Wunderkind Corporation (“Wunderkind”) is a behavioral automation software and analytics company. We help website publishers (our “Clients”) drive higher engagement from their website visitors (“Users”) via our behavioral automation platform, identity platform, ad serving platform, and performance advertising platform (collectively, the “Platforms”). This Privacy Policy describes the information that we collect through our websites, including www.wunderkind.co  (the “Websites”), our Platforms, our products, our services (“Services”), including the dashboard for our Clients to utilize or manage the Platforms and our Services (the “Services Dashboard”), and other information we receive from Clients. This Privacy Policy also describes how we use that information.  If you have any questions about our Privacy Policy, please contact us at privacyrequests@wunderkind.co.

Wunderkind is a member in good standing of the Internet Advertising Bureau and Network Advertising Initiative (“NAI”) and adheres to the Digital Advertising Alliance self-regulatory code.

 

The Types of Information that We Collect and How We Use it

The Websites and our general business operations

Our Websites are directed to our Clients, partners and vendors which are generally businesses. We collect two types of information from visitors to our Websites: personally identifiable information and pseudonymous information. Personally Identifiable Information (“PII”) is information that may be used to identify an individual and includes email address, telephone number or postal address. Pseudonymous information doesn’t enable us to identify anyone but may help us recognize a particular browser or device over time. Both PII and pseudonymous information are considered personal data and/or personal information in many places. We believe that maintaining the distinction between what we consider directly identifiable and what we consider to be pseudonymous can be helpful in describing our privacy practices, but recognize that some privacy laws don’t distinguish between the two types of data.

We don’t knowingly collect sensitive or special category data such as ethnicity, religion, sexual interest, health data or data from minors as defined under applicable law other than in an employment context which is covered under a different policy. We ask our Clients not to send this type of information to us. Some places consider precise location to be sensitive. We don’t collect or otherwise process precise geolocation data (e.g., lat/long) but we may obtain more general GEO data such as postal code or city (e.g., when we infer such information from an IP address).

 

We also generally don’t collect PII via the Websites unless it is provided to us. For example, if you purchase our products or Services, we may request certain personally identifiable information from you on our order form.  This includes contact information such as your name, email address, and address, as well as financial information such as a credit card number and its expiration date.  We use this information for billing purposes and to fill orders. If we have trouble processing an order, we also will use this information to contact you. We do not sell this information and generally will only use it for the purpose it was provided.

 

We also collect pseudonymous information via the Websites such as the name of your internet service provider, the IP address of the computer or device you are using, the type of browser and operating system that you use, the date and time you access our Websites, the website referrer address and other log file information.  Like most websites, our Websites use “pixel tags”, “web beacons”, “cookies” and/or similar tracking technologies that allow us to track the actions of visitors to our Websites as described here. We use this information to help us improve our Websites and the products, Services, applications, content and features that we provide. We also enable third parties to collect pseudonymous data via the Websites. This process may be deemed a sale of information in certain jurisdictions, and we will provide a notice and provide the ability to opt-out of such sales in those jurisdictions. We reserve the right to aggregate information collected from visitors to the Websites for any purpose, including publishing aggregate statistics about our Clients’ and/or Websites’ visitors, counting and better understanding our site visitors and protecting our Websites from security issues or fraud.

 

The Ad Serving Platform

The Wunderkind ad serving Platform is designed to process pseudonymous information from a particular Client’s websites, mobile applications and the Client’s data partners and does not intentionally collect PII. The type of pseudonymous information collected via the ad serving Platform includes IP address, browser type, operating system, Internet Service Provider, referrer address, the time/date an ad is served and the site or mobile app that the ad is served in addition to other log file information. This information is used to offer products and Services designed to help our Clients better understand how their websites are being utilized, draw insights on how to better engage Users on their sites, to deliver more relevant advertising messages based upon the User visits to their sites, and to provide Clients with ad delivery reports. Wunderkind operates the Ad Serving Platform as a “service provider” in that we only process such information as directed in writing by each Client.

