PRIVACY POLICY

t enters into force on janvier 30, 2022
  1. INTRODUCTION

This Privacy Policy together with the Terms and Conditions of Use establish how Aspiro AB and its affiliates (“PEERTRACKS”, “we”, or “our” ) process any personal data that they collect from you, or that you provide, when accessing and use the PEERTRACKS music streaming service, mobile applications or associated devices or web pages ( “Services” ). Our policy is to process your personal data at all times in accordance with applicable data protection laws and regulations.

By “personal data”, we mean any information that allows us to identify a person either directly or indirectly. By “affiliates,” we mean any member of our group including our affiliates, our holding company and its affiliates.

  1. WHO ARE WE?

The controller of your personal data is Aspiro AB, a Swedish company whose registered address is: 540 W 26th Street, 8th Floor, New York, NY 10001. If you have any questions, comments or requests about this Privacy Policy, please contact us by email to support@peertracks.com . You can also contact our Data Protection Officer at dpo@peertracks.com .

  1. CHILDREN AND PRIVACY

We do not knowingly collect or solicit information from children under the age of 13, nor do we knowingly allow them to sign up for our Services. If you are under the age of 13, you do not have permission to use the Services. If you are between the ages of 13 and 17, you can visit, browse and use the information on the website but cannot register for an account or submit personal data. If you are between the ages of 13 and 17, by browsing the website, using or accessing the Services, you confirm that you have the permission of a parent or guardian to do so. If you are a parent or guardian and you believe that we have collected personal data from your child without your consent, please notify us immediately via email at support@peertracks.com.

  1. COLLECTION AND USE OF PERSONAL DATA

We will process your personal data for the purpose of providing a Service to you and / or for the legitimate purpose of direct sales. We specifically collect the following types of personal data relating to you for the following purposes:

(a) Information that you provide us directly. When you register as a user of the Services and / or use the Services, you provide us with certain information that we store. This includes: username and password provided to use the Services; your name, contact and any other information in the user profile that you provide such as your address, telephone number, email address and age; information about payments to use the Services; User Content (for example, photos, comments, and other material) that you upload or post on the Services; metadata with said User Content (as defined in Section 9 of the PEERTRACKS Terms and Conditions of Use), which may include the date the content was created, formatting information; location information about where the User Content was recorded (geo-tags: “geotags”); and communications between you and us. We process that information in order to provide you with the Services including account management and to calculate the payment of the content owners.

(b ) Usage information . When using the Services, we collect and process information generated by your use of the Services, such as bookmarks, playlists created, music tracks that were listened to or downloaded, activity in PEERTRACKS applications, tracks listened to offline, the time you connected, what version of PEERTRACKS client you use, and the like. If you access the Services through a portable device, we also store the number that uniquely identifies the device. We use this information (i) to adapt and / or personalize your Services; (ii) in order to improve the service; and (iii) for marketing and advertising purposes (as described below in Section 10).

We may also use internal or third-party analytical tools for our own analytical purposes, to help us measure traffic and Services trends. These tools collect information sent by your device or the Services that helps us improve the Services. We collect and combine this information with analytical information from other visitors and users so that it cannot reasonably be used to identify any particular individual.

(c) Information from log files. This information can be automatically reported by your browser or device each time you request to visit, access or use the Services. When visiting, accessing or using the Services, our servers may automatically record certain information from the log files that includes the time of access, what version of PEERTRACKS client you are using, the IP (Internet Protocol) address, type of browser, referring pages. or of exit and the URLs, number of clicks and how it interacts with the links of the Services, domain names, landing pages, pages visited, and other similar information. We may also record device identification or other unique information for devices that are used to access the Services. We may also collect similar information from emails we send to you, which helps us track which emails are opened and which links are used by recipients. This information is used to (i) analyze the use of the Services; (ii) facilitate more accurate reports; (iii) improve the Services; and (iv) calculate the payment with the content owners.

(d) Survey information . If you respond to the surveys that we have provided, the information you have provided will be anonymous and added to the responses of other users, unless specified and will be used to improve the Services.

In addition to the specific uses of information that we describe in this Privacy Policy, we may use your personal data to: (i) process payments for the use of the Services; (ii) help you efficiently access your information and the features of the Services; (iii) remember information so that you do not have to re-enter it during your visit or the next time you use the Services; (iv) provide, improve, test and monitor the effectiveness of our Services; (v) develop and test new products and features; (vi) monitor parameters such as total visitors, traffic, and demographic models; (vii) diagnose or repair technological problems; and (viii) detect, investigate, and take the necessary steps to address misuse of the Services.

