The Gamma Point LLC Privacy Policy
Last updated: August 2, 2026 · Version: 2026-08-02
Introduction & Scope
The Gamma Point LLC (“TGP,” “we,” “us,” or “our”), provides this Privacy Policy (the “Policy”) to describe our practices regarding the collection, use, and disclosure of information about you.
This Policy applies to information we collect through the Popular POEM website located at popularpoem.com and any related online services on which this Policy is posted, as well as information collected through other interactions with us (collectively, the “Services”).
By providing us with information, accessing, or otherwise using the Services, you agree to our collection, use, and disclosure of information as described in this Policy.
The Gamma Point LLC is the controller of your personal information. You may contact us at contact@popularpoem.com.
The Information We Collect
We collect information about you when you use our Services. The types of information we collect depend on how you use the Services. Certain information is required for us to provide the Services. If you do not provide such information, or request that it be deleted, you may be unable to access certain features of the Services.
The information we collect may include information you provide directly to us, information collected automatically through your use of the Services, and information received from third parties.
Information You Provide Directly to Us
We may collect the following categories of information directly from you:
- Account information: we collect information when you create your account, such as your email address and mobile phone number.
- Payment information: we use third-party payment processors to process payments made through the Services. We do not retain any financial information such as credit card numbers. All such financial information, together with any personal information that you provide during payment, is provided directly to our third-party processors.
- Communications: we collect information that you provide when you contact customer support, communicate with us by email, chat, social media, or telephone, respond to surveys, participate in promotions, or otherwise interact with us.
Information We Collect Automatically
When you use our Services, we may automatically collect certain information using a variety of third-party technologies, including cookies and similar tools.
Some of the information we automatically collect when you use our Services includes:
- Verification Metadata, such as your verification status (approved, pending, declined, etc.), the count of verification attempts you have made, the session identifier of your most recent attempt, and reason verification was declined.
- Device Information, such as device type, device model, operating system, firmware and software versions, browser type, language settings, mobile carrier, IP address, network connection information, and other unique device identifiers.
- Usage Data, such as whether you have posted, your current posting streak, the time of day (in UTC) at which your posting cycle resets each day, pages viewed, features used, buttons clicked, search queries, referring and exit pages, dates and times of access, session duration, navigation paths, application launches, interactions with content or services, crash reports, performance data, and diagnostic information.
- Log and Analytics Information, such as log files, error reports, system activity, troubleshooting data, and analytics information regarding how users access and use the Services.
- Location Information, such as approximate location information derived from your IP address.
You can choose to accept or decline Cookies. Most web browsers automatically accept Cookies, but your browser may allow you to modify your browser settings to decline Cookies if you prefer. If you disable Cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. As we adopt additional technologies, we may also gather additional information through other methods.
Information We Collect from Other Sources
We may receive information from third parties that support operation of the Services, such as our payment processors and account verification vendors.
How We Use the Information We Collect About You
We may use information we collect to:
- Provide, operate, maintain, and improve the Services;
- Verify, create, and administer user accounts;
- Process subscriptions and payments;
- Communicate with you;
- Detect, investigate, and prevent fraud, abuse, and security incidents;
- Comply with legal obligations;
- Enforce our Terms of Service, other policies, and any other agreements we have with you;
- Protect the rights, safety, and integrity of our users and Services;
- Carry out any other purpose disclosed at the time information is collected or with your consent.
We may combine information that we collect from you through the Services with information that we obtain from other sources. We may also aggregate and/or de-identify information collected through the Services. We may use and disclose de-identified or aggregated data for any purpose.
Legal Bases for Using Your Information
The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Privacy Policy are as follows:
- Where use of your information is necessary to fulfil our obligations under a contract or commitment to you. For example, to provide the services you've requested from us, or to comply with our Terms of Service.
- Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate our business and our Services, make and receive payments, defend our legal rights, and prevent fraud.
- Where we use your information to comply with applicable legal obligations. For example, keeping track of purchases for tax and auditing purposes.
- Where you have consented to our processing of your information for a particular purpose.
When We Disclose the Information We Collect About You
We may disclose your information for various reasons as described below.
Affiliates. We may disclose your information to our affiliates.
