We respect your privacy, and are strongly committed to making our data processing practices more transparent and fair. This Policy concerns personal data collected, received or used via our website referring to this Policy (the "Website"), via our products and services (the “Platform”), or via other data sources as described below. The Platform together with our Website shall be referred to as the "Services".
You are not legally required to provide us with any Personal Data (defined below), but please be aware that without it we may not be able to provide you with the full range of Services or with the best user experience when using our Services.
1. Data Collection
We collect Personal Data of yours. Such data is typically collected and generated through your interaction with our Services, through automatic means, directly from you or through third parties. Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“):
- Data automatically collected or generated: When you visit our Website, interact with us or use our Services, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third-party service providers (as detailed in Section 4 below).
Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses (for Visitors), device identifier, browser, broad geographical information, system and software details, click-stream and usage logs, unique identifiers and similar data and information concerning log-in attempts, usage and use preferences regarding our Services. We mainly use this data to gain a better understanding on how you typically use and interact with our Services; how we could improve your user experience; to optimize our product; and to optimize the overall performance of our Services.
- Data received from you: such Personal Data includes any data or information you may provide which is identifiable to you (either in itself or due to the manner in which it was provided or the Data with which it was provided or generated), such as your name, a photo of yourself, contact details (such as e-mail and phone number), account setup and login details (such as usernames and hashed passwords for using our Platforms), as well as any free-form text or documentation you may choose to provide us. Such Personal Data may also include any content created or shared by you through the Services, as well as any messaging or other communication performed via our Services. Also, if you choose to sync or import information to the Service (such as contacts in your phone address book), we may use this information to enhance your experience in various ways, including, but not limited to, notifying you a person you know uses the Service, and notifying other users you know that you joined our Service.
- Data provided by third parties: We may receive your Personal Data from other sources. For example, when you create your account and/or authenticate with a third-party service (e.g., Google, Facebook, LinkedIn etc.’) you may allow us to receive information associated with that third-party account, such as your lists of friends, connections and/or followers. We may also receive information from third-party service providers to help us analyze how Visitors use the Website and to enhance user experience while visiting the Website.
Please note: If you are providing us with your friends contact details or other information you must first get their consent.
2. Data Uses
We use Personal Data as necessary for the performance of our Services; to comply with applicable law; as necessary for the performance of our contracts and agreements; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, advertising and sales practices, providing customer service and technical support, and protecting and securing our Visitors, Customers, Users, ourselves and our Services.
We do not sell your personal information.
Specifically, we use Personal Data for the following purposes:
- To facilitate, operate, and provide our Services;
- To verify the identity of our Users, and to allow them access to our Services;
- To further develop, customize and improve our Services, and to offer you a better experience, based on common or personal preferences, experiences and difficulties;
- To provide Users and Visitors with assistance and technical support, and to diagnose or fix technical problems reported by Users and Visitors;
- To facilitate and improve our marketing, advertising and sales practices, and make them more effective;
- To contact our Visitors and Users with general or personalized service-related notices, informational materials and promotional messages, in accordance with Section 5 below;
- To facilitate, organize, sponsor and offer certain events and promotions;
- To monitor aggregate metrics and create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we, our Customers, Users or business partners may use at our discretion, including to provide and improve our respective services;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of error, fraud or any illegal or prohibited activity;
- To act as permitted by, and to comply with, any legal or regulatory requirements.
3. Data Location and Retention
Data Location: Your Personal Data is maintained, processed and stored by us and our authorized Service Providers (defined below) in the Google servers in the US. We may also retain your Personal Data in other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required by law.
Data Retention: We may retain Users Personal Data for as long as their account with us is active. We shall not retain Users information after their account has been deleted, subject to the following exception: we will retain Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use). We may retain Visitor Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services, as well as for the reasons mentioned above.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at [firstname.lastname@example.org].
Please note that the deletion process may take up to 90 days. Some Personal Data may not be deleted from our servers but rather be anonymized or aggregated without reasonable ability to reverse the process or extract your Personal Information.
4. Data Sharing
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data in response to a legal request, such as a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We engage with a number of selected third-party companies and individuals to perform services complementary to our own. Such service providers may include Third Party service providers, hosting and server services, communications and content delivery networks, audio applications and infrastructure, online video streaming providers, data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail newsletter, distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, support and customer relation management systems, event sponsors and co-hosts, web analytics services and our legal and financial advisors (collectively, “Service Providers“).
Such Service Providers may receive or otherwise have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services and business, and may only use it for such limited purposes as determined in our agreements with them.
Other Users: certain information may be visible to other users of the Service. For example, other users may have access to any information you uploaded as part of your account profile (e.g., photo, information included in your public bio).
Protecting Rights and Safety: We may share your Personal Data with others, if we believe in good faith that this will help protect the rights, property or personal safety of Groove, any of our Visitors, Users or any members of the general public.
For the avoidance of doubt, we may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. Additionally, we may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
- Cookies and Tracking Technologies
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types. We may use these types of cookies to facilitate the use of the Website’s features and tools.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Website.
We also use analytics tools, including Google Analytics. These tools help us understand users’ behaviour on our Website, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service providers is available at www.google.com/policies/privacy/partners/. Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service maintenance or changes, password retrieval notices, etc. You will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may send you notifications concerning new features, offerings, events, and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contacts means available to us (e.g. mobile phone, e-mail), through the Services, or through our marketing campaigns on any other websites or platforms.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to email@example.com, or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions contained in the promotional communications you receive.
7. Data Security
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above. Therefore, you should take special care in deciding what information you send to us via the Internet.
In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third-party websites. Finally, we cannot control the actions of other Users and Visitors, who may seek to use third party platforms or devices to record, store, or share content or communication without other Users' prior consent. Please keep this in mind when using the Services.
8. Data Subject Rights
If you wish to request access to, or to rectify or erase your Personal Data held with us, or to restrict or object to such Personal Data’s processing – please send us an e-mail to firstname.lastname@example.org.
Please note that once you contact us, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Your request along with such additional data will be then retained by us for legal purposes (e.g. so we have proof of the identity of the person submitting the request), in accordance with Section 3 above.
9. Additional Notices
Children’s Privacy: Our Services are not intended for use by children under the age of 18. We do not knowingly collect Personal Data from minors under the age of 18 and do not wish to do so. In the event that it comes to our knowledge that a minor is using the Services, we will prohibit and block such user from accessing the Services (to the extent reasonably possible) and will make all efforts to promptly delete any Personal Data stored with us with regard to such user.
Effective Date: March 24th, 2021