go-TunePrivacy Policy

Welcome to Go-Tune, a service provided by Melian Software Company and its subsidiaries, including Go-Tune, Inc.

Your privacy is important to us. This Privacy Policyexplains how we collect, store, use, disclose and otherwise process yourinformation when you use go-tune.net and m.go-tune.net (together, the “Website”),our mobile and desktop apps (the “Apps”) and all relatedsites, players, widgets, tools, apps, data, software, APIs and other services providedby Go-Tune (the “Services”). This Privacy Policy applies toany Website, App, or Service that refers to this Privacy Policy, i.e. bylinking to it.

Information relating to our use of cookies and similartechnologies is set out in our CookiePolicy, which forms part of the Privacy Policy. When we refer to thePrivacy Policy, we are referring to the Privacy Policy and Cookie Policy.

Please take some time to read this Privacy Policy, alongwith our Terms of Use, in orderto ensure you understand and are comfortable with our use and disclosure ofyour personal information. If you see an undefined term in this Privacy Policy,it has the same meaning given to it in our Terms of Use.

Please note that this Privacy Policy only applies to theWebsite, Apps and Services (together, the “Platform”). Whenusing the Platform, you may find links to other websites, apps and services, ortools that enable you to share information with other websites, apps andservices. Go-Tune is not responsible for the privacy practices of these otherwebsites, apps and services and we recommend that you review the privacy policiesof each of these websites, apps or services before connecting your Go-Tuneaccount or sharing any personal data.

If you do not agree to any of the provisions ofthis Privacy Policy, you should not use the Platform. If you have any questions or concerns about this Privacy Policy,you can contact us through dataprotection@go-tune.net.

Data Controllers

When this policy mentions “Go-Tune,” “we,” “us,” or “our,”it refers to the Go-Tune entity that is responsible for your information underthis Privacy Policy (the “Data Controller”).

·        If you are located in theUnited States, Go-Tune Inc. is the Data Controller of your personal dataprovided to, or collected by or for, or processed in connection with, ourPlatform;

·        If you are located outside theUnited States, Go-Tune Ltd. is the Data Controller of your personal dataprovided to, or collected by or for, or processed in connection with, ourPlatform;

·        We may share your data withinour corporate group of companies that are related by common ownership orcontrol (“Melian Software Company”) and data of US users may be processed by Melian Software Company. on Go-Tune Inc.’s behalf.

Our Privacy Principles

Go-Tune is committed to putting its users first andbelieves you should know what data we collect about you, why we collect it, andhow we use and share it. That’s why we’ve designed this Privacy Policy to giveyou simple, clear, and actionable information about our privacy and dataprotection practices.

We believe users should also have meaningful choices overthe data we collect, use and share as described in this Privacy Policy, your Settings. We encourage you to take fulladvantage of these tools.

Information We Collect

The personal information we collect is related to providingthe Platform and its features and falls into three general categories:

  • 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.

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 any contract betweenus and you, including but not limited to the Terms of Use. Without it, we maynot be able to provide you with all the requested services and features of thePlatform.

You don’t need to register for a Go-Tune 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 Go-Tune account, you will need toprovide your email address (except when you sign-up with Facebook or Google anddon’t give your permission to share it with Go-Tune), 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, to provide additionalinformation for your public profile on Go-Tune – for example:

    • your real name
    • a user name (which may be your real name or a pseudonym)
    • the city and country in which you live
    • a profile picture, profile header image or avatar
    • information about how you categorize yourself with respect to your content (for example, whether you are a musician, a label or some other category of creator)
    • details of your other websites and social media profiles, including links to those pages
    • your gender if you wish to provide it
    • any additional information you choose to provide as part of your public profile, such as your real name, and links to your website and other social media profiles (but not your email address), will be published on your profile page. This information will be publicly accessible and may be viewed by anyone accessing the Website, or using our API or other Services.

·        Communications - When you communicate with Go-Tune by email or through thePlatform, or use the Platform to communicate with other users, we collectinformation about your communication and any information you choose to provide.

·        Survey Information - If you participate in any survey, you may provide certainpersonal data as part of your response, unless you respond anonymously.

