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PRIVACY POLICY

Last Updated and Effective as of: November 28, 2018
This website is operated by Smino, and their partners (collectively, “we,” “us” or “our”), who is a data controller responsible for the processing of personal data under applicable data protection law.

This Privacy Policy (”Policy”) explains our online information and the kinds of information we may collect as a result of your interaction with us through the websites on which this Policy is posted, including the websites that you may access using your mobile electronic device (collectively, “Sites”) and the services provided through the Sites (“Services”). This Policy also explains how we intend to use and share that information, how we protect that information, and how you can opt out of a use or correct or change such information.

This Policy does not apply to any third-party websites, services or applictions, even if they are accessible through our Services. All individuals whose responsibilities include the Processing of Personal Information on behalf of us are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

CONSENT TO PROCESSING

Our Sites are operated in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our Sites, or providing us with any informa.on, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

PROTECTION FOR CHILDREN - COPPA COMPLIANCE

The Children’s Online Privacy Protec.on Act (“COPPA”) imposes certain requirements upon websites and online services that are directed toward children. We are committed to protecting children’s online privacy and complying fully with COPPA. We do not collect any personally identifiable information anywhere on the Sites except where expressly stated. We believe that chil- dren should be able to use the Internet in a safe, productive and efficient manner and should be afforded the highest protection available with respect to their personal information. To that end, we only ask for adults’ personally identifiable information. We do not knowingly collect any individually identifiable information from users under the age of 13 anywhere on the Sites. If we become aware that a child under the age of 13 has submitted his or her personally identifiable information, we will delete such information immediately.

Visit
http://www.ftc.gov/privacy/privacyinitiatives/childrens_educ.html for information from the Federal Trade Commission about COPPA and protecting children’s privacy online.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may request certain information once per year about our disclosure of certain categories of Personal Information during the preceding calendar year to third parties for such third parties’ own direct marketing purposes.Please submit your request via https://privacy.umusic.com/#Contact. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy at anytime. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through the Site. Your use of such Site or your submission of any information in connection with such Site following such changes means that you accept the revised Privacy Policy.

INFORMATION WE MAY COLLECT FROM YOU

When you use the Site, two types of information are collected in connection with the Properties: Personal Identifiable Information (PII) and Other Information. “Personal Identifiable Information” is information that identifies you as an individual. “Other Information” is any information that does not reveal your specific identity. Other Information is addressed separately below, under the heading “OTHER INFORMATION”.

We and our third-party service providers (label, merchandise, marketing and advertising partners), may collect PII from you including your name, address, e-mail address and phone number, financial and credit card information, personal description, photographs or images, and comments. You may, however, visit our site anonymously.

We and our third-party service providers may collect PII through the Site, for example, when you participate in various opportunies provided through the Site, such as:

  • When you purchase a product or make a request
  • When you register for newsleUers or other communica.ons through the Site
  • When you participate in a contest, promotion, sweepstakes, survey or other promotion through the Site
  • When you participate in a blog or forum
  • Entering a competition, promotion or survey
  • Reporting a problem or requesting support for the Site


HOW WE MAY USE PERSONAL INFORMATION

We and our third-party service providers may use Personal Informa.on:

To respond to your inquiries and fulfill your requests, such
as to send newsleUers to you or to provide you with informa.on about our products and services

To send to you administra.ve informa.on, including informa.on regarding the Sites and changes to our terms, condi.ons, and policies

To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service

To send to you marke.ng communica.ons that we believe may be of interest to you (in- cluding, without limita.on, by our third-party service providers that send email and oth- er types of adver.sing, such as display adver.sing or sponsored adver.sing on the Sites or other proper.es, to those whose email addresses we have collected)

To send to you SMS text messages, if you have indicated you would like to receive them. Please keep in mind that message and data rates may apply. You should check with your mobile service provider for applicable data rates. At any .me, you may text back “HELP” for further informa.on regarding text messages, or “STOP” to unsubscribe from such messages. If addi.onal rules are provided in connec.on with any specific SMS text mes- sage sign-ups, such rules shall also apply and shall control in the event that they conflict with this Privacy Policy.

To personalize your experience on the Site by presen.ng products and offers tailored to you

To allow you to participate in sweepstakes, contests and similar promo.ons and to administer these activities. Some of these activities have additional rules, which could con- tain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully; in the event of a conflict between such rules and this Privacy Policy, such rules will govern.

To allow you to send messages (for example, music clips or ar.st informa.on) to a friend through the Proper.es. By using such func.onality, you are telling us that you are en.- tled to use and provide us with your friend’s name and email address.

For our business purposes, such as data analysis, audits, developing new products, en- hancing the Site, improving our services, iden.fying usage trends and determining the effec.veness of promo.onal campaigns

To adver.se - to measure or understand the effec.veness of adver.sing we serve to you and others, and to deliver relevant adver.sing to you

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to re- quests from public or government authori.es, including public or government authori-

.es outside your country of residence; (d) to enforce our terms and condi.ons; (e) to protect our opera.ons or those of any of our affiliates or ar.sts; (f) to protect our rights, privacy, safety or property, or that of our affiliates, our ar.sts, you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain

We may combine PII that you submit on or through the Site with informa.on that we collect from and about you from other online and offline sources, including from our own websites and web proper.es (including apps, widgets, and players) and third-party sources, which may in- clude social media services you interact with through our Sites. We treat such combined infor- ma.on as Personal Informa.on as long as it is so combined.