(e) Information collected from third parties. We may receive information about you from third parties who may have collected and transferred your personal data to us in accordance with their own privacy policy and / or terms of use. Examples of such third parties include social networks such as Facebook, business partners, ad networks, analytics providers, or any telecommunications provider through which you access the Services (for example, through bundled packages). When we receive such information from such third parties, we may combine it with other personal data that we have collected about you as set out above and use such information either alone or in combination with other personal data that we have for the purposes described in this Privacy Policy.

If we plan to use your personal data for any purpose other than those mentioned above, we will notify you of the purpose of such process and we will provide you with any other corresponding information either by updating this Privacy Policy or (in case of material change) by means of from an email or push notification.

  1. SHARE INFORMATION WITH THIRD PARTIES

We may share your personal data with those of our affiliates on whom we depend to provide the Services, for the purpose described in this Privacy Policy, (for more details, see Section 4 from (a) to (e) above).

We may share your personal data with third parties other than our affiliates in the following situations:

(a) when you have given us your consent to share such personal data. This may, for example, be related to Facebook or other third parties. Unless you have expressly given your consent, we will not share such personal data with third parties (eg advertisers) for marketing purposes, although we may provide such third parties with aggregated and anonymous collected data about you and other users of the Services.

(b) when necessary for billing purposes. We share the information with the billing agency to facilitate billing. Your billing and payment information is stored by the billing agency and not by PEERTRACKS, and the billing agency processes such information in accordance with its own Privacy Policy.

(c) when we engage third parties to perform services on our behalf with respect to the Services. In such cases we will remain responsible for your personal data and we guarantee that all management of such data will be in accordance with this Privacy Policy and applicable laws.

(d) if we are obliged (i) by applicable laws, or to comply with any legal obligation; (ii) to enforce or apply this Privacy Policy or our Terms and Conditions of Use; or (iii) to protect the rights, property, or safety of PEERTRACKS, our customers, and others. This includes exchanging information with other organizations for the purpose of fraud protection and credit risk reduction. You give your express consent for us to collect and share such information for fraud protection and credit risk reduction.

(e) if we sell or buy any business or goods, in which case we may disclose your personal data to the prospective seller or buyer of such business or goods.

(f) if we are sold to third parties or they acquire us or a substantial part of our assets, in which case the personal data we have about our users will be one of the transferred assets.

(g) with the rights holders of third parties whose content we have under license. The data that PEERTRACKS shares with rights holders is in a non-identifiable format that does not directly identify you, unless you have chosen to share your personal data.

(h) If you dispute any of our charges, we may share your personal information with our credit card company or bank in order to help you resolve the dispute.

(i) where you have given express consent, we may share certain information such as cookie data and streaming data (e.g., the number of times all users listened to a certain song or playlist) with external advertising partners to be able (a) to allow third-party ad networks to, among other things, deliver personalized advertisements that they believe will be of great interest to you; and (b) deliver you personalized emails and other communications regarding such advertisers, their products or services, and / or PEERTRACKS events sponsored or organized by such advertisers. We may delete certain parts of the data that can identify you and share anonymous data with third parties.

Some of our affiliates and / or third parties may be located outside the European Economic Area in countries whose laws may not provide adequate protection for your personal data. Before sharing your personal data with such affiliates (as applicable), we will take contractual or other steps reasonably necessary to ensure that your personal data is processed securely by such affiliates or third parties in accordance with this Privacy Policy.

Except as described in this Privacy Policy, we will never sell your personal data to third parties or allow third parties to access your personal data for their own purposes.

  1. SAFEGUARD PERSONAL DATA

We use organizational and technical measures to protect your personal data against unauthorized or illegal process, and against accidental loss, destruction or damage. Your personal data is safely stored on protected computer. Only a limited number of personnel have access to this equipment and only people with legitimate reasons have access to your personal data. Unfortunately, the transmission of your personal data over the internet is not completely secure. Although we will endeavor (through the use of appropriate security measures) to protect your personal data, we cannot guarantee the security of such data when transmitted to us via the internet: you agree that any such transmission of your personal data, it is at your own risk.

  1. RETENTION OF PERSONAL DATA

We will keep your personal data only for the period necessary to fulfill the purposes for which such data was collected, or for as long as is required by law. When it is no longer necessary for us to retain such data, it will be erased or made anonymous in a secure and permanent way or its access will be blocked in such a way that the legal requirements for data retention are exercised.

  1. YOUR RIGHTS

You have some rights in relation to the way we process your personal data. These include the right to:

  • be informed about any personal data we have about you;
  • request access to your personal data;
  • request that we correct or erase any incorrect personal data;
  • request that we restrict the processing of personal data in certain cases;
  • receive a copy of your personal data in a format that can be read by a machine and sent to another company;
  • object to the processing of your personal data in certain cases; 
  • File a complaint with the corresponding supervisory authorities if you think that we have violated any of the data protection laws.

