L36 Media LLC Privacy Policy


Last Updated and Effective Date:  7/7/25


L36 Media LLC and its affiliated subsidiaries (collectively, “L36”, “we”, “us”, or “our”) are committed to respecting the privacy and confidentiality of Personal Data. Please read this Privacy Policy (“Privacy Policy”) carefully. It provides information about how L36 collects, uses, discloses, and otherwise processes Personal Data when you visit, access, or use our Services (defined below). From time to time, we may update this Privacy Policy as described in the Changes to this Privacy Policy section below.

Please also review the applicable Terms of Service for each Service (defined below). Terms that are defined in the applicable Terms of Service have the same meaning in this Privacy Policy unless this Privacy Policy specifies differently.

If you have any questions, comments, or concerns, please contact us.

Table of Contents

  1. Scope of This Privacy Policy

  2. Personal Data We Collect and How We Use It

  3. How We Disclose Personal Data

  4. How Long We Retain Personal Data

  5. How We Protect Personal Data

  6. International Data Transfers

  7. Children’s Privacy

  8. Marketing Preferences

  9. Privacy Rights Requests for EEA and Non-US Residents

  10. California “Shine the Light” Disclosure

  11. Changes to this Privacy Policy

  12. Contact Us

  13. APPENDIX EEA AND NON-US RESIDENTS

  14. Cookie Policy


  1. Scope of This Privacy Policy

  2. Our Services

This Privacy Policy applies to Personal Data that L36 collects, uses, discloses, and otherwise processes when you: 

For purposes of this Privacy Policy, we refer to our Website, Products, and any other online service we provide that links to this Privacy Policy as the “Services.” Note that this Privacy Policy does not apply to or cover External Websites (see Out of Scope section below).

  1. Cookies 

This Privacy Policy covers how L36 uses and shares Personal Data captured by cookies and similar tracking technologies such as pixels (collectively, “Cookies”). Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. At this time, we do not respond to DNT signals. For more information about what cookies are and how to manage them, please review our Cookie Policy.

  1. Out of Scope

When engaging in our Services, we may provide links to third-party websites, resources, or features we do not have a contractual relationship with and over which we do not have control (collectively, “External Websites”), such as, websites for another unaffiliated company or integrated tools that enable you to share content via social media sites. This Privacy Policy does not apply to or cover External Websites. 


Such links for External Websites are not paid advertisements, nor do they constitute an endorsement by L36 of those External Websites. By clicking on links to the External Websites, the operators of the External Websites may collect Personal Data. We are not responsible for the content or data collection practices of those External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

  1. Personal Data We Collect and How We Use It

As used in this Privacy Policy, “Personal Data” or “Personal Information” means any information that identifies or could be used to identify an individual person. For example, Personal Data may include name, email address, and phone number. It also includes other non-public information that we associate with such identifying information. Personal Data does not include aggregated or anonymized information.

  1. Types of Personal Data

The types of Personal Data L36 collects are described below. Some privacy laws may use broader or different categories to describe these types of Personal Data.

Audio, Electronic, or Visual

Audio, electronic, or visual data includes photographs, images, and audio in connection with our Services. 


For example, this may include a profile photo if you provide one or audio recordings of calls.

Contact

Contact data includes billing address, residential address, email address and telephone numbers.

Financial

Financial data includes bank account and payment card details.


For more information about how Financial data is processed, please see the Payment Processors section below.

Geolocation

Geolocation data includes location coordinates when using a mobile device.

Identity

Identity data includes first name, middle name, maiden name, last name, title, tax ID, marital status, date of birth, gender, identity document number, nationality and any other information contained in any identification documents you provide to us (e.g. your passport or driver's license).

Inferences

Inferences include opinions, trends, assumptions, and similar derivative information drawn about an individual from other Personal Data. 


For example, we may generate inferences about the types of Services you might prefer based on other Personal Data we’ve collected about you.

Marketing Communications

Marketing communications data includes your preferences in receiving marketing from us and your communication preferences.

Professional

Professional data includes job title, company, work address, work email, and work telephone numbers.