HOW PERSONAL INFORMATION MAY BE DISCLOSED

Your Personal Informa.on may be disclosed:

  • To our third-party service providers (and in some cases, our affiliates) who provide ser- vices such as hos.ng, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery, credit card processing, audi.ng, and other similar services to enable them to provide such services

  • To our affiliates, to permit them to send marke.ng communica.ons to you.

  • To unaffiliated third par.es or their vendors, to permit them to send, or to cause to be sent, marke.ng communica.ons to you in online and offline media.

  • To our ar.sts (including any of the ar.sts’ band members, if applicable) and their repre- senta.ves, so that the ar.sts and their representa.ves may use this informa.on to send to you communica.ons (including marke.ng communica.ons) that they believe may be of interest to you, including, for example, if you (a) sign up to join the applicable ar.st’s mailing list and/or to receive such ar.st’s newsleUers, (b) register with the applicable ar.st’s website, or (c) have otherwise indicated that you would like to receive informa-

    .on and/or marke.ng communica.ons from the applicable ar.st. We do not control, and are not responsible for, ar.sts’ and their representa.ves’ use of Personal Informa-

    .on.

  • To third par.es that sponsor contests, sweepstakes, and similar promo.ons

  • To iden.fy you to anyone to whom you send messages on or through the Site

  • By you, on or through message boards, chat, profile pages and blogs, and other services to which you are able to post informa.on and materials. Please note that any informa-

    .on and materials that you post or disclose on or through a Site will become public in- forma.on, and may be available to visitors to such Site and to the general public, and may be redistributed through the Internet and other media channels where they will reach an even broader audience. We urge you to be very careful when deciding to dis- close your Personal Informa.on, or any Other Informa.on, on or through the Site. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE OF ANY INFORMATION YOU VOL- UNTARILY DISCLOSE THROUGH ANY SITE.

  • To a third party in the event of any reorganiza.on, merger, sale, joint venture, assign- ment, transfer, or other disposi.on of all or any por.on of our business, assets, or stock (including in connec.on with any bankruptcy or similar proceeding)

  • To a relevant ar.st who is no longer affiliated with us, if you indicated an interest in such ar.st (for example, by registering with the ar.st’s website)

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to re- quests from public or government authori.es, including public or government authori-

.es outside your country of residence; (d) to enforce our terms and condi.ons; (e) to

protect our operations or those of any of our affiliates or ar.sts; (f) to protect our rights, privacy, safety or property, or that of our affiliates, our ar.sts, you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain.


Sensisitive Information

We ask that you not send us, and you not disclose, any sensi.ve Personal Informa.on (e.g., so- cial security numbers, informa.on related to racial or ethnic origin, poli.cal opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through the Site or otherwise to us.


OTHER INFORMATION WE MAY COLLECT

With regard to each of your visits to our Site we may automa.cally collect the following informa.on: Technical informa.on, including IP address, login informa.on, geographic loca.on informa.on, browser type and version, .me zone segng, browser plug-in types and versions, opera.ng system, and plahorm

Informa.on about your visit, including the full URL clickstream to, through and from our site (including date and .me)

Pages you viewed or searched for; page response .mes, download errors, length of visits to certain pages, page interac.on informa.on (such as scrolling, clicks, and mouse- overs), and methods used to browse away from the page

Third-party partners may collect personal informa.on about your online activities overtime and across third-party websites or online services through your use of the Site


Please view the “TRACKING TECHNOLOGIES” sec.on below for details on how Other Informa-

.on may be collected.


HOW OTHER INFORMATION MAY BE DISCLOSED

Please note that we may use and disclose Other Informa.on for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Informa-

.on as Personal Informa.on under applicable law, then we may use it as described in “How We May Collect Other Informa.on” sec.on above, as well as for all the purposes for which we use and disclose Personal Informa.on. In some instances, we may combine Other Informa.on with Personal Informa.on (such as combining your name with your geographical loca.on). If we combine any Other Informa.on with Personal Informa.on, the combined informa.on will be treated by us as Personal Informa.on as long as it is combined.


We may also release your informa.on when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, Other Informa.on may be provided to other par.es including, but not limited to, sponsors, la- bels, management, partners, ar.sts, or agents for marke.ng, adver.sing, or other uses includ- ing:

  • Aggregate or anonymized data to adver.sers and adver.sing networks that require the data to select and serve relevant adverts to you and others

Analy.cs and search engine providers that assist us in the improvement and op.misa-

.on of our Site such as Google Analy.cs Demographics and Interest Repor.ng, or similar analy.cs repor.ng systems. The data collected from these tools may include age, gen- der, and general interests. To opt out of this service please visit hUps://www.google.- com/segngs/ads.


