Last Updated: 05 February 2021
This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with our application ‘The Sound Reserve’ (the “App”) and our website ‘www.thesoundreserve.com’ (the “Website”). Please read the Policy carefully to understand our views and practices regarding your personal data.
We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including without limitation the Data Protection Act 2018 and the UK GDPR (as defined in the Data Protection Act 2018). Where we decide the purpose or means for the processing of the personal data that you provide when using our services, we are the “data controller”.
You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.
If you have any concerns over privacy, or this Policy, contact us at firstname.lastname@example.org
How we collect and use your personal data
Below explains what data we collect, how we use it, and which recipients it might be shared with.
Your data, How we use it and Third Party Recipients
User Account information (information you provide to us to setup an App account):
Full name; Email address; and Linked Spotify or Apple Music account details.
We process this information in order for us to setup and manage your user account with our App.
This data may be shared with Spotify or Apple, if you choose to connect your Spotify or Apple account to your App account.
App feedback, support and enquiry information (information we receive when you get in touch with us for support through the App or by email):
Name; Contact details (address, phone number, email); and Other personal data you choose to send to us
Where your submission to us involves feedback, we process your data on the basis of our legitimate interests to promote the success of our business, so that we can consider your feedback and, if appropriate, consider how we can improve our App and services.
App analytics and usage information (collected automatically when you use the App, or which may be available to us from App platforms / stores):
Time zone; Spotify account ID and/or Apple Music account ID; Country of install and language; Device manufacturer and model; Operating system and version; and ‘Events’ related to App usage, such as progress, achievement of a milestone and the occurrence of other particular events during your App usage (such as App installation/uninstallation, music session durations, music listening history and choices/selections for different parts of the App),
(“App Technical & Usage Data”)
We may collect this data so that we can understand usage of our App, analyse and improve our App and develop new services or new parts thereof. This data may also help us to identify problems (e.g. bugs or problems preventing App usage).
We may process this data as part of customising the App experience for you. For example, in order to understand – and then recommend to you – content available through the App that we think you may be more interested in.
In some cases, we may process this information for fraud prevention purposes.
In many cases the data would be aggregated and/or anonymised so that it would not identify you.
Competition and promotion related entry data (where you may enter a competition / prize promotion with us (such as over email or over social media):
Your entry contact information (e.g. social media username or email); information submitted as part of your entry; and information submitted so we can process your entry (such as your address, if we need to send you a prize).
We may from time to time operate prize promotions and competitions (without any obligation to do so). If we do, your personal data processed in connection with that activity would be processed on the basis of performance of a contract (being the competition / prize promotion terms of entry).
Device-level consents and push notifications
Most smartphone and tablet devices compatible with the App provide in-device privacy control mechanisms such as that the device may require your prior consent (to your device provider) in order for the Application to access certain device data and to provide you with certain App functionality.
You can control your device-level consents by selecting your preferred option in the ‘pop-up’ option your device presents to you at the relevant time. Also, you may be able to edit your preferences later in the ‘settings’ options available from your device provider.
Your editable consent preferences may include, for example, whether you would like the App to send you ‘push notifications’ on your device or not.
Email newsletters (if we operate them):
• your email address; and
• other information collected and clearly identifiable to you at the point of your signing up to our email newsletter.
Consent-based mailing lists
We may process your data to make suggestions and recommendations to you and other users of our services about: (i) news and updates relating to us, our partners, products, services and content; (ii) content, goods and services that may interest you; and (iii) other promotional activity and events we think may be of interest.
To the extent required by law, we rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time by letting us know, including by emailing us.
‘Soft opt-in’ mailing lists
In some instances (such as with some of our existing customers) the law may permit us to process your personal information in order to send information to you by email that we think is of interest for you on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and our websites, content, products and services. We may process your information for this purpose. If the information is not of interest for you, you can opt-out at any time by letting us know, including by emailing us.
