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Soundstripe Privacy Policy

Last Modified: August 14, 2023

Soundstripe, Inc. (“Soundstripe,” “we,” “us,” or “our”) is committed to protecting the privacy of our clients, individuals interested in our business, and visitors to our website, soundstripe.com (the “Site”). This Privacy Policy explains our privacy practices and the types of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined by applicable privacy laws (“Personal Data”) that we may collect or receive from the Site, any of our affiliates and subsidiaries’ websites, any other web address, mobile site, or application controlled by Soundstripe that links to this Privacy Policy; when you use our products and services; or when you use the Soundstripe mobile app (collectively, the “Services”). 

By accessing and using the Services or otherwise providing information to Soundstripe, you have consented to the terms of this Privacy Policy, and consent to our privacy practices described herein including our use and disclosure of your Personal Data. If you do not agree to the terms and conditions of this Privacy Policy, then please do not provide us with your information. Please note, however, that if you choose to limit the information that you provide to us while using the Services, you may not be able to use or participate in certain features of the Services.



1. MODIFICATIONS AND REVISIONS


We may update this Privacy Policy from time to time to reflect changes to our privacy practices. We will notify you of any changes to this Privacy Policy by posting the revised or updated Privacy Policy and its “Last Modified” date on the Services. If the revision or modification is material, we will provide you notification via email or via the Site. Your continued use of the Services after the “Last Modified” date constitutes your acceptance of and agreement to the Privacy Policy and its revisions or updates. You should periodically read the Privacy Policy to learn of any revisions or updates. 

 

2. COLLECTION OF PERSONAL DATA


During your use of the Services, Soundstripe collects both Personal Data and non-personally identifiable information about you in various ways, including:

  • Directly from you when you provide it to us;
  • Automatically as you use the Services; and 
  • From third parties.

a. Information Provided by You

We may collect the following types of Personal Data and other information directly from you when you use the Services to register for an account, download or purchase a product or service, submit and/or post content, or communicate with our team.  We may collect the following types of Personal Data:

  • Account Data, including name, phone number, email, physical address, date of birth, user ID and password; 

  • Payment Data, including name, postal address, company, billing information, and financial or bank information;
    • You may be required to provide financial and bank information prior to purchasing select products and services. Please note, we do not store financial and bank information; such information is securely processed and stored by PayPal and Stripe, our payment processor. 
  • Transaction Data, including transaction history; and

  • Sensitive Personal Data, in certain situations, we may collect sensitive Personal Data including taxpayer identification number for our business-to-business customers and biometric information for those customers who voluntarily upload an account picture. 

    Special Category Data

Some of the information that we may collect as a result of providing the Services is particularly sensitive (e.g., taxpayer identification number). We only collect this information as provided by or consented by you.  

Such sensitive information is only shared for the purpose of providing the Services or as consented for and will not be shared or used by us for any other purposes.

 

b. Information Automatically Collected by the Services


Soundstripe and third-party service providers may automatically collect information about you when you use the Services. Like many other websites or apps, Soundstripe and its providers may collect and store information that is generated automatically as you navigate through the Services. This information is primarily needed to maintain the security and operation of the Services, and for our internal analytics so that we can improve the Services. This information includes: 

    • Internet and Electronic Activity Data, including cookies, details of your visits to the Services, including traffic data, logs, and other communication data and the resources that you access and use on the Services, device's unique device identifier, operating system, browser type, mobile network information, device's telephone number, mobile device ID, browsing history, browser and device information, advertising identifiers, clickstreams, search history, usage details, IP  address, pixel tags, browser version, operating system, other tracking technologies.

 

      • Cookies, are small data files that we transfer to your computer’s hard disk for record-keeping purposes. Cookies do not personally identify you; they merely identify the computer or device with which you access the Services. The Services use cookies to analyze trends, recognize you, tailor the Services to you, or to detect and prevent fraud. You can instruct your browser, by changing its options, to disable cookies or to prompt you before accepting a cookie from the Services. If you disable cookies, however, you may not be able to use all portions or functionality of the Services. For more information on Cookies, please visit our Cookie Policy

 

      • Third Party Cookies
        • Google Analytics, visitors to the Site may be tracked using Google Analytics. The Personal Data collected by Google Analytics is primarily used to optimize the Site for users; however, we may also use this data for marketing purposes. The Personal Data we automatically collect using Google Analytics is shared with Google. For more information on Google’s Privacy Policies, visit: https://policies.google.com/privacy. You can also opt-out of having your personal data used by Google Analytics by following the instructions located at https://tools.google.com/dlpage/gaoptout/.  Without limitation, Google Analytics may collect the following types of data from users of the Sites:

