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Privacy Policy

WINDOM MEDIA, INC. PRIVACY POLICY

Version 1.0 – Approved Publication Copy

Effective Date: August 22, 2026

Last Updated: August 22, 2026

Windom Media, Inc. (?Windom Media,? ?we,? ?us,? or ?our?) respects your privacy and is committed to handling personal information responsibly, transparently, and securely.

Windom Media is a media and entertainment company that develops and operates publishing, storytelling, digital, transmedia, phygital, community, commerce, artificial intelligence, and experiential properties.

Newdawn is a Windom Media brand and story universe encompassing transmedia storytelling, phygital experiences, digital and physical products, interactive experiences, collectibles, community, commerce, artificial intelligence, and an evolving experiential environment.

This Privacy Policy explains how Windom Media may collect, use, disclose, retain, and protect personal information when you interact with our websites, stores, author properties, communications, content, digital services, and other experiences that link to this Policy.

It also explains privacy choices and rights that may be available to you depending on where you live and which laws apply.

1. Scope of This Privacy Policy

This Privacy Policy applies to websites and digital properties operated by Windom Media that link to this Policy, including, as applicable:

  • Windom Media websites and digital properties;
  • the Newdawn Universe;
  • Newdawn Shop;
  • The Nexus / Newdawn Blog;
  • the official Dominique Luchart author website;
  • Newdawn Traveler experiences;
  • DAINN and other Windom Media AI-assisted experiences when made available to visitors; and
  • other Windom Media websites, applications, campaigns, forms, events, digital services, transmedia experiences, or interactive properties that link to this Policy.

Certain products, services, promotions, or experiences may provide additional privacy notices at the point where information is collected.

2. Who Is Responsible for Your Information

Windom Media, Inc. is the entity responsible for personal information processed through the Windom Media properties covered by this Policy, to the extent Windom Media determines the purposes and means of that processing.

For questions about privacy or to exercise applicable privacy rights, contact:

Windom Media, Inc. Privacy & Data Protection Email: info@windomedia.com

3. Information We May Collect

Information You Provide

We may collect information you voluntarily provide, including:

  • your name;
  • email address;
  • billing and shipping information;
  • account or registration information;
  • purchase and transaction information;
  • communications you send to us;
  • customer-support information;
  • preferences and interests you choose to provide;
  • information submitted through forms, surveys, promotions, contests, community features, or other experiences; and
  • information you choose to provide when interacting with AI-assisted or interactive experiences.

Purchase and Transaction Information

When you purchase a product or service, we may collect information necessary to process and administer the transaction, such as:

  • products purchased;
  • transaction date;
  • order value;
  • billing information;
  • shipping information;
  • order and fulfillment status; and
  • information necessary for returns, refunds, fraud prevention, accounting, and customer service.

Payment-card information may be processed directly by authorized payment providers rather than stored directly by Windom Media.

Information Collected Automatically

When you use our websites or digital experiences, certain information may be collected automatically, including:

  • IP address;
  • browser type;
  • device type;
  • operating system;
  • referring website or source;
  • pages viewed;
  • products viewed;
  • interactions with website features;
  • approximate location derived from IP address;
  • dates and times of visits;
  • cookie or similar technology identifiers;
  • campaign or referral information;
  • website performance information; and
  • security and error information.

Where permitted, this information may help us understand how visitors discover Windom Media and Newdawn, what they explore, and how our websites, products, content, and campaigns perform.

4. How We Use Personal Information

Depending on the interaction and applicable law, Windom Media may use personal information to:

  • provide and operate our websites and digital experiences;
  • process and fulfill purchases;
  • administer payments, orders, shipping, returns, and refunds;
  • provide customer service;
  • create or administer accounts and registrations;
  • administer Newdawn Traveler participation;
  • provide requested content or communications;
  • send marketing communications where permitted;
  • communicate about books, stories, releases, products, events, discoveries, and offers;
  • personalize content, products, recommendations, or experiences where permitted;
  • understand how visitors discover and use our properties;
  • measure marketing and campaign effectiveness;
  • develop and improve our products, stories, content, services, and experiences;
  • operate AI-assisted and interactive experiences;
  • protect against fraud, spam, abuse, and security threats;
  • troubleshoot technical issues;
  • maintain and protect our systems;
  • comply with applicable legal obligations;
  • establish, exercise, or defend legal claims; and
  • carry out other purposes disclosed at the time information is collected.

Where applicable law requires a legal basis for processing, Windom Media will rely on an appropriate legal basis, which may include consent, performance of a contract, compliance with a legal obligation, or legitimate interests where permitted by law.

