Mumbler Privacy Policy

Last update date: March 24, 2024

Mumbler is a platform for hosting, distributing, and monetizing audio content: podcasts, audiobooks, audio courses, etc. 

This Statement aims to inform you about how we collect, store, process, and protect your personal data when you use the Mumbler website and its services, and what your rights are in this regard.

We guarantee that as a data subject, you will always have control over your personal information, and we will never misuse or illegitimately exploit your personal data. 

This Privacy Policy is drafted in accordance with the principles and standards approved by Regulation (EU) 2016/679 of April 27, known as the General Data Protection Regulation or "GDPR".

1. IDENTITY AND CONTACT OF THE CONTROLLER

a-.Controller Identification: MUMBLER AUDIO S.L., hereinafter "MUMBLER".

b-.Tax ID: B05329073

c-.Address: Calle La Llotja (ED. COWORKING VIT) S/N - 08500 Vic (Barcelona) - Spain

d-.Email Address: hello@mumbler.io

2-.PERSONAL DATA COLLECTION

When you use our website or MUMBLER services, we may collect your personal data in one of the following ways:

a-. When you create an account.

We collect basic information, such as first and last name, email address, username, password, country of residence. 

You may also sign up using a Facebook or Google account. We will ask permission to access basic information from your Facebook or Google account, such as your name, email, and profile picture. You can choose to stop sharing that information with us at any time by going to Facebook or Google to remove Mumbler's access to that account and your ability to log in.

You also have the option to add more information to your public profile, such as a location, social media links and an about section, which we store along with any comments or messages you submit on MUMBLER.

b-. When you become a Listener

A listener is someone who joins the MUMBLER membership platform to pay for podcaster membership content. As a listener, you must provide your payment information to our payment processors. You can view the privacy policy of these payment processors on the Stripe site. At this time, MUMBLER does not receive your full card number. Payment processors provide us with a token that represents your account, the expiration date of your card, the type of card, and the last four digits of your card number. If you are asked to provide your name and email address to the payment processor, then you will also provide that information to us.

We collect and process information about the podcasters you are subscribed to.

c-. When you become a Podcaster

A podcaster is someone who creates and provides content for their listeners through the MUMBLER membership platform. To become a podcaster, you must create a page describing your membership podcast. To receive payments, you must create an account. We may also request your bank account information to process payments. You must also provide us with additional information for tax purposes. Depending on your location, you may need to fill out a form with these details: First and last name, language, country of residence, tax identification number, bank account details.

d-. Information collected automatically

We collect information automatically as you navigate through the site or through our third-party analytics providers. We may process usage information, such as the type of device you use to access MUMBLER, operating system, browser type, IP address and device ID, the pages you visit, links you click, referring sites, user interactions or the search terms used. 

e-. Blogs

We may process your email address, comments and profile information from our blog sites to better understand your interests and improve our services.

f-. Cookies

We use cookies for technical purposes (to enable the MUMBLER website and services to function) and analytical purposes (to help us understand how you use MUMBLER). For more information about how MUMBLER uses cookies, you can consult our Cookies Policy.

3-. PURPOSES OF THE PROCESSING OF YOUR DATA 

We will use your personal data for the following purposes:

a-. Manage information requests and contact with our users.

b-. Manage the provision of services contracted with MUMBLER.

c-. Analysis of use and navigation of the website and MUMBLER services by our users.

d-. Facilitate the correct functioning and security of the website and services.

4-. LEGAL BASIS: LEGITIMATION OF THE TREATMENT

In order to process your personal data, we use one of the following bases of legitimacy:

  1. a) Legitimate interests of the controller (article 6.1 letter f of the GDPR)

This legal basis of ‚Äúlegitimate interests‚ÄĚ means that we may process your personal data where we have a real, present and legitimate interest in doing so, and such processing does not prejudice your rights and interests. It is even likely that our legitimate interests and your own are aligned in some cases.

Therefore, we will use this legal basis to process the personal data that you provide us in order to contact us through the functionalities offered by this website (for example, via email, contact form, chatbot, etc.), in to the extent that we do not cause undue risk or harm to your rights and interests. We will also process your personal data (such as your IP address) out of legitimate interest in order to provide greater security to the website or for the purposes of preventing computer crimes.

Extract from the weighing of legitimate interests judgment: Data processing is necessary to achieve MUMBLER's objectives, specifically, to be able to communicate electronically with its clients, prospects and other contacts. Likewise, users are interested in being able to contact us by these means and it is within their reasonable expectations that said contact data processing is carried out. On the other hand, MUMBLER has an interest in providing security and trust to the interactions that may take place on the website, as well as in preventing or avoiding computer crime actions, communicating, where appropriate, the data collected to the Law Enforcement Forces and Bodies. State Security, as well as competent Judges and Courts.

b-. Execution of a contract to which the interested party is a party (article 6.1. letter b of the RGPD)

We will process your data in order to provide you with the services that you have contracted with MUMBLER by accepting our terms and conditions.

c-. Compliance with legal obligations (article 6.1. letter c of the RGPD)

In certain cases, we will process your personal information in order to comply with our legal obligations related to billing, accounting and tax. Also when other laws of the European Union or Spain require it from us.

b-. Consent of the interested party (article 6.1 letter a of the GDPR)

We will request your express, prior, free, informed and unequivocal consent in the event that at any time we use cookies that are not strictly necessary for the correct technical functioning of the website. You can consult our Cookies policy.

