We may share your data within our corporate group ofcompanies that are related by common ownership or control (“OrinPlay Group”)
Our Privacy Principles
Information We Collect
All the personal information we collect is related toproviding the Platform and its features and falls into three generalcategories:
· Information you provide to us
· Information collected automatically
· Information we obtain from third parties
Information You Provide
We ask for and collect the below personal information whenyou use the Platform. This information is necessary for the adequateperformance of the contract between you and us and to allow us to comply withour legal obligations.
We process this information in light of our legitimateinterest in improving the Platform and giving our users the best experience,and where it is necessary for the adequate performance of the contract betweenus and you. Without it, we may not be able to provide you with all therequested services and features of the Platform.
You don’t need to register for an OrinPlay account in orderto visit or use our Platform. However, certain Services require that youregister for an account and, by doing so, you will need to provide us withcertain information:
Account Information - When you register any kind of OrinPlayaccount, you will need to provide your email address (except when you sign-upwith Facebook and don’tgive your permission to share it with OrinPlay), your age, and choose apassword. In addition, if you purchase a Subscription, you will also need toprovide your real name, billing address, and payment verification information.
Profile Information - you may choose, at your discretion, toprovide additional information for your public profile on OrinPlay – forexample:
· your real name
· a user name (which may be your real name or apseudonym)
· the city and country in which you live
· a profile picture, profile header image oravatar
· information about how you categorize yourselfwith respect to your content (for example, whether you are a musician, a labelor some other category of creator)
· details of your other websites and social mediaprofiles, including links to those pages
· your gender if you wish to provide it
any additional information you provide as part of yourpublic profile, such as your real name, and links to your website and othersocial media profiles (but not your email address), will be published on yourprofile page. This information will be publicly accessible and may be viewed byanyone accessing the Website, or using our API or other Services. Please bearthis in mind when considering whether to provide any additional informationabout yourself
Communications - When you communicate with OrinPlay by emailor through the Platform, or use the Platform to communicate with other users,we collect information about your communication and any information you chooseto provide.
Survey Information - If you participate in any survey, youmay provide certain personal data as part of your response, unless you respondanonymously.
Information You Post - You may provide personal data whenyou upload Sounds to the Platform, or when you post comments, or contribute tocommunity discussions.
Information We CollectAutomatically
Usage Information - We collect information about yourinteractions with the Platform, including the pages that you visit and linksyou click on, streaming, offline listening or downloading tracks, uploading orrecording tracks, connecting your Facebook or Google+ account, sharing a soundwith another user, following or unfollowing another user, joining or leaving agroup, posting a comment, performing a search, the time, frequency and durationof your visits to the Platform, and whether you interact with email messages,for example, if you opened, clicked on, or forwarded the email message.
Log Data – We automatically collect log information when youuse the Platform, even if you have not registered for an account or logged in.That information includes, among other things: details about how you’ve usedthe Platform (including links to third party sites or services), InternetProtocol (IP) address, access times, your browser type and operating system,device information, device event information (e.g., crashes, browser type), andthe page you’ve viewed or engaged with before or after using the Platform.
Location Data – When you use certain features of thePlatform, we may collect data about your general location (e.g. IP address). Weuse this data to provide you with location-based services (such as advertisingand personalized content). Most mobile devices allow you to control or disablethe use of location services for applications in the device’s settings.
Device Information – We collect information from and aboutthe devices you use, including how you interact with the Platform andinformation about the device itself, such as the hardware model, operating system,IP addresses, cookie information, device settings, mobile device andadvertising identifiers, apps installed, browser type, language, battery leveland time zone. Apple’s iOS Advertising Identifier (IDFA) and Google’s AndroidAdvertising ID is examples of device identifiers. This information allows usto recognize and associate your activity, and provide personalized content andadvertising, consistently across all of your devices.
Software Development Kits – We may use third partiesincluding our business partners and service providers who use mobile SDKs tocollect information and information related to how mobile devices interact withthe Platform. An SDK is computer code that app developers can include in theirapps to enable ads to be shown, data to be collected and related services andfunctionality to be implemented. A mobile SDK is in effect the mobile appversion of a pixel tag or beacon. We may use this technology, for instance, toanalyze how you interact with content and advertisements and to enableanalytics or other features through mobile devices.
OrinPlay Widget – Other websites may integrate OrinPlaywidgets; when you visit a website with an OrinPlay widget embedded, we mayreceive certain information, including information about the website youvisited. OrinPlay and the widget may be able to recognize you, and in somecases, the widget may be used to show personalized content. We know when youinteract with a widget, and websites containing the widgets may receive thisinformation as well.
