This Policy sets out how BEATLOCK and its affiliated entities and each of their present, former and future parents, predecessors, successors, assignees, subsidiaries, owners, officers and directors (whether acting in such capacity or individually), agents and attorneys (“BEATLOCK,” “we,” “us” and/or “our”), handle, design, collect, store, share and use your personal information on the BEATLOCK music streaming service website, mobile and device applications (collectively “Services”) and your choices about the collection and use of your personal information. “Personal information” means information that can be used to uniquely identify a single person. If you have questions about this policy please contact us by email at firstname.lastname@example.org.
- COLLECTION OF PERSONAL INFORMATION
We collect the following types of information:
- Information you provide us directly. When you register as a user for the Services and/or use the Services you provide us with certain information that we store. This may include: username and password information provided for the Services; your name, contact and other user profile information you may provide (e.g., address, phone number, email, age), such as when registering for the Services; payment information provided to use the Services; User Content (e.g., photos, comments, and other materials) that you upload or otherwise post on the Services; metadata associated with User Content (as defined in Section 9 of BEATLOCK’s Terms and Conditions of Use), which may include content creation date, formatting information, and location information about where the User Content was recorded (i.e., geotags); and communications between you and BEATLOCK.
- Analytics information. When you use the Services, we collect and process information generated by your use of the Services, such as favorites, playlists created, tracks played and downloaded, activity in the BEATLOCK applications, off lined tracks, time of log-in, what version of BEATLOCK client you use. If you access the Services via a handheld device, we also store a number that uniquely identifies the device. We use this information (i) to tailor and/or personalize the Services to you; (ii) for service improvement purposes; and (iii) for marketing and advertising purposes (as further described herein). We may also use internal or third party analytics tools to help us measure traffic and usage trends for the Services. These tools collect information sent by your device or the Services that assists us in improving the Services.
- Log file information. This information may be automatically reported by your browser or device each time you make a request to visit, access or use the Services. When you visit, access or use the Services, our servers may automatically record certain log file information, including the time of log-in, what version of the BEATLOCK client you may be using, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also log the Device ID or other unique information for devices used to access the Services. We may also collect similar information from emails we send to you, which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.
Google Analytics: In addition to our own cookies, other cookies may be placed on your device by Google Analytics from Google Inc. to create anonymous usage statistics. If you have concerns relating to the usage of Google Analytics, it is possible to block Google Analytics by installing a plug-in to your browser. A plug-in for the most common browsers can be found here: http://tools.google.com/dlpage/gaoptout.
Facebook: If you enable the function “Connect to Facebook” in the settings of your BEATLOCK client we may share your favorites with Facebook enabling your Facebook friends to see your favorites and enabling you to see your Facebook friends’ favorites. If you use the “share” function you may be able to post to your Facebook account directly from the BEATLOCK client.
Twitter: If you use the function “share” you can post to your Twitter account directly from the BEATLOCK client. Such posting might involve sharing personal data.
- USE OF PERSONAL INFORMATION
In addition to some of the specific uses of personal information we describe in this Policy, we may use information that we receive to:
- Process payments for use of the Services;
- Help you efficiently access your information and features of the Services;
- Remember information so you will not have to re-enter it during your visit or the next time you visit the Services;
- Provide personalized content and information to you and others, which could include online ads or other forms of marketing;
- Provide, improve, test, and monitor the effectiveness of our Services;
- Calculate settlements for content owners;
- Develop and test new products and features;
- Monitor metrics such as total number of visitors, traffic, and demographic patterns;
- Diagnose or fix technology problems; or
- Detect, investigate and take all steps necessary to address misuse of the Services.
- SHARING INFORMATION WITH THIRD PARTIES
We will not rent, sell or share your personal information to third parties outside BEATLOCK without your consent, except as noted in this Policy.
(a) Parties with whom we may share your personal information.
- Rights Holders. BEATLOCK allows you to listen to and view content from third party rights holders. BEATLOCK shares information with the rights holders that license this content to BEATLOCK. The data that BEATLOCK shares with the rights holders is in a de-identified format that does not identify you directly, unless you opt into the sharing of your personal information.
- Service Providers. We may share User Content and your information (including but not limited to, information from cookies, log files, metadata and usage data) with third party organizations that help us provide the Services to you, including telecommunications companies with whom you have a contractual relationship and through which you may receive access to the Services (for example through a bundled package), and payment processors (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services under reasonable confidentiality terms.
- Marketing and Advertising. We may share certain information such as cookie data and streaming data (e.g., the number of plays of a particular song or playlist by all users) with third party advertising partners in order to allow third party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. We may also deliver targeted emails and other communications to you concerning such advertisers, their products or services and/or BEATLOCK events sponsored or hosted by such advertisers. We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information, which, in its aggregated form, may include demographic data such as how many users constitute a particular age group, general locations of where groups of users reside for purposes of, e.g., determining who may be interested in attending a BEATLOCK event and similar anonymized data.
