Public Comment Privacy Notice

Effective Date: Apr 2025

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This Privacy Notice aims to help you understand how Public Comment ("we," "us," or "PC") collects, uses, processes, and shares your personal information, as well as how you can exercise your privacy rights. For the purposes of this Privacy Notice, "Personal Information" refers to any information that relates to an identified or identifiable individual.

By visiting or using any of our services, you expressly consent to the collection, use, and disclosure of your Personal Information in accordance with this Privacy Notice.

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1. Scope of Privacy Notice

This Privacy Notice applies to the Personal Information processed by PC in connection with the use of our services, including our websites and any other services provided by PC (collectively referred to as the "Services"). This Privacy Notice is intended to comply solely with U.S. regulations. If you are accessing the Services from outside the United States, please be aware that the data you provide may be processed and stored in the United States under U.S. laws, which may not provide the same level of data protection as the laws in your country of residence.

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2. What Personal Information Do We Collect?

We collect the following types of Personal Information from our users:

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A. Information You Provide to Us

We collect and store any information that you enter through our Services or otherwise provide to us. The type of Personal Information collected depends on the Services you use and the features you enable, and may include:

• Contact Information: Information you provide when you contact us, such as your name, mobile phone number, email address, and home or business postal address.

• Demographic Information: Information such as your location, gender, birthdate, and age.

• Account Information: Information that enables you to create or log in to an account, such as a username, password, email address, phone number, or other contact details.

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B. Information Collected Automatically

We automatically collect certain information when you interact with our Services, including:

• Log Data: We automatically record data such as your IP address, browser type, operating system, and the pages you request on our Services.

• Cookies and Other Tracking Technologies: We use cookies, pixel tags, and other technologies ("Technologies") to automatically collect information, including when you arrive at our Services through external links or third-party sites. Cookies are small text files placed in your device’s browser that store preferences and enhance your user experience.

• Browser and Device Information: Automatically collected details include your IP address, MAC address, device type, browser type, operating system, device identifiers, and mobile carrier.

• Usage Information: We collect information on how you use our Services, such as the pages you visit, the content you interact with, and the frequency and duration of your activities. For example, we may track the time you start and complete a lesson or activity within our Services.

• Location Information: We collect general location information (e.g., derived from your IP address) when you use our Services. If you enable location services on your mobile device, we may collect your precise, real-time location data.

• Email Analytics: We may receive automated confirmation when you open an email from us, depending on your email program settings.

• Google Analytics Data: We use Google Analytics, a web analytics service from Google, Inc. (“Google”), on our websites. Google Analytics uses "cookies" to help analyze how visitors interact with our sites. The information collected through these cookies, including your IP address, is transmitted to and stored by Google. For more details about Google Analytics and how to opt out, visit https://tools.google.com/dlpage/gaoptout. By using our websites, you consent to Google processing your data.

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C. Personal Information Collected from Other Sources

We may obtain Personal Information about you from third-party sources, including:

• Third-Party Services: If you access our Services through a third-party application, such as an app store, social networking site, or login service, we may collect information from that service based on your privacy settings within the third-party application.

 

 

3. How We Use Your Personal Information

We use your Personal Information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and services. Specifically, we may use and disclose the information collected through our Services for the following purposes:

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A. To Provide Our Services

We use your Personal Information to fulfill our contract with you and deliver our Services, including:

• Managing your information and accounts.

• Providing access to specific features or areas of our Services.

• Responding to requests for customer or technical support.

• Communicating with you about your account, activities, and policy changes.

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B. For Administrative Purposes

We use your information for various legitimate business interests, including:

• Enhancing security, detecting fraudulent activities, and prosecuting those responsible.

• Measuring engagement and interest in our Services.

• Improving our Services.

• Developing new products and services.

• Determining eligibility for research or related activities.

• Ensuring internal quality control, safety, and compliance with legal obligations.

• Authenticating and verifying identities, including responding to requests regarding your rights under this Privacy Notice.

• Debugging and addressing issues with our Services.

• Auditing transactions and interactions.

• Sharing information with third parties when necessary for service delivery.

• Enforcing agreements and policies.

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C. To Create De-Identified and/or Aggregated Information

We may use your Personal Information to create de-identified or aggregated data, such as demographic information or health results. Such data is not subject to this Privacy Notice and may be used for research, internal analysis, and legally permissible purposes.

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D. For Notification and Communication Purposes

We may use your Personal Information to tailor and provide content to you, such as:

• Email campaigns

• Interest-based or personalized notification

You may opt out of certain activities by contacting us as described in the "Contact Us" section.

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E. For Other Purposes

We may also use your Personal Information for other purposes, as described to you at the time of collection or otherwise permitted by applicable law, including:

• To respond to your requests or as required by legal obligations.

• To protect the rights, property, or safety of our company, affiliates, users, customers, or others.

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4. How We Disclose Your Personal Information

We disclose your Personal Information to third parties for various business purposes, including providing our Services, ensuring compliance with legal obligations, and in cases of significant business transactions (e.g., mergers, sales, or transfers of assets). Below are the categories of third parties and situations where your Personal Information may be disclosed.

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A. Disclosures to Provide Our Services

We may share your Personal Information with third parties necessary to deliver and improve our Services:

• Service Providers

  • We share your Personal Information with third-party service providers that assist in providing IT support, hosting, payment processing, customer service, and related services. For example, chat communications may be disclosed to service providers that support our chat features.

• Business Partners

  • We may share your Personal Information with business partners to deliver a product or service you’ve requested. This includes partners with whom we jointly offer or develop products or services.

• Affiliates

  • Your Personal Information may be shared with our affiliates, including affiliated professional corporations that employ or contract with professionals providing services on our behalf.

