1.  ABOUT PEERTRACKS

We are PeerTracks, Inc. of 805 SW Broadway, Suite 2440, Portland, OR 97205 (PeerTracks, we, our or us).

2.  ABOUT THIS PRIVACY POLICY

This privacy policy (the Privacy Policy) applies to the personal data that you provide to us or that we collect about you through our website (www.peertracks.com), our mobile [and desktop] app(s), and all related sites, players, software, and services provided by us (together the Services). It explains, among other things, how and why we collect data about you when you use our Services, what data we collect, what we do with that data, how we look after it, and what your rights are in relation to it.

We may also collect and process certain personal data relating to our business contacts, in the normal course of conducting and running our business. Please refer to section 14 below for more information on how we process this personal data.


3.  SOME KEY TERMS

  SOUNDAC means the SOUNDAC music database, which you can read more about here.

  personal data means information about individuals (including you) and information from which such individuals could be identified.

  special category data means data relating to racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, health data, biometric data or sexual orientation.

  you means any individual whose personal data we process.


4.  DATA WE COLLECT ABOUT YOU

The personal data we collect via or in relation to the Services can be split into three broad categories:

  information you provide to us;

  information collected automatically; and

  information we obtain from third parties, including via SOUNDAC.

We do not collect, request, receive or otherwise process any special category data about you. 

Information you provide to us

We ask for and collect the following information when you use the Services:

Identity and profile information: We do not ask you to provide any personal information in order to use the Services.

Communications: When you communicate with us by email, post or telephone, or through/via the Services, we collect information about your communication (for example your email address) and any information you choose to provide.

Survey information: If you participate in any survey, you may provide certain personal data as part of your response, unless you respond anonymously.

Information we collect automatically

We collect certain information automatically when you use the Services. This information includes:

Usage information: Information about your interactions with the Services, including: the pages that you visit and links you click on, streaming history, search history, the time, frequency and duration of your visits and streams, your favourited tracks, and your liked tracks, and your IP address.

Location data: When you use certain features of the Services, we may collect data about your geographical location. We use this data to provide you with location-based services (such as advertising and personalised content). We support Do Not Track, which is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser.

Cookies: We use cookies and other similar technologies to track certain behavior on our behalf. This is described in more detail in our cookie policy [Here].

Automated profiling: In some circumstances we use automated profiling to help recommend or suggest audio/video content that we think that may interest you, and to provide targeting advertising, based on your usage of the Services or your geographical location.

Information we receive from other sources

SOUNDAC: We obtain certain information from the SOUNDAC database. This information is limited to information that is publicly available on SOUNDAC, for example your SOUNDAC username, the tokens you hold and the transaction history of your account.

Service providers and business partners: We may also receive information about you from our service providers and business partners, including companies that assist with analytics, data processing and management (e.g. to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you), account management, customer and technical support, hosting, and other services which we use to personalise your PeerTracks experience. We explain in more detail why and how we use this information below.

When we receive information from other sources, we rely on them having the appropriate provisions in place telling you how they collect data and who they may share it with.

5.  HOW YOUR PERSONAL DATA IS USED

In accordance with data protection laws, we will only process personal data where we have a lawful basis for doing so. In respect of your personal data, these bases are: (i) where it is necessary for the performance of a contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where you have given your consent; and, (iv) where it is in our (or a third party's) legitimate interests to process your personal data, provided that those interests do not prejudice your own rights, freedoms and interests. 

The following are a list of the purposes for which we process personal data, and the lawful basis on which we carry out such processing.  Where we are relying on legitimate interests we have also set out the specific interest.

Purpose

Lawful basis

To carry out our obligations arising from any contracts entered into between you and us (for example, our terms and conditions).

Necessary for the performance of a contract with you.

To provide you with the information, products, newsletters and services that you request from us.

Consent.

To respond to your enquiries or to process your requests in relation to your information.

Consent.

To provide, improve and personalise our Services.

Our legitimate interests to ensure our Services are as enjoyable and effective as possible. 

