Effective Date: January 12, 2026This Privacy Notice ("Privacy Notice" or "Notice") describes how MQL Media, Inc., doing business as PingMunk ("PingMunk," "we," "our," or "us"), collects, uses, discloses, and protects information through our artificial intelligence-powered telephone reception platform and associated services.

Scope of Services: This Notice applies to:

  • Our AI-powered telephone reception system ("AI Assistant")

  • Client dashboard, software applications, and integrations ("Platform")

  • PingMunk.com and related web properties ("Website")

  • All associated services (collectively, "Services")


Binding Effect: Your use of our Services constitutes acceptance of this Privacy Notice and our Terms of Service, including liability limitations and dispute resolution provisions.IMPORTANT: By indicating consent where offered or by using our Services in any manner, YOU CONSENT TO THE PRIVACY PRACTICES DESCRIBED HEREIN. If you disagree with this Privacy Notice, you must not access or use our Services.Updates and Modifications: We may update this Privacy Notice periodically. Material changes will be communicated through the Services or via email, with consent requested as required by applicable law.Questions and Contact: For privacy inquiries, contact [email protected]


1. CRITICAL DISTINCTIONS: CLIENTS VS. END USERS

1.1 Scope LimitationThis Privacy Notice governs PingMunk's privacy practices only. It does NOT apply to:

  • Personal information collection by our business clients ("Clients")

  • Client privacy practices or policies

  • Client use of data obtained through our Services

  • Third-party services integrated with our Platform


1.2 Client ResponsibilitiesOur Clients use the AI Assistant to handle telephone communications on their behalf. Each Client determines:

  • What personal information to collect from their callers ("End Users")

  • How to use and process End User data

  • Privacy settings and configurations

  • Notice and consent mechanisms for End Users

  • Data retention and deletion practices

  • Responses to End User privacy requests


1.3 End User InquiriesEnd Users should contact the business they called for:

  • Questions about personal information collection

  • Privacy rights requests (access, deletion, correction)

  • Concerns about data handling practices

  • Opt-out or consent withdrawal

  • General privacy inquiries

PingMunk typically processes End User data as a service provider on behalf of Clients. Our contractual agreements with Clients, not this Privacy Notice, primarily govern such processing.1

.4 AI Technology Development
Data processing for AI model training and development occurs under:

  • Contractual agreements with our Clients

  • Terms of Service provisions

  • Data Processing Addendum requirements

  • Not solely under this Privacy Notice


2. DEFINITIONS AND KEY TERMS


2.1 "Personal Information" DefinedPersonal Information means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, to a particular individual or household, including:Identifiers:

  • Full name, alias, or username

  • Email address and telephone number

  • Postal address and physical location

  • Internet Protocol (IP) address

  • Account credentials and user IDs

  • Social media handles

  • Device identifiers

  • Online identifiers and cookies


Sensitive Personal Information:

  • Voice recordings and voiceprints (biometric identifiers)

  • Precise geolocation data

  • Health and medical information

  • Financial account details

  • Government-issued identification numbers

  • Contents of communications (when we are not the intended recipient)

  • Information about known minors

  • Genetic or biometric data

  • Racial or ethnic origin

  • Religious or philosophical beliefs

  • Union membership

  • Sexual orientation or sex life


Legally Protected Classifications:

  • Race, color, or ethnicity

  • National origin or citizenship status

  • Religion or creed

  • Age or date of birth

  • Sex, gender, or gender identity

  • Marital or familial status

  • Disability status

  • Military or veteran status


Professional and Employment Information:

  • Current and former employment history

  • Job titles and responsibilities

  • Employer information

  • Professional licenses and certifications

  • Work performance data

Educational Information:

  • Educational records and transcripts

  • Degrees and certifications earned

  • Student identification numbers

  • Information protected under FERPA (20 U.S.C. § 1232g, 34 C.F.R. Part 99)

Commercial Information:

  • Products or services purchased, obtained, or considered

  • Purchasing histories and tendencies

  • Consumer preferences and interests

  • Transaction records

  • Payment history (not payment card numbers)

Internet and Network Activity:

  • Browsing history and search queries

  • Website and application interaction data

  • Content consumption patterns

  • Click streams and navigation paths

  • Time spent on pages or features

  • Referral sources

Inferences and Profiles:

  • Profiles reflecting preferences and characteristics

  • Behavioral predictions and tendencies

  • Psychological profiles

  • Attitudes and aptitudes

  • Propensities and predispositions

  • Intelligence assessments

2.2 Information Excluded from Privacy ProtectionsThe following categories are NOT considered Personal Information under most privacy laws:Publicly Available Information:

  • Government records accessible to the public

  • Widely distributed media publications

  • Information the consumer has made publicly available

Aggregated Data:

  • Statistical summaries about groups or categories

  • Data from which individual identities have been removed

  • Information that cannot identify specific individuals

De-identified Data:

  • Information processed to prevent re-identification

  • Data that cannot reasonably be linked back to individuals

  • Information subject to technical safeguards preventing re-identification

We commit not to attempt re-identification of de-identified data except as required by law.