·        Information You Post - You may provide personal data when you upload Sounds to thePlatform, or when you post comments, or contribute to community discussions.

Information We Collect Automatically

There is certain information that we collect automaticallyas the result of your use of the Platform, or through the use of cookies andother web analytics services as described in our Cookie Policy. Thisinformation generally includes:

·        Usage Information - We collect information about your interactions with the Platform,including the pages that you visit and links you click on, streaming, offlinelistening or downloading tracks, uploading or recording tracks, connecting yourFacebook or Google account, sharing a Sound with another user, following orunfollowing another user, posting a comment, performing a search, the time,frequency and duration of your visits to the Platform, and whether you interactwith email messages, for example, if you opened, clicked on, or forwarded the emailmessage.

·        Log Data – We automatically collect log information when you use thePlatform, even if you have not registered for an account or logged in. Thatinformation includes, among other things: details about how you’ve used thePlatform (including links to third party sites or services), Internet Protocol(IP) address, access times, your browser type and operating system, deviceinformation, device event information (e.g., crashes, browser type), and thepage you’ve viewed or engaged with before or after using the Platform.

·        Cookies – We use cookies and other similar technologies, such as pixels,local storage, and mobile device identifiers and may also allow our businesspartners to use these tracking technologies on the Platform, or engage othersto track your behavior on our behalf. For more information on our use of thesetechnologies, see our CookiePolicy.

·        Location Data – When you use certain features of the Platform, we may collectdata about your general location (e.g. IP address). We use this data to provideyou with location-based services (such as advertising and personalizedcontent). Most mobile devices allow you to control or disable the use oflocation services for applications in the device’s settings.

·        Device Information – We collect information from and about the devices you use,including how you interact with the Platform and information about the deviceitself, such as the hardware model, operating system, IP addresses, cookieinformation, device settings, mobile device and advertising identifiers, appsinstalled, browser type, language, battery level and time zone. Apple’s iOSAdvertising Identifier (IDFA) and Google’s Android Advertising ID are examplesof device identifiers. This information allows us to recognize and associateyour activity, and provide personalized content and advertising, consistentlyacross all of your devices.

·        Software DevelopmentKits – We may use third parties including ourbusiness partners and service providers who use mobile SDKs to collectinformation and information related to how mobile devices interact with thePlatform. An SDK is computer code that app developers can include in their appsto enable ads to be shown, data to be collected and related services andfunctionality to be implemented. We may use this technology, for instance, toanalyze how you interact with content and advertisements and to enableanalytics or other features through mobile devices.

·        Go-Tune Widget – Other websites may integrate Go-Tune widgets; when you visit awebsite with a Go-Tune widget embedded, we may receive certain information,including information about the website you visited. Go-Tune and the widget maybe able to recognize you in order to retrieve your library of content, and insome cases the widget may be used to show personalized content. We know whenyou interact with a widget, and websites containing the widgets may receivethis information as well.

Information From Third Parties

·        Single-Sign Ons – If you sign up for Go-Tune through a third party application likeFacebook or Google, you authorize us to collect your authenticationinformation, such as your username and encrypted access credentials, and otherinformation available through the third party application account, includingthe following information:

o   Facebook – Go-Tune allows you to sign up and sign in using your Facebookaccount. If you sign up using Facebook, Facebook will ask your permission toshare certain information from your Facebook account with Go-Tune. Thisincludes your Facebook user ID, first name, last name, email address(optional), gender, locale, your time zone, birthday and profile picture. Thisinformation is collected by Facebook and is provided to Go-Tune under the termsof Facebook’s Privacy Policy.You can control the information that we receive from Facebook using the privacyand data settings in your Facebook account. If you signed up using Facebook bymistake, you can delete your account from the Account page within your Settingsat any time, or you can contact us via the HelpCenter.

o   Google – You can sign up and log in to Go-Tune using your Google account.When you sign up using Google, Google will ask your permission to share certaininformation from your Google account with Go-Tune. This includes your Googleemail address, birthdate (optional), gender (optional), and avatar (optional).This information is collected by Google and is provided to us under the termsof Google’s Privacy Policy.You can regulate the information that we receive from Google using your Google activitycontrols. If you signed up using Google by mistake, you can delete youraccount from the Account page within your Settings at any time, or you cancontact us via the Help Center.

