PRIVACY POLICY

This Privacy Policy is incorporated by reference into Soundhalla’s Terms of Use. The terms “Soundhalla,” “we,” and “us” include Soundhalla Limited, and our affiliates and subsidiaries. The Privacy Policy explains how Soundhalla may: collect, use, and disclose the information we obtain through the “Soundhalla service” The “Soundhalla Service” and the “Service(s)” mean any websites, mobile applications, and other services under the control of Soundhalla, whether partial or otherwise, related to providing an online, mobile, or other digital platforms for Soundahalla’s services, including www.soundhalla.com, and the Soundhalla app. “Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, payment information, or phone number. We do not consider Personal Information to include information that has been de-identified so that it does not allow a third party to easily identify a specific individual. The Soundhalla Service may provide you with the ability to post or share content including posts, text, comments, photos, videos, music, links, and files to share with other users (“Your User Content”).

INFORMATION WE COLLECT AND USE
For purposes of this Policy, “Personal Information” is any information that identifies, relates to, or describes, directly or indirectly, an individual or household. In the course of operating the Soundhalla Service, we collect Personal Information, which we use for typical business and commercial purposes (including compliance with legal obligations and use for auditing, security, and anti-fraud purposes) and for other purposes as described below: Information You Give Us. When you sign up for and use the Soundhalla Services as an artist or listener, we may collect and store the Personal Information you provide, including:
Personal Identifiers. We receive personal identifiers you provide (including, your name, email address, log in and password, phone number, or similar identifiers) and use them to respond to and complete your requests, provide notifications, and communicate with you for registration, customer service, and informational purposes (including sending you confirmation emails, notices, updates, invoices, and security alerts), and for marketing purposes (including sending you news, promotions, and other information that we and our affiliates and partners believe may be of interest to you). We may also create internal identification and reference codes to identify you in our electronic systems.

Communications and Submissions: We collect the information and content you submit when you create a campaign (as an artist), submit a review (as a listener), otherwise use the Soundhalla Service (including posting public testimonials and other public content), or otherwise voluntarily interact with us. We also collect the information you submit through contact, sign-up, and profile forms, email communications, and other submissions (including reviews, feedback, and surveys), and when you communicate with Soundhalla service and support. We use this information to respond to and fulfill your requests, communicate with you about the Soundhalla Service, for promotional/marketing purposes, establish and manage our customer relations and customer service, and provide and improve our websites, products, and services.

Financial Information. We receive financial information such as payment cards, banking information, and other related information to process payments for campaigns you have requested and to process payments to listeners. Commercial Information. We collect and generate commercial information and transaction information (such as records of services purchased on our websites, music genre preferences, or services you have enrolled in). We use this information to respond to and fulfil requests, improve our product and service offerings, communicate with you, tailor our marketing efforts, and for internal reporting purposes. Soundhalla Referral Information. If you use our referral program to recommend Soundhalla to others, you may need to provide contact information for yourself and the friend. (We will automatically send your friend a one-time email inviting him or her to visit our Service/ or however Soundhalla decides to invite referred party). Soundhalla stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Inferences from the information listed above. We will use the information listed above to draw inferences about your preferences to help us develop and provide better products and services.

Audio and Visual Information. We receive audio files you share with us through our Services. Privacy Choices. We receive and retain any opt-outs or other choices related to how we collect, use, and disclose Personal Information.
Social Networks and Publicly Available Data. Our websites include social media features, such as the Facebook “Like” button and widgets like the “Share” button and similar functions. These features may collect your IP address, and the pages you are visiting on our website and may set cookies to enable them to function as you have requested. Social media features and widgets are either hosted by a third party or directly on our websites. We may also permit you to log in and connect your Soundhalla account with your accounts on other websites (like Spotify or Facebook), and we collect personal identifiers you have made available on those sites. We use the Personal Information collected in this way for the same purposes as described above.
Information Other Users Provide about You. Other users may provide us with your personal identifiers (such as your email address) or other information in order to invite you to use the Soundhalla Services or share content from the Soundhalla Services with you. In this case, we will use the information for the purposes for which it was provided.

Other Information We Collect: We also may collect other information about you, your device, or your use of the services in ways that we describe to you at the point of collection or otherwise with your consent. You may choose not to provide us with certain types of information but doing so may affect your ability to use some of the Soundhalla Services.

