Privacy Policy

Effective Date: July 17, 2023.

1. Introduction and Overview.

This Privacy Policy describes how PDNA, LLC (“IPRAY,” “we,” “our,” or “us”) collects, uses, and shares information about you and your rights and choices regarding such information. It applies to any online location that links to this Privacy Policy and all features, content, and other services that we own, control, and make available through such online location (collectively, the “Service”) or offline location that makes this Privacy Policy available to you.

By using the Service, you agree to our Terms of Service and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. If you are a Nevada resident or California resident, please see the additional disclosures at the end of this Privacy Policy.

This Privacy Policy does not cover other websites that may be linked to or from the Service; nor does this Privacy Policy apply to practices of companies that we do not control or to people we do not employ or manage.

2. Information We Collect.

A. Information You Provide.

We collect information about you when you use the Service. For example, we collect information when you register an account, update your profile, access, search for, or comment on any content, follow other users or creators, upload an event, picture or video, create and host an event on the Service, contact customer support, or otherwise communicate or transact with us through the Service.

The information we collect includes information that identifies you personally, directly or indirectly, (whether alone or in combination). The categories of information we collect include:

  • Contact Data, including your first and last name and email address.
  • Account Credentials, including your username, password, password hints, and information for authentication and account access.
  • Demographic Data, including your age, gender, and country.
  • Profile Data, including your interests, inferences, preferences, favorites, saved events, events attended, social media handles, uploaded profile picture and hosted event picture, tickets saved, and creators followed.
  • Content, including content within any event hosted or posted to the Service, any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service (such as in event comments or in our community engagement features). We also collect content within any messages you exchange with other users through the Service (such as when you host an event and are contacted by other users for more information).
  • Personal Contacts Data, including first and last name, email address, and phone number of your personal contacts. We collect data about your contacts with your consent in order to fulfill a request by you, such as sending an email to your contact’s email address with an upcoming event or inviting your contact to join the Service. We may include your contact information, if you've entered it, when you request that emails be sent to your contact. Such functionality is only intended for U.S. residents. By using this functionality, you acknowledge and agree that both you and your contact are based in the United States and that you have your contact’s consent for us to use their contact information to fulfill your request.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically.

We automatically collect information about you when you access or use the Service. The categories of information we collect automatically include:

  • Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day your browse, and your referring and exiting pages.
  • Device Data, including data about your device’s identifiers such as IP address and Ad Id, your browser or device type, operating system used, data regarding network connected hardware, and your device’s regional and language settings.
  • Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level), and with your consent, precise location data (such as latitude/longitude data).

The types of tracking technologies we use to automatically collect information include:

  • Log Files. Like many commercial websites, IPRAY uses log files to record events that occur in connection with your use of the Service. Information stored in log files may include IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.
  • Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. For example, by setting a cookie, you may not have to log in to our Service with a password more than once. We use both session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire once you close your browser, the cookie simply terminates. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. To learn more about how we use cookies, please visit our Cookie Policy.
  • Pixels (also known as web beacons), are small graphic images, also known as "internet tags" or "clear gifs," embedded in website, video, advertisement, or email that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to count the number of visitors to the Service, monitor how users navigate the Service, count content views, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
  • Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.
  • Location-identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth, may be used to collect precise location data when you consent to precise location tracking through our apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
  • In-App Tracking Methods, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.

For further information on tracking technologies for analytics and advertising, and your rights and choices regarding them, please see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

C. Information from Other Sources.

We collect information from other sources. The categories of sources from which we collect information include:

  • Data brokers from which we purchase data to supplement the data we collect.
  • Social networks with which you interact.
  • Partners that offer co-branded services or content such as hosted events and streaming of other live videos, sell or distribute our services, or engage in joint marketing activities.
  • Publicly available sources, including data in the public domain.