·        Service Providers andBusiness Partners – We may also receiveinformation about you from our service providers and business partners,including companies that assist with payment processing, analytics,advertising, marketing, data processing and management (e.g. to measure adquality and responses to ads, and to display ads that are more likely to berelevant to you, including for Go-Tune products) account management, hosting,customer and technical support, content moderation, and other services which weuse to personalize your Go-Tune experience. We explain in more detail why andhow we use this information below.

How We Use Your Information

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

o   To operate and maintain your Go-Tuneaccount, and to provide you with access to and use of the Platform. Your emailaddress and password are used to identify you when you log into the Platform.Your device-IDs are used to ensure that you are in control of the devices thathave access to your Subscription.

o   To identify you as the creatorof the Sounds that you upload, the comments that you post and/or the othercontributions that you make to the Platform.

o   To provide creators with statsand insights about users’ listening behavior of their Sounds, (i.e. streamingand downloading their Sounds or following their profiles).

o   We conduct surveys andresearch, test features in development, and analyze the information we have toevaluate and improve products and services, develop new features, and conductaudits and troubleshooting activities.

o   If you purchase a Subscription,your name, address and payment verification information will be used to processyour account subscription and renewals and to collect your payment. All paymentverification information is transmitted using industry-standard SSL (SecureSocket Layer) encryption. Go-Tune also complies with the Payment Card IndustrySecurity Standards.

o   Your email will be used to sendyou service updates and notifications about your account.

o   To respond to you about anycomment or enquiry you have submitted.

o   We use your age to enable agerestrictions.

We process this information inlight of our legitimate interest in improving the Platform and giving our usersthe best experience, and where it is necessary for the adequate performance ofour contract with you (e.g. Terms of Use).

·        Maintain a Safe andSecure Environment

o   Detect and prevent fraud, spam,abuse, security incidents, and other suspicious activity.

o   Verify and authenticate youridentity and prevent unauthorized or illegal activity.

o   Enhance the safety and securityof our products and services.

o   Conduct security investigationsand risk assessments.

o   To prevent or take actionagainst activities that are, or may be, in breach of our Terms of Use,Community Guidelines or applicable law.

o   To provide you with customerand technical support.

We process this information inlight of our legitimate interest in improving the Platform and giving our usersthe best experience, and where it is necessary for the adequate performance ofour contract with you (e.g. Terms of Use).

·        Personalize Content,Advertising and Marketing

o   To improve your experience onthe Platform by providing personalized content, recommendations, and features.

o   To customize the content andmeasure performance of any email, push notification, or in-app message we maysend to you.

o   Administer sweepstakes,contests, or other promotional activities or events sponsored or managed by Go-Tuneor its partners.

o   Use automated systems anddecision making to profile user characteristics and infer preferences based oninformation that you provide to us, your interactions with the Platform andcontent, your profile information, and information obtained from third parties.This data is used to create groups of users, called segments, who share similarcharacteristics and interests; we use segments to serve personalized content,advertising, and marketing messages. We also use automated systems to associateyour activity over time across devices, and may associate activity and accountsunder a single user ID, in order to determine that certain devices are relatedto each other and provide you with a personalized experience across devices andplatforms.

o   To deliver targeted marketingfor Go-Tune products on and off the Platform and measure the success of thosecampaigns. When you see our ads on a third party website or apps, we or thirdparty services we engage for this purpose, may collect information that yourbrowser or mobile app makes available when seeing the ad (e.g IP address,referral URL, browser details, timestamp of request), including whether a clickconverted to an actual purchase of a Subscription. Please see the privacypolicy of such third party websites to understand what data may be collectedand how to opt-out.

o   Ads are more effective whenthey are shown to people who are likely to be interested in the product orservice advertised. For this reason, we use the information we collect andreceive to help us select which ads to show you on behalf of advertisers. Thisincludes information you choose to provide to us (e.g. age and gender) and makeavailable to us when you interact with the Platform (e.g. by listening, likingor creating playlists), as well as general location data. We may also displayads based on the page you’re on or content you have recently viewed, searched,or listened to. This allows us to show you ads that will likely be morerelevant and interesting to you.

o   When we engage third partyservices such as ad-networks and exchanges that enable us showing you targetedads, we may also allow them to collect certain information such as cookie dataand device identifiers. That information is used to synch or match users to segmentsand serve targeted advertising, including based on device activity, inferredinterests, and general location information.

o   Combine information we collectabout you with information from business partners and use it to serve morerelevant advertising.