To let you know about important changes or developments to our Services.

Necessary for the performance of a contract with you.

To ensure that our Services are presented in the most effective manner for you and for your device.

Our legitimate interests to ensure that the Services are as accessible as possible.

To detect and protect us against error, fraud and other criminal activity, and enforce our Terms and Conditions (which you can find here).

Our legitimate interests to ensure that our users are protected; and (where applicable) necessary to comply with legal obligations. 

For internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

Our legitimate interests to allow us to understand our Services and develop improvements. 

To allow you to participate in interactive features of our Services, when you choose to do so.

Consent.

To be used as part of our efforts to keep the Services safe and secure.

Our legitimate interests to ensure our Services are enjoyable and safe for all.

To recommend content that we think may interest you, and to provide targeting advertising.

Our legitimate interests to offer new content to users and to generate revenue.  

6.  SHARING YOUR PERSONAL DATA

The following describes the ways we may share your personal data in the normal course of business and in order to provide our Services.

Cloud Storage: We transmit personal data to, and store it in, Google Cloud. You can find out more about how Google Cloud protects data on this page here.

With your consent: We will disclose your personal data when and if you have agreed that we may do so. We will make this clear to you at the point at which we collect your personal data, including the purpose(s) for which we will use the personal data.

Service providers: We use third-party service providers to facilitate or outsource some aspects of our business, products and Services and some of these service providers will process your personal data.

If required by law: We may be required to disclose your personal data by law, in response to a valid order of a court or other authority, or to respond to requests relating to criminal investigations.

Change of control: If a business transfer or change of business ownership takes place or is envisaged, we may transfer your personal data to the new owner (or a prospective new owner). If this happens, you will be informed of this transfer.

Protecting our rights: We may disclose your personal data if we feel this is necessary in order to protect or defend our legitimate rights and interests and/or to ensure the safety and security of the Services.

7.  DIRECT MARKETING COMMUNICATIONS

We offer a newsletter, which aims to keep our users informed and aware of the best products, services, promotions and events that we offer. We will only send you the newsletter if you expressly consent to receive it. If you consent but later change your mind, you can unsubscribe at any time by following the unsubscribe instructions provided in the newsletter or by contacting us at [team@peertracks.com].

8.  BEHAVIOURAL REMARKETING

We use remarketing services to advertise to you on third party web sites after you have visited/used our Services. We, and our third party vendors, use cookies to inform, optimise and serve ads based on your past visits to our Services. Details are set out below:

Google

Google AdWords remarketing service is provided by Google Inc. You can opt out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page here.

Google also recommends installing the Google Analytics Opt-out Browser Add-on (here) for your web browser. The Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit their web page here.

Twitter

Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter's interest-based ads by following their instructions here.

You can learn more about the privacy practices and policies of Twitter by visiting their page here.

Facebook

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page here.

To opt out from Facebook's interest-based ads follow these instructions from Facebook.

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt out from Facebook and other participating companies through the European Interactive Digital Advertising Alliance in Europe here, or you can opt out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy here.

9.  DATA SECURITY

We take your privacy seriously and are committed to maintaining the privacy and security of the personal data you provide to us, and the choices you have regarding our collection and use of your personal data.

Once we have received your personal data, we follow strict security procedures as to how your personal data is stored and used, and who sees it, to help stop any unauthorised access.

PeerTracks maintains technical, administrative, and physical safeguards that are designed to prevent unauthorised access, use or disclosure of personal data we collect or store. We regularly monitor our systems for possible vulnerabilities and attacks.

When we use third party organisations to process your personal data on our behalf, we require that they: (a) have appropriate security arrangements in place; (b) must comply with our contractual requirements and instructions; and (c) must ensure compliance with the GDPR and any other relevant data protection legislation, all as required under the GDPR.

