Last Updated: April 23, 2025

Effective Date: April 7th, 2025

This Privacy Notice for Plumwheel, LLC (”we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (”process”) your personal information when you use our services (”Services”), including when you:

  • Visit our website at plumwheel.com, or any other site of ours that links to this Privacy Notice

  • Use our client portal or any digital interface we provide (not a public app)

  • Engage our team for short-form video production and social media services, including:

    • Guided on-camera interviews

    • Video editing and strategy development

    • Social media post generation and scheduling

    • Client portal engagement, where you can approve content, view analytics, and communicate with our team

  • Interact with us in other related ways — including sales, inquiries, or events

Questions or concerns?

Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, contact us at privacy@plumwheel.com.

SUMMARY OF KEY POINTS

This summary highlights key points from our Privacy Notice. You can find more detail in the sections that follow or by referring to our table of contents.

What personal information do we process?

We process limited personal information that you provide directly — for example, your name, email, social media links, or preferences related to content and publishing.

Do we process any sensitive personal information?

No. Plumwheel does not collect or process any sensitive personal information, such as data related to health, racial or ethnic origin, sexual orientation, or religious beliefs.

Do we collect any information from third parties?

No. We do not collect personal data from third parties. All data comes from your direct use of our Services.

How do we process your information?

We process your information to:

  • Provide and maintain our Services

  • Communicate with you directly

  • Enhance content personalization

  • Protect against fraud, misuse, or unauthorized access

  • Comply with legal obligations

We will only process your information when we have a valid legal reason, such as your consent or our legitimate business interests. Learn more about how we process your information.

In what situations and with which parties do we share personal information?

We may share your personal information:

  • With service providers who help deliver our services (e.g., cloud storage, email services)

  • To comply with legal obligations

  • To protect our rights, privacy, or safety

    Learn more about when and with whom we share your personal information.

How do we keep your information safe?

We use organizational and technical safeguards to protect your data. However, no digital system is completely secure, and we cannot guarantee protection from all unauthorized access. You should also take precautions when submitting personal information online.

Learn more about how we keep your information safe.

What are your rights?

Depending on your location, you may have rights under privacy laws, such as:

  • Accessing your data

  • Correcting or deleting your information

  • Withdrawing consent or objecting to processing

    Learn more about your privacy rights.

How do you exercise your rights?

You can submit a request by contacting us directly at privacy@plumwheel.com

We’ll respond in accordance with applicable privacy laws.

Want to know more?

For full details, review the Privacy Notice in full below.


1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: We collect personal information that you provide to us voluntarily.

We collect personal information when you express interest in learning more about us or our services, participate in our offerings, or otherwise contact us directly.

Personal Information Provided by You

The specific personal information we collect depends on how you interact with us and the choices you make. It may include:

  • Phone numbers

  • Names

  • Email addresses

  • Job titles

  • Contact preferences

  • Contact or authentication data

  • Company name

  • LinkedIn URL

Sensitive Information: We do not collect or process any sensitive personal information (e.g., health data, racial or ethnic origin, political opinions, etc.).

All information you provide must be accurate, complete, and up to date. You are responsible for notifying us of any changes to your personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with legal obligations. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate delivery of services to the user.

    We process your information to provide the services you requested.

  • To respond to user inquiries / offer support to users.

    We process your information to reply to questions and help resolve any support issues.

  • To send administrative information to you.

    We process your data to send updates about our services, terms, policies, or other relevant notices.

  • To fulfill and manage your orders.

    We may process your information to support invoicing, orders, or billing as part of service delivery.

  • To request feedback.

    We use your information to ask for feedback and assess how we can improve our Services.

  • To send you marketing and promotional communications.

    If you’ve opted in, we may use your data to send promotional emails or other content. You can unsubscribe at any time.

  • To identify usage trends.

    We may analyze how users interact with our platform to improve usability and performance.

  • To determine the effectiveness of our marketing and promotional campaigns.

    We assess user behavior and campaign performance to improve our marketing strategies.

  • To save or protect an individual’s vital interest.

    In rare cases, we may process your data to prevent harm to you or someone else.

  • Information shared for service delivery.

    We process information in the course of brand strategy sessions, content scheduling, interview management, and creation of short-form videos for social media platforms.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In short: We only process your personal information when we believe it is necessary and have a valid legal reason (i.e., a legal basis) to do so under applicable law. This may include your consent, performance of a contract, legal compliance, protection of vital interests, or our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

Under the General Data Protection Regulation (GDPR) and UK GDPR, we rely on the following legal bases to process your personal information:

  • Consent.

    We may process your data if you’ve given us permission to do so for a specific purpose. You may withdraw this consent at any time. Withdraw your consent.

  • Performance of a Contract.