Information We Get from Your Use of The Soundhalla Service.
In addition to the information you provide when you use the Soundhalla Service, we keep track of information about how you have used the Service, like when you open one of our emails or whether you viewed and interacted with certain content (collectively, “Usage Information”). We use this information to provide and improve our products and services, tailor your experience on and across our websites and other services, tailor our marketing efforts, and create aggregate internal reports on website usage and activity, such as views of certain pages and content. Usage Information includes: Device Information. We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information, including phone number).

Browsing Information. This includes the URL that referred you to the Soundhalla Services, the areas within the Soundhalla Services that you visit, how long you spend on the Soundhalla Services, and the time of day of your visit. IP Address. An IP address is a string of numbers associated with the device you use to access the Internet.

Location Information. Many mobile devices permit applications to access real-time geolocation information. We may collect and use such information with your consent when you use our websites. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points, and cell towers and provide geo-location information. Inferences from the information listed above. We may use the information listed above to draw inferences about your preferences to help us provide you with personalized content and offers and help us develop and provide better products and services.

Automatic Collection of Information from Cookies and Other Technology. We and our partners use various technologies to collect and store information when you visit the Soundhalla Services, which we use for the same purposes as Usage Information and to help us improve our websites and communications. This automatic information collection may include using cookies or similar technologies to identify your browser or device:

Mobile Identifiers. We may use software development kits (“SDKs”) or mobile advertising identifiers (i.e., IDFA on Apple mobile devices or Advertising ID on Android mobile devices), which function similarly to cookies on mobile devices. You may reset your IDFA or Advertising ID in the settings on your mobile device. Cookies. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs,” “one-pixel GIFs,” or “clear GIFs”) may be included in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Soundhalla Services, to monitor how users navigate the Soundhalla Services, to make cookies more effective, and to analyze how our emails, articles, and links were opened, viewed, and used.

** Most browsers will tell you how to stop accepting new cookies, how to receive notifications of new cookies, and how to disable existing cookies. For more information about cookies and how to disable them, or restrict the categories of cookies you wish to accept, you can consult the information at www.allaboutcookies.org/manage-cookies/.

Please note that rejecting cookies does not mean that you will no longer see ads when you browse the internet. Also, without cookies, you may not be able to take full advantage of all of the Soundhalla Services and some parts of the Soundhalla Services may not function properly. Anonymous or Aggregated Information. We de-identify or aggregate data we receive and may use and disclose it for any business purpose.

HOW WE DISCLOSE PERSONAL INFORMATION
Service Providers. We share any of the personal information described above with service providers (including but not limited to payment processors, fraud detection vendors, and service-related technology providers) that provide services to you and us, including to help us maintain our databases and websites, administer emails, display content, and analyze website user activity. For example, we may provide your personal identifiers and commercial information to vendors so they can send you communications on our behalf. We require that service providers use Personal Information only for the purposes specified in our agreements.
Advertising Partners. We may share your personal identifiers and commercial information with advertising partners that use various technologies to send (or serve) relevant ads on our behalf on platforms or websites operated by others.

Within Our Organization. We may share any of your Personal Information with parents, subsidiaries, joint venture partners, and other entities under common control subject to this Privacy Policy.

Social Networks. You may interact with features of the Soundhalla Services that cause certain categories of Personal Information to be published to your social networks. To understand the precise categories of Personal Information shared in this manner, please review the privacy policies of the relevant social networks and/or log out of the applicable service before you use our online services.

Disclosures Using Non-Restricted Services. As explained in the Soundhalla Terms of Use, the information you post to the Soundhalla Service may be shared in order for us to provide the Service. Artists’ submissions may be shared to Spotify by persons and entities over which we have no control. Please exercise caution and good judgment when disclosing any Personal Information in posts you make to Soundhalla Services. Note that we cannot be responsible for any online postings by a family member, friend, acquaintance, or other person or entity outside of our control. Such activities and the associated postings are also outside the scope of this Policy. Sweepstakes, Contests, and Promotions. Soundhalla may offer sweepstakes, contests, and other promotions (“Promotion(s)”) that may require registration. By participating in a Promotion, you are agreeing to the terms, conditions, or official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

Legal and Similar Disclosures. We may disclose Personal Information about you to law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process, if necessary to do so by law or based on our good faith belief that it is necessary to enforce or apply our contracts, conform or comply with the law or is necessary to protect us, the users of the websites, or others.

