Last Updated: November 1, 2023
COLLECTION OF INFORMATION
The information we collect from you varies depending on the way you use our Platform. When you browse our public website to explore our Platform to learn more about us or purchase our products online (“Website Visitor”), the information we collect and use is different from the information we collect if you are a business owner or agent acting on behalf of a business (“Business Owner”) or if you are a songwriter, creator, music user, or publisher (collectively, “Platform User”). Below, we describe the different ways we might collect information from you.
Information You Provide to Us
If you are a Website Visitor, you may share information directly with us when you sign up for our newsletter, fill out a form, application, or questionnaire, purchase merchandise, or otherwise communicate with us. The types of personal information we may collect include your name, business and personal email address, address, phone number, and any other information you choose to provide.
Business Owners and Platform Users
If you are a Business Owner or Platform User, the information we may collect from you varies depending on how we engage with you. In general, we collect your:
- Business and personal email
- Phone number
- Business name
- Job title
- Information relating to your application for a license
- Account username and chosen password
- Family status
- Any other information you submit in connection with our Platform
In some instances, where we need to make payments to you, we might collect your:
- Social Security Number
- Tax Identification Number
- Business number
- FCC ID number
If you make a purchase from us, we engage third-party payment processors to collect and process your payment information.
Information We Collect Automatically
When you access or use our Platform or otherwise transact business with us, we automatically collect certain information, including:
- Device and Usage Information: We collect information about how you access our Platform, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Platform, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Platform.
- Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Platform. These technologies help us improve our Platform and your experience, see which areas and features of our Platform are popular, and count visits. For more information about the cookies and other tracking technologies we use, and the choices available to you, see the Your Privacy Rights and Choices section below.
Information We Collect From Other Sources
We obtain information from third-party sources. For example, we may collect information about you from music usage database providers and performance monitoring companies, which includes for example metadata, names of song writers, interested parties for purposes of paying artists or analytics.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on you IP address or infer that you are looking to purchase certain services based on your browsing behavior.
We use the information we collect to provide, maintain, and improve our Platform. We also use the information we collect to:
- Process and facilitate transactions and send you related information, including registration and license information, confirmations, receipts, invoices, and customer experience surveys;
- Personalize and improve your experience on our Platform, including ads you see;
- Send you technical notices, security alerts, and support and administrative messages;
- Respond to your comments and questions and provide customer service;
- Communicate with you about products, services, and events offered by the Company and others and provide news and information that we think will interest you (see the Your Privacy Rights and Choices section below for information about how to opt out of these communications at any time);
- Allow you to send and receive messages and invitations to and from other individuals, through or in connection with the Platform, and to send and receive such messages and invitations on your behalf;
- Enable you to participate in message boards or public forums on the Platform;
- Monitor and analyze trends, usage, and activities in connection with our Platform;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of the Company and others;
- Debug to identify and repair errors in our Platform;
- Comply with our legal and financial obligations; and
- Carry out any other purpose described to you at the time the information was collected.
We disclose personal information in the following circumstances or as otherwise described in this policy:
- We disclose personal information at your direction to other third parties with whom you have directed us to share certain information (e.g., those Business Owners who have invited you to join the Company or Platform Users with whom you have asked us to share or provide access to your information).
- We disclose personal information to vendors, service providers, and consultants that perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, IT services and infrastructure, data analysis, e-mail delivery, auditing, information and identity verification, background checks, credit checks, marketing, advertising, and other similar services.
- We disclose personal information to identify you to anyone to whom you direct us to send messages or invitations through or in connection with the Platform, including messages and invitations that we may send on your behalf.
- We disclose personal information to facilitate business transactions, business relationships and the resolution of disputes and other issues by, within, or among the Company, the Company’s related legal entities, publishers, licensees, and others.
- We disclose personal information to our third-party clients to whom we provide licensing and royalty distribution administration services, as needed, in the Company’s sole discretion, to support the clients’ operations or to facilitate business transactions.
- If you choose to use integrations we offer on our Platform, such as via third-party social media plugins, (e.g., Facebook “Like” or Google “+1” buttons), we may disclose certain information with the integration partners.
- We disclose personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is shared between and among the Company and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We disclose personal information with your consent or at your direction.
We also process aggregated or de-identified information that cannot reasonably be used to identify you. The Company processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.
TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
The Company is located in the United States and has operations and service providers in the United States and other countries. Therefore, we and our service providers process data in the United States and may transfer your personal information to, or store or access it in, jurisdictions that may not provide similar levels of data protection. Where required by law, we provide adequate protection for the transfer of personal information in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, executing Standard Contractual Clauses, or complying with another approved data transfer mechanism. Where relevant, you may request a copy of these Standard Contractual Clauses by emailing us at firstname.lastname@example.org.