 

The Behavioral Automation Platform

The Behavioral Automation Platform is a marketing technology offering that enables our Clients to target ads and emails powered by data that each Client collects from direct interactions with its customers. Wunderkind processes email addresses and other PII such as telephone number via our behavioral automation Platform. We typically obtain this information from our Clients that collect it via online forms on Client owned websites, mobile applications, and other digital properties (collectively, “Digital Properties”). We use this data only as directed by each Client. Our systems may access this information automatically as each data point is entered by a user into a particular web form in accordance with applicable law. We combine this PII with pseudonymous information also collected via Client Digital Properties such as a Client’s User ID, mobile o/s advertising ID, hashed user emails and/or other pseudonymous IDs to help our Clients with conversion tracking, site optimization and conversion. We may also collect an email address and a Client’s User ID when directed by a Client (e.g., when a user clicks on a link sent by one of our Clients via the Client’s email service provider). Wunderkind and our Clients may also use this information to send targeted email and SMS marketing messages to our Clients’ customers and prospective customers. We only deploy messages as directed the applicable Client but may use machine learning via data collected across Client Digital Properties to optimize ad and message timing and to use data to target ads and marketing messages to users inferred interests..

 

You can opt out of receiving any further marketing or promotional text (e.g, SMS/MMS) messages from Wunderkind at any time by replying “STOP” to any SMS message you receive from Wunderkind.  For help, reply “HELP” to any SMS message you receive from Wunderkind.  In addition to any fee of which you are notified, your mobile provider’s standard message and data rates may apply to the SMS message correspondence with Wunderkind according to your individual rate plan provided by your wireless carrier.  Please consult your mobile service carrier’s pricing plan to determine the charges for browsing data and sending and receiving SMS messages.  Under no circumstances will Wunderkind or Wunderkind’s affiliates be responsible for any SMS messaging or wireless charges incurred by you or by a person that has access to your wireless device or telephone number. If your carrier does not permit SMS messages, you may not receive the SMS messages.

 

The Identity Platform

The Identity Platform is designed to enable our Clients to activate their data in and across any marketing channel. Our Clients provide us with their customer emails lists and other PII, and we hash that PII for each customer into a pseudonymous ID. Our Clients may also provide us with demographic, purchase and site visit data for their customers, and that data is only used as directed by each Client.  Where our systems see that same user visit Client Digital Properties via different browsers and devices, we process the hashed email addresses, cookie IDs, mobile advertising o/s IDs and other pseudonymous identifiers in order to help us understand whether two devices are likely to be used by the same User or household. For example, where a User opens an email and we are able to place a cookie on that User’s browser, we may be able to determine that this was the same User that had recently visited and logged into our Client’s website. Once we’ve established that linkage, we may use the information across Clients to enable Clients to more effectively recognize Users via these pseudonymous identifiers, and to enable Clients to leverage the data collected from their Digital Properties as well as their customer demographic data.  This technology enables us to identify browsers and devices over time and across different websites via the Identify Platform while ensuring that each Client’s customer demographic and targeting data remain under the control of each individual Client. Wunderkind may use machine learning via data collected across Client Digital Properties to optimize ad and message timing and to use data to target ads and marketing messages to users inferred interests. We also may enable Clients to leverage those pseudonymous identifiers to purchase advertising on the Wunderkind Performance Advertising Platform as well as digital media platforms owned and operated by third parties.

 

The Performance Advertising Platform

Wunderkind also operates a Performance Advertising Platform that enables our Clients to both create and utilize interest segments (e.g., frequent shopping, interest in fishing) from data collected across multiple non-affiliated websites or mobile apps in order to deliver more relevant ads to your browser or device. These segments are provided to us by Clients based on their customer interactions with each Client (e.g., visits to Client sites). The segments may also include data provided by third-party data partners. The segments are attached to one or more pseudonymous identifiers described below for the purpose of delivering, customizing and reporting on advertising messages purchased via digital media platforms.

 

The Audiences Platform

The Audiences Platform is a personalization platform that acts as a central repository for Client marketing data and enables our Clients to activate that data to send marketing messages. Such marketing messages are determined by each client based on automated triggers (e.g., when a user abandons a digital shopping cart) as well as via recurring sends (e.g., monthly emails to a Client’s best customers). Wunderkind collects email addresses and other PII such as telephone number via the Audiences Platform and use this data as directed by each Client. Our systems may access this information automatically as each data point is entered by a user into a particular web form in accordance with applicable law. We combine this PII with pseudonymous information also collected via Client Digital Properties such as a Client’s User ID, mobile o/s advertising ID, hashed user emails and/or other pseudonymous IDs to help our Clients with conversion tracking, site optimization and conversion. Wunderkind may use machine learning via data collected across Client Digital Properties to optimize ad and message timing and to use data to target ads and marketing messages to users inferred interests. Wunderkind and our Clients may also use this information to send customized and retargeted email, text (e.g., SMS/MMS) marketing messages to our Clients’ customers and prospective customers and we may use aggregate information to improve all of our Platforms, products or Services.