We may use your data for otherpurposes, provided we disclose the purposes and use to you at the relevanttime, and provided that you consent to the proposed use of your personal data.

Sharing of Your Information

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 public profile (other than your emailaddress) will be accessible by other users of the Platform, who may view yourprofile information, listen to and comment on any of your public Sounds, addthemselves to your list of followers, and send you messages. If you listen toany Sounds uploaded by a Go-Tune Pro user, the fact that you have listened tothose Sounds will be shared with that Pro user, and that you are following thatPro user, so that they can track the popularity of their Sounds. Similarly, ifyou comment on any Sounds on the Platform, your comments will be available toall users of the Platform.

·        With Your Consent – We will disclose your information if you have agreed that we maydo so. We will make this clear to you at the point at which we collect yourinformation, including the purpose(s) for which we will use the data.

·        Service Providers – We use a variety of service providers, some of who may be locatedoutside of the European Economic Area (“EEA”), to provide services to us or toour users on our behalf. These service providers have access to yourinformation solely to perform these tasks on our behalf, and are contractuallybound to implement appropriate organizational and technical security measuresto protect against unauthorized disclosure of personal data, and only toprocess personal data in accordance with our instructions and to the extentnecessary to provide their services to us. We need to share your information,including personal information, in order to ensure the adequate performance ofour contract with you.

·        Content Partners – The Platform allows you to listen to a variety of audio content,including licensed streaming content from our commercial content partners. Weshare information with these content partners that license this content to usto 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 and advertising serviceproviders and business partners in order to serve ads based on your interestsand measure the reach and effectiveness of those ads, including whether a usertook an action (e.g. purchase a product). We may also share cookie data anddevice identifiers with service providers for data matching purposes, in orderto improve ad targeting.

·        Social Media – For users outside of the EU/EEA, where permissible underapplicable law, we may share your email address (in hashed form, so that itdoes not identify you) with Facebook in order to target you with ads for Go-Tuneproducts on Facebook and on third party websites and applications in the FacebookAudience Network. We also allow Facebook and other social media platformsto collect information through cookies and similar technologies like pixels inorder to serve ads for Go-Tune on those third party websites and apps and driveusers to our Platform. In order to measure the effectiveness of and optimizethese marketing campaigns, these technologies track activity taken acrossdevices after a user sees a Go-Tune ad, in order to determine performancemetrics like sign ups, visits to the Platform, and purchases. We undertakethese activities based on our legitimate interest in acquiring new customersand offering products we think you may be interested in. Any questions regardinghow these social media platform service provider processes your personal datashould be directed to such third party platform.

·        Aggregated Data – We may also share aggregated information (information about ourusers that we render in such a way that it no longer identifies or referencesan individual user) and other pseudonymised information for regulatorycompliance, industry and market analysis, demographic profiling, marketing andadvertising, and other business purposes.

·        API Integrations – Go-Tune has an open application-programming interface (API),which enables application developers to integrate elements of the Platform intoother apps. Some of these developers may be located outside of the EEA. Anyinformation you choose to make public on the Platform, including your publicprofile information and any public Sounds, may be accessible to thesedevelopers, subject to our API Terms of Use.Please bear this in mind when deciding what information to publish on yourprofile. For information on how to limit the information that is availablethrough the API, please see the Your Choices and Controls section below.