 

          • Type of web browser used, software manufacture and version number.
          • Type of operating system
          • Color processing ability of the users screen
          • JavaScript support
          • Flash version
          • Screen resolution
          • Network location and IP address
          • Country, city, state, region, county, or any other geographic data
          • Hostname
          • Bandwidth (internet connection speed)
          • Time of visit
          • Pages visited
          • Time spent on each page of the Site
          • Referring site statistics
          • The website the user came through in order to arrive at the Site
          • Search engine query used
        • We also use Google Analytics for Display and Search Advertising and, specifically, Google Analytics Demographics and Interest Reporting, on the Site to help display advertising for products or Services that we think may be of interest to you. We will use demographic information collected through our use of Google Analytics Demographics and Interest Reporting for purposes of performing internal statistical analytics relating to the Site. You can opt-out of receiving interest-based advertisements through the Site, as well as customize the types of advertisements that will be displayed to you through the Site, by following the instructions located at https://support.google.com/ads

 

        • Meta Pixel, we use Meta Pixel Tags to better measure, optimize, and retarget our marketing campaigns. This allows user specific behavior to be tracked after they have been redirected to the advertiser’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, in other words, we do not see the Personal Information of individual users. This data is stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. For more information on opt-out options, please visit: https://www.facebook.com/help/568137493302217.

 

        • Cloudflare, we use Cloudflare to offer better global performance through the internal CDN (Content Distribution Network) and additional security against DDoS attacks. Allowing the placement of Cloudflare cookies onto your browser is a requirement when visiting the Site to ensure that security features work properly.  For more information about Cloudflare and Cloudflare’s Privacy Policy, please visit: https://www.cloudflare.com/privacypolicy/

 

        • Hubspot, we use Hubspot to assist with analytics of the Site.  Hubspot will set cookies for tracking visitors. It contains the domain, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session.

 

        • Mixpanel, we use Mixpanel to help us understand how the Site is used and also to help us detect important events and send out push notifications or e-mail messages.  For more information regarding Mixpanel’s privacy practices, please visit: https://mixpanel.com/privacy/. You can also opt out from Mixpanel data collection.

 

    • Heat Mapping and Session Recording, are used to capture how you use and interact with the Site through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Site usage data is captured using Hotjar’s first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for Site optimization, fraud/security purposes, and advertising. For more information regarding Hotjar’s tracking cookies, please visit: https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies. You can also opt out from Hotjar’s data collection. 

 

    • Live Webchat.  We utilize a live webchat service provided by a third party vendor, Crisp, that collects, uses, stores, shares, discloses, and protects customer Personal Data in accordance with the Crisp privacy policy, located at the following link: https://crisp.chat/en/privacy/. The data Crisp stores from our customers is strictly for our use. Information can include operator names and emails, visitor names and emails, visitor phone numbers, email addresses, and IP addresses. 

 

c. Information Received from Third Parties


In some instances, Soundstripe may receive Personal Data and/or anonymous data about you from other parties, such as our affiliates, business partners, service providers, and other third parties such as Google and Apple. That information may be obtained online, offline, or through publicly available resources.  We may combine this information with the information you provide, and other data we already have about you.

We may also receive information about you from social media platforms when you interact with us on those platforms, access our social media content, if you use a third-party account to sign-in to the Services, or link a third-party account to your account. Please note that the information we may receive from those third parties (such as Facebook, Twitter, LinkedIn, Instagram, TikTok, and Youtube) is governed by the privacy settings, policies and/or procedures of the applicable platform, and we strongly encourage you to review them before submitting any information using a social media platform.




3. PURPOSE OF COLLECTION


Soundstripe may process your Personal Data for the following lawful business and commercial purposes, in accordance with the practices described in this Privacy Policy, and based upon the legal justification set forth in the parenthetical: 

 