 

Our Services Dashboard

Employees of our Clients (“Client Personnel”) may provide contact information, such as their name and email addresses, in the Services Dashboard. We may use such contact information to message those Client Personnel to inform them about new releases, new functionality or services, training or other events being offered by Wunderkind that may be of interest to users of our Services, to provide important information about the Services (such as dates and times for scheduled maintenance), and for other purposes consistent with our ability to provide our Services and keep our Clients informed about our Services.

 

Additionally, when Client Personnel access or use the Services Dashboard, we will track and collect usage data, such as the date and time they visited the Services Dashboard, what information and data have been accessed via the Services Dashboard and other interactions they may have with the Services Dashboard. Wunderkind may use such data to determine the performance of the Services Dashboard, analyze how users of the Services Dashboard are utilizing our Services, identify potentially fraudulent or malicious activity, and for other purposes consistent with our ability to provide our Services and maintain or improve the Services Dashboard.

 

Profile Segments by the Wunderkind Platforms 

Some of The Wunderkind Platforms processes data to draw inferences about Users based upon website visits and mobile app usage. Some of our Platforms also help our Clients collect email addresses and telephone numbers. We use the collected information to help our Clients engage their site visitors and bolster their advertising programs. Some examples of behaviors which generate profiles include: whether or not a visitor has visited a particular website, purchased something from that website, interacted with certain ads or other features placed on the website and/or submitted their email address to the website. As noted above, we may use machine learning via data collected across Client Digital Properties to optimize message timing and to use data to target ads to users inferred interests. To that end, our systems may create profile segments generated via artificial intelligence (AI). When we use AI in this way, we take steps to: (a) evaluate the privacy risks (if any) so that they may be mitigated, (b) roll-up any profiles created into broad commercial topics which don’t identify any individual Client, and (c) stop using the AI for users that have requested that we stop. We don’t create profiles which are considered sensitive or high risk under applicable law, and we don’t sell data collected via our Platforms except as otherwise indicated. The profiles created by our Platforms enable our Clients to offer a more engaging experience when you visit their websites and help our Clients serve targeting advertising messages on other websites.

 

The Tracking Technologies used by our Platforms and our Services

Our Platforms and our Services may utilize tracking technologies such as pixel tags, HTML5 cookies, HTTP cookies, web beacons, statistical identifiers, and mobile o/s advertising identifiers such as Apple’s IDFA, the Android Advertising ID and other pseudonymous information. For more information about cookies and web beacons, please visit allaboutcookies.org. Statistical identifiers are created when our systems read pseudonymous information about your computer or device, including the user agent, IP address, and the browser and operating system of your computer and device. We call this statistical identifier a “BxID”. Statistical identifiers enable our systems to determine within a reasonable level of certainty that they are encountering the same computer or device, including in environments where third-party cookies are not supported. If you would like to reset the value of this identifier, you may do so here. More information on this reset functionality under “choice mechanisms”  below.

 

How We May Transfer the Information We Gather to Third Parties

Generally, we will not disclose the PII that we collect through your use of our Websites or the Services Dashboard to unaffiliated third parties without consent.  We reserve the right, however, to provide such information to our affiliates, employees, contractors, agents, service providers and designees to the extent necessary to enable them to perform certain services for us, including order fulfillment and Website-related services such as web hosting, to improve Website-related services and features, to perform maintenance services, to distribute advertisements and other marketing materials on our behalf and to host our data. Other third-party service providers used by Wunderkind include: a) cloud computer, data storage and file storage providers, b) email marketing providers, c) website and b2b sales analytics providers, d) customer relationship management, contact database vendors, data hygiene vendors, survey vendors and project management software providers, e) customer billing systems partners, f) login authentication providers to ensure that the logins to our systems are working efficiently, g) social media platforms for advertising and marketing purposes, h) outsourced computer programmers helping ensure our systems are operating properly, i) auditing, debugging and security vendors. These agents work on our behalf and use data only as directed by us under written agreements which outline how they may use such data and require that such third party agents provide at least the same level of privacy protection as we do.