Business Transfers. In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets (whether by private sale, through the operation of law, as part of a divestiture plan, or otherwise), your Personal Information, and any other information that we have collected, may be disclosed to the persons and/or entities assuming control of the relevant business unit or as otherwise necessary to complete the transaction as permitted by law or contract.

Otherwise with Your Consent or At Your Direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

ONLINE ADVERTISING AND USAGE ANALYTICS
We do not share your Personal Information with third parties for their own marketing purposes. However, we use email services to send informational and marketing emails, and analytics services to help us understand and improve the usage of our websites and emails. We also use advertising services to serve ads as you browse other sites on the internet. These services will collect your personal identifiers (such as IP address, device ID, and cookie information), device characteristics (such as browser version), and website browsing activity by placing cookies and using other similar technology. They use that information to provide advertisements to you and/or to provide analytical information for our websites. These companies also may collect and combine information about your online activities over time, on other devices, and on other websites or online services that we do not control, if those websites and online services also use the same partners. We currently use (insert Analytics service used) to collect and process usage-related data on the Soundhalla Service. To learn more about (insert Analytics used) and how to opt-out, please visit (insert website…). You may learn more about advertising networks and opt-out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those sites are here: Network Advertising Initiative: http://www.networkadvertising.org/choices/ Digital Advertising Alliance: http://www.aboutads.info/choices/ When you opt-out of personalized advertising, you may continue to see online advertising on the sites and/or our ads on other websites and online services.

OPT-OUT CHOICES AND ACCOUNT INFORMATION
At your request, and where required by law, we will confirm and/or update the Personal Information we hold about you. We may have to verify your identity to do so. If you do not want to receive marketing information from us, you may “opt-out” by writing or emailing us using the contact information listed below. If you were opt-out, you may still receive information from us but only if it is necessary to provide you with our services, including administrative messages and satisfaction surveys. We do not sell Personal Information for monetary consideration. However, you can submit a request to opt-out of us selling your Personal Information for monetary consideration by contacting us using the information below.

SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. By using the Soundhalla Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Soundhalla Service. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on the Soundhalla Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at support@soundhalla.com.
CHILDREN’S PRIVACY
No one under the age of 13 is authorized to submit any information, including Personal Information, on the Soundhalla Service. Under no circumstances may anyone under the age of 13 use the Service. If you learn that your child has provided us with Personal Information without your consent, you may alert us at support@soundhalla.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

INTERNATIONAL USERS
By using the Soundhalla Service, you will transfer data to the Federal Republic of Nigeria. By choosing to visit the Soundhalla Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the Federal Republic of Nigeria and the adjudication of any disputes arising in connection with Company or the Soundhalla Service will be in accordance with the Terms of Use. If you are visiting from West Africa or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the Federal Republic of Nigeria and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.

LINKS TO THIRD-PARTY WEBSITES
This Service may contain links to third-party websites or enable sharing of content with third-party websites, including Spotify. This Privacy Policy does not apply to the practices of other websites and services, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those other websites and services.

UPDATING YOUR INFORMATION OR POSING A QUESTION OR SUGGESTION
If you have any questions or concerns about this Privacy Policy or the use of your information, or to modify or update any information we have received, please contact support@soundhalla.com. Data Retention. We will retain your information for as long as needed to provide you with the Soundhalla Service and as permitted by law. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Account Deactivation and Deletion. If you no longer desire to use the Soundhalla Service, you may deactivate or delete your account by sending us an email to support@soundhalla.com. Deactivating your account puts your account on hold and is the same as you telling us not to delete any information because you might want to reactivate your account at some point in the future. When you delete an account, you are requesting that your account and the information stored therein be permanently deleted from the Soundhalla Service. You should only delete your account if you are sure you never want to reactivate it. Please note, that certain data you have provided may continue to exist in aggregate form that cannot be used to identify you.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES
We may revise this Privacy Policy, so review it periodically.
Posting of Revised Privacy Policy. We may update this privacy policy to reflect changes to our information practices. If we make any change in how we use Personal Information we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Soundhalla Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.