Likewise, we will obtain your express consent when you enter your data in the appropriate forms, intended for any of our subscription services for MUMBLER news, news or publications by email. In this sense, to obtain your consent you must check the appropriate box.

5-. DATA CATEGORIES 

We collect the minimum possible amount of personal data to be able to provide the online service that you request in each case when using this website. 

None of the data collected on this website is of special or sensitive category.

At the time of collecting your personal data through this website, we will inform you which of said data is mandatory to be able to provide the corresponding services (normally by marking it with the asterisk symbol or with the legend ‚Äúmandatory‚ÄĚ).¬†

We consider it important that you understand that the omission or failure to complete the data indicated as ‚Äúmandatory‚ÄĚ could lead to the impossibility of providing the corresponding requested service.

So that the information contained in our processing system is always up-to-date and does not contain errors, you must inform us as soon as possible of any modifications and rectifications that may be made to your personal data.

MUMBLER will not be responsible for the incorrect introduction, whether accidental or intentional, of personal data in the forms and contact facilities existing on this website.

6-. DATA OF MINORS

MUMBLER's offering of services and digital content is not deliberately directed at minors. Therefore, we do not intentionally collect personal information or data from children under fourteen (14) years of age.  

Please, pay attention! If you are under that age (14 years), you are required to have the prior consent of your parents, guardians or legal representatives before proceeding to include your personal data in any of the forms on this website. 

Please pay attention! If you are under that age (14 years), you are required to have the prior consent of your parents, guardians or legal representatives before proceeding to include your personal data in any of the forms on this website.

7-. RECIPIENTS OF PERSONAL DATA

We will not transfer the data collected on or through this website to any other company, person, entity or organization.

Only when a rule of European Union Law or a law of Spanish Law obliges us to do so, could we communicate your data to the appropriate Public Administrations, to the competent authorities, as well as, where appropriate, to judges and courts. 

We will also use some suppliers directly to be able to adequately provide you with the services we have on the website (e.g. web hosting service).

When your personal data is to be processed on behalf of MUMBLER, we will only choose suppliers (processors) who offer sufficient guarantees to apply appropriate technical and organizational measures and who guarantee your data protection rights. If you want more information about the data processors used by MUMBLER, write us an email to hello@mumbler.io and we will provide it to you.

8-. INTERNATIONAL DATA TRANSFERS

In which cases could your personal data be transferred to a third country outside the European Economic Area?

Certain Mumbler services are hosted on servers located in the European Union but managed by companies whose headquarters and/or decision center is in the United States of America. Currently, the European Union recognizes the United States as a country that provides an adequate level of protection to your data (Adequacy Decision of the European Commission called ‚ÄúData Privacy Framework‚ÄĚ). However, MUMBLER will in any case evaluate the capacity of the respective foreign providers to provide and manage your personal data with appropriate technical and organizational measures, and match the level of protection to that stipulated by European regulations.

In the event that the use of cookies or similar technologies on this website gives rise to such transfer of your data, we will notify you in due time in our Cookies Policy.

9-. DATA CONSERVATION CRITERIA

We will retain your personal data as long as such retention is necessary to fulfill the purposes for which it was collected.

Once these purposes are met, we may keep your data during the statute of limitations for legal liability actions that may arise from your contractual or commercial relationship with MUMBLER.

10-. RIGHTS OF THE INTERESTED PARTY

1-. Data protection rights:

1.1. Right of access: you have the right to obtain confirmation from MUMBLER as to whether or not we are processing your personal data. If so, we will provide you with a copy.

1.2. Right to rectification: you have the right to obtain rectification of your personal data without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of an additional declaration.

1.3. Right to deletion: you have the right to obtain the deletion of your personal data without undue delay. When the circumstances expressed in article 17.1 of the RGPD occur, we would be obliged to delete your data without delay.

1.4. Right to data portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit it to another data controller without us preventing it, when the treatment is based on your consent and, in addition , is carried out by automated means.

1.5. Right to limit processing: when the processing of your personal data has been limited by virtue of a request on your part, said data may only be processed, with the exception of mere conservation, with your consent or for the formulation, the exercise or defense of claims, or with a view to the protection of the rights of another natural or legal person, or for reasons of important public interest. You will have the right to obtain the limitation of the processing of your personal data when any of the circumstances provided for in article 18.1 of the RGPD are met.

1.6. Right to object: you have the right to object at any time, for reasons related to your particular situation, to your personal data being processed based on the legitimate interests of MUMBLER or third parties. 

We remind you that, when the legal basis for data processing is your consent, you will always have the right to withdraw that consent as easily as you provided it to MUMBLER.