 

Wunderkind may transfer data collected through Wunderkind’s Website, and our marketing activities to entities such as: (i) website analytics vendors, who collect cookie and website engagement information to help understand website performance, (ii) advertising vendors, who collect cookie and website engagement information to target relevant advertising, and (iii) email marketing and lead database vendors, who collect email address and other personal information to improve email marketing efforts. We also may transfer some of the data collected via the Services Dashboard to analytics vendors. Some of the transfers to these entities would constitute a sale or sharing of personal information under applicable law.

 

Our Platforms are designed to interact with a number of other affiliated technology platforms as described here. While we don’t operate a data marketplace, some of the transfers of data from the Platforms may be considered a sale of personal information under certain jurisdictions in the U.S. such as the state of California. For example, where we use the Identity Platform to create pseudonymous IDs to identify browsers and devices, we enable the use of those pseudonymous IDs across multiple Clients. Where we are acting as an agent (i.e., a service provider / data processor) for our Clients, we will transfer information as directed by such Clients. This collection and use is generally subject to our respective Clients’ privacy policies, not ours. We also reserve the right to disclose any information that we collect to any third party if we believe that we are required to do so for any or all of the following reasons: (i) to comply with the law; (ii) to comply with legal processes or governmental requests including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our Websites or our network; and/or (iv) to protect the rights, property, safety and security of Wunderkind and its employees, our Websites’ visitors, and/or the public. Finally, we may transfer information, including any PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change and will provide notice of such change on our Websites.

 

We also may aggregate the data processed by our Website and Platforms in order to derive insights across our Clients. For example, we may publish a report that reflects aggregated statistics regarding seasonal trends in shopping patterns or outlining differences between different retail verticals. By aggregating this data, we have removed any identifiable or pseudonymous personal data.

 

Choice Mechanisms

Wunderkind supports high standards for digital privacy. We enable Users to opt-out from our Identity Platform (including cross-device linking), our Performance Advertising Platform and from our creation of profile segments as described below. Where our transfer of data to a third-party would be deemed a sale under applicable law, we offer a notice and the opportunity to opt-out from such sales.

 

Web based Opt-Out Choice Mechanisms. You can opt-out of our Identity Platform and our Interest Based Ads Platform on your browser as follows:

• You can visit Wunderkind’s opt-out page at https://www.wunderkind.co/privacy/opt-out-of-data-processing/.
• You can visit the Network Advertising Alliance self-regulatory opt-out page at https://optout.networkadvertising.org/?c=1#!/to opt-out and to see whether Wunderkind is using non-cookie based technology  on the browser you are currently using. You should select the “opt out” button there for Wunderkind.
• You can visit the Digital Advertising Alliance self-regulatory program opt-out page at https://optout.aboutads.info/?c=2&lang=EN. You should select the “opt out” button there for Wunderkind. When our systems detect that you’ve opted out via this method from a browser or device located in the EEA or UK, we will treat your opt-out request as a request for Wunderkind to stop collecting or processing data associated with this browser in accordance with EU/UK data protection law.
• Some of the advertisements we deliver via the Platforms and Services will contain the advertising option Icon, a symbol that we license from the Digital Advertising Alliance. If you click onto the advertising option icon, you will be taken to a page like this page where you will see behavioral advertising and other types of targeted advertising, including a mechanism that enables you to opt-out from Wunderkind’s use of data for targeted advertising.
• Each of the above opt-out mechanisms will also opt you out from Wunderkind’s sale as “sale” is defined under applicable law.

When you opt out via the web-based choice mechanisms described above, we will attempt to place an opt-out cookie that instructs us not to use information about your browser for IBA on our Identity Platform and our Performance Advertising Platform.

 

If your browsers are configured to reject cookies when you visit our opt-out page, we cannot set our no-track / opt-out cookie. Also, this choice mechanism is only applicable to the browser you are using, so if you subsequently erase your cookies, use a different computer or change web browsers, you will need to opt-out again.

