PRIVACY POLICY
Last updated
This privacy notice for
SUMMARY OF KEY POINTS
This summary provides
key points from our privacy notice, but you can find out more details about any
of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking
for.
What personal
information do we process? We collect log information on how you
use the app, including number of songs and duration you play and other
information related to showing advertisements in the app. We also collect your
Smule ID, songs and metadata that you download to enhance and maintain the app.
Do we process any
sensitive personal information?
Do we receive any information
from third parties?
How do we process your
information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your information for
other purposes with your consent. We process your information only when we have
a valid legal reason to do so. Learn more about how
we process your information.
In what situations and
with which
How do we keep your
information safe? We have
What are your rights? Depending
on where you are located geographically, the applicable privacy law may mean
you have certain rights regarding your personal information. Learn more about your
privacy rights.
How do you exercise your
rights? The easiest way to exercise your rights is by
Want to learn more about what we do with any
information we collect? Review the privacy
notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We
collect personal information that you provide to us.
We collect personal
information that you voluntarily provide to us when you
Sensitive Information.
In Short: Some
information — such as your Internet Protocol (IP) address and/or browser and
device characteristics — is collected automatically when you visit our
Services.
We automatically collect
certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about
how and when you use our Services, and other technical information. This
information is primarily needed to maintain the security and operation of our
Services, and for our internal analytics and reporting purposes.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We
process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your consent.
We process
your personal information for a variety of reasons, depending on how you
interact with our Services, including:
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process
your personal information when we believe it is necessary and we have a valid
legal reason (i.e.
If you are located in
the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and
UK GDPR require us to explain the valid legal bases we rely on in order to
process your personal information. As such, we may rely on the following legal
bases to process your personal information:
If you are located in Canada, this section applies to you.
We
may process your information if you have given us specific permission (i.e.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
In Short: We
may share information in specific situations described in this section and/or
with the following
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We
keep your information for as long as necessary to
We will only keep your
personal information for as long as it is necessary for the purposes set out in
this privacy notice, unless a longer retention period is required or permitted
by law (such as tax, accounting, or other legal requirements).
When we have no ongoing
legitimate business need to process your personal information, we will either
delete or
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We
aim to protect your personal information through a system of
We have implemented
appropriate and reasonable technical and
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We
do not knowingly collect data from or market to
We do not knowingly solicit
data from or market to children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are the parent or guardian
of such a minor and consent to such minor dependent’s use of the Services. If
we learn that personal information from users less than 18 years of age has
been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:
In some regions (like
We will consider and act
upon any request in accordance with applicable data protection laws.
If you are located in the
EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your Member
State data protection authority or UK data protection
authority.
If you are located in
Switzerland, you may contact the Federal Data
Protection and Information Commissioner.
Withdrawing your consent:
If we are relying on your consent to process your personal information,
However, please note that this will not affect
the lawfulness of the processing before its withdrawal nor,
If
you have questions or comments about your privacy rights, you may email us at
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some
mobile operating systems and mobile applications include a Do-Not-Track (
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
In Short: Yes,
if you are a resident of California, you are granted specific rights regarding
access to your personal information.
California Civil Code Section
1798.83, also known as the
If you are under 18 years of
age, reside in California, and have a registered account with Services, you
have the right to request removal of unwanted data that you publicly post on
the Services. To request removal of such data, please contact us using the
contact information provided below and include the email address associated
with your account and a statement that you reside in California. We will make
sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our
systems (e.g.
CCPA Privacy Notice
The
California Code of Regulations defines a
(1) every individual who is
in the State of California for other than a temporary or transitory purpose and
(2) every individual who is
domiciled in the State of California who is outside the State of California for
a temporary or transitory purpose
All other individuals are
defined as
If this definition of
What
categories of personal information do we collect?
We have collected the
following categories of personal information in the past twelve (12) months:
Category |
Examples |
Collected |
A.