You also have the right to file a claim with the Spanish Data Protection Agency, if you consider that we have not adequately attended to or satisfied any of the rights mentioned so far. For more information, you can go to the website of said authority at https://www.aepd.es

Finally, you also have the right not to be subject to a decision by MUMBLER that is based solely on the automated processing of your personal data, including profiling, that produces legal effects on you or that significantly affects you in a similar way.

  1. How you can exercise these rights 

You can exercise the rights mentioned above at any time by email addressed to the address listed in section 1 (Identity of the Controller and Contact), or by sending a letter to the address of the Controller (also stated in section 1 of this Policy). Of privacy). Important: we will not require a copy of the appropriate official identity document as long as we can verify by other means the identity of the person exercising the data protection right (for example, if the email used to exercise the right corresponds to the one provided by the user in any of our services).

You have more information about your data protection rights, and even forms or models so that you can exercise them in this website Agencia Espa√Īola de Protecci√≥n de Datos.

11-. SECURITY MEASURES

User privacy and the security of personal data are key principles and firm commitments in MUMBLER's actions and interaction with your personal data. 

Therefore, MUMBLER will apply appropriate technical and organizational measures to guarantee a level of security appropriate to possible security risks. Such technical and organizational measures will be aimed at reducing or, to the extent possible, mitigating the risks of loss, misuse, alteration, unauthorized access, or disclosure of said personal information.

In other words, we will take the necessary measures to protect the confidentiality, integrity and availability of your personal data.

We will also require appropriate security measures, both technical or organizational, from our suppliers, especially those who provide us with web hosting services, payment management services or email sending services.

These are some of the security measures we use:

Security measures implemented by our hosting providers (web hosting)

Encryption of client-server communications using secure page SSL protocol (https://)

12-. MODIFICATION OF THIS POLICY

In order to effectively implement the principle of proactive and constant compliance with data protection regulations, as well as in accordance with our duty of transparency with interested parties, it is likely that we will modify this Privacy Policy from time to time, if the regulations change. circumstances of the processing of your personal data.

We will make the most diligent efforts to notify you of any significant changes to this Privacy Statement that may have an impact on your rights or interests as the owner of personal data.

MORE INFORMATION

To clarify any doubt, question or concern raised or unresolved by reading this Privacy Policy, you can contact MUMBLER at the postal and email addresses listed in Section 1 (IDENTITY OF THE CONTROLLER AND CONTACT).

Last update: March 2024-.

EXPANDED INFORMATION ON DATA PROTECTION ‚Äď EMAIL ‚ÄúTRANSCRIPTION TAG‚ÄĚ

1-. Data controller ‚Äď Identity and contact:

  • Mumbler Audio S.L. ("Mumbler")
  • Headquarters: Vic – Barcelona (Spain)
  • Contact: hello@mumbler.io

2-. Purposes of treatment:

  • Provide podcast publishers with relevant information to boost the reach and audience of their podcasts.
  • Promote the increase in listeners and, in general, podcast users.
  • Contribute to the accessibility of digital content by people with hearing disabilities.
  • Strengthen the podcaster ecosystem.
  • Make known the existence of Mumbler, as a podcast distribution platform.¬†

3-. Legal basis:

  • Nature of data: Mumbler will only process the email address that you provide to your podcast publishing platform and that is accessible from your podcast's public RSS feed. Mumbler will not process any other personal data.
  • Content: The content of the email is purely informative and communicates precise and relevant information, which benefits both the podcast editors who have received said email, and, in general, the podcast ecosystem. Mumbler's legitimate interests are aligned with your interests: to promote the dissemination of your podcast (e.g. by increasing the search engine positioning possibilities of the transcribed text) and to provide better accessibility to your digital content (if your podcast has a written transcription it will be accessible e.g. people with some type of hearing disability). Mumbler believes that this action does not impact your rights and freedoms, and that your reasonable expectation, as a recipient of this email, is that you will consider this communication to be proportionate, useful and appropriate.
  • Mumbler has adopted data minimization measures prior to sending this informational communication. To carry out this sending, Mumbler has selected an emailing service provider (Mailgun, based in the United States) that provides adequate security measures to protect your data. You can consult Mailgun's DPA (Data Protection Addendum) here (link to https://www.mailgun.com/legal/dpa/). We remind you that the European Union considers the United States as an adequate country when it comes to providing your data with a level of protection comparable to that provided by the GDPR.

4-. Data provenance

Mumbler has obtained your email address from your podcast's RSS feed.

5-. Data recipients:

Mumbler will not transfer your data to any person or entity.

6-. Data retention:

Once this communication is sent, Mumbler will no longer use your email address for any purpose (unless you expressly authorize Mumbler or use one of its services), and will proceed to securely delete your data.

7-. Rights:

Notwithstanding the above, in accordance with the GDPR you have the right to access your data, rectify it, delete it. You can also object to the treatment. To exercise your rights, you can directly use the "Unsubscribe" link/button that you will find in the email you received. You can also exercise your rights or request additional information about the processing of your data by writing an email to Mumbler: hello@mumbler.io

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