·        Third PartyApplications – If you choose to connect your Go-Tuneaccount to other apps or social networks such as Facebook and Google you may besharing certain information with these apps or networks. Content that you sharewith Facebook will appear on your timeline and in your Facebook friends’newsfeeds. In the case of connected apps, you will need to provide the appdeveloper with full access to your Go-Tune® account in order to upload anddownload Sounds, or comment on, favorite, or repost Sounds from within the app.This means sharing your public information, plus access to your private Sounds.Go-Tune is not responsible for these other apps or networks, so please makesure you only connect your account with apps or services that you trust. Forinformation on how to control the information that you share, and how todisconnect your account from these apps, please see the Your Choices andControls section below. If you do not want this information shared withFacebook or Google, please change your Go-Tune Settings on ourPlatform or in those networks.

·        Compliance with Laws – We may disclose your information to courts, law enforcementagencies, and governmental authorities (i) to comply with our legalobligations, (ii) to comply with legal process and to respond to claimsasserted against Go-Tune, (iii) to respond to verified requests relating to acriminal investigation or alleged or suspected illegal activity or any otheractivity that may expose us, you, or any other of our users to legal liability,(iv) to enforce and administer our Terms of Use and other agreements withusers, or (v) to protect the rights, property or personal safety of Go-Tune,its employees, and members of the public.

·        Protecting our Rights – We may disclose your information if we feel this is necessary inorder to protect or defend our legitimate rights and interests, or those of ourusers, employees, directors, officers, or shareholders, and/or to ensure thesafety and security of the Platform and/or the Go-Tune community.

·        To Our Affiliates – We may share your personal information within the Go-Tune Groupin order to provide the Platform and for any other purposes described in thisPrivacy Policy.

·        Change of Control – We may also share your personal data as part of a sale, merger orchange in control of Go-Tune, or in preparation for any of these events. Anyother entity that buys us or part of our business will have the right tocontinue to use your data, but only in the manner set out in this PrivacyPolicy unless you agree otherwise.

Cookies and Similar Technology

As further described in our Cookie Policy we use cookiesand similar technologies (e.g., pixels, local storage, and device identifiers)to recognize you and/or your device(s) on and off the Platform, and acrossdevices and devices. To the extent allowed by your settings or your device, wealso allow third parties to use cookies as described in our Cookie Policy inorder to track user behavior on and off the Platform in order to show you adsbased on your interests and preferences. You can control cookies through yourbrowser and other tools as described in the Cookie Policy.

Information Security

Go-Tune 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.

International Data Transfers

Go-Tune operates globally and may share your informationinternally within the Go-Tune Group, and third parties for the purposesdescribed in this Privacy Policy. Information collected within the EEA may, forexample, be transferred to countries outside of the EEA for the purposes asdescribed in this Privacy Policy. We utilize appropriate safeguards such asStandard Contractual Clauses approved by the European Commission, or anotherlegally approved mechanism, to ensure the lawful transfer of your personal dataoutside of the EEA.


Go-Tune 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 dataprotection@go-tune.net.

Your Choices and Controls

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 Go-TuneSettings. If you register an account, you maymanage the content and information you share when you use Go-Tune through youraccount Settings, including for thefeatures explained below. You are solely responsible for keeping your Settings up-to-date.

o   Email – You can adjust your Settings in the Notification tab to disableemail and desktop notifications (other than important service updates andessential notifications about the Platform or your account). All commercialemails and newsletters also allow you to unsubscribe at any time.

o   Analytics – To control whether we collect analytics and usage information,including through cookies and similar technologies, you can adjust yourSettings in the “Analytics” tab.

o   Marketing – If you do not want to receive personalized ads, offers or othermarketing messages for Go-Tune products or services, you can adjust yourSettings in the “Communications” tab.

o   Advertising – If you do not want Go-Tune to deliver “interest based” orpersonalized ads for third party products, you can adjust your Settings in the“Advertising” tab. Please note, however, that even if you opt out ofpersonalized ads, you may still see ads, but they will likely not be asrelevant or useful to you.

o   Content Sharing – It’s not possible to make your account entirely private. However,you do have the option to make all of your tracks, playlists and other uploadsprivate.

o   Third Party Apps – If you have chosen to connect your account to a third-partyapplication, like Facebook or Google, you can disable permission for the app byadjusting your Settings in the “Connections” tab.

