Privacy Policy


Effective Date: February 2, 2026
This 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 help@pingmunk.com

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")

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Client privacy practices or policies
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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")

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How to use and process End User data
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Privacy settings and configurations
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Notice and consent mechanisms for End Users

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Data retention and deletion practices
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Responses to End User privacy requests
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1.3 End User Inquiries
End Users should contact the business they called for:

Questions about personal information collection

Privacy rights requests (access, deletion, correction)

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Concerns about data handling practices
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Opt-out or consent withdrawal
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General privacy inquiries
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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:

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Contractual agreements with our Clients
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Terms of Service provisions
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Data Processing Addendum requirements
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Not solely under this Privacy Notice
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2. DEFINITIONS AND KEY TERMS


2.1 "Personal Information" 
Defined
Personal 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:

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Full name, alias, or username
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Email address and telephone number
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Postal address and physical location
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Internet Protocol (IP) address
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Account credentials and user IDs
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Social media handles
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Device identifiers
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Online identifiers and cookies
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Sensitive Personal Information:

Voice recordings and voiceprints (biometric identifiers)

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Precise geolocation data
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Health and medical information
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Financial account details
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Government-issued identification numbers

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

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Information about known minors
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Genetic or biometric data
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Racial or ethnic origin
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Religious or philosophical beliefs
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Union membership
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Sexual orientation or sex life
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Legally Protected Classifications:

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Race, color, or ethnicity
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National origin or citizenship status
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Religion or creed
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Age or date of birth
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Sex, gender, or gender identity
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Marital or familial status
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Disability status
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Military or veteran status
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Professional and Employment Information:

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Current and former employment history
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Job titles and responsibilities
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Employer information
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Professional licenses and certifications

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Work performance data
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Educational Information:

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Educational records and transcripts
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Degrees and certifications earned
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Student identification numbers
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Information protected under FERPA (20 U.S.C. § 1232g, 34 C.F.R. Part 99)

Commercial Information:

Products or services purchased, obtained, or considered

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Purchasing histories and tendencies
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Consumer preferences and interests
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Transaction records
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Payment history (not payment card numbers)

Internet and Network Activity:

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Browsing history and search queries
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Website and application interaction data

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Content consumption patterns
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Click streams and navigation paths
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Time spent on pages or features
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Referral sources
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Inferences and Profiles:

Profiles reflecting preferences and characteristics

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Behavioral predictions and tendencies
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Psychological profiles
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Attitudes and aptitudes
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Propensities and predispositions
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Intelligence assessments
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2.2 Information Excluded from Privacy Protections
The following categories are NOT considered Personal Information under most privacy laws:
Publicly Available Information:

Government records accessible to the public

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Widely distributed media publications
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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 Principles
PingMunk collects, uses, retains, and discloses Personal Information only:

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As described in this Privacy Notice
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As disclosed at the time of collection
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To the extent reasonably necessary and proportionate for stated purposes

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

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

Business name and legal entity information

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Contact person name and title
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Business email address and telephone number

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Physical business address
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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 support
Profile and Configuration Data:Clients provide:

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Employee and team member information
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Business hours and scheduling preferences

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Call handling instructions and scripts
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Frequently asked questions and responses

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Service customization preferences
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Integration settings and API credentials

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

Content from Client websites and web properties

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Online reviews and public feedback
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Social media presence and content
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Marketing materials and brand information

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Product or service descriptions
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Publicly available business information
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Purpose: AI model training, response generation, context understanding, service personalization
Integrated System Data:
When Clients connect third-party systems:

Customer relationship management (CRM) data

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Calendar and scheduling information
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Email marketing platform data
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E-commerce transaction records
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Help desk and support ticket information

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Analytics and reporting data
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Purpose: Enhanced service delivery, automation, synchronization, comprehensive support
Client 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

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Transaction history and billing records
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Feature usage and adoption patterns
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Platform interaction logs
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Support requests and communications
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Configuration changes and settings history

Purpose: Service delivery, billing, usage analytics, product improvement, customer support
Communications 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

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Complaint details and resolutions
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Purpose: Customer support, relationship management, service improvement
Marketing 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

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Browser types and versions
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IP addresses and network information
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Access times and duration
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Error logs and diagnostic data
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Purpose: Technical support, security monitoring, platform optimization, troubleshooting

3.3 Information Collected from End Users
Important 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:

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Names and contact information
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Appointment preferences and availability

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Product or service inquiries
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Complaint or feedback details
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Account information or customer numbers
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Special requests or accommodation needs
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Any other information voluntarily shared during conversations

How Information is Used:

Generate appropriate responses to End User requests

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Schedule appointments in Client systems
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Send appointment reminders (email or SMS)

Route calls to appropriate departments or personnel

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Process transactions or bookings
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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:

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Understand speech and detect intent
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Recognize when responses require adjustment

Identify situations requiring human intervention

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Detect emotional tone and urgency
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Improve speech recognition accuracy
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Enhance natural conversation flow
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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:

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Mobile telephone numbers collected
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SMS message content processed
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Conversation history maintained
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Opt-in and opt-out preferences recorded
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SMS Use Cases:

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Appointment confirmations and reminders
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Links to scheduling platforms or websites

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Business location directions
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Promotional offers (only with explicit opt-in)

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Continued conversation from phone call
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Important:

We do not share mobile information with third parties or affiliates for marketing or promotional purposes.