    We may process your information to fulfill a contract with you, such as providing services or responding to pre-contract inquiries.

  • Legitimate Interests.

    We may process your information if it is necessary for our legitimate business interests and these do not override your rights. Examples include:

    • Sending promotional offers or updates

    • Analyzing usage to improve services

    • Supporting internal marketing strategies

    • Understanding user behavior for better service delivery

  • Legal Obligations.

    We may process your data when required to do so by law or to comply with a regulatory obligation (e.g., cooperating with authorities, defending legal claims).

  • Vital Interests.

    We may process your data if it is necessary to protect you or someone else’s life or safety — for example, in emergencies.

If you are located in Canada, this section applies to you.

We may process your data under the following bases:

  • Express Consent.

    When you explicitly agree to our use of your data for a specific purpose.

  • Implied Consent.

    When your actions imply consent (e.g., submitting a contact form or signing up for services).

You may withdraw your consent at any time. Withdraw your consent.

In exceptional cases, we may still be permitted to process your information without consent, such as:

  • When it is in the interest of an individual and consent cannot be obtained in a timely way.

  • It is clearly in the interest of an individual and consent cannot be obtained in a timely way

  • It is necessary for investigations and fraud detection or prevention

  • It relates to business transactions, provided certain legal conditions are met

  • It is included in a witness statement and needed to assess, process, or settle an insurance claim

  • It helps identify injured, ill, or deceased individuals and allows for next of kin communication

  • We have reasonable grounds to suspect someone has been, is, or may be a victim of financial abuse

  • Obtaining consent would compromise the accuracy or availability of the information in the context of an investigation

  • Disclosure is required to comply with a subpoena, warrant, court order, or other legal process

  • The information was produced by an individual in their professional or employment capacity and is collected for consistent purposes

  • It is solely for journalistic, artistic, or literary purposes

  • The information is publicly available and specified by regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We may share information in specific situations described below and/or with the following third parties.

We may need to share your personal information in the following situations:

  • Business Transfers.

    We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or part of our business by another company.

Note: We do not sell your personal data to third parties. Any transfer of information is limited to what is necessary for delivering services or required by law.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies such as web beacons or pixels to gather data when you interact with our website or client portal. These technologies help us:

  • Improve service performance and security

  • Prevent errors and fix bugs

  • Retain user preferences

  • Support essential website functionality

We may also allow third-party service providers to use tracking technologies for:

  • Analytics and performance (e.g., how users interact with our Services)

  • Advertising (e.g., tailoring ads to your interests or remarketing campaigns)

These third parties may display ads based on your browsing behavior on our site or others. You may be able to control cookie preferences through your browser settings or opt-out mechanisms provided by ad networks. 

To the extent these online tracking technologies are deemed to be a “sale” or “sharing” (including for targeted advertising as defined under applicable U.S. state laws), you can opt out by submitting a request as described in the section:

“DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

For more detailed information about how we use cookies and how you can control or refuse them, please refer to our full Cookie Notice: http://www.plumwheel.com/cookies

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers (“AI Service Providers”), including Anthropic, Perplexity, and OpenAI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in “WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?”.

You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

  • AI automation

  • AI document generation

  • Text analysis

  • Video analysis

  • Video generation

  • AI insights

  • AI search

  • AI research

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreements with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data’s safety.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request.

We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@plumwheel.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:

  • (i) to request access and obtain a copy of your personal information,

  • (ii) to request rectification or erasure,

  • (iii) to restrict the processing of your personal information,

  • (iv) if applicable, to data portability, and

  • (v) not to be subject to automated decision-making.

In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your

Member State data protection authority or the UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can do this by contacting us using the details provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

Please note that withdrawing your consent will not affect the lawfulness of processing before its withdrawal, nor will it affect processing conducted under other lawful bases.

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional emails at any time by clicking the unsubscribe link or contacting us using the details in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”. You will be removed from the marketing list, but we may still send you service-related communications (e.g., security, service requests, account notifications).

Cookies and similar technologies:

Most web browsers are set to accept cookies by default. You can usually remove or reject cookies via your browser settings. Rejecting cookies may affect the functionality of the Services.