o   Third Party Developers – Go-Tune has an open API, which allows third party developers tobuild some really cool apps as an extension of the Platform. If you wouldprefer that your Sounds are not made available to third party app developers,you can disable API access within the sound page for each of the Sounds thatyou upload. Click on the pencil icon in the waveform player, and uncheck the“Apps enabled” box at the bottom of the page. Please note that your publicprofile information will still be accessible, but this does not includeanything that is not publicly available on the Website.

o   Deleting Your Account – If you have an account and would like to delete it, you may do soby adjusting you Settings in the Account tab. If you delete your account, alldata associated with your account (except for backup copies), including theSounds that you have uploaded and the usage data associated with those Sounds,will be deleted and may not be recoverable. We therefore advise you to copy orbackup all content uploaded to your account before deletion. Even if you deleteyour Go-Tune account, it is possible that your information may still show up insome internet search results for a short while afterwards, if the search enginemaintains a temporary cache of web pages. Search engines’ caching processes areoutside of Go-Tune’s control and therefore we cannot be responsible for anyinformation that remains cached by search engines after that information hasbeen removed from the Platform. Please note that deleting any Go-Tune Apps, orany third party apps to which your Go-Tune account is connected, will notdelete your Go-Tune account. Similarly, if you delete a third party app that isconnected to your Go-Tune account over our API, this will not necessarilydelete all data about your Go-Tune activity from within that third party app.You will need to refer to the app provider’s terms of use and privacy policy tofind out how to delete data about your Go-Tune activity from that third partyapp.

·        Managing DeviceSettings

    • On your mobile device, enable the “Limit Ad Tracking” setting in your iOS phone’s settings, or the setting to “Opt out of Ads Personalization” in your Android phone’s settings. To opt-out of location tracking when using our Apps, you can use the settings of your device. You can disable mobile analytics and bug reporting through these same settings as well.

·        Managing BrowserSettings

    • To control cookies, you can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that if you choose to block cookies, doing so may impair the Platform or prevent certain elements of it from functioning.

·        Additional Choices andControls

Exercising Your EU Privacy Rights

·        Data Access andPortability

    • You may be entitled to request copies of your personal information held by us. While a lot of the personal information you provide to us can be accessed in your account Settings, you may also be entitled to request copies of personal information you have provided to us in machine-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 andDeletion

o   We generally retain data for aslong as your account is in existence or as needed to provide the Platform.However, specific retention times can vary based on the context of theprocessing we perform and on our legal obligations.

o   You have the right to ask us todelete all or some of the personal data we hold about you. If you have anaccount, you can also delete your account through the Settings at any time asdescribed below.

o   We may need to retain some ofyour personal data even after you have closed your account if reasonablynecessary to comply with our legal obligations, or where we have a legitimateinterest in doing so (e.g. to prevent fraud and abuse and maintain and enhancesecurity).

·        Objection to Processing

o   You may object to processingyour personal information in some circumstances (in particular, where we don’thave to process the information to meet a contractual or other legalrequirement, or where we are using the information for direct marketing).

o   If you object to suchprocessing Go-Tune will no longer process your personal information for thesepurposes unless we can demonstrate compelling legitimate grounds for suchprocessing or such processing is required for the establishment, exercise ordefense of legal claims or obligations.

o   Where your personal informationis processed for direct marketing purposes, you may, under certaincircumstances, ask Go-Tune to cease processing your data for these directmarketing purposes.

·        Restriction ofProcessing

    • Under certain circumstances, you may have the right to limit the ways in which we use your personal information.

·        Withdrawing Consent

    • Where you provide consent to the processing of your personal information by Go-Tune, you may withdraw your consent at any time by changing your account Settings or by sending a communication to Go-Tune specifying the specific consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

·        Lodging Complaints

Notice To California Users

Pursuant to the California Consumer Privacy Act of 2018(“CCPA”), we are providing the following details regarding the categories ofpersonal information about California residents we have collected or disclosedwithin the preceding 12 months.