3. How We Use Information.

We collect and use information for business and commercial purposes consistent with our statements under this Privacy Policy or as permitted by applicable law. Our business purposes for collecting and using information, include to:

  • Manage our Service, including your registration and account;
  • Perform services requested by you, such as facilitating your ability to access your favorites, saved events, notifications for your favorite creators, and tickets; upload events, add notes, videos, and resources, and engage in forums; respond to your comments, questions and requests; and provide customer service;
  • Enhance Service performance and user experience;
  • Determine what areas of the Service are frequently used, and make those areas richer or more prominent;
  • Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
  • Prevent and address fraud, breach of policies or terms, and threats or harm;
  • Monitor and analyse trends, usage, and activities;
  • Conduct research, including focus groups and surveys;
  • Improve the Service or other IPRAY websites, applications, marketing efforts, products and services;
  • Develop and send you direct marketing, including advertisements and communications about our and other entities’ products, services, offers, promotions, rewards and events we think you may be interested in;
  • Conduct promotions, including verifying your eligibility and delivering prizes in connection with your entries;
  • Fulfill any other purpose at your direction; and
  • With notice to you and with your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

4. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

  • Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing (our current service provider for payment processing is Stripe), data analytics, marketing and advertising, content review, website hosting, and technical support. These service providers are contractually prohibited from retaining, using, or disclosing information for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law;
  • Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below;
  • Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes;
  • Partners. We share information with our partners in connection with offering co-branded services, such as hosting events and streaming of other live videos, selling or distributing our products and services, or engaging in joint marketing activities;
  • Public Forums. We share information you make public through the Service, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below;
  • Security and Compelled Disclosure. We share information to comply with the law or where we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on IPRAY, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else;
  • Merger and Acquisition. We share information in the event IPRAY negotiates or goes through any proposed or actual business transition, such as a merger, acquisition by another company, or sale of all or any portion of its assets, your information will, in most instances, be part of the assets discussed and/or transferred;
  • Facilitating Requests. We share information at your request or direction; and/or
  • Consent. With share information with notice to you and your consent.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

5. Viewing Information.

In certain circumstances, we may need to share information about the videos, including virtual events and live streaming events, you view on our Service along with other information we have about you, including information you have provided to us (such as your name or address) and information we have automatically collected (such as an IP address, device identifier, or precise location data). By using the Service, you consent to our doing so, including the collection, use, and sharing as described in our Video Privacy Notice and Consent. For more information, please review that policy.

6. Sweepstakes, Contests, Promotions.

From time to time, IPRAY or a partner may sponsor a promotion, sweepstake, survey, or contest (each a “Promotion”). In order to participate in a Promotion, you may be asked to provide information, including your name, email address, postal address, and/or answers to certain other questions that may be applicable. When you voluntarily enter a promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.

7. Events and Public Information.

Certain information that you submit to us, such as your picture, social media handles, username, any events hosted on or off the Service, event type and topic(s), users followed, and text or video comments, will automatically be displayed to other users of the Service and may be shared outside the Service. Your phone number and email address will not be displayed to other users. In the case of the events hosted on and off the Service, including live streaming events, public events will be displayed to all users, while private events will be limited to users you've designated as friends. Public events may also be embedded in services or platforms owned and/or operated by other entities that are viewable to individuals outside of the Service.

If you make information public through the Service, including sensitive information such as information regarding health or mental condition or disease, other people will have access to it. Please think carefully before making information public or viewable as you are solely responsible for information you make public or available to other users of the Service. Do not submit any videos of identifiable individuals or content where you do not own or have licenses to all underlying rights. Once you have posted information, you may not be able to edit or delete such information; however, California residents have additional rights as set forth in the “Additional Disclosures” section below.

8. Other Parties.

Our Service contains content from and hyperlinks to other websites, locations, platforms, and services owned and operated by other parties. In addition, our Service integrates technologies operated and controlled by other parties.

Some examples include:

  • Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
  • Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Service that allows you to “like” or “share” content on, or log-in to your account through social media.
  • Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with IPRAY in a tweet or post), we may use your reference on or in connection with our Service.

Remember that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and may solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

9. Analytics and Advertising.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies on our Service (including our website and emails) as well as into our ads displayed on other websites and services to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies and your choices regarding them, please see “Information Collected Automatically” above and “Your Rights and Choices” below.