 

Statistical device ID reset. Wunderkind may also create a non-cookie based system created pseudonymous identifier (a “BxID”) which is used enable are systems to more effectively recognize a browser over time. Information collected as outlined in “The Types of Information that We Collect” may be associated to this identifier over time. If you would like to reset the value of this identifier, you may do so here. Note that any new data collected after resetting your identifier may resemble data previously collected if you engage in similar activities on websites.

 

Mobile App Opt-out Choice Mechanism. Where we process pseudonymous mobile ad IDs, we honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). The NAI maintains a helpful list of opt-out mechanisms for mobile operating system platforms which you may find here. For devices where we are able to see that such a selection has been made, we will not use information collected about your mobile app usage on our Identity Platform and our performance advertising  Platform. This choice mechanism is only applicable to the apps you are using on your current mobile device.

 

Precise Location Choices.  While we don’t generally collect or otherwise process precise location data such as lat/long, we offer the following information as a courtesy. If you’d like to adjust your choices regarding the use of precise location data by third parties, you may do so via your device settings. For your convenience, we provide links to instructions for both Apple iOS and Android devices. Also, most mobile applications that collect precise location information offer mechanisms to control the collection and use of precise location information. Please note that these choice mechanisms won’t impact previously collected precise location information.

 

Some of our Clients may utilize third-party advertisers on their websites. These third-party advertisers generally collect pseudonymous information across multiple non-affiliated websites and mobile apps to create interest segments for ad targeting and content customization purposes. This practice is sometimes referred to as interest based advertising (“IBA”) or online behavioral advertising (“OBA”) and is distinct from the Behavioral Automation Platform and Identity Platform offered by Wunderkind.  To learn more about third-party advertising companies and your choices regarding how that information is used, please visit https://thenai.org/opt-out/, https://optout.aboutads.info/?c=2&lang=EN  or https://youronlinechoices.com/.

 

While our systems may be able to recognize a Do Not Track (DNT) setting in a browser or similar opt-out preference signals, we currently take no response to such signals unless required to do so by law.

 

Wunderkind ensures that text (e.g., SMS/MMS), email, and similar direct marketing messages sent using our behavioral automation Platform contain a choice mechanism as required by applicable law.

 

Children’s Privacy

Wunderkind adheres to the Children’s Online Privacy Protection Act. Our Websites are not directed at children. If we are made aware that we have received personally identifiable information from someone under 18, we will use reasonable efforts to remove that information from our records.

 

We are Committed to Making Sure Your Information is Protected

Our physical, electronic, and procedural safeguards meet or exceed current industry standards regarding the protection of the information in our systems.  We also require contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us.  Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure.  Consequently, while we use commercially reasonable efforts to protect information in our systems, we cannot guarantee the absolute security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Websites or Platforms.  Any information that you provide to us is done so entirely at your own risk.

 

Data Minimization and Retention

Wunderkind has internal procedures which are designed to ensure that we only process the minimum data as requested by Clients. We retain the IBA data that we collect for up to 13 months from the date of collection. Cookies used for IBA expire 13 months after they are last updated. EU data subjects may have additional rights or information as described below.

 

Data Subject Access Rights

Upon request, Wunderkind will provide you with information about whether we hold any of your PII. If you’d like to update, correct, delete, or deactivate any PII that you have provided to the company on this Website, please send your request to privacyrequests@wunderkind.co, and we will process your request. We will respond to your request to access within a reasonable timeframe. EU and California data subjects may have additional access rights as described below.

 

We Reserve the Right to Update and Revise this Privacy Policy at Any Time.

From time to time, we review this Privacy Policy to ensure that it complies with applicable law.  Consequently, we reserve the right to update and revise this Privacy Policy at any time.  You will know if this Privacy Policy has been revised since your last visit to the website by referring to the “Effective Date of Current Policy” date at the top of this page.  Your use of our Websites constitutes your notice and acceptance of the terms of the Privacy Policy as amended or revised by us from time to time, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.

 

In the Event We Engage in a Business Combination, We Reserve the Right to Transfer Any Information in Our Systems.

If we sell all or any part of our business or sell or transfer all or a material part of our assets or are otherwise involved in a merger or other transfer or disposition of any part our business, we reserve the right to access, transfer or disclose any and all information that we collect from our Websites’ visitors, or that we otherwise collect in connection with the Websites or Platform, to the party or parties involved in the transaction as part of that transaction.