We collected, including through service providers, anddisclosed the following categories of personal information:

·        Identifiers, such as your name,email address, birthday, profile name, as well as IP addresses, device IDs,mobile advertising IDs, anonymous Go-Tune user IDs, and other similaridentifiers;

·        Payment and financialinformation you provide when you purchase a Subscription or use certain featuresof the Platform;

·        Characteristics about you likeany gender information you choose to provide when you register an account onthe Platform;

·        Commercial information, such asSubscription and other purchase or transaction information related to your useof the Platform;

·        Internet or other networkactivity information, including browsing and search history and otherinformation about your use of the Platform, as well as information about howyou interact with ads for Go-Tune off the Platform;

·        Geolocation data derived fromIP addresses;

·        Audio, visual, and otherelectronic information, such as sound recordings, images, and comments;

·        Education information to verifyyour student status if you purchase a Go+ for Students Subscription; and

·        Inferences drawn from any ofthe personal information above to create a profile or segment about you so wecan provide you with personalized content and advertising.

We disclosed the categories of personal information above,including to our service providers and affiliates, for a range of operationalbusiness purposes, including:

·        To operate and maintain thePlatform and your account;

·        To market and sell our productsand services;

·        To provide personalized contentand ads;

·        To perform research anddevelopment;

·        To perform data and businessanalytics;

·        To detect and prevent fraud orabuse;

·        To perform identityverification;

·        To process Subscriptionpayments;

·        To process user inquiries andrequests;

·        To perform security and otherrisk testing;

·        To undertake quality assurancemeasures;

·        To maintain our systems andinfrastructure;

·        To comply with law or exerciseor defend legal claims;

·        To perform accounting, auditsand other internal functions; and

·        To otherwise operate ourbusiness and achieve our business objectives

For purposes of CCPA, the disclosure of personalinformation to our advertising partners to provide you with personalized adsmay constitute a “sale” in some instances. The personal information disclosedis limited to the following:

·        IP address and device ID

·        Age and gender you provide

·        General location information

·        Inferred music preferencesbased on your use of the Platform

We do not otherwise “sell” personal information.

Exercising Your California Privacy Rights

CCPA and other California law provides California residentswith the additional rights listed below. You may exercise any of the rightsdescribed in this section through the Help Center or by contacting us at dataprotection@go-tune.net. Pleasenote that we may ask you to verify your identity before taking further actionon your request.

·        Right to Access: You have the right to know and access what data we have collectedabout you over the past 12 months, including:

o   The categories of personalinformation we’ve collected about you;

o   The categories of sources fromwhich the personal information is collected;

o   The business or commercialpurpose for collecting your personal information;

o   The categories of personalinformation about you which we shared and/or sold;

o   The categories of third partieswe have shared or sold personal information to; and

o   The specific pieces of personalinformation we have collected about you.

·        Right to Delete: You have the right to request that we delete personal informationwe have collected from you (and direct our service providers to do the same).In some instances, however, we may decline to honor your request where anexception applies.

·        Right to Opt Out: You have the right to opt-out of any future “sale” of personalinformation about you by clicking here or by adjusting yourSettings in the “Advertising” tab.

·        Other Rights: You can request certain information about our disclosure ofpersonal information to third parties for their own direct marketing purposesduring the preceding calendar year. This request may be made once a year. Youalso have the right not to be discriminated against for exercising any of therights listed above.

Contact Information

If you have questions or complaints about this PrivacyPolicy or our practices, please contact our Data Protection Officer by email atdataprotection@go-tune.net orwrite to us at Go-Tune Limited, Rheinsberger Str. 76/77 10115 Berlin, GermanyAttention: Data Protection Officer.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time in oursole discretion. If we make changes to this Privacy Policy, we will post therevised Privacy Policy on the Platform and update the “Last Amended” datebelow. Please be sure to periodically check this page to ensure that you areaware of any changes to this Privacy Policy. Any material changes to thisPrivacy Policy will be communicated to registered users by a notification totheir account and/or by posting a notice of the change on the Website. Yourcontinued access to or use of the Platform after the effective date of suchchanges will be subject to the revised Privacy Policy.

Last Amended: 06 January 2020


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