10. Your Rights and Choices.

A. Accessing Your Information.

You may access, modify, or remove certain information that you have voluntarily submitted to us through your account at any time by logging in to your account and accessing your organizer profile. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents have additional rights set forth in the “Additional Disclosures” section below.

B. Tracking Technology Choices.

  • Cookies and Pixels. Most browsers accept cookies by default. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Browsers offer different functionalities and options so you will need to set them each separately. Your ability to limit cookies is subject to your browser settings and limitations.
  • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
  • App and Location Technologies. With respect to our mobile apps, you can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. Also, you can stop all collection of precise location data through an app, by uninstalling the app or withdrawing your consent through your mobile device settings.

Please be aware that if you disable or remove tracking technologies, some parts of the Service may not function correctly.

C. Analytics and Interest-Based Advertising.

You may exercise choices regarding certain information collected by Google Analytics by going to https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance ("DAA") and/or the Network Advertising Initiative (“NAI”). To learn more about the DAA and how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you will continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

Please note that if you opt out of using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

D. Communications.

We may communicate with you via email for any reason set forth in “How We Use Information” above, including to send you a link for resetting your password, if you have forgotten your password and request an email, if you submit feedback and specifically request that we respond via email, when you send/receive friend requests to/from other people, to notify you of changes to our policies or technical issues, or for marketing communications purposes.

You can opt-out of receiving promotional communications (emails and push notifications) from us at any time by (i) for emails, following the instructions as provided in emails to click on the unsubscribe link, or contacting us here with the word UNSUBSCRIBE in the subject field of the email; and (ii) for push notifications or in-app messages, adjusting the permissions in your mobile device. Please note that your opt-out is limited to the email address and/or device used and will not affect subsequent subscriptions or, for emails, non-promotional communications, such as those about your account, transactions, servicing, IPRAY’ ongoing business relations.

Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.

11. Children.

The Service is intended for a general audience and not directed to children. IPRAY does not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”). If you are a parent or guardian and believe IPRAY has collected personal information in a manner not permitted by COPPA, please email us support@pdna.com. We will remove the personal information to the extent required by COPPA. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at the email address set out in “Contact Us” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

12. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through our Service.

13. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy.

14. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Whenever we change this Privacy Policy, we will post the revised Privacy Policy to our website, and other places we deem appropriate, so you are always aware of our privacy practices. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.

15. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law please contact us:

By email:

support@pdna.com

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at support@pdna.com.

16. Additional Disclosures for Nevada Residents.

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at support@pdna.com.

17. Additional Disclosures for California Residents.

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

A. Notice of Collection.

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

  • Identifiers, including name, email address, and online identifiers (such as IP address).
  • Characteristics of protected classifications under California or federal law, including gender.
  • Commercial or transactions information, including records of products or services, included virtual events purchased, attended, saved, obtained, or considered.
  • Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
  • Geolocation data.
  • Inferences drawn from the above information about your predicted characteristics and preferences.

For further details on information we collect, including the sources from which we receive information, review the “Information We Collect” section above. We collect and use these categories of personal information for the business purposes described in the “How We Use Information” section above, including to manage our Service.

We do not generally sell information as the term “sell” is traditionally understood. However to the extent “sale” under the CCPA is interpreted to include the activities set out in this Privacy Policy, such as those disclosed in the “Analytics and Advertising” section above, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. Please review the “Sharing of Information” section above for further details about the categories of parties with whom we share information.

B. Right to Know and Delete.

You have the right to know certain details about our data practices in the past 12 months. You may request the following from us:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

In addition, you have the right to delete the personal information we have collected from you.

To exercise any of these rights, please submit a request through our Online Form or by sending an email to support@pdna.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

C. Right to Opt-Out of Sale.

To the extent IPRAY sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information or by emailing us at support@pdna.com.

D. Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

E. Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

F. Shine the Light.

Users who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Your Data Protection Rights Under The General Data Protection Regulation (GDPR)

If you or a user are a resident of the EEA, you have the following data protection rights:

  • You may access, correct, update, or request deletion of your personal information.
  • In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.
  • Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
  • We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To exercise any of these rights, please contact us at support@pdna.com.