  • Provide the Services. We may use your Personal Data to provide the Services and any other services you may request from us. (CONSENT; CONTRACT; LEGITIMATE INTEREST)
  • Provide API. We may use Personal Data to enhance your product with a premium music API and boost engagement with your users. 
  • Monitor the Services. We collect your Personal Data for monitoring purposes to help us diagnose problems with our servers, administer and troubleshoot the Services, calculate usage levels, analyze industry standards, and analyze transactions, trends, and statistics regarding the use of the Services. (CONSENT; LEGITIMATE INTEREST)
  • Respond to Inquiries and Fulfill Requests.  We may use your Personal Data to respond to your inquiries and to fulfill your requests for information. (CONSENT)
  • Communicate with You.  We may use your Personal Data to send you marketing information about the Services, special promotions, and other items that may be of interest to you.  We may also contact you on behalf of our third-party business partners about a particular offering of theirs that may be of interest to you. (CONSENT; LEGITIMATE INTEREST)
  • Improve the Services.  We may use your Personal Data to make the Services more stable and user-friendly, to analyze service issues, improve the design and content of the Services, personalize your experience, analyze how the Services are used, offer new services, and to develop new marketing programs relating to the Services. (CONSENT, LEGITIMATE INTEREST)
  • Customer Service. We may use your Personal Data when contacting you regarding customer service, the Services, resolve disputes, or in response when you provide feedback. We may also use your information to send administrative emails regarding the Services or to inform you of any changes to this Privacy Policy, our terms or other agreements with you, or our third-party partner’s terms. (CONSENT; LEGITIMATE INTEREST)
  • Support Business Operations. We may use your Personal Data to support our internal and business operations, including marketing, security, and advertising. (CONSENT; LEGITIMATE INTEREST)
  • Enforce Agreements. We may use your Personal Data to enforce separate agreements between you and us, enforce this Privacy Policy, our Terms of Use or other agreements with you, or our third-party partner’s Terms of Use, or in connection with a transaction with a similar effect. (CONSENT; CONTRACT)
  • Fulfill Other Purposes. We may use your Personal Data to fulfill: (a) any other purpose for which you provide it; (b) any legal or regulatory requirements and any of our internal policies; (c) other purposes disclosed at the time of collection; (d) any other purpose with your consent; and (e) any other purposes set forth in this Privacy Policy. (CONSENT; LEGITIMATE INTEREST)
    1. Legal Basis for Processing

      If our processing is based solely on your consent, subject to legal exceptions, you have the right to withdraw your consent at any time.

4. DISCLOSURE OF PERSONAL DATA


Except as otherwise described in this Privacy Policy, we do not sell, share, rent, or otherwise disclose your Personal Data that we collect from the Services to any third parties for monetary or other valuable consideration, unless stated below or with your consent: 

 

  • Subsidiaries and Affiliates. We may disclose Personal Data about you to our subsidiaries and affiliates.

  • Service Providers & Contractors. To help us provide superior service, your Personal Data may be shared with our service providers, contractors, and other third parties we use to support our business and who will safeguard it in accordance with this Privacy Policy. Such third parties may help us with order processing and fulfillment, providing customer service, maintaining and analyzing data, and sending customer communications on our behalf. For more information about our specific service providers and contractors and their activities, please visit www.soundstripe.com/service-partners, which may be updated from time to time. 

  • Live Chat and Interactive Support. The Services may include “live chat” or other live interactive features.  We may provide these features through technology provided by third parties, and you consent to the transfer of your Personal Data to these providers by using these features.

  • Marketing Partners. We may share your Personal Data with entities that perform marketing or data aggregation services on our behalf, or with which Soundstripe or an affiliate has joint marketing arrangements. We may also share your Personal Data with Soundstripe Partners for marketing and promotional purposes. 

  • Advertising Partners. We may share your Personal Data with third party advertising partners, including but not limited to Microsoft, Bing Ads, TikTok, Reddit, LinkedIn, and Google Display Advertising and Remarketing services. These advertising partners may use first- and third-party cookies together to inform, optimize, and serve ads based on your past visits to the Services. You can opt out of these services using the Ads Preferences Manager or you can use the Google Analytics opt-out browser add-on. These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks, commonly referred to as “interest-based advertising.”

  • Analytics Partners.  We may use analytics-based technologies to assist with personalization, advertising, and marketing.  These technologies capture how you interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products and services.  

  • Authorized Representatives. If another individual is managing your account with us or your email account which the Services connect to on your behalf (for example, a wife managing the account of a husband), as authorized by you or as a personal representative under applicable law, that person can view all Personal Data about you on the Services.

  • In the Event of Merger, Sale, Divestitures, or Change of Control. Soundstripe reserves the right to transfer Personal Data to a buyer or other successor in interest that acquires rights to that information as a result of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of Soundstripe or substantially all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about you is among the assets transferred. 

  • With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction. 