 

U.S. DATA SUBJECTS IN APPLICABLE STATES

Certain U.S. States each provide additional privacy protections for data subjects located within their jurisdictions, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete), c) the right to correct data we have about you, your computer or device,   d) the right to opt-out of the sale or sharing of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales or sharing of your information), e) the right to opt-out of profiling decisions and/or targeted advertising about you, your computer or device, and fe) the right to port such data to a different company. We do not
discriminate against you if you exercise any of the above rights. Data subjects located in Colorado or Virginia also may have the right to appeal on privacy grounds our response to certain of your requests, and may be able to further complain to the attorney general located in your state. Moreover, with respect to data subjects in these places, PII (sometimes referred to as personal information) includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID.  While we attempt to honor these rights for data subjects located in all U.S. states, please note that we may not be able to honor a right if doing so would otherwise violate applicable law. Further details about exercising these rights can be found on our data
request page.  Data subjects may access those rights with respect to Wunderkind by calling our toll-free California privacy hotline at (888) 594- 0111 or sending us an email to privacyrequests@wunderkind.co.

 

Below is the details about privacy requests received by Wunderkind in the applicable year:

 

2023	Received	Complied	Denied
Requests to know	164	164	0
Requests to Delete	53,961	53,961	0
Requests to Opt-out	7201	7201	0

 

 

The median number of days within which Wunderkind substantively responded to requests to know, requests to delete and requests to opt-out: 10 days, 10 days, and 10 days. However, requests to opt-out which are made via an opt-out link are honored in real time.

We collect the categories of personal information about California consumers identified in the chart below. The below is designed more as a summary. More information regarding the personal information we collect can be found throughout this privacy policy.

Categories of Personal Information	Examples	Collected in Prior 12 Months
A. Personal and online identifiers.	A real name, alias, unique personal identifier, online identifier Internet Protocol address, email address, account name, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, telephone number, education, employment, or employment history. Some personal information included in this category may overlap with other categories.	Yes. Employment information covered in a separate policy.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, sex (including gender, gender identity, or gender expression), veteran or military status, or genetic information.	No, although our Clients may direct us to indicate that a particular user is male or female.
D. Commercial or transactions information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history.	Yes. Employment information covered in a separate policy.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No

Categories of Sources
We collect personal information from, without limitation, consumers directly, our Clients, via our Platforms and Services, service providers, and public sources. More information regarding the sources from which we collect personal information can be found above in the section titled “What Information We Collect.”

Special Data Protections for EU, UK and Brazil Data Subjects.

The General Data Privacy Regulation (“GDPR”) and similar country specific data protection laws afford additional rights to data subjects located in applicable jurisdictions such as the European Economic Area, the United Kingdom and Brazil:

• requesting information about the processing of your data, as well as the receipt of a copy of your personal data;
• correcting your data;
• deleting or blocking your data;
• restricting the processing;
• objecting to the processing of your data;
• revoking your consent to the processing of your data in the future, and
• complaining to the competent supervisory authority about inadmissible data processing.

 

These rights can be exercised by visiting our data request page. Moreover, with respect to data subjects in these places, PII (sometimes referred to as personal data) includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID.  Where Wunderkind is a processor of data (e.g., via the Behavioral Automation or Ad Serving Platforms), the legal basis for processing such data and the retention period is determined by our Clients. Where Wunderkind is a controller of data (e.g., via the Performance Advertising or Identity Platforms to the extent we choose to operate those platforms in the EU), the legal basis will be both legitimate interest (e.g., where we have evaluated that our interests are not overridden by Users’ fundamental rights) and consent depending on the type of information subject to processing and the information we receive from upstream partners. Where Wunderkind receives a request to cease processing of data from a data subject located in the EU or Switzerland, Wunderkind will stop all data processing with respect to the opted-out browser or device unless such processing is required by law. Wunderkind’s Data Protection Officer is Alan Chapell and Wunderkind’s EU representative is Verasafe and both may be contacted at dpo@wunderkind.co or by mailing to the address found below. Wunderkind’s UK contact details are also provided below.

 

Cross-border data transfers between the EU, Switzerland, UK and the U.S.