If you have any concerns or complaints about the way in which we handle your personal data, or to exercise your aforementioned rights, please contact our Data Protection Officer at dpo@peertracks.com . Alternatively, you can contact the Swedish Data Protection Authorities (Integritetsskyddsmyndigheten) ( www.imy.se/other-lang/in-english/ ) or the Information Commissioner’s Office ( https://ico.org.uk / concerns / ).

  1. COMMUNICATIONS

If you have provided us with your email address or telephone number, we will use that information to communicate with you about matters pertaining to the Services in a manner consistent with your preferences, this Privacy Policy, and applicable laws. Such information includes proof of payment, information about changes to the Services, changes to the end user agreement, and this Privacy Policy. You will not be able to exclude yourself from certain important email communications (eg, account verification, payment vouchers, technical or security notifications).

  1. MARKETING AND ADVERTISING

We may provide you with details about our products, services, and events that we think are of interest to you, including details about future streaming content, information about artists, and / or copies of our newsletter. We may also send you promotional offers and communications from external advertisers about your products or services and / or events sponsored or organized by such advertisers, of which you have opted to receive such information from us. We do not sell or provide your email to other companies for their own marketing purposes. In your account options, you can choose not to receive some or no communications of this type.

  1. COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small file that is placed on your device that allows PEERTRACKS and our partners to recognize your device when you return to the website. We use cookies to provide access functionality, to remember user preferences and to understand how our web pages are used.

We use both temporary (“session”) and continuous cookies. We use the following cookies:

Strictly necessary cookies . These are cookies that are required for the operation of our website, they include, for example, cookies that allow you to enter secure areas of our website.

Analytical / performance cookies. These allow us to recognize and count the number of users and to see how users move within our website when they are using it. This helps us improve the way our website works, for example by ensuring that users find what they are looking for easily.

Functionality cookies. These are used to recognize you when you return to our website. This allows us to personalize content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you visited and the links you followed. We will use this information to make our website more relevant to your interests. Where you have expressed your consent, we may also share this information with third parties for these purposes, as described above in Section 5 (i).

You can delete cookies from your browser at any time and you can also configure them by activating the total or partial blocking of cookies in your browser settings. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website.

In addition to our own cookies, Google Analytics (Google Analytics) also sets cookies as described below.

  1. INTEGRATION OF THIRD PARTY SERVICES

Google Analytics : We use Google Analytics from Google on our web pages to create anonymous usage statistics. If you have concerns related to the use of Google Analytics, we inform you that it is possible to block Google Analytics by installing a plug-in in your browser. A plug-in for the most common browsers can be found here: http://tools.google.com/dlpage/gaoptout . Please refer to Google’s privacy policy to understand how Google processes your personal data.

Facebook : If you allow the “Connect to Facebook” function in your PEERTRACKS client settings, we will share your favorites with Facebook by allowing your Facebook friends to see your favorites and allowing you to see your friends’ favorites. Also, if you use the “share” function, you can post to your Facebook account directly from the PEERTRACKS client. Please see Facebook’s privacy policy to understand how Facebook processes your data.

Twitter : If you use the “share” function, you can post to your Twitter account directly from the PEERTRACKS client. Such postings may involve the sharing of personal data. Please refer to the privacy policy of Twitter to understand how Twitter processes your data.

  1. INTEGRATION OF THIRD PARTY WEBSITES

We may link to third party websites. PEERTRACKS cannot control or be held responsible for the privacy policy of third parties and their content. Please refer to the privacy policy of the third party site to understand how they process your personal data.

We are not responsible for the practices implemented by any website or services that are linked to or from the Services such as, but not limited to, Facebook and Twitter. This includes the information or content within these. By using a link to go from our Services to another website or service, our Privacy Policy no longer applies to third-party websites or services. Your navigation or interaction on any third party website or services, including those that have a link in our Services, are subject to their own rules and policies. Furthermore, you understand and agree that we are not responsible for or have control over third parties to whom you authorize to have access to your personal data (including User Content).

  1. DETECTION OF THE MISUSE OF THE SERVICES

If we suspect misuse of the Services, we may combine the personal data that we have collected in accordance with this Privacy Policy along with other information to investigate the extent to which it was misused and who is responsible.

  1. ACCESS, RECTIFICATION AND DISPOSAL

If you have questions about the personal data we have stored, including a request to access, rectify or delete it, or if you object to certain uses, please contact us by sending an email to 
dpo@peertracks.com or support@peertracks.com .

  1. MODIFICATIONS TO THE PRIVACY POLICY

The services are subject to continuous improvement and future changes may influence what types of personal data we store and how we process it. This Privacy Policy may be updated to reflect such changes, changes in the legal framework, or improvements in how we manage personal data. Please check back frequently for updates to the Privacy Policy. When we make material changes to the Privacy Policy, we will provide you with appropriate notice in the circumstances, for example by sending you an email.