  • Other Disclosures. We may disclose your Personal Data if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) conform to legal requirements and comply with any court order, law, or legal process, including responding to any government, law enforcement, or regulatory request; (ii) enforce the Terms of Use, other agreements, including between you and us, and any other documents included or referenced therein (all of which are incorporated into and made a part of this Privacy Policy by reference); (iii) fulfill the purpose for which you provide it; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to our, your, or third parties’ rights, property, or safety. 

We may share and disclose de-identified and/or aggregate analytics with third-party partners for the purposes described in this Privacy Policy or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with Personal Data.

5. CHOICES


We strive to provide you with choices regarding how we use the Personal Data you provide to us. Please understand that if you choose not to disclose information to us, it may affect your ability to use some features of the Services. We have created mechanisms to provide you with the following control over your information:

  1. Account Profile
    To update your information or discontinue the Services, please contact us as specified in the Contact Information section below. You also may be able to update your information by logging into your Account.
  2. Advertising
    We may use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements about the Services. Such third parties may gather information about your visit to the Services, monitor your access or market the Services to you, monitor the ads you view, click-on, or interact with, when they were delivered, and the screens and pages that they are on. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. 
    We and our service providers may use information about your interactions with the Services to predict your interests and select the ads you see on and off the Services. This is known as interest-based advertising. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance. For more information about interest-based advertising and how you can opt out, visit:
  3. Marketing
    From time to time if you have supplied your email address, we may send you marketing or informational emails. If you prefer not to receive any or all of our marketing and promotional communications, you may opt-out of these communications by following the opt-out prompts on these communications. You also may ask us not to send you other marketing or informational communications by contacting us as specified in the Contact Information section below, and we will honor your request. Please note that even after you are removed from our marketing lists, we may still send you non-promotional communications, such as responding to your support requests.
  4. Do Not Track
    Some browsers have a “Do Not Track” (“DNT”) feature that lets you tell websites and online services that you do not want to have your online activities tracked. Such browser features and industry standards are not uniform. As such, Soundstripe does not monitor or respond to DNT browser requests.  If a standard is adopted that we must follow in the future, then we will inform you about that practice in a revised version of this Privacy Policy.

 

6. THIRD-PARTY SERVICES, LINKS, AND WEBSITE


The Services may contain links to third-party services, websites, mobile applications, and/or contain advertisements from third parties that are not affiliates with us and which may link to other websites, services, or applications. While we endeavor to work with third parties that share our respect for user privacy, we are not responsible for the privacy policies or privacy practices of such third parties. Any information collected by third parties are not covered by this Privacy Policy. You are responsible for knowing when you are leaving the Services to visit a third-party website, service, or application and for reading and understanding the terms of use and privacy policy statements for each such third party. This Privacy Policy only governs information collected through the Services. 

We may allow you to connect a YouTube channel to your account on the Site. In this case, we will access certain information from YouTube about your channel by using YouTube API Services. We may store your channel ID for reference when creating licenses, which will be treated in accordance with this Privacy Policy. We may share your channel id to our content ID licensing partner, Orfium (www.orfium.com), who facilitates our content ID licensing. If you decide to connect a YouTube channel to your Soundstripe account, you will also be subject to Google’s privacy policy available here: http://www.google.com/policies/privacy. When disconnecting a YouTube channel on our Site, We will delete the stored data associated with that YouTube channel. You can also revoke access to the data we collect via the YouTube API Services by changing your security settings on Google here: https://security.google.com/settings/security/permissions.

 

7. CHILDREN


The Services are not intended for children, and we encourage parents and guardians to be aware of and monitor the websites visited by their children. Soundstripe does not knowingly collect any Personal Data from children under 16 years of age. If Soundstripe learns that a child under the age of 16 has submitted Personal Data to the Services without guardian or parental consent, we will take all reasonable measures to remove or delete such information as soon as practicable and not use such information for any purpose, except where necessary to protect the safety of the child or others or as required or allowed by law. If you believe a child under age 16 has provided us with Personal Data, please contact us as specified in the Contact Information section below. 

8. RETENTION PERIOD 


Soundstripe may retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. We are under no obligation to store such Personal Data indefinitely and, to the extent permitted by law, disclaim any liability arising out of, or related to, the destruction of such Personal Data.

9. CONFIDENTIALITY AND SECURITY


We take the security of your Personal Data seriously and have implemented appropriate technical and organizational measures to protect it from unauthorized access, disclosure, or destruction. While we implement these measures, please note that 100% security is not possible, and we cannot guarantee that the security measures we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective.