• Partners

  • We may disclose your information to third-party partners, who may set tracking technologies to collect information about your device and activities on our Services (e.g., IP address, cookie identifiers, location).

• Third-Party Services You Interact With

  • Some features of our Services allow you to interact with or share information with third-party websites, services, or products. Any information collected by these third parties is subject to their privacy policies, and we are not responsible for their data practices.

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B. Disclosures to Protect Us or Others

We may disclose your Personal Information if we believe it is necessary to:

• Comply with legal requirements, such as court orders, subpoenas, or law enforcement requests.

• Protect our rights, property, or the safety of our users, affiliates, or others.

• Enforce our contracts or policies.

• Collect amounts owed to us.

• Assist with an investigation or prosecution of suspected illegal activities.

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C. Disclosures Related to Business Transactions

We may disclose your Personal Information in connection with significant business transactions, such as:

• Mergers, Acquisitions, or Sales
  In the event of a merger, acquisition, or sale of our business or assets, your Personal Information may be transferred to the buyer or successor.

• Insolvency or Bankruptcy Proceedings
  If we are involved in insolvency or bankruptcy proceedings, your Personal Information may be transferred as part of such processes.

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D. Disclosures to Legal or Regulatory Bodies

We may share your Personal Information with government agencies, legal authorities, or regulatory bodies in order to:

• Comply with our legal obligations.

• Respond to lawful requests.

• Address any legal or regulatory issues.

 

F. Other Disclosures

We may also disclose your Personal Information to:

• Any organization with your consent or authorization, such as when we seek your explicit permission to share specific data.

• Any organization as described when or prior to collecting Personal Information, or as noted in privacy notices presented to you during your use of our Services.

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5. How Do We Protect Your Personal Information?

We implement administrative, physical, and technical safeguards designed to protect the Personal Information we collect through our Services. These security measures are intended to prevent unauthorized access, disclosure, or misuse of your data. Specific steps we take include:

• Administrative Measures: Policies and procedures to ensure secure handling of data by our personnel.

• Physical Measures: Securing physical access to systems where Personal Information is stored.

• Technical Measures: Encryption, firewalls, and secure authentication protocols to safeguard data in transit and at rest.

Additionally, when you access certain features of the Services, your Personal Information may be accessible through your login credentials. It is your responsibility to keep your user credentials (e.g., username, password) confidential and secure. We recommend that you regularly update your password and take steps to protect your login information to further safeguard your Personal Information.

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6. What Choices Do I Have Regarding My Personal Information?

You have choices regarding the Personal Information we maintain about you. While you can choose not to disclose your Personal Information to us, this may limit your ability to utilize certain features of our Services. Below are your rights and options related to your Personal Information:

• Access and Correction

  • You may request to confirm whether we are processing your Personal Information, obtain access to or a copy of your Personal Information, and request the correction or amendment of your Personal Information using the contact information provided below.

• Account Deletion

  • You may ask us to delete your account or remove your records from our system. Please note that in certain circumstances, some Personal Information may remain in our records after deletion, especially if we are legally or contractually obligated to retain it.

• Email Communications

  • You can choose not to receive communications from us by indicating your preferences or using the opt-out or unsubscribe features included in our communications. Note that you will still receive transaction-related emails for products or services you have requested.

• Do Not Track

  • Our Services do not currently respond to Do Not Track (“DNT”) signals from web browsers. While you can adjust your browser settings to decline or block cookies, this may affect the functionality of our Services.

• Cookies and Personalized Advertising

  • You can stop or restrict the placement of cookies on your device or remove them by adjusting your browser or device settings. Please note that cookie-based opt-outs are not effective on mobile applications, but you may opt out of personalized advertisements on certain mobile applications by following the instructions for Android, iOS, and other platforms. Please note that you must separately opt out in each browser and on each device.

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If you would like to exercise any of these rights or have questions regarding your privacy choices, please contact us using the information provided in the "Contact Us" section below. We will process requests in accordance with applicable laws.

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7. Children’s Information

Our Services are not directed to individuals under the age of 18, and we do not knowingly or intentionally collect personal information from children. If you are a parent or guardian and believe that your child has submitted personal information to our site without your consent, please contact us using the information provided in the “Contact Us” section below.

In the event we become aware that a child has provided us with personal information in violation of applicable law, we will take the necessary steps to delete such information promptly, unless we are legally obligated to retain it, and we will terminate the child’s account.

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8. Changes to This Privacy Notice

By using our Services, you agree to be bound by the current Privacy Notice. We encourage you to review this Privacy Notice periodically, as we may make changes at any time without prior notice.

Any modifications will take effect immediately upon posting, unless otherwise specified. Your continued access to or use of the Services after we have posted a modification or provided you with notice of a change constitutes your acceptance of the updated Privacy Notice.

We may revise this Privacy Notice at our discretion, and in the event of any material changes, we will notify you as required by applicable law. The date at the top of this page indicates when this Privacy Notice was last updated.

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9. Retention of Personal Information

We retain the personal information we collect as outlined in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purposes for which it was collected. This includes, but is not limited to:

• Providing our Services

• Resolving disputes

• Establishing legal defenses

• Conducting audits

• Pursuing legitimate business purposes

• Enforcing our agreements

• Complying with applicable laws

Once the information is no longer necessary for these purposes, we will securely delete or anonymize it in accordance with applicable laws.

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10. Links to Other Websites and Services

Our Services may contain links to third-party websites or applications. These websites and applications are not governed by this Privacy Notice, and we have no control over their security, privacy policies, or practices.

When you click on a link to a third-party website or app, we encourage you to exercise caution and review the privacy notice provided by those external sites or applications. We are not responsible for the content or practices of these third parties.

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11. Contact Us

Please contact us at privacy@pcomment.com if you have any questions about this Privacy Notice