:

CategoryExamples
A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, address, telephone number.
D. Commercial information.Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.Physical location or movements.

Please note that personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the CCPA’s scope, like:

  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Pushkin Industries, Inc. obtains the categories of personal information listed above from the following categories of sources both directly and indirectly, as described in our Privacy Policy.

Please note that some personal information may be collected from you in connection with your purchase of or registration for our products and services on third-party websites. For example, forms related to registrations and purchases, which capture certain personal information, may be hosted by our fulfilment partners. Such personal information is then shared with Pushkin Industries, Inc. and used in accordance with “Use of Personal Information” below.

  1. Your Rights and Choices.

The CCPA provides California residents with specific rights regarding their personal information. This section describes such rights and explains how to exercise them.

  1. Access to Specific Information and Data Portability Rights. You have the right to request that Pushkin Industries, Inc. disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:
    1. The categories of personal information we collected about you.
    2. The categories of sources for the personal information we collected about you.
    3. Our business or commercial purpose for collecting that personal information.
    4. The categories of third parties with whom we share that personal information.
    5. The specific pieces of personal information we collected about you (also called a data portability request).
    6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
      1. sales, identifying the personal information categories that each category of recipient purchased; and
      2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  2. Deletion Request Rights. You have the right to request that Pushkin Industries, Inc. delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights”), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
    1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    3. Debug products to identify and repair errors that impair existing intended functionality.
    4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    8. Comply with a legal obligation.
    9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 
  3. Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
  1. Calling us at 332-203-2550
  2. Emailing us at [email protected]

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

  1. Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
  2. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

In the event that Pushkin Industries, Inc. does provide a CCPA-permitted financial incentive program that results in different prices, rates or quality levels, such program will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

  1. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents who use our websites to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via the contact information listed in “Contact Information” below.

  1. Changes to Our Privacy Notice

Pushkin Industries, Inc. reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our websites and update the notice’s effective date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.

  1. Contact Information

If you have any questions or comments about this notice, the ways in which Pushkin Industries, Inc. collects and uses your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 332-203-2550

Email: [email protected]

Postal Address: 5-9 Union Square West, New York, NY 10003