Information From Third Parties
Single-Sign Ons – If you sign up for OrinPlay through a third-party application like Facebook or Google, you authorize us to collectyour authentication information, such as your username and encrypted accesscredentials, and other information available through the third partyapplication account, including the following information:
Service Providers and Business Partners – We may alsoreceive information about you from our service providers and business partners,including companies that assist with payment processing, analytics, dataprocessing and management (e.g. to measure ad quality and responses to ads, andto display ads that are more likely to be relevant to you, including for OrinPlayproducts) account management, hosting, customer and technical support, andother services which we use to personalize your OrinPlay experience. We explainin more detail why and how we use this information below.
How We Use YourInformation
We use the personal information we collect from you,including with the help of automated systems and decision making, for a rangeof different business purposes according to different legal bases of processingand subject to the choices you make in your Settings.
Provide, Improve, andDevelop the Platform
To operate and maintain your OrinPlay account, and toprovide you with access to and use of the Platform. Your email address andpassword are used to identify you when you log into the Platform. Your device-IDsare used to ensure that you are in control of the devices that have access toyour Subscription.
To identify you as the creator of the Sounds that youupload, the comments that you post and/or the other contributions that you maketo the Platform.
To provide creators with stats and insights about users’listening behavior of their Sounds, (i.e. streaming and downloading theirSounds or following their profiles).
We conduct surveys and research, test features indevelopment, and analyze the information we have to evaluate and improveproducts and services, develop new features and conduct audits andtroubleshooting activities.
If you purchase a Subscription, your name, address andpayment verification information will be used to process your accountsubscription and renewals and to collect your payment. All payment verificationinformation is transmitted using industry-standard SSL (Secure Socket Layer)encryption. OrinPlay also complies with the Payment Card Industry SecurityStandards.
Your email will be used to send you service updates andnotifications about your account.
To respond to you about any comment or enquiry you havesubmitted.
We use your age to enable age restrictions.
Maintain a Safe and Secure Environment
Detect and prevent fraud, spam, abuse, security incidents,and other suspicious activity.
Verify and authenticate your identity and preventunauthorized or illegal activity.
Enhance the safety and security of our products andservices.
Conduct security investigations and risk assessments.
To provide you withcustomer and technical support.
Personalize Content,Advertising and Marketing
To improve your experience on the Platform by providingpersonalized content, recommendations, and features.
To customize the content and measure performance of anyemail, push notification, or in-app message we may send to you.
Administer sweepstakes, contests, or other promotionalactivities or events sponsored or managed by OrinPlay or its partners.
Use automated systems and decision making to profile usercharacteristics and infer preferences based on information that you provide tous, your interactions with the Platform and content, your profile information,and information obtained from third parties. This data is used to create groupsof users, called segments, who share similar characteristics and interests; weuse segments to serve personalized content, advertising, and marketingmessages. We also use automated systems to associate your activity over timeacross devices, and may associate activity and accounts under a single user ID,in order to determine that certain devices are related to each other andprovide you with a personalized experience across devices and platforms.
Ads are more effective when they are shown to people who arelikely to be interested in the product or service advertised. For this reason,we use the information we collect and receive to help us select which ads toshow you on behalf of advertisers. This includes information you choose toprovide to us (e.g. age and gender) and make available to us when you interactwith the Platform (e.g. by listening, liking or creating playlists), as well asgeneral location data. We may also display ads based on the page you’re on orcontent you have recently viewed, searched, or listened to. This allows us toshow you ads that will likely be more relevant and interesting to you.
When we engage third-party services such as ad-networks andexchanges that enable us showing you targeted ads, we may also allow them tocollect certain information such as cookie data and device identifiers. Thatinformation is used to synch or match users to segments and serve targetedadvertising, including based on device activity, inferred interests, andgeneral location information.
Combine information we collect about you with informationfrom business partners and use it to serve more relevant advertising.
We may use your data for other purposes, provided wedisclose the purposes and use to you at the relevant time, and provided thatyou consent to the proposed use of your personal data.
Sharing of YourInformation
This section describes how the information collected orgenerated through your use of the Platform may be shared by you or by us.
Through Your Profile – Any information in your publicprofile (other than your email address) will be accessible by other users ofthe Platform, who may view your profile information, listen to and comment onany of your public Sounds, add themselves to your list of followers and sendyour messages. If you listen to any Sounds uploaded by an OrinPlay Pro user, thefact that you have listened to those Sounds will be shared with that Pro user,and that you are following that Pro user, so that they can track the popularityof their Sounds. Similarly, if you comment on any Sounds on the Platform, yourcomments will be available to all users of the Platform.
With Your Consent – We will disclose your information if youhave agreed that we may do so. We will make this clear to you at the point atwhich we collect your information, including the purpose(s) for which we willuse the data.