5. Newdawn Shop and Purchases

Windom Media may process personal information necessary to operate Newdawn Shop and fulfill purchases.

This may include contact, order, billing, shipping, transaction, fulfillment, and customer-service information.

Windom Media may use ecommerce technologies, including WooCommerce and related providers, to operate commerce functions.

Payment information may be transmitted directly to authorized payment processors. Those providers may process information in accordance with their own privacy notices and applicable law.

Windom Media may retain transaction information as reasonably necessary for:

  • fulfillment;
  • customer service;
  • accounting;
  • taxation;
  • fraud prevention;
  • dispute resolution;
  • legal compliance; and
  • legitimate business recordkeeping.

6. Traveler Registration and Email Communications

Visitors may choose to receive Windom Media or Newdawn communications or participate in experiences such as Newdawn Traveler.

When you register, we may collect your email address and information reasonably necessary to administer the registration, such as:

  • signup date and time;
  • consent status and timestamp;
  • signup source;
  • confirmation status; and
  • campaign or referral information where available.

We may use forms, customer-relationship-management systems, and email-delivery technologies to administer registrations and communications.

Where appropriate, Windom Media may use confirmation or double opt-in procedures.

Communications may include:

  • Newdawn stories and discoveries;
  • books and publishing news;
  • new releases;
  • products and collectibles;
  • events and experiences;
  • Traveler communications;
  • Newdawn Universe developments;
  • Windom Media news;
  • promotions; and
  • commercial offers.

You may unsubscribe from marketing email at any time using the unsubscribe mechanism included in the communication.

Withdrawing marketing consent will not prevent us from sending transactional or service communications necessary to complete a purchase or provide a service you requested.

7. Cookies and Similar Technologies

Windom Media properties may use cookies, pixels, local storage, tags, and similar technologies for purposes such as:

  • essential website operation;
  • security and fraud prevention;
  • shopping-cart functionality;
  • remembering preferences;
  • analytics;
  • website performance;
  • campaign attribution; and
  • advertising or marketing measurement where permitted.

Where applicable law requires consent before non-essential technologies are used, Windom Media will implement appropriate consent mechanisms.

We may provide additional cookie notices or controls describing technologies used on particular Windom Media properties.

8. Analytics, Marketing and Attribution

Windom Media may use analytics and measurement technologies to understand how people discover and interact with our websites, content, books, products, and campaigns.

This may include determining whether a visitor arrived through:

  • search;
  • social media;
  • Pinterest;
  • an advertisement;
  • an email;
  • another Windom Media property;
  • a referral; or
  • another campaign or traffic source.

We may use this information to evaluate marketing effectiveness, improve visitor experiences, understand product interest, and make business and content decisions.

Where applicable law provides rights relating to targeted advertising, sale, sharing, profiling, or similar processing, Windom Media will provide applicable mechanisms for exercising those rights.

9. Artificial Intelligence and Automated Experiences

Windom Media may offer experiences using artificial intelligence or automated technologies, including DAINN and other clearly identified AI-assisted experiences.

AI-assisted technologies may be used to:

  • help visitors discover content;
  • provide navigation or guidance;
  • respond to questions;
  • identify relevant stories, books, products, or experiences;
  • provide recommendations;
  • support customer service;
  • personalize experiences where permitted; or
  • improve Windom Media properties and services.

Information supplied during an AI interaction, together with contextual information reasonably necessary to provide the experience, may be processed to perform the requested interaction.

Where applicable law requires disclosure that a person is interacting with an AI system, Windom Media will provide an appropriate notice at or before the relevant interaction.

Windom Media will not intentionally present an AI system as a human where applicable law requires disclosure of its artificial nature.

Where AI-generated or AI-manipulated content is subject to applicable transparency or labeling requirements, Windom Media will implement appropriate disclosures or other required measures.

The EU AI Act contains specific transparency obligations for certain systems that interact directly with natural persons and for certain AI-generated or manipulated content.

Additional AI-specific notices may be provided within individual experiences.

10. Personalization, Profiling and Automated Decision-Making

Windom Media may use information to personalize content, communications, product recommendations, or experiences where permitted.

Our entertainment and commerce recommendation experiences are not intended to make decisions producing legal or similarly significant effects concerning individuals.

If Windom Media later introduces automated decision-making subject to specific access, notice, consent, assessment, explanation, or opt-out requirements, we will implement applicable protections before using those systems for those purposes.