HOW WE PROTECT YOUR INFORMATION

We implement a variety of security measures to maintain the safety of your personal informa-

.on when you place an order or enter, submit, or access your personal informa.on.

We offer the use of a secure server. For PII entered on a commerce site related to the Site where purchases are completed - such as merchandise, .cke.ng, and album sales - all supplied sensi-

.ve/credit informa.on is transmiUed via Secure Socket Layer (SSL) technology and then en- crypted into our Payment gateway providers’ database only to be accessible by those autho- rized with special access rights to such systems, and are required to keep the informa.on confi- den.al.

A[er a transac.on, your private informa.on (credit cards, social security numbers, financials, etc.) will not be stored on our servers.


TRACKING TECHNOLOGIES

The Site uses technologies such as pixel tags, cookies, and beacons. Pixel tags are small bits of code that provide a method of delivery informa.on on a webpage which allow the operator of the page or a third party to collect informa.on about the users of the page. Cookies are small text files that are stored on the browser of your computer that uniquely iden.fy your browser and provide informa.on to the cookie sender.

We use cookies to help us understand and save your preferences for future visits, target and keep track of adver.sements, and compile aggregate data about site traffic and site interac.on so that we can offer beUer site experiences and tools in the future. In some of our email mes- sages, we may also use “click-through URLs” or pixel tags to determine whether the email has been opened and to measure the effec.veness of our customer communica.ons. This data may also be used to gauge your interest in par.cular topics, so we can deliver a more relevant, personal and convenient user-experience.

We may use third-party adver.sing companies to collect data and/or serve ads when you visit our website or applica.on. These companies may use informa.on about your visits to this and other websites or applica.ons in order to provide adver.sements about goods and services of interest to you. Please keep in mind that your browser segngs may not permit you to control the technologies u.lized by these third-party companies. If you would like more informa.on about this prac.ce and to know your choices about not having this informa.on used by these companies, visit hUp://youronlinechoices.com/ or http://optout.aboutads.info/?c=2#!/.

You may be able to change your browser segngs to refuse cookies or to alert you of when a cookie has been placed on your browser. Check your browser for details. You can visit hUp:// www.networkadver.sing.org/choices/ for informa.on on op.ng out of targeted adver.sing.

If you do not want informa.on collected through the use of cookies, there is a simple procedure on most devices through which the Site is accessed that allows you to decline the use of cook- ies. To learn more about cookies, please visit hUp://www.allaboutcookies.org/. If you choose to decline cookies, then some or all of the features, func.onality, and promo.ons available through the Site may not be available to you.


THIRD PARTY LINKS

Occasionally, at our discre.on, we may include or offer third party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and ac.vi.es of these linked sites. None- theless, we seek to protect the integrity of our Site and welcome any feedback about these third-party sites.


SOCIAL MEDIA

Our Site may include Social Media Features, such as the Facebook Like buUon. These Features may collect your IP address, which page you are visi.ng on our site, and may set a cookie to en- able the Feature to func.on properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interac.ons with these Features are governed by the privacy policy of the company providing it.

You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authen.cate your iden.ty and provide you the op.on to share certain personal informa.on with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the op.on to post informa.on about your ac.vi.es on this Web site to your profile page to share with others within your network.


USERS OF SITES IN THE EUROPEAN ECONOMIC AREA

This sec.on of this Privacy Policy applies only if you use the Site from a country that is a Mem- ber State of the European Economic Area, and supplements the informa.on in this Privacy Poli- cy.

Legal Basis for Data Processing: We process personal data for the purposes set out in this Priva- cy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract between you and us (for example, to provide you with the services you request and to iden.fy and authen.cate you so you may use the Site); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legi.mate interests (for example, to manage our rela.onship with you and to improve the Site); and based on consent by our customers (for example, to communicate with you about our products and services and provide you with marke.ng informa.on), which may subsequently be withdrawn at any .me (by using preference segngs in emails or on our Sites, or emailing us as set out in the Contac.ng Us sec.on) without affec.ng the lawfulness of processing based on consent be- fore its withdrawal.

In some instances, you may be required to provide us with personal data for processing as de- scribed above, in order for us to be able to provide you to use all the features of the Site
INTERNATIONAL TRANSFERS

Our sharing your personal data in accordance with this Privacy Policy, may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protec.on is afforded to it by ensuring, where re- quired by law, at least one of the following safeguards is implemented:

  • transferring personal data to countries that have been deemed to provide an adequate level of protec.on for personal data by the European Commission;

  • using specific contracts approved by the European Commission which give personal data the same protec.on it has in Europe; or

  • transferring personal data to the United States to an entity if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

You may be entitled, in accordance with applicable law, to request a copy of relevant safeguards by contacting us as described in the “Contacting Us” section.


CONTACTING US
If you have any ques.ons about this Privacy Policy, please contact us at https://privacy.umusic.- com/#Contact.
Please note that email communica.ons are not always secure, so please do not include credit card informa.on or other sensi.ve informa.on in your email messages to us.