Identifiers |
Contact
details, such as real name, alias, postal address, telephone or mobile
contact number, unique personal identifier, online identifier, Internet
Protocol address, email address, and account name |
|
B. Personal information
categories listed in the California Customer Records statute
Name, contact information, education,
employment, employment history, and financial information
C. Protected classification
characteristics under California or federal law
Gender and date of birth
D. Commercial information
Transaction information,
purchase history, financial details, and payment information
E. Biometric information
Fingerprints and voiceprints
F. Internet or other similar
network activity
Browsing history, search
history, online
G. Geolocation data
Device location
H. Audio, electronic,
visual, thermal, olfactory, or similar information
Images and audio, video or call
recordings created in connection with our business activities
I. Professional or
employment-related information
Business contact details in
order to provide you our Services at a business level or job title, work
history, and professional qualifications if you apply for a job with us
J. Education Information
Student records and
directory information
K. Inferences drawn from
other personal information
Inferences drawn from any of
the collected personal information listed above to create a profile or summary
about, for example, an individual’s preferences and characteristics
L. Sensitive Personal Information
You may contact us
If you are using an
Will your
information be shared with anyone else?
We may disclose your
personal information with our service providers pursuant to a written contract
between us and each service provider. Each service provider is a for-profit
entity that processes the information on our behalf, following the same strict
privacy protection obligations mandated by the CCPA.
We may use your personal
information for our own business purposes, such as for undertaking internal
research for technological development and demonstration. This is not
considered to be
We have not disclosed, sold,
or shared any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. We will not sell
or share personal information in the future belonging to website visitors,
users, and other consumers.
Your
rights with respect to your personal data
Right to
request deletion of the data — Request to delete
You can ask for the deletion
of your personal information. If you ask us to delete your personal
information, we will respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but not limited to) the
exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to
be informed — Request to know
Depending on the
circumstances, you have a right to know:
In accordance with
applicable law, we are not obligated to provide or delete consumer information
that is de-identified in response to a consumer request or to re-identify
individual data to verify a consumer request.
Right to
Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate
against you if you exercise your privacy rights.
Right to Limit Use and
Disclosure of Sensitive Personal Information
We
do not process consumer's sensitive personal information.
Upon receiving your request,
we will need to verify your identity to determine you are the same person about
whom we have the information in our system. These verification efforts require
us to ask you to provide information so that we can match it with information
you have previously provided us. For instance, depending on the type of request
you submit, we may ask you to provide certain information so that we can match
the information you provide with the information we already have on file, or we
may contact you through a communication method (e.g.
We will only use personal
information provided in your request to verify your identity or authority to
make the request. To the extent possible, we will avoid requesting additional
information from you for the purposes of verification. However, if we cannot
verify your identity from the information already maintained by us, we may
request that you provide additional information for the purposes of verifying
your identity and for security or fraud-prevention purposes. We will delete
such additionally provided information as soon as we finish verifying you.
Other
privacy rights
11. DO
VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Virginia, you
may be granted specific rights regarding access to and use of your personal
information.
Virginia
CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act
(CDPA):
If this definition
The information we collect, use, and disclose
about you will vary depending on how you interact with us and our Services. To
find out more, please visit the following links:
Your rights
with respect to your personal data
We
have not sold any personal data to third parties for business or commercial
purposes. We will not sell personal data in the future belonging to website
visitors, users, and other consumers.
Exercise
your rights provided under the Virginia CDPA
More
information about our data collection and sharing practices can be found in
this privacy notice
You may contact us by email at
If you are using an
Verification process
We may request that you provide additional
information reasonably necessary to verify you and your consumer's request. If
you submit the request through an
Upon receiving your request, we will respond
without undue delay, but in all cases, within forty-five (45) days of receipt.
The response period may be extended once by forty-five (45) additional days
when reasonably necessary. We will inform you of any such extension within the
initial 45-day response period, together with the reason for the extension.
Right to
appeal
If we decline to take action regarding your
request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email
us at
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes,
we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy
notice from time to time. The updated version will be indicated by an updated
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or
comments about this notice, you may
United
States
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM YOU?