11. How We Disclose Personal Information

Windom Media may disclose personal information to vendors, processors, contractors, and other service providers reasonably necessary to operate our business and properties.

These may include providers supporting:

  • website hosting;
  • ecommerce;
  • payment processing;
  • fulfillment and shipping;
  • forms;
  • customer relationship management;
  • email delivery;
  • analytics;
  • advertising and marketing measurement;
  • security;
  • fraud prevention;
  • cloud infrastructure;
  • customer service;
  • professional services; and
  • other technology necessary to provide Windom Media experiences.

We may also disclose personal information when reasonably necessary to:

  • comply with applicable law;
  • respond to valid legal process;
  • protect our rights or property;
  • enforce agreements;
  • investigate suspected fraud, abuse, or security incidents;
  • protect users or others; or
  • establish, exercise, or defend legal claims.

If Windom Media or relevant assets are involved in a merger, acquisition, financing, restructuring, sale, or similar transaction, information may be transferred as permitted by applicable law.

12. Sale, Sharing and Targeted Advertising

Windom Media does not sell personal information for money in the ordinary meaning of the word ?sell.?

Certain privacy laws, however, define sale, sharing, or targeted advertising more broadly than an exchange for money.

Certain advertising, analytics, or marketing relationships may therefore constitute regulated sale, sharing, or targeted advertising under applicable law depending on how those technologies are used.

Where Windom Media engages in processing that creates an applicable opt-out right, we will provide the required method for exercising that right.

Where applicable law requires recognition of qualifying universal opt-out signals, Windom Media will implement the applicable mechanism.

13. Digital Collectibles, Blockchain and Emerging Technologies

Windom Media may in the future offer digital collectibles, blockchain-enabled experiences, tokenized or digitally authenticated assets, or other forms of digital ownership associated with Newdawn or other Windom Media properties.

If such experiences are introduced, additional information may be processed, such as:

  • public blockchain addresses;
  • wallet identifiers;
  • transaction information;
  • digital-asset ownership information; or
  • information necessary to authenticate, administer, or deliver an experience.

Blockchain transactions may create records on public or distributed networks that Windom Media does not control and may not be able to alter or delete.

Before collecting or connecting personal information with blockchain-based activity, Windom Media will provide additional notices where required by applicable law.

Before introducing applicable blockchain, tokenized, or digital-ownership functionality, Windom Media may also provide additional terms, disclosures, consent mechanisms, or other protections appropriate to the particular experience and applicable law.

Nothing in this section means that Windom Media or Newdawn currently offers NFTs, tokens, digital wallets, or blockchain functionality.

14. Data Retention

Windom Media retains personal information for as long as reasonably necessary for the purposes for which it was collected and for legitimate operational, contractual, legal, accounting, security, and recordkeeping purposes.

Retention periods may differ depending on:

  • the nature of the information;
  • why it was collected;
  • whether an account or relationship remains active;
  • legal and regulatory requirements;
  • security and fraud-prevention needs; and
  • applicable limitation periods.

When personal information is no longer reasonably required, we may delete, anonymize, aggregate, or securely dispose of it as appropriate.

15. Security

Windom Media uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, destruction, loss, alteration, or disclosure.

No internet transmission, electronic system, or storage method can be guaranteed to be completely secure.

Windom Media maintains and develops security practices separately from this public Privacy Policy and may modify those practices as technology, threats, and legal requirements evolve.

16. International Data Transfers

Windom Media and service providers supporting our operations may process personal information in countries other than the country in which you live.

Where applicable law requires safeguards for international transfers of personal information, Windom Media will use an appropriate lawful transfer mechanism.

For transfers governed by European Economic Area or United Kingdom data-protection requirements, applicable mechanisms may include adequacy decisions, approved contractual safeguards, or another lawful transfer basis.

17. Your Privacy Rights

Depending on where you live and which privacy laws apply to Windom Media and the particular processing involved, you may have rights concerning your personal information.

These may include the right to:

  • know whether we process your personal information;
  • access personal information;
  • obtain information about its collection, use, or disclosure;
  • correct inaccurate personal information;
  • request deletion;
  • obtain a portable copy of certain information;
  • withdraw consent where processing is based on consent;
  • object to or restrict certain processing;
  • opt out of certain sales or sharing;
  • opt out of targeted advertising;
  • opt out of certain profiling or automated processing;
  • appeal certain privacy-request decisions; and
  • exercise privacy rights without unlawful discrimination or retaliation.

Privacy rights differ by jurisdiction and may be subject to statutory exceptions.