 

10. PUBLIC FORUMS


We may provide public areas on the Services, such as forums, blogs message boards, and chat rooms (“Public Forum”), where you can post information about yourself and others. Please exercise discretion and use caution with respect to your data, especially in such public areas. We do not control who reads postings on the Services, or how they may use or disclose such information. If you choose to voluntarily disclose information on Public Forums, that information will be publicly available and can be collected and used by other users. 

 

11. INTERNATIONAL TRANSFER OF INFORMATION


The Services are hosted in the United States. If you are visiting the Services from outside the United States, your Personal Data may be transferred to, stored, and processed in the United States in accordance with this Privacy Policy and applicable U.S. laws. Please note your Personal Data will be transferred, processed, collected, use, accessed, and/or stored in the United States, a country and jurisdiction that may not have the same data protection laws or rights as the country in which you reside, and subject to U.S. laws. Please do not provide your Personal Data to us if you do not want this information to be transferred or processed outside of your country, or if the laws in your country restrict such transfers. By using the Services, you consent to the transfer of your information to our facilities and the practices described in this Privacy Policy.

 

12. EEA, UK, AND BRAZIL PRIVACY RIGHTS


Individuals (“Data Subjects”) in the European Economic Area (EEA), the United Kingdom (UK), and Brazil have certain privacy rights under Brazilian, EU, and UK law, including the General Data Protection Regulations (the “GDPR”), UK Data Protection Act 2018, and Lei Geral de Proteção de Dados Pessoais (the “LGPD”).

In the event, we collect Personal Data (as defined in the GDPR or LGPD) that is subject to the GDPR or LGPD, this section shall apply. Terms in this section are to be understood in a manner consistent with the GDPR or LGPD including the definitions of such terms in the GDPR or LGPD. Such terms may have a different definition or meaning in other portions of this Privacy Policy because the GDPR or LGPD may not apply to those sections.

  1. Data Controller
    The Data Controller is Soundstripe.
  2. Processing Purposes and Legal Bases
    Soundstripe processes your Personal Data for the lawful purposes, and under the legal bases set forth in the Collection of Personal Data section above.
  3. Onward Transfer
    Soundstripe will not disclose Personal Data to a third party except as stated below:
    We may disclose Personal Data to subcontractors and third-party agents. Before disclosing Personal Data to a subcontractor or third-party agent, we will obtain assurances by contractual agreement from the recipient that it will: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the subcontractor or third-party agent is obligated to provide at least the same level of privacy protection as is required by the GDPR; (iii) take reasonable and appropriate steps to ensure that subcontractors and third-party agents effectively process the Personal Data transferred in a manner consistent with the organization’s obligations under the GDPR; (iv) require subcontractors and third-party agents to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the GDPR; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with subcontractors and third-party agents to the Supervisory Authorities upon request.
    We also may be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements, or in the event of a merger or acquisition.
  4. Rights under the GDPR
    Data Subjects have the following privacy rights under the GDPR:
    • Right of Access. You have the right to obtain confirmation from us as to whether or not we process Personal Data from you, and you also have the right to at any time obtain access to your Personal Data stored by us.
    • Right to Rectification. If we process your Personal Data, we use reasonable measures to ensure that your Personal Data is accurate and up-to-date for the purposes for which your Personal Data was collected. If your Personal Data is inaccurate or incomplete, you have the right to require us to correct it.
    • Right to Erasure. You may have the right to require us to delete your Personal Data.
    • Right to Restrict Processing. You may have the right to request the restriction or suppression of Personal Data.  
    • Right to Withdraw Consent. If you have given your consent to the processing of your Personal Data, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal.
    • Right to Data Portability. You may have the right to receive the Personal Data concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.
    • Right to Object. You may have the right to object to the processing of your Personal Data as further specified in this Privacy Policy and you may have the right to object to decisions being made with your Personal Data based solely on automated decision making or profiling.
    • Right to Lodge a Complaint with Supervisory Authority. You have the right to lodge a complaint with a data protection supervisory authority located in the European Union or UK. Further information about how to contact your local data protection authority is available at the website of the European Commission.