Service Providers – We use a variety of third-party serviceproviders, some of who may be located outside of the European Economic Area(“EEA”), to provide services to us or to our users on our behalf. These service providers have access to your information solely to perform these tasks on ourbehalf, and are contractually bound to implement appropriate organizational andtechnical security measures to protect against unauthorized disclosure ofpersonal data, and only to process personal data in accordance with ourinstructions and to the extent necessary to provide their services to us. Weneed to share your information, including personal information, in order toensure the adequate performance of our contract with you.
Content Partners – The Platform allows you to listen to avariety of content, including licensed streaming content from our contentpartners. We share information with these content partners that license thiscontent to help them understand how the content they provide is performing, includinginsights about general user listening trends and preferences. We use technicalmeasures to ensure the data is de-identified and/or aggregated so it does notidentify you directly. We share this data based on our legitimate interest inhelping content partners deliver high performing content and to ensure thefulfillment of our contract with those partners.
Advertising – We share the data collected about you,generally in hashed, aggregated, or de-identified forms with advertisers andadvertising service providers and business partners in order to serve ads basedon your interests and measure the reach and effectiveness of those ads,including whether a user took an action (e.g. purchase a product). We may alsoshare cookie data and device identifiers with service providers for datamatching purposes, in order to improve ad targeting.
Social Media – For users outside of the EU/EEA, wherepermissible under applicable law, we may share your email address (in hashedform, so that it does not identify you) with Facebook in order to target youwith ads for OrinPlay products on Facebook and on third-party websites andapplications in the Facebook Audience Network. We also allow Facebook and othersocial media platforms to collect information through cookies and similartechnologies like pixels in order to serve ads for OrinPlay on those thirdparty websites and apps and drive users to our Platform. In order to measurethe effectiveness of and optimize these marketing campaigns, these technologiestrack activity has taken across devices after a user sees an OrinPlay ad, in orderto determine performance metrics like sign ups, visits to the Platform, andpurchases. We undertake these activities based on our legitimate interest inacquiring new customers and offering products we think you may be interestedin. Any questions regarding how these social media platform service providerprocesses your personal data should be directed to such a third party platform.
Aggregated Data – We may also share aggregated information(information about our users that we render in such a way that it no longeridentifies or references an individual user) and other pseudonymizedinformation for regulatory compliance, industry and market analysis,demographic profiling, marketing, and advertising, and other business purposes.
Third Party Applications – If you choose to connect your OrinPlayaccount to other apps or social networks such as Facebook you may be sharingcertain information with these apps or networks. Content that you share withFacebook will appear on your timeline and in your Facebook friends’ newsfeeds. Inthe case of connected apps, you will need to provide the app developer withfull access to your OrinPlay® account in order to upload and download Sounds or comment on, favorite, or repost Sounds from within the app. This meanssharing your public information, plus access to your private Sounds. OrinPlayis not responsible for these other apps or networks, so please make sure youonly connect your account with apps or services that you trust. For informationon how to control the information that you share, and how to disconnect youraccount from these apps, please see the Your Choices and Controls sectionbelow. If you do not want this information shared with Facebook, please changeyour OrinPlay Settings on our Platform or in those networks.
Protecting our Rights – We may disclose your information ifwe feel this is necessary in order to protect or defend our legitimate rights andinterests, or those of our users, employees, directors, officers, orshareholders, and/or to ensure the safety and security of the Platform and/orthe OrinPlay community.
To Our Affiliates – To enable and support us in providingthe Platform and Services, we may share your information, including personalinformation, within the OrinPlay Group. The data sharing is necessary for theperformance of the contract between you and us and is based on our legitimateinterests in providing the Platform globally.
Cookies and SimilarTechnology
OrinPlay maintains appropriate technical, administrative,and physical safeguards that are designed to prevent unauthorized access, useor disclosure of personal information we collect or store and to ensure a levelof security appropriate to the risk of varying likelihood and severity for therights and freedoms of natural persons that may be involved with our processingoperations. We regularly monitor our systems for possible vulnerabilities andattacks. However, it is not possible to guarantee the security of informationtransmitted over the Internet. You use the Platform and provide us withinformation at your own discretion and risk.
OrinPlay is not intended for use by children. Anyone underthe age of 16 in the EEA, or 13 in the United States and the rest of the world,is not permitted to use the Platform and must not attempt to register anaccount or submit any personal information to us. We do not knowingly collectany personal information from any person who is under the age of 16 or 13, asthe case may be, or allow them to register an account. If it comes to ourattention that we have collected personal data from a person under the age of16 or 13, as applicable, we will delete this information as quickly aspossible. If you have reason to believe that we may have collected any suchpersonal data, please notify us immediately at email@example.com.
Your Choices andControls
We do our best to give you as much choice as possibleregarding the amount of information you provide to us, and the control you haveover that information.