The Company participates in the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework (collectively, “DPF”) issued by the U.S. Department of Commerce and approved by the European Commission, UK Information Commissioner’s Office, and the Swiss Data Federal Data Protection Commission. The Company commits to comply with the DPF Principles with respect to personal information the company receives from the EU, UK, and Switzerland in reliance on the DPF.
If third-party agents process personal information on our behalf in a manner inconsistent with the DPF Principles, we remain liable unless we prove we are not responsible for the event giving rise to any damages. If you have a question or complaint related to our compliance with the DPF Principles, please contact us as described in the Contact Us section below.
For any complaints related to DPF that cannot be resolved with us directly, you may refer the matter to JAMS pursuant to the JAMS Data Privacy Framework Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-data-privacy-framework. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the consumer may refer the matter to the U.S. Federal Trade Commission, which has DPF investigatory and enforcement powers over the Company. Under limited circumstances, and after other available dispute resolution mechanisms have been exhausted, consumers may be able to invoke binding arbitration to address complaints about the Company’s compliance with the DPF Principles.
Access, Correction, and Deletion
Depending on where you reside, you may have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, and (4) not be discriminated against for exercising these rights.
To request access, correction, or deletion of your personal information, email us at email@example.com or call our toll-free telephone number at 866-730-9841. You can also access, correct, or delete certain information stored within your online account by logging into your account. We may verify your request by asking you to provide information related to your recent interactions with us or other information we may have about you.
If you no longer want to receive marketing-related e-mails from us, you may opt out of receiving such communications by clicking the “unsubscribe” link that is included at the end of marketing-related emails or emailing us at firstname.lastname@example.org. Please also note that if you opt out of receiving marketing-related communications from us, we may still send to you non-marketing related communications, such as those about your account or our ongoing business relations.
Cookies and Similar Tracking Technologies
The California Consumer Privacy Act, as amended by the California Privacy Rights Act, affords consumers residing in California certain rights with respect to their personal information. Accordingly, if you are a Website Visitor, Business Owner, or Platform User that resides in California, this section applies to you.
The Company collects different categories of personal information depending on how you engage with us. The categories of personal information we may collect from you could include identifiers, characteristics of protected classifications under California or federal law, commercial information, internet or other electronic network activity information, and inferences. For details about the categories of personal information and precise data points we collect, as well as the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
|Category of Personal Information||Categories of Recipients|
|Identifiers (such as name, email, address, and IP address)||Service providers and contractors, including internet service providers, cloud storage service providers, payment processing providers, fraud prevention partners, data analytics providers, direct marketing and advertising providersThird parties with whom you have directed us to share certain information (e.g., those Business Owners who have invited you to join the Company or Platform Users with whom you have asked us to share or provide access to your information|
|Characteristics of protected classifications under California or federal law (such as age)||Service providers and contractors, including internet service providers, cloud storage service providers|
|Commercial information (such as transaction data)||Service providers and contractors, including internet service providers, cloud storage service providers, payment processing providers, fraud prevention partners, data analytics providers|
|Internet or other electronic network activity information (such as technical and usage data)||Service providers and contractors, including internet service providers, cloud storage service providers, payment processing providers, fraud prevention partners, data analytics providers|
|Inferences||Service providers and contractors, including internet service providers, cloud storage service providers, data analytics providers, direct marketing and advertising providers|
The Company does not sell your personal information, and we do not knowingly sell personal information about consumers under the age of 16.
Your Privacy Rights
Please see the Your Privacy Rights and Choices section above for more information about the privacy rights you have as a California resident, how to exercise your rights, and how we will verify your requests. If you are submitting a rights request as an authorized agent for a consumer that resides in California, we may ask for proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive personal information in connection with this request, such as a driver’s license or other government-issued ID. In some cases, we may contact the individual who is the subject of the request to verify his or her own identity or confirm you have permission to submit this request. If you are an authorized agent seeking to make a request, please email us at email@example.com.
Do Not Track
If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the following section applies to you.
Legal Basis for Processing
When we process your personal data as described above, we do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
- When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.
Data Subject Requests
Please see the Your Privacy Rights and Choices section above for more information about your privacy rights and how to exercise them. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please email us at firstname.lastname@example.org.
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
- For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
- For individuals in the UK: https://ico.org.uk/global/contact-us/
- For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
ATTN: Legal Department
35 Music Square East
Nashville, TN 37203