Vendors. We may disclose your information to employees, consultants, and other vendors who need access to such information to carry out work or perform services on our behalf, such as those who provide data storage, payment, technology support and services, customer service, analytics, fraud prevention, legal services, and marketing services.
Law Enforcement, Regulators, and Other Parties for Legal Reasons. We may disclose information about you to third parties as required by law or if we believe in good faith that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our agreements or to protect the security or integrity of our Services; and/or (c) exercise or protect the rights, property, or personal safety of TGP, its agents and affiliates, our customers, or others.
Business Transactions. We may disclose information to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
At Your Direction/Consent. We may disclose your information as otherwise permitted or required by law or as authorized by you.
California Do Not Track Statement
Our websites do not respond differently or limit their practices under the terms of this Policy when you access our site with a browser that uses a do not track signal.
Third-Party Websites or Services
The Services may include links to other websites or services, or the Services may include embedded content from other websites. This Policy applies only to the Services and not to other websites or services accessible from the Services, which may have privacy policies materially different from this Policy. TGP is not responsible for the privacy practices or content of those sites. It is your responsibility to review the privacy policies of non-TGP websites and service to confirm that you understand and agree with them.
Your Choices
Updating Your Account: You may update account information through your account settings or by contacting us.
Deleting Your Account: You can delete your account using the “Delete my account” link on the Account page or by contacting us at contact@popularpoem.com. We will send you a confirmation email and delete your account after a three-day waiting period, during which you can cancel the scheduled deletion. You can cancel your deletion request on your Account page or by clicking the link provided in the confirmation email. Please note that certain information may not be deleted, such information that has been de-identified or information we are legally required to retain.
Cookies: Most browsers allow users to manage cookie preferences. Disabling cookies may affect functionality of the Services.
Marketing communications: You can opt out of receiving marketing emails from us by following the instructions at the bottoms of the email. Please note that your request will take some time to process, in accordance with applicable law. After you opt out, you will still receive transactional communications from us regarding your account or important legal information.
Your Rights
The laws of your jurisdiction may give you certain rights. You may have the right to request that we:
- Provide you with access to and/or a copy of personal information we hold about you in a readily usable format (where technically feasible and legally required)
- Confirm that we are processing your information
- Correct or update personal information we hold about you
- Delete personal information we have about you
- Restrict (or you can object to) certain processing of your information
- Withdraw your consent to our use of your information for certain processing purposes, where the processing purpose was based on your consent
We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. Please note, however, that certain information may be exempt from such requests, such as information that has been de-identified or information we are legally required to retain.
To make a request, please contact us at contact@popularpoem.com. You can also access certain of your information by using the “Download my data” link on your Account page.
If you have any concerns or complaints about our data processing activities, we urge you to first try to resolve such issues directly with us. However, if applicable, you may make a complaint to the data protection supervisory authority in the country where you are based or seek a remedy through local courts if you believe your rights have been breached.
Security
We implement a variety of technical and organizational measures to protect your information against accidental or unlawful access, destruction, loss, misuse, change or damage. However, no Internet or email transmission is ever fully secure or error-free. Please keep this in mind when disclosing any information to us.
Data Retention
We will retain your information for only as long as necessary to provide the Service and for the other legitimate business purposes set out in this Policy such as safety, security, compliance, and dispute resolution. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. For example, we will retain humanness verification data for no longer than the earlier of the date the initial purpose for collecting the data is satisfied or within three years of your last interaction with us.
Information From Children
The Services are not intended for minors under 18, and we do not knowingly collect personal information from individuals under 18. If we learn that such information has been collected, we will take appropriate steps to delete it.
Consent to Transfer
By using the Services, you understand that your information may be transferred to and processed in the United States. Please do not use the Services if you do not agree to the transfer and processing of information about you in the United States, which may not provide the same level of protection for your data as your home country.
We take reasonable steps to protect your information in accordance with this Privacy Policy and applicable laws. These measures may include implementing Standard Contractual Clauses to govern the transfer of your information, or other means recognized by applicable laws.
Changes to this Policy
We may update this Policy from time to time. At the top of our Policy, we will indicate the date of the most recent update. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.
Contact Us
If you have questions about this Policy or our privacy practices, please contact us by email at contact@popularpoem.com.