Information may be shared with service providers who support our operations, such as customer support.

All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
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:

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Preferred dates and times
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Service or appointment type
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Duration preferences
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Special requirements or notes
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Contact information for reminders
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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

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Text transcripts with timestamps
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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

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Dispute resolution and verification
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Training data for speech recognition enhancement

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Analytics and statistical analysis
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Functional Necessity:
Recordings and transcripts are essential for:

Executing End User requests (scheduling appointments, providing information)

Sending automated reminders through Client systems

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Generating accurate service records
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Enabling Client review of interactions
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Supporting customer service excellence
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Notice and Consent Requirements:
Clients may configure the AI Assistant to:

Provide audible notification of recording at call beginning

Request explicit consent before proceeding

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Offer opt-out by ending call
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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

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Develop new features and capabilities
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Conduct research and analytics
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Benchmark performance and quality
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3.5 Real-Time Access to Conversations
CRITICAL NOTICE: End User interactions with AI Assistants may be accessible to PingMunk personnel and third-party service providers simultaneously and in real-time for:

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Quality monitoring and assurance
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Technical support and troubleshooting
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Security monitoring and fraud prevention

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Performance optimization
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Emergency intervention when needed
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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 Processing
PingMunk 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 Protection
Services 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 help@pingmunk.com immediately.
3.8 Communications with PingMunk
Prospective 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 inquiry
Customer Support:
When current or former Clients contact support:

We collect issue description and relevant details

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We maintain support ticket history
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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 Collection
Website and Application Usage:We automatically collect technical information during Platform use:
Device Information:

IP address and geographic location (city/region level)

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Operating system and version
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Browser type and version
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Device type and model
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Mobile network information (if applicable)

Caller ID information (for telephone interactions)

Screen resolution and display characteristics

Usage Analytics:

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Pages viewed and features accessed
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Time spent on pages and in Platform
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Click paths and navigation patterns
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Search queries entered
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Content interactions and engagement
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Feature adoption and usage frequency
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Session duration and frequency
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Stored Information:

Cookies and similar tracking technologies

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Local storage data
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Cache and temporary files
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Metadata and log files
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Cookies and Tracking Technologies:
We use various types of cookies:
Essential Cookies:

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Required for Platform functionality
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Enable core features and security
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Cannot be disabled without affecting service

Analytics Cookies:

Understand how visitors use Website and Platform

Measure performance and identify improvement opportunities

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Track aggregated usage patterns
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Marketing Cookies:

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Deliver targeted advertising
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Measure campaign effectiveness
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Personalize marketing content across platforms

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Retarget visitors who showed interest
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Cookie Control:

Adjust browser settings to block or limit cookies

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Install third-party privacy plugins
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Use Platform cookie preference settings
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Note: Blocking essential cookies may impair functionality

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

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Provide, maintain, and improve Services
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Process transactions and fulfill requests

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Manage accounts and subscriptions
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Provide customer support
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Communicate about Services and accounts
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Development and Innovation:

Develop new products, services, and features

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Conduct research and analysis
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Test and optimize Platform performance
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Enhance user experience
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Security and Fraud Prevention:

Prevent fraud, abuse, and illegal activity

Protect security of systems, networks, and data

Detect and investigate policy violations

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Enforce Terms of Service and agreements
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Respond to security incidents
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Legal Compliance:

Comply with legal obligations and requirements

Respond to legal process and government requests

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Exercise and defend legal rights
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Protect rights and safety of PingMunk, users, and public

Business Operations:

Support business transitions (mergers, acquisitions, sales)

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Manage corporate governance
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Conduct audits and assessments
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Maintain business records
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4. INFORMATION SHARING AND DISCLOSURE

4.1 Disclosure PrinciplesPingMunk discloses Personal Information only:

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As described in this Privacy Notice
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With your permission or at your direction

To accomplish legitimate business purposes

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As required or permitted by law
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Disclosure Recipients (Last 12 Months):We have disclosed Personal Information from all collection categories to the following recipient types:

4.2 Disclosure to Clients
Primary 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:

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End User conversation content and data
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Call recordings and transcripts
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Appointment and scheduling information
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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 Vendors
We engage service providers to support our operations, including:
Infrastructure and Hosting:

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Cloud storage and computing providers
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Content delivery networks
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Backup and disaster recovery services
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Analytics and Performance:

Website and application analytics platforms

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Performance monitoring tools
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A/B testing and optimization services
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Communications:

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Email delivery services
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SMS messaging platforms
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Customer support ticketing systems
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Marketing and Advertising:

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Marketing automation platforms
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Advertising networks and exchanges
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Social media advertising tools
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Security and Compliance:

Security monitoring and threat detection

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Compliance auditing services
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Identity verification providers
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Professional Services:

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Legal counsel and advisors
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Accounting and financial services
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Consulting and advisory services
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Service Provider Obligations:All service providers must:

Maintain contractual commitments to protect Personal Information

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Use data only for specified purposes
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Implement commercially reasonable security measures

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Comply with applicable privacy laws
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Return or delete data upon request or contract termination

4.4 Legal and Regulatory Disclosures
We 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

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To protect safety of individuals
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To prevent harm to persons or property
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To enforce our Terms of Service and policies

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

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Mergers or acquisitions
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Sale of business assets or divisions
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Corporate reorganization or restructuring

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Bankruptcy or insolvency proceedings
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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

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In ways you explicitly approve
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4.7 Important Clarifications
We 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

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Monetize Personal Information directly
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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:

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Train and improve AI language models
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Develop new features and capabilities
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Conduct research and publish findings
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Benchmark performance and industry trends

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Create statistical reports and analyses
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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

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Needed for legitimate business purposes
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Useful for establishing, exercising, or defending legal claims

5.2 End User Data Processed for Clients
Client-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 Data
Active 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 Data
Active 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 Retention
We 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:

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Litigation hold requires preservation
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Investigation necessitates data retention

Dispute resolution demands information availability

Legitimate Business Purposes:

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Fraud prevention and detection
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Abuse prevention
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Account security and recovery
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5.7 Deletion and Disposal
When retention period ends:

Preferred Methods:

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Permanent deletion from active systems
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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:

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Data securely stored and isolated
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Prevented from further processing
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Deleted when technically feasible
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Secure Disposal:

Industry-standard deletion methods employed

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Data destruction verified when critical
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Third-party service providers follow same standards

6. THIRD-PARTY SERVICES AND LINKS

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

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Third-party software applications
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External websites and services
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Social media platforms
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Partner services and tools
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6.2 PingMunk's Limited Control
We have NO control over:

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Third-party privacy practices
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Third-party security measures
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Third-party data collection or use
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Third-party terms and conditions
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6.3 Your Responsibilities
When 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

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Accept third-party terms independently
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6.4 Third-Party Liability
PingMunk is NOT responsible for:

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Third-party data practices or security
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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 Appropriately
For 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 Requests
How to Submit:

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Email: help@pingmunk.com
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Subject: Privacy Rights Request
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Include: Name, contact information, specific request, account details (if applicable)

Types of Requests:

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Access to Personal Information
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Correction or update of information
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Deletion of Personal Information
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Restriction of processing
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Objection to processing
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Data portability
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Withdrawal of consent
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Complaint or concern submission
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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

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Modify account settings and preferences
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Adjust privacy and communication settings

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Review and download data
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Delete certain information
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Contact for Assistance: If unable to make desired changes through account:

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Email help@pingmunk.com
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Request assistance with specific changes

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Revoke previously granted consents
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7.4 Email Communication Preferences
Service Emails (Required):

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Account notifications and updates
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Billing and payment information
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Security alerts and notices
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Critical service announcements
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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 help@pingmunk.com 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 Preferences
Service 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 Controls
Browser 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 Permissions
Mobile 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 Users
End 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 help@pingmunk.com)

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 help@pingmunk.com

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 (help@pingmunk.com)

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 Notice
Geographic 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 Commitment
PingMunk 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 Measures
Personnel:

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 Response
Preparation:

```
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 Disclaimers
No 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 Modify
We 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 Changes
For 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 Changes
Obtaining 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 Updates
Your 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 Requests
Primary Contact:

```
Email: help@pingmunk.com
```
```
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 help@pingmunk.com 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 Concerns
Filing Complaints:If you believe we have violated your privacy rights:

Contact help@pingmunk.com 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 PingMunk
For Privacy Matters: help@pingmunk.com
For General Inquiries: Visit PingMunk.com

13. ADDITIONAL PROVISIONS

13.1 California Privacy Rights Addendum
California 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 Disclosures
Residents 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 help@pingmunk.com for state-specific information

13.3 Nevada Privacy Rights
Nevada residents may opt out of sale of Personal Information. While we do not sell Personal Information, Nevada residents may submit opt-out requests to help@pingmunk.com.
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 Accessibility
We are committed to ensuring this Privacy Notice is accessible to individuals with disabilities. If you experience difficulty accessing this Notice, contact help@pingmunk.com for assistance.
13.6 Language
This 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: February 2, 2026
Owner and Operator: MQL Media, Inc. dba PingMunk
Contact: help@pingmunk.com