      If you would like to exercise your EEA and UK privacy rights, please contact us as specified in the Contact Information section with a reference to “EEA and UK.”  
  5. Choices under the GDPR
    Data Subjects have the right to opt out of (i) disclosures of their Personal Data to third parties not identified at the time of collection or subsequently authorized, and (ii) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized. Data Subjects who wish to limit the use or disclosure of their Personal Data should submit that request to our Data Protection Officer. We will cooperate with Data Subjects’ instructions regarding Data Subjects’ choices.
    All of our general emails also contain an unsubscribe link at the bottom and you can unsubscribe to such emails at any time by clicking on that link.
  6. Security
    See Confidentiality and Security section above for more information about our security practices. 
  7. Retention of Personal Data
    For more information, please refer to the Retention Period section above. 
  8. Transfers to the United States
    In using the Services, your Personal Data will be transferred to the United States.. Soundstripe relies on your consent or Article 49 of the GDPR for transfers of data collected from Data Subjects in the EU and EEA. Transfers are made to Soundstripe only if the Data Subject has explicitly consented to the proposed transfer after having been informed of the possible risks of such transfers. Additionally, we transfer data as necessary for the performance of a contract between you as the Data Subject and Soundstripe as the Controller, to Data Processors who have an agreement with us that includes protecting your privacy and the security of your data, and in cases where your Personal Data is necessary for the implementation of pre-contractual measures taken in accordance with your requests.

 

 

13. CANADIAN DATA SUBJECT RIGHTS


Individuals in Canada have certain privacy rights under Canadian law, including the Personal Information Protection and Electronic Documents Act (the “PIPEDA”) and any applicable provincial laws. In the event, we collect Personal Information (as defined in the PIPEDA) that is subject to the PIPEDA, this section shall apply. Terms in this section are to be understood in a manner consistent with the PIPEDA including the definitions of such terms in the PIPEDA. Such terms may have a different definition or meaning in other portions of this Privacy Policy because the PIPEDA may not apply to those sections.

a. PIPEDA Principles

  1. Principle 1 – Accountability 
    Soundstripe is accountable for Soundstripe’s compliance with the PIPEDA Principles. 
  2. Principle 2 – Identifying Purposes
    Soundstripe processes your Personal Data for the lawful purposes set forth in the Purpose of Collection section above at or before the time of collection.
  3. Principle 3 – Consent
    Soundstripe uses and discloses your Personal Data, with your consent, for the reasons set forth in the Purpose of Collection and Disclosure of Personal Data sections above. 
  4. Principle 4 – Limiting Collection
    Soundstripe collects the type of Personal Data specified in the Collection of Personal Data section above, which is necessary to fulfill the purposes identified in the Purpose of Collection section above. 
  5. Principle 5 – Limiting Use, Disclosure, and Retention
    Soundstripe will retain and destroy your Personal Data as specified in the Retention Period section above.
  6. Principle 6 – Accuracy
    Your Personal Data shall be accurate, complete, and up-to-date. For more information about updating your Personal Information, please contact as specified in the Contact Information section below.  
  7. Principle 7 – Safeguards
    For more information about our security safeguards, please refer to the Confidentiality and Security section above.
  8. Principle 8 – Openness
    Individuals have the right to acquire information about Soundstripe’s policies and practices with respect to the management of Personal Data. You may request the following information: (i) the name or title, and the address of the person accountable for Soundstripe’s policies and practices and to whom complaints or inquiries can be forwarded; (ii) the means of gaining access to Personal Data held by Soundstripe; (iii) a description of the type of Personal Data held by Soundstripe, including a general account of its use; (iv) a copy of any brochures or other information that explain Soundstripe’s policies, standards, or codes; and (v) what Personal Data is made available to related organizations of Soundstripe, such as affiliates and subsidiaries. 
  9. Principle 9 – Individual Access
    Individuals have the following privacy rights under the PIPEDA:
    Right of Access. Upon request, Soundstripe must inform you whether or not we hold Personal Dataabout you and the source of this information. You also have the right to request an account of the use that has been made or is being made of your Personal Data and an account of the third parties to which it has been disclosed. 

    Right to Challenge Accuracy and Completeness. If you have successfully demonstrated the inaccuracy or incompleteness of your Personal Data, we will amend the information as required, and where appropriate, transmit the amended information to third parties with whom we have shared or disclosed the information in question. Depending upon the nature of the Personal Data challenged, we may either correct, delete, or add additional information to the information in question. If we are unable to resolve your challenge to your satisfaction, we will record the substance of the unresolved challenge, and when appropriate, transmit the unresolved challenge to third parties with whom we have shared or disclosed the information in question. 

