Scope and Controller
This GDPR Notice explains how Plings processes personal data of individuals located in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland in accordance with the General Data Protection Regulation (GDPR) and applicable local implementations. Plings is operated in the United States of America and this Notice is intended to be read together with any other disclosures we provide under U.S. law.
The data controller is: Victoria McGovern, 3401 Dale Rd, Modesto, CA 95356, United States. Contact: [email protected].
Categories of Personal Data
Depending on your interactions with Plings (for example, browsing content, creating alerts, subscribing to notifications, or contacting us), we may process the following categories of personal data:
- Identifiers: name, email address, username or handle, country/region, and optional contact preferences.
- Technical and Usage Data: IP address, device and browser type, operating system, language settings, referral URLs, pages viewed, time on page, clickstream, approximate location derived from IP, and error logs.
- Profile and Service Data: watchlists, alert preferences (e.g., price or listing alerts), saved content, settings, and interaction history with our notifications, newsletters, and messages.
- Communication Data: messages and inquiries you send to us, including support requests.
- Marketing and Analytics Data: campaign attribution, engagement metrics, and preferences.
- Public or Third-Party Source Data: information derived from publicly available sources (e.g., blockchain data, market listings) or service providers supplying market, analytics, or anti-abuse signals.
We do not intentionally collect special categories of personal data (sensitive data) and we do not knowingly collect data from children as described below.
Purposes of Processing
We process personal data for the following purposes:
- To provide and operate the Plings services, including crypto pings, links, token and exchange discovery, airdrop listings, alerts, and educational content.
- To create and manage accounts, preferences, and user-configured alerts and watchlists.
- To send service communications, transactional notices, and requested alerts or newsletters.
- To improve, secure, troubleshoot, and analyze the performance of our services and to develop new features, content, and tools.
- To prevent, detect, and investigate fraud, abuse, security incidents, and violations of our terms.
- To comply with legal obligations and respond to lawful requests.
- To conduct marketing and measure the effectiveness of outreach, subject to your choices.
Lawful Bases for Processing
We rely on the following lawful bases under GDPR:
- Contract: to provide the services you request, including account and alert functionality.
- Legitimate Interests: to maintain, secure, and improve our services; to perform analytics; to prevent fraud and misuse; and to personalize non-intrusive aspects of the experience. We balance these interests against your rights and expectations.
- Consent: for certain emails, alerts, cookies, or similar technologies where required by law. You may withdraw consent at any time.
- Legal Obligation: to meet recordkeeping, regulatory, tax, and compliance requirements or to respond to lawful requests.
Recipients and Disclosure
We share personal data only as necessary for the purposes described above:
- Service Providers (Processors): hosting, cloud infrastructure, customer support tools, analytics, security and anti-abuse services, email and notification delivery, and similar vendors acting on our instructions and subject to confidentiality obligations.
- Business Operations and Professional Advisors: auditors, accountants, legal counsel, and consultants under appropriate duties of confidentiality.
- Compliance and Safety: law enforcement, regulators, courts, or third parties when required by law or to protect rights, safety, and integrity of our services.
- Business Changes: in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate safeguards and continued protection of personal data.
We do not sell personal data and we do not share personal data with third parties for their own direct marketing without your consent.
International Data Transfers
Plings operates in the United States. When we transfer personal data from the EEA, UK, or Switzerland to countries that may not provide the same level of data protection, we rely on appropriate safeguards, such as European Commission-approved Standard Contractual Clauses (and the UK Addendum, where applicable), or other lawful transfer mechanisms. You may contact us to request more information about these safeguards.
Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to provide services, comply with legal, accounting, or reporting obligations, resolve disputes, and enforce agreements. Criteria we use include the nature of the data, the purpose of processing, our legal obligations, and the potential risk of harm from unauthorized use or disclosure. Where feasible, we anonymize or aggregate data for longer-term analytics and research.
Your GDPR Rights
Subject to applicable law, you have the following rights:
- Access: receive confirmation whether we process your personal data and obtain a copy.
- Rectification: request correction of inaccurate or incomplete personal data.
- Erasure: request deletion of personal data in specific circumstances.
- Restriction: request restriction of processing under certain conditions.
- Portability: receive personal data you provided to us in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible.
- Objection: object to processing based on legitimate interests, including profiling, and object to direct marketing at any time.
- Withdraw Consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of processing before withdrawal.
- Complaint: lodge a complaint with your local supervisory authority in the EEA, UK, or Switzerland.
How to Exercise Your Rights
To exercise your rights or submit a privacy inquiry, contact: [email protected]. We may ask for information to verify your identity and request. We will respond without undue delay and in any event within one month of receipt, unless an extension is permitted by law due to complexity or number of requests. If we decline a request where permitted by law, we will explain the reasons and your options to challenge the decision.
Cookies and Similar Technologies
We use cookies and similar technologies to provide core functionality (e.g., session management), remember preferences, perform analytics, and deliver or measure communications. Where required by law, we seek your consent before setting non-essential cookies. You can manage cookies via your browser settings, including blocking, deleting, or receiving alerts before placement; doing so may affect certain features.
Automated Decision-Making and Profiling
We may use limited profiling (for example, to tailor non-intrusive alerts or prioritize content relevance) to improve your experience. We do not engage in automated decision-making that produces legal or similarly significant effects. You may object to profiling based on our legitimate interests and opt out of marketing personalization at any time.
Security
We implement appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. No security measure is perfect, and we cannot guarantee absolute security; however, we continually assess and enhance our safeguards.
Children's Data
Our services are intended for individuals who are the age of majority in their jurisdiction. We do not knowingly collect personal data from children under 13 (or under 16 in the EEA/UK) without appropriate consent. If you believe a child has provided personal data, please contact us so we can take appropriate action.
Contacts for Data Protection Matters
Controller: Victoria McGovern, 3401 Dale Rd, Modesto, CA 95356, United States. Email: [email protected]. For all GDPR-related queries, this is your primary point of contact.
Updates to This Notice
We may update this GDPR Notice from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will take appropriate steps to notify you consistent with the significance of the changes, and indicate the effective date of the update.