10.  INTERNATIONAL DATA TRANSFERS

PeerTracks operates globally and may share your information internationally for the purposes described in this Privacy Policy. PeerTracks itself is based in the USA. Information collected within the European Economic Area (EEA) will therefore transferred to countries outside for the purposes described in this Privacy Policy. We use appropriate safeguards to ensure the lawful transfer of your personal data outside the EEA.

11.  CHILDREN

PeerTracks is not intended for use by children. Individuals under the age of 13 are not permitted to use the Services and must not attempt to register an account or submit any personal data to us. We do not knowingly collect any personal data from any person who is under the age of 13, or allow them to register an account. If it comes to our attention that we have collected personal data from a person under the age of 13, we will delete this information as quickly as possible.

If you are a parent or guardian and you learn that your child (under the age of 13) has provided us with personal data, please notify us immediately at [team@peertracks.com].

12.  RETAINING YOUR PERSONAL DATA

It is our policy to retain your personal data for no more than the length of time required for the specific purposes for which it is processed by us and which are set out in this Privacy Policy. However, we may sometimes need to keep your personal data for a longer period, for example, where required by our legal obligations, or in order to ensure we have effective IT back-up systems. In such cases, we will ensure that your personal data will continue to be treated in accordance with this Privacy Policy, we will restrict access to any archived personal data, and ensure that all personal data is held securely and kept confidential.

In any event, we will always delete any personal data when you request us to do so (unless we're prevented by law from doing so).

13.  YOUR RIGHTS

You have various rights in relation to your personal data, including:

  the right of access to a copy of the personal data we hold about you;

  the right to require us to correct any inaccuracies in your personal data;

  the right to object to decisions about you being taken by automated means;

  where we have sought your consent, the right to withdraw your consent at any time; and

  the right to ask us not to process your personal data for direct marketing purposes (although we do not currently undertake any direct marketing).

You may also have the following rights in relation to your personal data in certain circumstances:

  the right to restrict or object to our use of your personal data;

  the right to require us to provide a copy of your personal data to others; and

  the right to require us to erase your personal data.

Please be aware that these rights are not always absolute and there may be situations in which you cannot exercise them or they are not relevant. To help you understand how they work, we have provided a link to the UK Information Commissioner's Office's guidance on each of the rights here.

If you wish to exercise any of your rights please contact us at [team@peertracks.com].

14.  IF YOU ARE A BUSINESS CONTACT OF PEERTRACKS

This Privacy Policy primarily applies to the processing of personal data of visitors to and users of our Services.

However, we may also collect and process personal data relating to our business contacts, in the normal course of conducting and operating our business. Where we do so:

  we will process such personal data on the lawful bases of our legitimate business interests and/or for the performance of a contract with you, and/or on the basis of your consent (as applicable);

  we will process and share such information only as necessary for the pursuance of the lawful bases listed above;

  if your personal data is shared with recipients outside the EEA, we will put in place appropriate safeguards to ensure your rights are protected;

  your personal data will be subject to the security measures set out in section 9 above;

  we will retain such personal data in accordance with section 12 above; and

  you will have the rights set out in section 13 above.

15.  MORE INFORMATION

It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please email us at [team@peertracks.com].

16.  HOW TO MAKE A COMPLAINT

If you have a question about the information provided in this Privacy Policy, or you have a concern or complaint about the way in which we process your personal data, please contact [team@peertracks.com].  In any event, if you are an EU citizen you have the right to address a complaint to the Information Commissioner in the UK. The Information Commissioner can be contacted at:

  Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

  www.ico.org.uk

  +44 (0)303 123 1113

17.  CHANGES TO THIS PRIVACY POLICY

This privacy policy may change from time to time and, if it does, the up-to-date version will always be available on our Services. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Services and update the ÒLast updatedÓ date at the top of this page. Please be sure to periodically check this page to ensure that you are aware of any changes to this Privacy Policy. Any material changes to this Privacy Policy will be communicated to registered users by a notification to their account and/or by posting a notice of the change on the Services.

 

Last updated January 16th 2019

Contact Us

If you have any questions about this Privacy Policy, please contact us.