Profile

Profile data includes your username or similar identifier, password, and your preferences.

Survey and Customer Feedback

Survey and customer feedback data includes information you provide in any survey or feedback forms on L36 Services.

Transaction

Transaction data includes details of your purchases, subscriptions, and registrations through the L36 Services, such as the amount, date, time, and recipient for each transaction.

Technical

Technical data includes log data, such as your internet protocol (IP) address, login data, and device data, such as browser type and version, time zone setting and location, browser plug-in types and versions, device identifiers, operating system and platform and other technology on the devices you use to access the L36 Services.

Usage

Usage data includes information about how you use the L36 Services such as features that you use, clickstream data, access dates and times, and how you interact with the Services. When you visit the Website, this information may also include referring / exit pages and URLs, how you interact with links on the Website, landing pages, and pages viewed. We also may collect the date and time you open an email communication from us or click on any links in an email, and we or our service provider may associate this information with the email address we already have from you.  

  1. Sources of Personal Data

The Personal Data we collect and how we collect it depends on how you use the Services. Personal Data may be collected:

  1. Purposes for Processing Personal Data

[L36 only processes Personal Data where there is a legal ground or lawful basis to do so, as described below. The applicable lawful basis depends on the Services you use and how you use them. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.]

We will only use your Personal Data for the purposes described below. If we need to use your Personal Data for a different purpose, we will notify you and we will explain the legal basis which allows us to do so.

You may choose not to provide Personal Data to us. However, some Personal Data is necessary so that we can provide you with the Services you have requested. Failure to provide this information may prevent us from providing you with access to our Services.


Purpose

Lawful Basis for Processing

Types of Personal Data Collected

Sources of Personal Data

Account Creation:

  • To register or create an account to use the Services

  • To verify identity and assess risk

  • Performance of a contract

  • Legal obligation

  • Contact

  • Identity

  • Inferences

  • Professional

  • Profile

  • Technical

  • Usage

  • Directly from you

  • Third-party sources

  • Automatically

Providing Services and Account Management:

  • To provide and operate the Services

  • To process and manage billing and payment for Services

  • To address  inquiries, support requests,and feedback

  • To provide notices, transactional updates, and other information to you about, or in connection with, our Services

  • To enforce our Terms of Service, resolve disputes or otherwise to carry out our obligations and enforce our rights, and to protect our business interests and rights of third parties

  • To keep you updated about changes to policies related to our Services (including this Privacy Policy)

  • Performance of a contract

  • Legitimate interest

  • Legal obligation

All types of Personal Data

  • Directly from you

  • Third-party sources

  • Automatically

Improving Services:

  • To conduct research and analytics related to the Services, such as to understand how they are being used and where improvements may be needed;

  • To personalize and improve user experience with the Services;

  • To update, improve, and/or enhance the Services, and develop new features, functionalities, and/or Services

  • To better understand your personal preferences and to enable us to provide you with improved and personalized communications

  • To compile aggregate data, such as about traffic and interaction with or on the Services

  • Performance of a contract

  • Legitimate interest

  • Contact

  • Identity

  • Inferences

  • Geolocation

  • Professional

  • Profile

  • Survey and Customer Feedback

  • Technical

  • Transaction

  • Usage

  • Directly from you

  • Automatically

Marketing:

To send you marketing communications and newsletters about us, our Services, and any third party products or services that we think may be of interest to you

  • Consent (when there is not an existing business relationship)

  • Legitimate interest (when there is an existing business relationship)

  • Contact

  • Identity

  • Inferences

  • Marketing Communications

  • Professional

  • Profile

  • Technical

  • Transaction

  • Usage

  • Directly from you

  • Third-party sources

  • Automatically

Advertising

  • To display personalized advertisements to you regarding the Services on third-party sites and measure their success

  • To tailor the content and advertising we display to you or others and to analyze trends and statistics

Consent

  • Contact

  • Geolocation 

  • Identity

  • Inferences

  • Marketing Communications

  • Professional

  • Profile

  • Technical

  • Transaction

  • Usage

  • Directly from you

  • Third-party sources

  • Automatically

Social Media and Events:

  • To interact with you through social media and other third-party platforms

  • To interact with you at live and virtual events hosted by L36 or another organization



Legitimate interest

All types of Personal Data


  • Directly from you

  • Third-party sources

  • Automatically

Fraud Prevention, Security, Business Transfers, and Other Legal Obligations

  • To verify your identity

  • To detect and prevent fraudulent or other unauthorized activities

  • To audit our compliance with legal and contractual requirements and internal policies

  • To comply with legal and contractual obligations and requirements, law enforcement requests, and legal process

  • For business transfers and transactions, such as a merger or acquisition

  • To allow you to exercise your rights under privacy laws or other legal or regulatory provisions in force

  • Performance of a contract

  • Legal obligation

  • Legitimate interest

  • Contact

  • Geolocation

  • Identity

  • Inferences

  • Marketing Communications

  • Professional

  • Profile

  • Technical

  • Transaction

  • Usage

  • Directly from you

  • Third-party sources

  • Automatically

For any other reason by consent

Consent

All types of Personal Data

  • Directly from you

  • Third-party sources

  • Automatically


  1. How We Disclose Personal Data

We transmit, disclose, grant access, make available and provide all types of Personal Data mentioned above to or with authorized L36 personnel that have a business need for access and the following types of third parties. 

If you are located in the EEA and other Non-US countries, please be aware that some of the third parties below may act as co-controllers in respect of your Personal Data. To understand what type of relationships we have third parties we disclose Personal Data to or with, please contact us.]

  1. Other Users

Certain features of the Services may allow you to display or disclose information to or with other users. If you post or share content through the Services, that information is public and will be disclosed to other users of the Services. We encourage you to be thoughtful as to how you interact with the features of our Services, how you interact with others in our community, and the information you publish or otherwise disclose within the Services (for example, through creating a public profile, comments, and blog or forum posts).

  1. L36 Affiliates and Subsidiaries

Your Personal Data may be shared with other affiliates and subsidiaries of L36 Media LLC to meet legal and regulatory obligations and to provide you with the possible service and customer support.

  1. Third-Party Vendors

We disclose Personal Data with our third-party vendors, including consultants, agents, and contractors, that help us provide our Services or with any of the purposes described in this Privacy Policy. Depending on the Services you use and how you use the Services, the following categories of vendors may collect data on our behalf or receive Personal Data, for example:

  1. Payment Processors

L36 works with third-party payment processors to collect payment information for our Services. Note that your payment information is passed directly to the payment processors. L36 will not store your credit card or have access to it after a payment is submitted. Please review our payment processors’ privacy notice to learn more about how they collect, process and protect your personal information: 

  1. Legal, Compliance and Regulatory 

We may disclose Personal Data if we believe that it is necessary to: 

Non-public information about our users will not be released to law enforcement except in response to an appropriate legal process such as a subpoena, court order, or other valid legal process that has been reviewed by L36. However, if we receive information that provides us with a good faith belief that there is an exigent emergency, we may provide information to law enforcement trying to prevent or mitigate the danger, to be determined on a case-by-case basis.

  1.  Business Transfers

We may disclose Personal Data to third parties we choose to acquire or with buyers, successors, or others in connection with a merger, divestiture, restructuring, reorganization, financing due diligence, initial public offering, dissolution, or other sale or transfer of some or all of our assets or transition of service to another provider, whether as a going concern or as part of bankruptcy, receivership, liquidation or similar proceeding, as permitted by law and/or contract.

  1. With Your Consent or Authorization

There may be situations where you are asked to consent to disclose Personal Data with third parties for additional reasons not included in this Privacy Policy. Likewise, if you specifically authorize us to do so, we will share your information with other third parties.

  1. How Long We Retain Personal Data

We retain Personal Data for the purposes stated in this Privacy Policy and as required under applicable law. To determine how long we keep Personal Data, we consider the amount, nature, and sensitivity of Personal Data, the reasons for which we collect and process the information, and applicable legal requirements. For information about retention periods for specific types of Personal Data, please contact us.