For more, please see our Cookie Notice: http://www.plumwheel.com/cookies

Contact Us:

If you have questions or comments about your privacy rights, email us at privacy@plumwheel.com.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

A. Identifiers: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name (YES)

B. Personal information: as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial information (YES)

C. Protected classification characteristics under state or federal law: Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data (YES)

D. Commercial information: Transaction information, purchase history, financial details, and payment information (YES)

E. Biometric information: Fingerprints and voiceprints (NO)

F. Internet or other similar network activity: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements (NO)

G. Geolocation data: Device location (NO)

H. Audio, electronic, sensory, or similar information: Images and audio, video or call recordings created in connection with our business activities (YES)

I. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us (YES)

J. Education Information: Student records and directory information (NO)

K. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics (YES)

L. Sensitive personal information (NO)

Additional Personal Information Collection

We may also collect other personal information outside of the listed categories when you interact with us in person, online, by phone, or mail. These include:

  • Receiving help through our customer support channels

  • Participation in customer surveys or contests

  • Facilitation in the delivery of our Services and responding to inquiries

Retention of Personal Information

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - As long as the user has an account with us

  • Category B - As long as the user has an account with us

  • Category C - As long as the user has an account with us

  • Category D - As long as the user has an account with us

  • Category H - As long as the user has an account with us

  • Category I - As long as the user has an account with us

  • Category K - As long as the user has an account with us

Will your information be shared with anyone else?

  • Your information may be disclosed to service providers under contract.

  • More about this is covered in:

    “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

We may also use your personal information for our own business purposes, such as internal research or product development. This is not considered a “sale” of your data.

Important Note:

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the past 12 months, and we do not intend to.

Your Rights

Under certain US state privacy laws, you may have rights which include:

  • Right to know whether we are processing your personal data

  • Right to access your personal data

  • Right to correct inaccuracies in your personal data

  • Right to request deletion of your personal data

  • Right to obtain a copy of your personal data

  • Right to non-discrimination for exercising your rights

  • Right to opt out of the processing of your personal data if it’s used for targeted advertising, the sale of personal data, or profiling that produces legal or significant effects (per laws like California’s).

Depending on your US state of residence, you may have the following additional rights:

  • Right to access the categories of personal data being processed (e.g., Minnesota).

  • Right to obtain a list of third-party categories to which personal data has been disclosed (e.g., California, Delaware, Maryland).

  • Right to obtain a list of specific third parties to which personal data has been disclosed (e.g., Minnesota, Oregon).

  • Right to review, understand, and correct profiling decisions (e.g., Minnesota).

  • Right to limit the use or disclosure of sensitive personal data (e.g., California).

  • Right to opt out of the collection of sensitive data via voice/facial recognition features (e.g., Florida).

How to Exercise Your Rights

You can exercise your rights by emailing: privacy@plumwheel.com

If applicable under state law, you may designate an authorized agent to act on your behalf. The agent must provide proof of authorization, or your request may be denied.

Request Verification

When you submit a request:

  • We must verify your identity to confirm you are the person whose data is in our system.

  • We may ask for additional verification if necessary for security or fraud prevention.

  • If submitted by an authorized agent, we may request a written and signed authorization.

Appeals Process

If we deny your request under US state privacy laws:

  • You may appeal by emailing privacy@plumwheel.com

  • We will respond with a written explanation for any decision.

  • If your appeal is denied, you may escalate the matter to your state attorney general.

California “Shine The Light” Law

Under California Civil Code Section 1798.83, also known as the “Shine The Light” law, California residents have the right to request and obtain, once per year and free of charge, the following information:

  • Categories of personal information (if any) disclosed to third parties for direct marketing purposes

  • Names and addresses of all third parties with whom personal information was shared during the previous calendar year

If you are a California resident and wish to make such a request, please submit it in writing using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.

14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process personal information under the obligations and conditions of:

  • Australia’s Privacy Act 1988

  • New Zealand’s Privacy Act 2020

This Privacy Notice complies with both Acts by explaining:

  • What personal information we collect

  • From which sources

  • For which purposes

  • With whom we share it

If you choose not to provide necessary personal information, this may limit our ability to:

  • Offer products or services you want

  • Respond to or help with your requests

You have the right at any time to request access to or correction of your personal information.

You can do so by using the contact details in the section:

“HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you believe we are unlawfully processing your data, you may submit a complaint to:

Republic of South Africa

You have the right at any time to:

  • Request access to your personal information

  • Request correction of your personal information

You can do this by contacting us through the section:

“HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you’re not satisfied with our response, you may contact:

The Information Regulator (South Africa)

  • General enquiries: enquiries@inforegulator.org.za

  • Complaints:

    • PAIAComplaints@inforegulator.org.za

    • POPIAComplaints@inforegulator.org.za

15. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes, we may notify you by:

  • Posting a notice of such changes prominently, or

  • Sending you a direct notification.

We encourage you to review this Privacy Notice frequently to stay informed about how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions or comments about this notice, you may contact us at:

📧 Email: privacy@plumwheel.com

📫 Mail:

Plumwheel, LLC

418 Broadway SRE N

Albany, NY 12207

United States

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to:

  • Access the personal information we collect from you

  • Understand how we have processed it

  • Correct inaccuracies

  • Delete your personal information

  • Withdraw consent to processing

These rights may be limited under certain legal conditions. To exercise any of these rights, please email: privacy@plumwheel.com

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