Managing OrinPlay Settings. If you register an account, youmay manage the content and information you share when you use OrinPlay throughyour Account Settings, including for the features explained below. You aresolely responsible for keeping your Settings up-to-date.
Email – You can adjust your Settings in the Notification tabto disable email and desktop notifications (other than important serviceupdates and essential notifications about the Platform or your account). Allcommercial emails and newsletters also allow you to unsubscribe at any time.
Analytics – To control whether we collect analytics andusage information, including through cookies and similar technologies, you canadjust your Settings in the “Analytics” tab.
Marketing – If you do not want to receive personalized ads,offers or other marketing messages for OrinPlay products or services, you canadjust your Settings in the “Communications” tab.
Advertising – If you do not want OrinPlay to deliver“interest-based” or personalized ads for third-party products, you can adjustyour settings in the “Advertising” tab. Please note, however, that even if youopt out of personalized ads, you may still see ads, but they will likely not beas relevant or useful to you.
Content Sharing – It’s not possible to make your accountentirely private. However, you do have the option to make all of your tracks,playlists and other uploads private. This means that no one will be able toaccess and listen to your Sounds without your explicit permission. You canlearn more about these settings here.
Third Party Apps – If you have chosen to connect youraccount to a third-party application, like Facebook or Google, you can disablepermission for the app by adjusting your Settings in the “Connections” tab.
Third Party Developers – OrinPlay has an open API, whichallows third-party developers to build some really cool apps as an extension ofthe Platform. If you would prefer that your Sounds are not made available tothird-party app developers, you can disable API access within the sound pagefor each of the Sounds that you upload. Click on the pencil icon in thewaveform player, and uncheck the “Apps enabled” box at the bottom of the page.Please note that your public profile information will still be accessible, butthis does not include anything that is not publicly available on the Website.
On your mobile device, enable the “Limit Ad Tracking”setting in your iOS phone’s settings, or the setting to “Opt out of AdsPersonalization” in your Android phone’s settings. To opt-out of locationtracking when using our Apps, you can use the settings of your device. You candisable mobile analytics and bug reporting through these same settings as well.
To control cookies, you can modify your settings in most webbrowsers to accept or deny cookies or to request your permission each time asite attempts to set a cookie. You can also manually delete previously storedcookies at any time. Please note that if you choose to block cookies, doing somay impair the Platform or prevent certain elements of it from functioning.
Additional Choices and Controls
Exercising Your Rights
In some jurisdictions, including the EU/EEA, you mayexercise any of the rights described in this section through the Help Center.Please note that we may ask you to verify your identity before taking furtheraction on your request.
Data Access andPortability
You may be entitled to request copies of your personalinformation held by us. While a lot of the personal information you provide tous can be accessed in your Account Settings, you may also be entitled torequest copies of personal information you have provided to us inmachine-readable format.
Change or Correct Data
Where you cannot update data yourself through an account,you have the right to ask us to correct change, update or rectify your data.
Data Retention and Deletion
We generally retain data for as long as your account is inexistence or as needed to provide the Platform. However, specific retentiontimes can vary based on the context of the processing we perform and on our legalobligations.
You have the right to ask us to delete all or some of thepersonal data we hold about you. If you have an account, you can also deleteyour account through the Settings at any time as described below.
We may need to retain some of your personal data even afteryou have closed your account if reasonably necessary to comply with our legalobligations, or where we have a legitimate interest in doing so (e.g. toprevent fraud and abuse and maintain and enhance security).
Objection to Processing
You may object to processing your personal information insome circumstances (in particular, where we don’t have to process theinformation to meet contractual or other legal requirements, or where we areusing the information for direct marketing).
If you object to such processing OrinPlay will no longerprocess your personal information for these purposes unless we can demonstratecompelling legitimate grounds for such processing or such processing isrequired for the establishment, exercise or defense of legal claims orobligations.
Where your personal information is processed for directmarketing purposes, you may, under certain circumstances, ask OrinPlay to ceaseprocessing your data for these direct marketing purposes.
Restriction of Processing
Under certain circumstances, you may have the right to limitthe ways in which we use your personal information.
Where you provide consent to the processing of your personalinformation by OrinPlay, you may withdraw your consent at any time by changingyour account Settings or by sending a communication to OrinPlay specifying thespecific consent you are withdrawing. Please note that the withdrawal of yourconsent does not affect the lawfulness of any processing activities based onsuch consent before its withdrawal.
You have the right to lodge complaints about the dataprocessing activities carried out by OrinPlay before a competent dataprotection authority. A list of EU data protection authorities is available athttp://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
If you have questions or complaints about this PrivacyPolicy or our practices, please contact our Data Protection Officer by email firstname.lastname@example.org
Changes to this PrivacyPolicy