  1. How We Protect Personal Data

At L36, we take our responsibility to protect the security and privacy of Personal Data seriously. To prevent Personal Data from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way, we have implemented what we believe to be reasonable administrative, technical, and physical data security practices that are appropriate to the volume and nature of the Personal Information at issue.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and we cannot and do not guarantee that Personal Data is completely secure and safe from such risks. By using the Services, you understand and assume the risks associated with your activities on the Internet.

  1. International Data Transfers

The Personal Data that we collect or receive may be transferred to and processed in countries located outside of your country of residence to the countries where we or our third-party service providers process it. The data protection laws of the countries where Personal Data is processed may not be as comprehensive as or equivalent to those in your country of residence.  Whenever we transfer Personal Data internationally, we take steps to protect it as required under applicable law.


If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, we rely on the Standard Contractual Clauses to provide an adequate level of data protection for the transfer of your Personal Data from the EEA, the UK, or Switzerland, where the country of import is not deemed adequate under applicable law.


Children’s Privacy

Our Services are not intended for use by anyone younger than the age of 18 or under the applicable legal age of the relevant country. We do not knowingly collect Personal Data from children younger than the age of 18 without the consent of a parent or legal guardian, as required under applicable law. 

If you learn or believe that a child under the age of 18 has provided us with Personal Data, please contact us.

  1. Marketing Preferences

  1. Marketing Communications


To stop receiving, or opt-out of, promotional email communications from L36, click on the "unsubscribe" link or follow the relevant opt-out instructions within the marketing communication. 

If you opt-out of receiving marketing emails, we will still send you transactional emails, such as for responses to your requests or communications about your account. 

If you need assistance unsubscribing or opting-out of marketing communications, please contact us.

We will obtain your express opt-in consent before we share your Personal Data with any company outside the L36 group of companies for marketing purposes.

  1. Third Party Advertising and Analytics

L36 works with third-party network advertisers, ad agencies, and other advertising partners to serve L36 ads online. We may use information we have learned about you to target ads to you and to allow our third-party advertising partners (e.g., Meta/Facebook, Google, etc.) to manage our advertising on their websites. We also use third-party analytics providers to provide us with information regarding the use of the Services and the effectiveness of our advertisements. For more information about the tracking technologies that these third parties use and your options, please see the Cookie Policy.

  1. Privacy Rights Requests for EEA and Non-US Residents

Depending on your jurisdiction, you may have certain rights regarding your Personal Data. If you are an EEA or Non-United States (“Non-US”) resident, you can learn about EEA and Non-US Residents Privacy Rights below.


California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt-out of the sharing of certain categories of Personal Data with third parties for their direct marketing purposes. We do not currently share or disclose Personal Data with third parties for their own direct marketing purposes.

  1. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will revise the “Last Updated and Effective Date” at the top of this Privacy Policy and post a link to the updated Privacy Policy on our Services. Changes to this Privacy Policy are effective when they are posted. If we make any material changes, we will provide you with notice as required under applicable law. Please review this Privacy Policy periodically to ensure you are aware of any such changes.

  1. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at [email protected] 


APPENDIX EEA AND NON-US RESIDENTS 

  1. Scope

This Appendix for EEA and Non-US Residents supplements the information provided in this Privacy Policy and applies only to individuals located in the EEA, UK, Switzerland, or another country other than the United States with a comprehensive data protection law who are within the scope of this Privacy Policy. 

For the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and relevant local data protection laws, L36 the Data Controller of Personal Data from individuals that use its Services.

  1. EEA and Non-US Residents Privacy Rights

Under the GDPR and relevant local data protection laws, you have certain rights regarding your Personal Data. 

Right to Know and Right to Access / Portability

You have the right to know what Personal Data L36 has collected about you and how it is processed. And, you have the right to receive such information from us in a machine-readable format.

Right to Correct

You have the right to request a correction of inaccurate Personal Data we have about you or a completion of missing information.

Right to Delete

You have the right to request a deletion of the Personal Data we have about you.