3. INFORMATION COLLECTION AND USE PRACTICES

3.1 Collection PrinciplesPingMunk collects, uses, retains, and discloses Personal Information only:

  • As described in this Privacy Notice

  • As disclosed at the time of collection

  • To the extent reasonably necessary and proportionate for stated purposes

  • With appropriate legal basis (consent, legitimate interest, legal requirement)

3.2 Information Collected from ClientsRegistration and Account Information:When Clients register for Services, we collect:

  • Business name and legal entity information

  • Contact person name and title

  • Business email address and telephone number

  • Physical business address

  • Billing and payment information (processed through third-party payment processors)

  • Account credentials (username and password)

  • Business category and industry classification

Purpose: Account creation, service delivery, authentication, billing, and customer supportProfile and Configuration Data:Clients provide:

  • Employee and team member information

  • Business hours and scheduling preferences

  • Call handling instructions and scripts

  • Frequently asked questions and responses

  • Service customization preferences

  • Integration settings and API credentials

Purpose: Platform customization, AI Assistant training, service optimizationBusiness Intelligence for AI Training:Clients authorize us to collect:

  • Content from Client websites and web properties

  • Online reviews and public feedback

  • Social media presence and content

  • Marketing materials and brand information

  • Product or service descriptions

  • Publicly available business information

Purpose: AI model training, response generation, context understanding, service personalizationIntegrated System Data:When Clients connect third-party systems:

  • Customer relationship management (CRM) data

  • Calendar and scheduling information

  • Email marketing platform data

  • E-commerce transaction records

  • Help desk and support ticket information

  • Analytics and reporting data

Purpose: Enhanced service delivery, automation, synchronization, comprehensive supportClient Responsibility: Clients bear sole responsibility for ensuring they have proper authorization to share Personal Information with PingMunk for all purposes.Transaction and Usage Data:We collect:

  • Services purchased and subscription tier

  • Transaction history and billing records

  • Feature usage and adoption patterns

  • Platform interaction logs

  • Support requests and communications

  • Configuration changes and settings history

Purpose: Service delivery, billing, usage analytics, product improvement, customer supportCommunications with PingMunk:When Clients contact us, we collect:

  • Communication content (emails, chat messages, phone calls)

  • Support ticket information and resolution details

  • Feedback, suggestions, and feature requests

  • Complaint details and resolutions

Purpose: Customer support, relationship management, service improvementMarketing Communications:Clients may opt out of marketing communications while remaining subscribed. However:

  • Service-related announcements continue regardless of marketing preferences

  • Account, billing, and security notifications remain active

  • Product updates and critical information will be sent as needed

Technical Information from Client Use:We may collect:

  • Device information and operating systems

  • Browser types and versions

  • IP addresses and network information

  • Access times and duration

  • Error logs and diagnostic data

Purpose: Technical support, security monitoring, platform optimization, troubleshooting3.3 Information Collected from End UsersImportant Context: End User data is typically collected on behalf of and at the direction of our Clients. PingMunk processes this information as a service provider under Client instructions.Conversation Content and Context:End Users may provide during AI Assistant interactions:

  • Names and contact information

  • Appointment preferences and availability

  • Product or service inquiries

  • Complaint or feedback details

  • Account information or customer numbers

  • Special requests or accommodation needs

  • Any other information voluntarily shared during conversations

How Information is Used:

  • Generate appropriate responses to End User requests

  • Schedule appointments in Client systems

  • Send appointment reminders (email or SMS)

  • Route calls to appropriate departments or personnel

  • Process transactions or bookings

  • Provide requested information about Client's business

Consent Mechanism: End Users consent to this processing by voluntarily providing information to the AI Assistant and continuing the interaction.Voice Biometric Data:The AI Assistant processes voice characteristics to:

  • Understand speech and detect intent

  • Recognize when responses require adjustment

  • Identify situations requiring human intervention

  • Detect emotional tone and urgency

  • Improve speech recognition accuracy

  • Enhance natural conversation flow

This processing occurs in real-time during calls and may involve temporary storage of voice data for processing purposes.SMS and Text Messaging:When Clients enable SMS features and End Users consent:

  • Mobile telephone numbers collected

  • SMS message content processed

  • Conversation history maintained

  • Opt-in and opt-out preferences recorded

SMS Use Cases:

  • Appointment confirmations and reminders

  • Links to scheduling platforms or websites

  • Business location directions

  • Promotional offers (only with explicit opt-in)

  • Continued conversation from phone call

Important:

  • SMS messages sent only with End User consent

  • End Users can opt out by replying STOP or UNSUBSCRIBE

  • Consenting to receive one SMS message does NOT add End User to marketing campaigns

  • Client privacy practices govern SMS communications

Appointment and Scheduling Data:When End Users schedule appointments:

  • Preferred dates and times

  • Service or appointment type

  • Duration preferences

  • Special requirements or notes

  • Contact information for reminders

This information integrates with Client's scheduling systems and CRM platforms.3.4 Call Recordings and TranscriptsRecording Practices:All AI Assistant interactions are recorded, generating:

  • Audio recordings of complete conversations

  • Text transcripts with timestamps

  • Metadata about call duration, time, and routing

  • Call quality metrics and performance data

Purposes for Recording:

  • Quality assurance and performance monitoring

  • Service improvement and AI model training

  • Client business records and documentation

  • Compliance with Client policies and legal requirements

  • Dispute resolution and verification

  • Training data for speech recognition enhancement

  • Analytics and statistical analysis

Functional Necessity:Recordings and transcripts are essential for:

  • Executing End User requests (scheduling appointments, providing information)

  • Sending automated reminders through Client systems

  • Generating accurate service records

  • Enabling Client review of interactions

  • Supporting customer service excellence

Notice and Consent Requirements:Clients may configure the AI Assistant to:

  • Provide audible notification of recording at call beginning

  • Request explicit consent before proceeding

  • Offer opt-out by ending call

End User Consent: Continuing the call after recording notification constitutes consent to recording.Client Responsibility:

  • Clients bear sole responsibility for compliance with applicable recording laws

  • Federal, state, and local laws vary regarding consent requirements (one-party vs. all-party)