    Right to Data Portability. You may have the right to receive your requested information in a reasonable time and at a minimal or no cost to you, and in a form that is generally understandable. 
    If you would like to exercise your Canadian privacy rights, please contact us as specified in the Contact Information section with a reference to “Canada.”  
  10. Principle 10 – Challenging Compliance

You have the right to make inquiries or lodge complaints concerning Soundstripe’s compliance with any of the Principles under PIPEDA to the individual identified in Principle 1 – Accountability section above. You may contact them as specified in the Contact Information section below with a reference to “PIPEDA Complaint.” Upon contact, they will inform you of Soundstripe’s relevant complaint procedures, including any regulatory handling practices. 

 

b. Commercial Electronic Messages (“CEM”) in Canada


Canada’s Anti-Spam Law Legislation (“CASL”) requires that Soundstripe obtain the express consent of Canadian citizens before sending an electronic message such as an email that contains a promotion about our products. We will ask you for your explicit consent when you provide us with your email address or other Personal Information through which we intend to encourage your participation in a commercial activity, such as a promotion for our products.

If you explicitly consent to receiving CEM, each communication sent to you will contain an option to unsubscribe to the communications or to revoke your consent to receive CEM. Alternatively, you can contact us as specified in the Contact Information section to be removed from our mailing lists.

 

14. CALIFORNIA PRIVACY RIGHTS


This section explains how we collect, use, and disclose Personal Information about users, customers, and visitors who reside in California (“consumers” or “you”). It also explains certain rights afforded to consumers under California’s Shine the Light law and the California Consumer Privacy Act of 2018 (“CCPA”), as revised and updated by the California Privacy Rights Act (“CPRA”). This section uses certain terms that have the meaning given to them in the CCPA including Personal Information.

a. Shine the Light
Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the Contact Information section below with a reference to California Disclosure Information.


b. Categories of Personal Information Collected
We may collect (and have collected during the 12-month period prior to the “Last Modified” date of this Privacy Policy) the above categories of Personal Information about you in the Collection of Personal Data section above.


c. Purpose of Collection
We may use (and may have used during the 12-month period prior to the “Last Modified” date of this Privacy Policy) your Personal Information for the business or commercial purposes described in the Purpose of Collection section above.


d. Sources of Personal Information
During the 12-month period prior to the “Last Modified” date of this Privacy Policy, we may obtain (and may have obtained) Personal Information about you from the sources identified in the Collection of Personal Data section above.


e. Selling and Sharing Personal Information
We do not sell or share your Personal Information in exchange for monetary consideration; however, we may use tools described above such as Google Analytics, which may be interpreted as sharing your Personal Information.  As such, please see the above Personal Data Automatically Collected and Choices sections for more information regarding opting out of use of these tools.
During the 12-month period prior to the “Last Modified” date of this Privacy Policy, we may have shared or disclosed the following categories of Personal Information about you for a business or commercial purpose with certain categories of third parties, as described below:

 

Categories of Personal Information that May Be Sold, Shared, or Disclosed

Categories of Third Parties to whom Personal Information May Be Sold, Shared, or Disclosed

Business or Commercial Purpose of Selling, Sharing, or Disclosing Personal Information

Account Data

Subsidiaries and Affiliates
Service Providers and Contractors
Marketing Partners
Advertising Partners
Provide the Services
Communicate with you 
Monitor the Services
Respond to Inquiries and Fulfill Requests
Improve the Services
Support Business Operations
Fulfill Other Purposes

Payment Data

Subsidiaries and Affiliates
Service Providers and Contractors
Communicate with you 
Monitor the Services
Respond to Inquiries and Fulfill Requests
Process payment
Support Business Operations
Fulfill Other Purposes

Transaction Data

Subsidiaries and Affiliates
Service Providers and Contractors
Marketing Partners
Advertising Partners
Provide the Services
Communicate with you 
Monitor the Services
Respond to Inquiries and Fulfill Requests
Improve the Services
Support Business Operations
Fulfill Other Purposes

Sensitive Personal Data

Subsidiaries and Affiliates
Service Providers and Contractors
Provide the Services
Monitor the Services
Respond to Inquiries and Fulfill Requests
Support Business Operations
Fulfill Other Purposes

Internet or Other Electronic Network Activity 

Subsidiaries and Affiliates
Service Providers and Contractors
Marketing Partners
Advertising Partners
Provide the Services
Monitor and maintain the Services
Improve the Services
Support Business Operations 
Fulfill Other Purposes

 

f. California Consumer Privacy Rights

Under CCPA, consumers have certain rights regarding their Personal Information, as described below.

  • Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
    • The categories of Personal Information that we collected about you;
    • The categories of sources from which the Personal Information is collected;
    • The business or commercial purpose for collecting or selling Personal Information;
    • The categories of third parties with whom we share Personal Information;
    • The specific pieces of Personal Information that we have collected about you;
    • The categories of Personal Information that we disclosed about you for a business purpose or sold to third-parties; and
    • For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
  • Right of Deletion: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law. 
  • Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration.  However, we do not sell any Personal Information. 
  • Right to Opt-In: We do not have actual knowledge that we collect, share, or sell the Personal Information of minors under the age of 16.
  • Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for “the purpose of inferring characteristics about a consumer.”  However, we do not collect or process Sensitive Personal Information for this purpose.
  • Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law. 

If you would like to exercise your California privacy rights, please refer to the Consumer Requests and Verification section below.  

 

15. VIRGINIA, COLORADO, CONNECTICUT, UTAH
PRIVACY RIGHTS


This section is applicable to residents of Virginia, Colorado, Connecticut, or Utah. If you are a resident of Virginia, Colorado, Connecticut, or Utah, you have certain rights described below. The following do not apply to individuals who do not live in Virginia, Colorado, Connecticut, or Utah on a permanent basis, individuals we do not collect personal information about, or individuals for whom all of the information we collect is exempt from the statutes. “Personal Data,” for purposes of this section regarding the rights of residents, means any information that is linked or reasonably linkable to an identified or identifiable natural person and does not include de-identified information or publicly available information.

This section applies only to Virginia, Colorado, Connecticut residents to the extent their Personal Data is subject to the Virginia Consumer Data Protection Act (VCDPA), or the Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act (UCPA) or any amendments or acts thereto upon their effective dates.  The categories of Personal Data processed, the purposes of processing, the categories of Personal Data shared, and the categories of third parties to which Personal Data is shared are provided in the above sections of this Policy, including the chart depicted in the above section California Privacy Rights.

 

a. Rights under VCDPA, CPA, CTDPA, and UCPA

Virginia, Colorado, Connecticut, and Utah privacy law provides residents with specific rights regarding Personal Data, including:

    • Right to Access. You have the right to confirm whether or not we are processing your Personal Data and to access such information.
    • Right to Correction. You have the right to correct inaccuracies in your Personal Data which we have collected, taking into account the nature of the Personal Data and the purposes of processing the Personal Data.
    • Right to Deletion. You have the right to request deletion of Personal Data provided by or obtained about you, subject to legal exemptions.
    • Right to Data Portability. You have the right to obtain a copy of your Personal Data.
    • Right to Opt-Out. You have the right to opt out of the processing of Personal Data for purposes of (1) targeted advertising; (2) the sale of Personal Data; or, if you are in Virginia or Colorado (3) profiling in furtherance of decisions that produce legal or similarly significant effects.  

If you would like to exercise any of the rights provided, please refer to the Consumer Requests and Verification section below. 

16. CONSUMER REQUESTS AND VERIFICATION

a. Right to Non-Discrimination

We may not discriminate against you because you exercise any of your privacy rights contained in this Privacy Policy including, but not limited to:

    • Denying goods or services to you;
    • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
    • Providing a different level or quality of goods or services to you; or
    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

b. Verifying Requests

You may request to exercise your rights of access, deletion, or correction by contacting us as described in the Contact Information section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request.  If you request access to or deletion of your Personal Data, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following: 

    • As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name.  We may ask for additional information if needed.
    • We will confirm that you want your information accessed, corrected, and/or deleted.
    • We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.
    • We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
    • In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.

c. Authorized Agents


You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the Contact Information section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:

    • The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
    • You to verify your identity directly with us; or

    • You to directly confirm with us that you provided the authorized agent permission to submit the request.

d. Virginia and Connecticut Appeal Process


If you have made a request to access, correct, or delete your Personal Data under VCDPA and CTDPA, and we have declined to take action, you may appeal our decision within 45 days of the denial. When you make such an appeal, you can expect the following:

    • We will verify your identity. You will need to provide us with your email address and full name.  We may ask for additional information if needed.
    • We will review your appeal and respond in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision, within 45 days upon receipt of your appeal. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
    • In certain cases, an appeal may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your appeal, we will explain why we denied it and provide you with a method to contact your state’s Attorney General to submit a complaint.



17. CONTACT INFORMATION


If you have any questions or concerns about this Privacy Policy or our privacy practices, you can contact us via: 

Email: help@soundstripe.com

Mail: Attn: Privacy Compliance Officer

Soundstripe

1103 Holly St.

Nashville, TN 37206