Right to Restrict and Object to Processing

Under limited circumstances, you have the right to request that we suspend processing, object to processing for certain purposes, or limit other parameters of processing.

Rights for Automated Decision-Making and Profiling

You have the right to know whether L36 is processing your Personal Data for automated decision-making or profiling that may result in a legal or similarly significant decision and the right to opt-out of such processing.

Right to Withdraw Consent

Where consent is the legal basis for processing, you have the right to revoke that 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 processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

Right to Direct Use After Your Death

You have the right to provide L36 with instructions about how to use and disclose your Personal Data (e.g., retention, deletion, transfer to a third party, etc.) after your death.

Please note that these rights are not absolute and L36 may refuse requests, in whole or in part, where exceptions under applicable law apply. Additionally, we may refuse to fulfill your request if it is unfounded, repetitive, or excessive.

  1. Exercising Your Rights

To exercise your rights below, please email us at [[email protected]].


Include only the following information:


Please refrain from including more Personal Data than necessary in this initial message. If we need additional information, we will ask for it at a later time.


To verify your identity, we may ask you to confirm Personal Data we already have on file for you. This is a security measure to help ensure that your Personal Data is not disclosed to any person who has no right to receive it and to help ensure that the person exercising the right is the person about whom the Personal Data relates.


If we cannot verify your identity from the information we have on file, we may request additional information, which we will only use to verify your identity and for security or fraud prevention purposes.

  1. Questions and Complaints

You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us.

For more information on how to contact your data protection authority if you are located in the EEA, the UK, or Switzerland, please see:

 EEA Data Protection Authorities (DPAs)

● Swiss Federal Data Protection and Information Commissioner (FDPIC)

● UK Information Commissioner’s Office (ICO)]

Cookie Policy


Last Updated and Effective Date: [DATE]


This Cookie Policy describes how L36 uses and discloses Personal Data captured by cookies and similar tracking technologies such as pixels (collectively, “Cookies”). 

For more information about L36’s privacy practices, please review our Privacy Policy.

Table of Contents

  1. What Are Cookies?

  2. Types of Cookies

  3. What Types of Information Do Cookies Collect?

  4. How Do We Use Cookies?

  5. How to Manage or Delete Cookies


  1. What Are Cookies?

Cookies are small data files that are placed on your device set by us or by third parties when you visit a website or other online service. In addition to cookies, we may use other technologies that are similar in function, such as pixels, also called web beacons or single-pixel tags/gifs, local or web storage, and embedded scripts. 

We use the term “Cookie” throughout this Privacy Policy to cover all these technologies.

You can find more information about cookies at: www.allaboutcookies.org.


  1. Types of Cookies

Cookies are often described by who created and placed them and how long they last. Types of Cookies generally include the following:

  1. What Types of Information Do Cookies Collect?

Cookies collect different types of information depending on the type of Cookie and its purpose. Some examples of information that may be collected by Cookies when you use our Services include:

  1. How Do We Use Cookies?

L36 uses Cookies for purposes such as providing content or features on our Services, helping us remember you and your preferences, and improving your user experience by making our Services more efficient and relevant to you. We, our service providers, and/or agents acting on our behalf, use the following persistent and session Cookies (which may be first-party or third-party Cookies) on our Services:

  1. How to Manage or Delete Cookies 

You can exercise your preferences concerning Cookies served on our Services by taking the steps outlined below.

Opting out through these mechanisms does not block all online advertising. You will continue to receive generic advertisements.

To learn more about how to manage Cookies and opt-out of Cookies being placed on your devices, please visit www.allaboutcookies.org.

  1. Changes to this Cookie Policy

We may update this Cookie Policy from time to time. When we update this Cookie Policy, we will revise the “Last Updated and Effective Date” at the top of this Cookie Policy and post a link to the updated Cookie Policy on our Services. Changes to this Cookie Policy are effective when they are posted. If we make any material changes, we will provide you with notice as required under applicable law. Please review this Cookie Policy periodically to ensure you are aware of any such changes.

  1. Contact Us

If you have any questions about this Cookie Policy or our privacy practices, please contact us.