18. California Residents

Where the California Consumer Privacy Act, as amended (?CCPA?), applies to Windom Media and to particular processing, California residents may have rights provided by that law.

Depending upon applicability and circumstances, those rights may include rights to know, access, correct, delete, and exercise applicable rights concerning sale or sharing of personal information and certain automated processing.

Additional notices or mechanisms may be provided where required.

19. Colorado Residents

Where the Colorado Privacy Act applies to Windom Media and particular processing, Colorado consumers may have rights to access, correct, delete, obtain certain personal data in portable form, and opt out of certain sales, targeted advertising, and certain profiling.

Additional rights and protections may apply depending on the processing involved.

Where required, Windom Media will recognize applicable universal opt-out mechanisms.

20. New York Residents

Windom Media maintains safeguards designed to protect personal information and will comply with applicable New York privacy and data-security requirements where they apply.

Where a security incident triggers applicable notification requirements, Windom Media will provide required notifications in accordance with applicable law.

21. Residents of Other U.S. States

Residents of other U.S. states may have additional rights under applicable state privacy laws.

Where such laws apply to Windom Media or particular processing, Windom Media will provide required rights, disclosures, notices, and opt-out mechanisms.

As privacy laws evolve or Windom Media expands, we may update this Policy and our privacy controls accordingly.

22. European Economic Area

Where the General Data Protection Regulation (?GDPR?) applies, individuals may have rights including access, rectification, erasure, restriction of processing, data portability, objection to certain processing, withdrawal of consent where processing is based on consent, and applicable rights concerning certain automated decision-making.

These rights are subject to the conditions and limitations provided by applicable law.

Where consent is relied upon as a legal basis, withdrawing consent does not affect the lawfulness of processing performed before withdrawal.

You may also have the right to lodge a complaint with the competent data-protection supervisory authority.

23. United Kingdom

Where United Kingdom data-protection law applies, individuals may have rights available under the UK GDPR and applicable UK data-protection legislation, subject to applicable conditions and limitations.

These may include rights relating to access, correction, erasure, restriction, portability, objection, consent, and certain automated decision-making.

Individuals may also have the right to complain to the United Kingdom Information Commissioner's Office.

24. Children's Privacy

Windom Media does not knowingly collect personal information from children in violation of applicable law.

If we learn that personal information from a child has been collected in circumstances requiring parental consent or another authorization that was not obtained, we will take appropriate steps consistent with applicable law.

If Windom Media introduces experiences specifically intended for younger audiences, those experiences may be governed by additional notices, age controls, parental-consent mechanisms, or other safeguards where required.

25. Exercising Your Privacy Rights

To ask a privacy question or submit a request concerning your personal information, contact:

Windom Media, Inc. Privacy & Data Protection info@windomedia.com

Please describe your request sufficiently for us to understand and respond to it.

We may need to verify your identity before fulfilling certain requests.

Where permitted by applicable law, an authorized agent may submit a request on your behalf, subject to appropriate authorization and verification.

Where applicable law provides a right to appeal a privacy-request decision, we will provide information concerning the applicable appeal process.

Windom Media will respond to verified privacy requests within the time required by applicable law.

26. Marketing Choices

You may unsubscribe from marketing emails at any time by using the unsubscribe link provided in the communication.

We may continue to send communications that are not marketing messages when reasonably necessary to:

  • fulfill an order;
  • administer an account or registration;
  • provide requested services;
  • communicate important service information;
  • address security issues; or
  • comply with legal obligations.

Cookie, targeted-advertising, sale, sharing, or similar privacy choices may also be available through mechanisms provided on the applicable Windom Media property where required.

27. Third-Party Websites and Services

Windom Media properties may contain links to third-party websites, retailers, social platforms, payment providers, embedded media, or other services that Windom Media does not control.

This Privacy Policy does not govern independent third parties' privacy practices.

We encourage you to review the privacy notices of third parties before providing information directly to them.

28. Changes to This Privacy Policy

Windom Media may update this Privacy Policy as our business evolves, Newdawn and other properties expand, our technologies change, new experiences are introduced, or applicable laws and regulatory requirements change.

When we update this Policy, we will revise the Last Updated date above.

Where applicable law requires additional notice or consent for a material change, we will provide that notice or obtain that consent before applying the change as required.

29. Contact Windom Media

Questions about this Privacy Policy, Windom Media's privacy practices, or applicable privacy rights may be directed to:

Windom Media, Inc. Privacy & Data Protection Email: info@windomedia.com