We may share this information with our email marketing vendors such as MailChimp (The Rocket Science Group LLC). You can find out more about their privacy practices here .
For the purposes of our advertising attribution activities, we may process the following personal data:
App Technical & Usage Data, as defined above; and Information about the details of the advertising campaign and partner which resulted in your engagement with us (e.g. which Facebook ad you clicked through to then install the App).
We may process this information so that we can understand which of our partners, and/or our marketing campaigns or adverts, directed you to us, such as to install our App.
Attribution information enables us to promote the success of our company by better understanding the comparative successes of our marketing and our partners’ efforts, so that we can be more efficient with our marketing and our arrangements with partners.
We process this information on the basis of our legitimate interests, being our interests to promote the success of our company.
Your Rights In Relation To Your Personal Data
You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:
for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
to restrict, stop processing, or to delete your personal data;
for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/.
To make a request in relation to any of the aforementioned rights, please send your request to email@example.com.
You may request deletion of your personal data by sending an e-mail to firstname.lastname@example.org. Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally.
For data processing activities for which we rely upon your consent, you can withdraw your consent at any time by using the tools provided (if applicable, such as in-App or through your device settings) or otherwise by contacting us at email@example.com.
DISCLOSURE OF YOUR PERSONAL DATA
We will share your personal data with third parties only in the ways that are described in this Policy. Group, suppliers, subcontractors, service providers. We keep your personal data confidential, but may disclose it to any member of our corporate group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy.
In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Potential acquirers or investors
If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the website of any changes in ownership or use of your personal data, as well as any choices you may have.
We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.
We may also disclose your personal data, to the extent necessary, to application stores or platforms (such as the Apple App Store and Google Play Store) if that is required, for example, for fulfilment of an order you make (e.g. if needed to fulfil a subscription order) or in order to investigate or prevent fraud. Such platforms and stores may also process your information in order to provide you with cross-device access to your current position in the App and your in-App progression, for example. We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.
We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected, or as otherwise described in this Policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our service visitors and customers. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
International Data Transfers
Where necessary, there are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a national data protection regulator and/or approved by the European Commission, such as the European Commission’s standard contractual clauses, or other appropriate measures. If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at firstname.lastname@example.org.
If you follow a link from the App to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites. We may make changes to this Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email. All questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours or otherwise within a reasonable time.
Cookies (and equivalent devices in the context of mobile devices) are small text files that are placed on your device by websites that you visit and mobile applications you use. They are widely used in order to make websites and applications work, or work more efficiently, as well as to provide information to the owners of the sites and apps.
The below explains the main cookies we use in our App and why:
Purpose/ Third Party Access
This technology enables us to collect data about when a click from our marketing on Facebook platforms results in an installation of our App. This advertising attribution information allows us to better understand which of our advertising campaigns are successful. The data is shared with vendor Facebook for this purpose. You can find out more about Facebook’s privacy practices here .
Spotify Analytics SDK
Your data may be shared with Spotify for that purpose. You can read more about Spotify’s privacy practices here .
This technology is included within our App in order for us to be able to provide connectivity to your Spotify account, to play music accessible through your Spotify account via the App.
Your data may be shared with Spotify for that purpose. You can read more about Spotify’s privacy practices here .
Apple Music API
This technology is included within our App in order for us to be able to provide connectivity to your Apple account, to play music accessible through your Apple account via the App.
You can find out more about Apple’s privacy practices here .
As the above devices are contained within the App (as may vary between each of our Apps), the duration for which they are on your device will be the same as the duration for which the App is installed on your device.
HOW DO I CHANGE MY COOKIE SETTINGS
For some of our services, we may provide you with in-service preference tools which you can use to edit your cookie preferences. Most web browsers and mobile devices allow some control of most cookies and similar devices through the browser and mobile device settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org. Your mobile or tablet device provider may also provide you with additional cookie and browser control options, which may be available to you in your device settings – please consult your device settings for such device-specific controls (if applicable).