  • Clients must ensure proper notice and consent mechanisms

  • PingMunk provides tools; Clients ensure legal compliance

Data Ownership: Call recordings and transcripts belong to the Client, not PingMunk. Retention periods and usage determined by Client privacy practices.De-identified Usage:We may create de-identified datasets from recordings to:

  • Understand conversation patterns and user behaviors

  • Train and improve AI models and algorithms

  • Develop new features and capabilities

  • Conduct research and analytics

  • Benchmark performance and quality

3.5 Real-Time Access to ConversationsCRITICAL NOTICE: End User interactions with AI Assistants may be accessible to PingMunk personnel and third-party service providers simultaneously and in real-time for:

  • Quality monitoring and assurance

  • Technical support and troubleshooting

  • Security monitoring and fraud prevention

  • Performance optimization

  • Emergency intervention when needed

End User Consent: By interacting with an AI Assistant, End Users consent to this real-time access by PingMunk and our authorized service providers.Opt-Out: End Users who do not consent to real-time monitoring should not interact with the AI Assistant.3.6 Payment ProcessingPingMunk Does NOT Process Payments:Critical clarifications:

  • PingMunk is NOT a payment processor, bank, or financial institution

  • We NEVER collect, store, or process payment card information

  • We do NOT handle, transmit, or receive funds

  • All payment processing occurs through PCI-DSS compliant third-party processors

Our Role:

  • Facilitate connection between Clients and payment processors

  • Enable payment collection feature within Platform

  • Provide interface for payment-related workflows

Payment Processor Responsibility:

  • Third-party payment processors collect payment information

  • Payment processors store and secure payment data

  • Payment processor terms and privacy policies govern payment data

  • Clients and payment processors have direct relationship

For Subscription Fees:

  • Client subscription payments processed by our payment processor

  • Payment processor's terms and privacy notice apply

  • We receive confirmation of payment, not payment details

For End User Payments:

  • When Clients collect payments from End Users through Platform

  • Client's payment processor handles all payment information

  • End User should review payment processor's privacy practices

3.7 Children's Privacy ProtectionServices Not Designed for Children:Our Services are designed exclusively for adult business communications, not for children.Client Responsibilities:

  • Clients must prevent children from providing Personal Information through Services

  • Clients must restrict AI Assistant access to individuals aged 16 and older

  • Clients using Services to collect children's information do so under their own privacy practices

PingMunk's Commitment:If we discover a child under 16 has provided Personal Information:

  • We will promptly delete the information from our systems

  • We will take reasonable steps to prevent future collection

  • We will notify the Client of the incident

Reporting: If you believe we have collected information from a child under 16 or become aware of unauthorized submissions, contact [email protected] immediately.3.8 Communications with PingMunkProspective Client Inquiries:When you request information about Services:

  • We collect contact information needed to respond (name, email, phone, company)

  • We use information to provide requested materials

  • We may follow up regarding your interest in Services

  • Information may be used for marketing communications (with opt-out available)

Legal Basis: Consent provided when submitting inquiryCustomer Support:When current or former Clients contact support:

  • We collect issue description and relevant details

  • We maintain support ticket history

  • We may record support calls for quality assurance

  • We retain communications for service improvement

Feedback and Suggestions:When you provide feedback:

  • We collect and analyze suggestions for product improvement

  • Feedback may influence feature development

  • We may contact you for clarification or follow-up

3.9 Automated Data CollectionWebsite and Application Usage:We automatically collect technical information during Platform use:Device Information:

  • IP address and geographic location (city/region level)

  • Operating system and version

  • Browser type and version

  • Device type and model

  • Mobile network information (if applicable)

  • Caller ID information (for telephone interactions)

  • Screen resolution and display characteristics

Usage Analytics:

  • Pages viewed and features accessed

  • Time spent on pages and in Platform

  • Click paths and navigation patterns

  • Search queries entered

  • Content interactions and engagement

  • Feature adoption and usage frequency

  • Session duration and frequency

Stored Information:

  • Cookies and similar tracking technologies

  • Local storage data

  • Cache and temporary files

  • Metadata and log files

Cookies and Tracking Technologies:We use various types of cookies:Essential Cookies:

  • Required for Platform functionality

  • Enable core features and security

  • Cannot be disabled without affecting service

Analytics Cookies:

  • Understand how visitors use Website and Platform

  • Measure performance and identify improvement opportunities

  • Track aggregated usage patterns

Marketing Cookies:

  • Deliver targeted advertising

  • Measure campaign effectiveness

  • Personalize marketing content across platforms

  • Retarget visitors who showed interest

Cookie Control:

  • Adjust browser settings to block or limit cookies

  • Install third-party privacy plugins

  • Use Platform cookie preference settings

  • Note: Blocking essential cookies may impair functionality

Legal Basis: Legitimate interest in providing and improving Services, with consent for non-essential cookies where required3.10 Additional Use PurposesBeyond specific purposes described above, we may use Personal Information to:Service Delivery and Administration:

  • Provide, maintain, and improve Services

  • Process transactions and fulfill requests

  • Manage accounts and subscriptions

  • Provide customer support

  • Communicate about Services and accounts

Development and Innovation:

  • Develop new products, services, and features

  • Conduct research and analysis

  • Test and optimize Platform performance

  • Enhance user experience

Security and Fraud Prevention:

  • Prevent fraud, abuse, and illegal activity

  • Protect security of systems, networks, and data

  • Detect and investigate policy violations

  • Enforce Terms of Service and agreements

  • Respond to security incidents

Legal Compliance:

  • Comply with legal obligations and requirements

  • Respond to legal process and government requests

  • Exercise and defend legal rights

  • Protect rights and safety of PingMunk, users, and public

Business Operations:

  • Support business transitions (mergers, acquisitions, sales)

  • Manage corporate governance

  • Conduct audits and assessments

  • Maintain business records


4. INFORMATION SHARING AND DISCLOSURE

4.1 Disclosure PrinciplesPingMunk discloses Personal Information only:

  • As described in this Privacy Notice

  • With your permission or at your direction

  • To accomplish legitimate business purposes

  • As required or permitted by law

Disclosure Recipients (Last 12 Months):We have disclosed Personal Information from all collection categories to the following recipient types:

4.2 Disclosure to ClientsPrimary Disclosure:Personal Information collected on behalf of Clients belongs to those Clients and is made available to them for processing according to their own privacy practices.This includes:

  • End User conversation content and data

  • Call recordings and transcripts

  • Appointment and scheduling information

  • Any Personal Information collected through AI Assistant interactions

PingMunk's Limited Role:

  • We process this data as a service provider under Client direction

  • We do not control Client privacy practices

  • We are not responsible for Client use or disclosure of data

  • Clients determine retention, use, and further disclosure

End User Inquiries: End Users should contact the Client they called for privacy questions, not PingMunk.4.3 Service Providers and VendorsWe engage service providers to support our operations, including:Infrastructure and Hosting:

  • Cloud storage and computing providers

  • Content delivery networks

  • Backup and disaster recovery services

Analytics and Performance:

  • Website and application analytics platforms

  • Performance monitoring tools

  • A/B testing and optimization services

Communications:

  • Email delivery services

  • SMS messaging platforms

  • Customer support ticketing systems

Marketing and Advertising:

  • Marketing automation platforms

  • Advertising networks and exchanges

  • Social media advertising tools

Security and Compliance:

  • Security monitoring and threat detection

  • Compliance auditing services

  • Identity verification providers

Professional Services:

  • Legal counsel and advisors

  • Accounting and financial services

  • Consulting and advisory services

Service Provider Obligations:All service providers must:

  • Maintain contractual commitments to protect Personal Information

  • Use data only for specified purposes

  • Implement commercially reasonable security measures

  • Comply with applicable privacy laws

  • Return or delete data upon request or contract termination

4.4 Legal and Regulatory DisclosuresWe may disclose Personal Information to:Law Enforcement and Government:

  • In response to valid legal process (subpoenas, court orders, warrants)

  • To comply with applicable laws and regulations

  • To cooperate with law enforcement investigations

  • To respond to national security requests

Legal Proceedings:

  • In connection with litigation or dispute resolution

  • To establish, exercise, or defend legal claims

  • To protect legal rights of PingMunk or others

Safety and Protection:

  • To prevent or investigate fraud or illegal activity

  • To protect safety of individuals

  • To prevent harm to persons or property

  • To enforce our Terms of Service and policies

4.5 Business TransfersPersonal Information may be disclosed in connection with:Corporate Transactions:

  • Mergers or acquisitions

  • Sale of business assets or divisions

  • Corporate reorganization or restructuring

  • Bankruptcy or insolvency proceedings

In such events:

  • Acquiring party assumes privacy obligations

  • Personal Information transferred as business asset

  • Privacy Notice continues to govern unless updated

  • Notice provided of material privacy practice changes

4.6 With Your ConsentWe may disclose Personal Information:

  • To third parties you authorize or direct

  • For purposes you specifically consent to

  • In ways you explicitly approve

4.7 Important ClarificationsWe Do NOT Sell Personal Information:PingMunk does not and will not:

  • Sell Personal Information to third parties for monetary consideration

  • Exchange Personal Information for other valuable consideration

  • Disclose End User data to third parties for payment

  • Monetize Personal Information directly

We Do NOT Share for Cross-Context Marketing:PingMunk does not:

  • Share Personal Information with third parties for cross-contextual behavioral advertising

  • Enable third-party targeted advertising using our user data

  • Participate in advertising networks that use Personal Information for profiling

Clients may independently choose to sell or share End User data under their own privacy practices. Review Client privacy notices for their data handling.4.8 Aggregated and De-identified DataUnrestricted Use:We may:

  • De-identify or aggregate any Personal Information collected through Services

  • Use such de-identified or aggregated data without restriction

  • Disclose de-identified or aggregated data to third parties for any purpose

Permitted Uses:

  • Train and improve AI language models

  • Develop new features and capabilities

  • Conduct research and publish findings

  • Benchmark performance and industry trends

  • Create statistical reports and analyses

Re-identification Prohibition:We commit not to attempt re-identification of de-identified data except as required by law. De-identified and aggregated data is not Personal Information and does not carry privacy restrictions.


5. DATA RETENTION PRACTICES

5.1 Retention PrinciplesWe retain Personal Information only as long as:

  • Necessary for purposes for which it was collected

  • Required by legal, regulatory, or contractual obligations

  • Needed for legitimate business purposes

  • Useful for establishing, exercising, or defending legal claims

5.2 End User Data Processed for ClientsClient-Directed Retention:As a service provider to Clients:

  • We retain End User data until Client deletes it or instructs deletion

  • Retention periods determined by Client business practices

  • Clients control data lifecycle and retention schedules

  • We process deletion requests from Clients promptly

End Users should contact the Client for information about retention practices and deletion requests.5.3 Client Account DataActive Accounts:

  • Account information retained while subscription remains active

  • Includes registration data, configuration settings, transaction history

  • Updated as Clients modify account information

Post-Cancellation:

  • Account data deleted thirty (30) days after subscription cancellation

  • Thirty-day window allows data retrieval and transition

  • After deletion period, recovery is not possible

Exceptions:

  • Billing records retained per financial regulations

  • Information subject to legal holds preserved

  • Data needed for dispute resolution maintained

5.4 Marketing and Prospective Client DataActive Engagement:

  • Marketing list data retained while engagement continues

  • Prospective Client information kept until opt-out or business purpose ends

Inactive Contacts:

  • Information from non-clients with no engagement for two (2) years removed from marketing lists

  • Automatic list cleaning and data hygiene performed regularly

Opt-Out Immediately Effective:

  • Removal from marketing communications upon request

  • Suppression list maintained to prevent re-addition

5.5 Technical and Log DataSystem Logs:

  • Error logs and diagnostic data retained for troubleshooting

  • Security logs maintained per security policy

  • Access logs kept for audit and compliance purposes

Analytics Data:

  • Aggregated analytics retained indefinitely

  • Individual-level analytics subject to standard retention periods

5.6 Legal and Regulatory RetentionWe may retain Personal Information beyond standard periods when:Legal Requirements:

  • Tax laws require financial record retention (typically 7 years)

  • Employment laws mandate personnel record retention

  • Regulatory compliance requires specific retention periods

Legal Proceedings:

  • Litigation hold requires preservation

  • Investigation necessitates data retention

  • Dispute resolution demands information availability

Legitimate Business Purposes:

  • Fraud prevention and detection

  • Abuse prevention

  • Account security and recovery

5.7 Deletion and DisposalWhen retention period ends:Preferred Methods:

  • Permanent deletion from active systems

  • De-identification removing linkability to individuals

  • Anonymization eliminating individual identification

Backup Systems:

  • Backups overwritten per normal rotation schedule

  • Isolated from further processing until permanent deletion

  • Securely stored until backup cycle completes

Where Immediate Deletion Infeasible:

  • Data securely stored and isolated

  • Prevented from further processing

  • Deleted when technically feasible

Secure Disposal:

  • Industry-standard deletion methods employed

  • Data destruction verified when critical

  • Third-party service providers follow same standards


6. THIRD-PARTY SERVICES AND LINKS

6.1 Third-Party IntegrationPlatform may integrate with or link to:

  • Third-party software applications

  • External websites and services

  • Social media platforms

  • Partner services and tools

6.2 PingMunk's Limited ControlWe have NO control over:

  • Third-party privacy practices

  • Third-party security measures

  • Third-party data collection or use

  • Third-party terms and conditions

6.3 Your ResponsibilitiesWhen using third-party services:

  • Review third-party privacy notices before use

  • Understand what information will be shared

  • Make informed decisions about data disclosure

  • Exercise caution with Personal Information

  • Accept third-party terms independently

6.4 Third-Party LiabilityPingMunk is NOT responsible for:

  • Third-party data practices or security

  • Losses resulting from third-party services

  • Third-party compliance with privacy laws

  • Accuracy of third-party content or services

Links and integrations do not constitute endorsement of third parties or their practices.


7. PRIVACY CONTROLS AND YOUR CHOICES

7.1 Directing Inquiries AppropriatelyFor End Users: If you interacted with an AI Assistant provided by one of our Clients:

  • Contact the Client directly for all privacy requests

  • Client controls your data and privacy rights

  • PingMunk processes data on Client's behalf under their direction

For Clients and Website Visitors: Use the options below to exercise privacy controls with PingMunk.7.2 Privacy Rights RequestsHow to Submit:

  • Email: [email protected]

  • Subject: Privacy Rights Request

  • Include: Name, contact information, specific request, account details (if applicable)

Types of Requests:

  • Access to Personal Information

  • Correction or update of information

  • Deletion of Personal Information

  • Restriction of processing

  • Objection to processing

  • Data portability

  • Withdrawal of consent

  • Complaint or concern submission

Response Timeline: We respond to requests as required by applicable law, typically within 30-45 days depending on jurisdiction and request complexity.7.3 Client Account ControlsSelf-Service Options:Clients can access account dashboard to:

  • Update contact information and business details

  • Modify account settings and preferences

  • Adjust privacy and communication settings

  • Review and download data

  • Delete certain information

Contact for Assistance: If unable to make desired changes through account:

  • Email [email protected]

  • Request assistance with specific changes

  • Revoke previously granted consents

7.4 Email Communication PreferencesService Emails (Required):

  • Account notifications and updates

  • Billing and payment information

  • Security alerts and notices

  • Critical service announcements

  • Cannot opt out while maintaining active subscription

Marketing Emails (Optional):

  • Promotional content and offers

  • Product updates and news

  • Educational content and resources

  • Event invitations

Opt-Out Methods:

  • Click unsubscribe link in email footer

  • Adjust preferences in account settings

  • Email [email protected] with opt-out request

Effect of Opt-Out:

  • Marketing emails cease

  • Service emails continue

  • Opt-out processed within 10 business days

7.5 Text Message PreferencesService Messages: If you provide wireless number:

  • Consent to receiving service-related texts

  • Account alerts and notifications

  • Service disruption notices

Marketing Messages:

  • Only sent with explicit opt-in

  • Separate consent from service messages

  • Frequency depends on services used

Client-Directed Messages: End Users may receive texts from PingMunk on behalf of Clients:

  • Governed by Client privacy practices

  • Sent per Client's instructions and your consent with Client

  • Contact Client with questions or opt-out requests

Opt-Out Process:

  • Reply STOP or UNSUBSCRIBE to any text message

  • Processing immediate upon receipt

  • Confirmation message sent

Cost Notice:

  • Standard messaging and data rates apply

  • Contact wireless carrier for rate information

  • Responsibility for carrier charges

7.6 Cookie and Tracking ControlsBrowser Settings:

  • Configure browser to block or limit cookies

  • Adjust cookie acceptance preferences

  • Enable private or incognito browsing

Website Cookie Preferences:

  • Use cookie preference center on Website

  • Select categories to allow or block

  • Save preferences for future visits

Third-Party Tools:

  • Install privacy-focused browser extensions

  • Use ad blockers and tracking prevention tools

  • Enable Do Not Track signals (note limitations below)

Effect of Blocking:

  • Essential cookies required for functionality

  • Blocking may impair Platform operation

  • Marketing and analytics cookies optional

7.7 Device Settings and PermissionsMobile Applications:Control data collection through device settings:

  • Location services permissions

  • Camera and microphone access

  • Contact list access

  • Calendar access

  • Notification preferences

Revoke Permissions:

  • Access device settings

  • Manage app permissions

  • Disable specific data access

7.8 Do Not Track SignalsCurrent Status: Our systems do NOT currently recognize or respond to browser "Do Not Track" signals.Alternative Controls:

  • Use cookie preferences described above

  • Adjust browser privacy settings

  • Employ third-party privacy tools


8. PRIVACY RIGHTS BY JURISDICTION

8.1 Important Notice for End UsersEnd Users must contact the Client they called to exercise privacy rights related to AI Assistant conversations.The information in this section is provided to End Users as courtesy only. The Client you contacted is responsible for:

  • Processing your Personal Information

  • Supporting exercise of your privacy rights

  • Providing required notices and disclosures

  • Responding to privacy requests

8.2 United States Privacy RightsApplicable Laws:Consumer privacy governed by:

  • Federal laws covering specific industries and data types

  • State comprehensive privacy laws in: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Nevada, Oregon, Tennessee, Texas, Utah, Virginia

  • Additional state-specific protections

Rights Available (Varies by State):Right to Know:

  • Receive information about Personal Information collection and use

  • This Privacy Notice provides required disclosures

  • Additional notices may be provided for specific processing

  • Clients separately responsible for End User right to know

Right to Reasonable Expectations:

  • Expect responsible Personal Information handling

  • Collection, use, and disclosure only for stated purposes

  • Changes communicated with consent requested when required

  • Ability to withdraw consent with reasonable notice (contact [email protected])

  • End Users contact Client to change or withdraw consent

Right to Accuracy and Correction:

  • Correct inaccurate Personal Information

  • Update outdated information in your account

  • Request corrections via [email protected]

  • Note: PingMunk relies on Clients for accuracy of Client-controlled data including AI Assistant collected information

  • End Users contact Client to correct information collected through AI Assistant

Right to Access:

  • Obtain copy of Personal Information held about you

  • Receive details about processing purposes and categories

  • Learn about third parties receiving your information

  • Requests subject to legal limitations on scope and frequency

  • End Users contact Client for AI Assistant data access

Right to Deletion:

  • Request deletion of Personal Information

  • Subject to legal, contractual, and business exceptions

  • We balance interests and obligations against deletion requests

  • Deletion may not be absolute or immediate

  • End Users contact Client to request deletion of AI Assistant data

Right to Data Portability:

  • Receive Personal Information in structured, machine-readable format

  • Ability to transmit to another organization

  • Available where legally required

No Sale of Personal Information:

  • PingMunk does not sell Personal Information

  • PingMunk does not share for cross-contextual behavioral advertising

  • Clients may independently sell or share under their practices

  • Review Client privacy notice for opt-out methods

Limited Use of Sensitive Personal Information:

  • PingMunk does not use sensitive data to infer characteristics

  • Clients may collect sensitive information through AI Assistant

  • Review Client privacy notice for details and opt-out

Right to Non-Discrimination:

  • No denial of goods or services for exercising rights

  • No different pricing or rates

  • No different quality of goods or services

  • No retaliation against employees or contractors

  • No suggestion of disadvantageous treatment

  • Exceptions permitted by law

Right to InformationDisclosure: Request details about:

  • Categories of Personal Information collected

  • Sources of Personal Information

  • Business purposes for collection and disclosure

  • Categories of third parties receiving information

  • If selling or sharing: lists of recipients and categories

Right Against Automated Decision-Making:

  • AI Assistants use generative AI that may qualify as automated decision-making

  • Clients responsible for this processing

  • End Users can request human intervention through Services or discontinue call

Right to Restrict Processing:

  • Request processing restrictions under certain circumstances:

    • Data is inaccurate

    • Processing is unlawful

    • We no longer need the data

    • You object to processing

  • May be limited to sensitive data or certain processing purposes

  • End Users contact Client regarding AI Assistant data

Right to Object:

  • Object to specific processing activities under certain circumstances

  • Request limitations on Personal Information processing

  • Available where required by law

California Shine the Light:

  • California residents may request disclosure about Personal Information sharing with affiliates or third parties for marketing

  • Annual requests permitted

Health Data Rights:

  • PingMunk does not collect health data

  • Clients may collect health data through AI Assistant

  • Some laws provide rights including:

    • Confirmation of collection, sharing, or sale with access

    • List of third parties receiving health data

    • Method to withdraw consent

    • Right to deletion

8.3 Canadian Privacy RightsApplicable Laws:

  • Personal Information Protection and Electronic Documents Act (PIPEDA)

  • Provincial privacy laws (where applicable)

Rights Under Canadian Law:Right to Know:

  • Understand why Personal Information is collected, used, and disclosed

  • This Privacy Notice explains PingMunk practices

  • Additional notices may be provided

  • Clients separately responsible for End User notices

Right to Reasonable Expectations:

  • Expect responsible collection, use, and disclosure

  • Processing only for purposes to which you consented

  • Consent may be express or implied

  • Withdraw consent with reasonable notice ([email protected])

  • End Users contact Client to withdraw consent

Right to Accuracy:

  • PingMunk takes reasonable steps to ensure accuracy for own purposes

  • Cannot guarantee accuracy of Client-controlled data

  • Clients responsible for accuracy of data processed on their behalf

  • End Users contact Client regarding AI Assistant data accuracy

Right to Access:

  • Request access to Personal Information under our control

  • Receive information about how data is used

  • Learn about third parties receiving information

  • Response within 30 days or written notice if more time needed

  • Refusals documented with reasons and further steps

Access Limitations: Where legally limited or risks third-party privacy:

  • May not provide some or all requested information

  • Written notification of refusal

  • Documentation of reasons

  • Outline of available next steps

8.4 International Access NoticeGeographic Scope: Services currently offered ONLY in United States and Canada.Prohibition on International Use:

  • Services not marketed for use outside US/Canada

  • Clients prohibited from making Services available internationally

  • End Users outside US/Canada should not use Services

Future Expansion: If Services expand to additional markets:

  • Privacy Notice updated with required disclosures

  • Jurisdiction-specific rights and notices added

  • Compliance with local privacy laws implemented


9. INTERNATIONAL DATA TRANSFERS

9.1 United States OperationPingMunk is:

  • United States-based company

  • Using US technical infrastructure

  • Subject to US legal jurisdiction

  • Governed by US privacy laws

9.2 Intended Geographic ScopeServices marketed exclusively for:

  • United States-based Clients and End Users

  • Canadian-based Clients and End Users

Clients are contractually prohibited from making Services available to End Users in other jurisdictions.9.3 Access from Other JurisdictionsWarnings for International Users:If you access Services from outside US/Canada:

  • Access at your own initiative and risk

  • Personal Information transferred to United States

  • US laws govern data processing and storage

  • Legal protections may differ from your home country

  • Government access may occur under US law

Data Transfer:When information transferred internationally:

  • Storage and processing occur in United States

  • Laws protecting Personal Information may differ

  • Rights and remedies may vary from home jurisdiction

  • US government authorities may access data under applicable law

Consent to Transfer:By providing Personal Information or allowing its collection:

  • You consent to international transfer

  • You accept processing in United States

  • You acknowledge different legal protections may apply

9.4 Client ResponsibilityEach Client responsible for:

  • Determining whether Services comply with applicable laws in their jurisdiction

  • Ensuring lawful data transfers occur

  • Providing required notices to End Users about international transfers

  • Obtaining necessary consents for cross-border data flows

9.5 No Warranty of AppropriatenessWe do NOT warrant that:

  • Services are appropriate outside United States

  • Services are authorized in all jurisdictions

  • Use complies with local laws everywhere

  • Legal protections are equivalent across jurisdictions


10. DATA SECURITY MEASURES

10.1 Security CommitmentPingMunk implements and maintains reasonable security measures appropriate to:

  • Volume and scope of Personal Information processed

  • Nature and sensitivity of data handled

  • Risks presented by processing activities

  • Industry standards and best practices

10.2 Technical Security MeasuresEncryption:

  • Data encrypted in transit using TLS/SSL protocols

  • Data encrypted at rest using AWS AES-256 encryption

  • Encryption keys securely managed and rotated

  • End-to-end encryption for sensitive transmissions

Infrastructure Security:

  • Cloud environment hosted on secure AWS infrastructure

  • Multi-layered network security

  • Firewalls and intrusion detection systems

  • Regular security patches and updates

  • Access controls and authentication requirements

Data Isolation:

  • Client data logically separated

  • Multi-tenant architecture with secure boundaries

  • Database access restrictions

  • Application-level data segregation

10.3 Organizational Security MeasuresPersonnel:

  • Security training required for all personnel

  • Background checks for employees with data access

  • Confidentiality agreements and obligations

  • Role-based access controls

  • Least privilege access principles

Policies and Procedures:

  • Information security policies maintained

  • Incident response procedures established

  • Data handling protocols documented

  • Regular policy reviews and updates

  • Compliance monitoring and auditing

Vendor Management:

  • Service providers contractually bound to security standards

  • Vendor security assessments performed

  • Ongoing vendor compliance monitoring

  • Data processing agreements in place

10.4 Operational SecuritySystem Monitoring:

  • Continuous security monitoring

  • Automated threat detection

  • Log analysis and review

  • Anomaly detection and alerting

Backup and Recovery:

  • Regular data backups performed

  • Disaster recovery procedures established

  • Business continuity planning

  • Backup testing and verification

Audit and Assessment:

  • Regular security audits conducted

  • Vulnerability assessments performed

  • Penetration testing when appropriate

  • Third-party security reviews

10.5 Incident ResponsePreparation:

  • Incident response plan maintained

  • Response team identified and trained

  • Communication protocols established

  • Escalation procedures documented

Detection and Response:

  • Monitoring for security incidents

  • Rapid incident identification

  • Containment and remediation procedures

  • Root cause analysis and remediation

Notification:

  • Incident notification per customer agreements

  • Compliance with applicable breach notification laws

  • Timely communication to affected parties

  • Cooperation with regulatory authorities

10.6 Client ResponsibilitiesClients are responsible for:

  • Securing Personal Information on their own systems

  • Implementing appropriate access controls

  • Training their personnel on data security

  • Monitoring their use of Platform for security

  • Reporting suspected security incidents promptly

  • Maintaining security of integration credentials

10.7 Limitations and DisclaimersNo Absolute Security:

  • No system is completely secure

  • Internet transmission inherently involves risk

  • Unauthorized access possible despite safeguards

  • Security breaches may occur

Transmission Risk:

  • Data transmissions over Internet at sender's risk

  • We cannot guarantee transmission security

  • Users responsible for secure transmission methods

  • Consider encryption for sensitive communications

User Responsibility:

  • Protect account credentials and passwords

  • Use strong, unique passwords

  • Enable multi-factor authentication when available

  • Maintain device security

  • Report suspicious activity promptly


11. CHANGES TO THIS PRIVACY NOTICE


11.1 Right to ModifyWe reserve the right to:

  • Update this Privacy Notice at any time

  • Modify privacy practices as needed

  • Respond to legal or regulatory changes

  • Improve transparency and clarity

11.2 Notice of Material ChangesFor material changes affecting privacy practices:

  • Updated Privacy Notice posted with new effective date

  • Email notification sent to email address on file

  • In-Platform notification for active users

  • Reasonable advance notice provided when feasible

11.3 Consent to ChangesObtaining Consent:

  • Where required by law, we will seek your consent to material changes

  • Consent mechanisms provided as appropriate

  • Opportunity to review changes before they take effect

Implied Consent:

  • Continued use of Services after effective date constitutes acceptance

  • Review updated Privacy Notice before continuing use

  • Discontinue use if you disagree with changes

11.4 Reviewing UpdatesYour Responsibility:

  • Periodically review Privacy Notice for changes

  • Check "Last Updated" date at top of Notice

  • Understand how changes affect your privacy

  • Contact us with questions about updates

11.5 Historical VersionsUpon request, we may provide:

  • Information about material changes made

  • Summary of key modifications

  • Effective dates of previous versions


12. CONTACT INFORMATION AND COMPLAINTS

12.1 Privacy Questions and RequestsPrimary Contact:

  • Email: [email protected]

  • Subject: Privacy Inquiry

  • Include: Detailed description of question or request

Response Timeline:

  • Acknowledgment within 2-3 business days

  • Response within timeframe required by applicable law

  • Complex requests may require additional time

12.2 Privacy Rights ExerciseTo exercise privacy rights:

  • Email [email protected] with specific request

  • Provide information needed to verify identity

  • Specify desired action (access, deletion, correction, etc.)

  • Include account details if applicable

12.3 Complaints and ConcernsFiling Complaints:If you believe we have violated your privacy rights:

  • Contact [email protected] with detailed complaint

  • Provide specific information about the concern

  • Allow reasonable time for investigation and response

Regulatory Complaints:You also have the right to file complaints with:

  • State attorney general offices

  • Federal Trade Commission (FTC)

  • Canadian Privacy Commissioner (for Canadian residents)

  • Provincial privacy commissioners (for Canadian residents)

  • Other applicable regulatory authorities

We will cooperate with regulatory investigations and work to resolve complaints.12.4 Company InformationLegal Entity: MQL Media, Inc. doing business as PingMunkFor Privacy Matters: [email protected]For General Inquiries: Visit PingMunk.com


13. ADDITIONAL PROVISIONS

13.1 California Privacy Rights AddendumCalifornia Consumer Privacy Act (CCPA) Disclosures:For California residents, in the preceding 12 months:Categories Collected:

  • Identifiers

  • Commercial information

  • Internet/network activity

  • Sensitive personal information (voice recordings)

  • Inferences

  • Professional information (from Clients)

Sources:

  • Directly from you

  • Automatically through Services

  • From Clients (for End User data)

  • From third-party integrations

  • From public sources

Business Purposes:

  • Service delivery and fulfillment

  • Customer support

  • Platform improvement and development

  • Security and fraud prevention

  • Legal compliance

  • Marketing and advertising

Categories Disclosed:

  • All categories disclosed to service providers

  • Client data disclosed to Clients

  • Information disclosed per legal obligations

Sale and Sharing:

  • We do NOT sell Personal Information

  • We do NOT share for cross-contextual advertising

Sensitive Personal Information:

  • Voice recordings collected (biometric identifiers)

  • Used only for AI processing and service delivery

  • Not used to infer characteristics

Retention:

  • As described in Section 5 (Data Retention)

California Rights:

  • All rights described in Section 8.2 apply

  • Authorized agents may submit requests on your behalf

  • Requests verified before fulfillment

13.2 Other State-Specific DisclosuresResidents of Other States with Privacy Laws:If your state has enacted comprehensive privacy legislation:

  • Rights described in Section 8.2 generally apply

  • Specific rights may vary by state law

  • Contact [email protected] for state-specific information

13.3 Nevada Privacy RightsNevada residents may opt out of sale of Personal Information. While we do not sell Personal Information, Nevada residents may submit opt-out requests to [email protected].13.4 Children's Online Privacy Protection Act (COPPA)Our Services are not directed to children under 13. We do not knowingly collect Personal Information from children under 13. If we discover such collection, we will promptly delete the information.13.5 AccessibilityWe are committed to ensuring this Privacy Notice is accessible to individuals with disabilities. If you experience difficulty accessing this Notice, contact [email protected] for assistance.13.6 LanguageThis Privacy Notice is provided in English. Translations may be provided for convenience, but the English version controls in case of conflicts.


ACKNOWLEDGMENT

By using our Services, you acknowledge that you have read, understood, and agree to this Privacy Notice and our information handling practices as described herein.Effective Date: January 8, 2026Owner and Operator: MQL Media, Inc. dba PingMunkContact: [email protected]