Wunderkind is based in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as those of your country of residence.  Wunderkind complies with legal requirements for cross-border data protection, including through the use of European Commission-approved Standard Contractual Clauses and similar contract language required under applicable data protection laws.

Certain U.S. States each provide additional privacy protections for data subjects located within their jurisdictions, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete), c) the right to correct data we have about you, your
computer or device,   d) the right to opt-out of the sale or sharing of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales or sharing of your information), e) the right to opt-out of profiling decisions and/or targeted advertising about you, your computer or device, and fe) the right to port such data to a different company. We do not
discriminate against you if you exercise any of the above rights. Data subjects located in Colorado or Virginia also may have the right to appeal on privacy grounds our response to certain of your requests, and may be able to further complain to the attorney general located in your state. Moreover, with respect to data subjects in these places, PII (sometimes referred to as
personal information) includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID.  While we attempt to honor these rights for data subjects located in all U.S. states, please note that we may not be able to honor a right if doing so would otherwise violate applicable law. Further details about exercising these rights can be found on our data
request page.  Data subjects may access those rights with respect to Wunderkind by calling our toll-free California privacy hotline at (888) 594-0111 or sending us an email to privacyrequests@wunderkind.co.

In cases of onward transfer to third parties of data of EU, UK or Swiss residents received pursuant to the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, Wunderkind is responsible for the processing of personal information it receives under the above listed DPF programs and subsequently transfers to a third party acting
as an agent on its behalf. Wunderkind shall remain liable under the above listed DPF programs if its agent processes such personal information in a manner inconsistent with the DPF program principles, unless Wunderkind demonstrates that it is not responsible for the event giving rise to the damage.

Wunderkind has certified that it adheres to the DPF program principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies of this privacy policy and the DPF program principles, the DPF program principles shall govern. To learn more
about the DPF programs, and to view our certification page, please visit https://www.dataprivacyframework.gov/s/.

In compliance with the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Wunderkind commits to resolve complaints about your privacy and our collection or use of your personal data. European Union, UK or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Wunderkind at privacyrequests@wunderkind.co.  We will make every effort to resolve your concerns. Alternatively, you may contact us at the address below:

 

Wunderkind Corporation

Attn: Privacy Officer

1 World Trade Center, FL 74

New York, NY 10007

If a privacy complaint or dispute relating to PII received by Wunderkind in reliance of the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, or the Swiss-U.S. DPF (or any of its predecessors) that cannot be resolved through our internal processes, we have agreed to participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/public-resources/dispute-resolution/submit-dispute/

Should your complaint remain fully or partially unresolved after a review by Wunderkind, BBB Data Privacy Framework Program and the relevant DPA, you may be able to, under certain conditions, seek binding arbitration before the Data Privacy Framework Panel. For more information, please visit https://www.dataprivacyframework.gov/s/european-individuals. Wunderkind is subject to the investigatory and enforcement powers of the Federal TradeCommission (FTC).

Our Websites may Contain Links to Other Websites.
Please be aware that we are not and cannot be responsible for the privacy practices of any websites that you access through our Websites and that this Privacy Policy applies solely to the information which we collect.  We encourage you to ensure that you read the privacy statements of all the destination websites which you visit.
 
Changes to This Privacy Policy
This Policy may be amended from time to time, consistent with applicable laws. When we do, we will also revise the “Last Updated” section above. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the information we collect.
 
Contact Wunderkind Regarding Our Privacy Practices.
If you have any questions or concerns regarding this Privacy Policy, please contact us at privacyrequests@wunderkind.co.  We will make every effort to resolve your concerns. Alternatively, you may contact us at the address below:

TCF Compliance Statement.
We participate in the Transparency and Consent Framework (TCF) v2.2, developed by IAB Europe, and adhere to its policies. Our Vendor ID is 256. The TCF is designed to help ensure transparency, choice, and control over how data is used for online behavioral advertising purposes. For more information about the TCF, please visit https://iabeurope.eu/transparency-consent-framework/.

Wunderkind Corporation

Attn: Privacy Officer
1 World Trade Center, FL 74
New York, NY 10007

Wunderkind UK:

16 Dufour’s Place
London
W1F 7SP

 

UK GDPR Representative:

Wulfric Light-Wilkinson

General Manager, EMEA

Email: privacyrequests@wunderkind.co