- Your Financial Institution. In the event you contest or dispute Subscription charges, we may share information collected in accordance with this policy, as reasonable, to assist your credit card company or financial institution to investigate and resolve your claim.
- Parties with whom you may choose to share your User Content. Any information (e.g., name) or User Content (e.g., picture) that you voluntarily share or disclose for posting to the Services may become available to the public. This can also include parties to whom you have given us consent to share such personal information, for example Facebook, as further described above.
- What happens in the event of a change of control. If we transfer, voluntary or involuntarily, part or the whole of the Services or our assets to another organization, your information such as name and email address, User Content and any other information collected through the Services may be among the items transferred. The Terms and Conditions of Use otherwise sets out your rights with respect to your User Content. The buyer or transferee will have to honor the commitments we have made in this Policy.
- Responding to legal requests and preventing harm. We may access, preserve and share your personal information in response to a legal request (such as a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of Kenya where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. By allowing for sharing and use of personal information for these purposes, BEATLOCK is not assuming any affirmative duty to undertake such actions.
- STORING PERSONAL INFORMATION
- By registering for, accessing, visiting or otherwise using the Services, you consent to the transfer of your personal information to anywhere where BEATLOCK or its Service Providers maintain facilities, including facilities in another country.
- We use commercially reasonable safeguards to help keep the personal information collected through the Services secure and take reasonable steps to protect your personal information. Only a limited number of personnel with a legitimate business or legal need are given access to users’ personal information. However, we cannot ensure the security of any information you transmit to BEATLOCK or guarantee that information on the Services may not be accessed, used, disclosed, altered, or destroyed.
- Please do your part to help us. You are responsible for maintaining the secrecy of any non-public information that you provide BEATLOCK, accessing the Services and making payments from a secure computer or device, and for controlling access to emails between you and BEATLOCK, at all times. Any social media services that you use to connect to the Services (e.g., Facebook, Twitter) may also affect your information; we are not responsible for the functionality, privacy, or security measures of any other organization.
- User Content that you provide to the Services may be retained and made publicly available on the Services indefinitely, consistent with our Terms and Conditions of Use.
- Information we collect or receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
- COMMUNICATIONS, NOTICES, & CONSENT
If you have provided us with your email address, we may use this information to communicate with you in matters relevant to the Services and consistent with your preferences and applicable law. Such information includes receipts for payment; information about and changes to the Services, including, for example, forthcoming streaming content and artist information, BEATLOCK newsletter, BEATLOCK events and certain revisions to the Terms and Conditions of Use and/or this Policy. We will not email you information about third party services (although a particular BEATLOCK event may involve third party sponsors).
You may unsubscribe from email communications from BEATLOCK by clicking on the “unsubscribe link” provided in such communications. You may not be able to opt out of certain important email communications (e.g., account verification, payment receipts, technical and security notices) and by signing up for or using the Services, you thereby agree to receive such important email communications.
By providing us with a telephone number for a mobile device, including a number that you later convert to a mobile device number, you expressly consent to receiving communications—including but not limited to prerecorded or artificial voice message calls, text / SMS messages, and calls made by an automatic telephone dialing system—from BEATLOCK at that number, about the Services as described immediately above. This express consent applies to each such telephone number that you provide to us now or in the future. Calls and messages may incur access fees from your mobile service provider. You understand that you need not provide this consent as a condition of purchase, or by visiting, accessing or using the Services, and that you may revoke your consent at any time by emailing email@example.com, or replying STOP in response to any text message you receive from BEATLOCK.
If you have questions regarding your data stored with us, its rectification or deletion, or would like to revoke any consent provided to us, object against certain uses, please contact us by email at firstname.lastname@example.org.
- CHILDREN AND PRIVACY
BEATLOCK does not knowingly collect or solicit any personal information from anyone under the age of 18 or knowingly allow such persons to register for the Services. The Services and their content are not directed at children under the age of 18. In the event that we learn that we have collected personal information from a child under age 18 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any personal information from or about a child under 18, please notify us immediately by sending an email to email@example.com.
- DO NOT TRACK
BEATLOCK does not respond to Do Not Track (DNT) signals and handles all personal information consistent with its Terms and Conditions of Use and this Policy.
- CONDITIONS OF USE AND REVISIONS TO THIS POLICY
If you choose to visit, access, or use the Services, your visit, access and/or use and any dispute over privacy is subject to this Policy and BEATLOCK’s Terms and Conditions of Use, including limitations on damages, resolution of disputes — including an agreement to arbitrate, to not proceed in court or on a class or collective basis, and to not have the right to resolve disputes by a judge or a jury — and application of applicable federal law and the laws of the Republic of Kenya.
The Services are subject to constant improvement and future changes may influence how we collect, use, share, and store your personal information. This Policy will be updated to reflect such changes, changes in legal framework or improvements in how we handle personal information.