Re3 Privacy Policy

Effective as of 26 December 2022

1. About this Policy

2. Your personal data rights and controls

3. Personal data we collect about you

4. Our purpose for using your personal data

5. Sharing your personal data

6. Data retention

7. Keeping your personal data safe

8. Changes to this Policy

9. How to contact us

1. About this Policy

This Privacy Policy describes how we process your personal data at Re3 Music Inc. From now on, we'll call it the 'Policy'.

It applies to your use of:

  • all Re3 services as a user. For example this includes:
  • your use of Re3 for minting new sounds
  • the infrastructure required to provide our services
  • connection of your Re3 account with another application
  • both our free or paid service options (each a 'Service Option')
  • other Re3 services which include a link to this Policy. These include Re3 websites and Customer Service

From now on, we'll collectively call these the 'Re3 Service'.

From time to time, we may develop new or offer additional services. They'll also be subject to this Policy, unless stated otherwise when we introduce them.

This Policy is not...

  • the Re3 Terms of Use, which is a separate document. The Terms of Use outline the legal contract between you and Re3 for using the Re3 Service. It also describes the rules of Re3 and your user rights
  • about your use of other Re3 services which have their own privacy policy

2. Your personal data rights and controls

Many privacy laws give rights to individuals over their personal data. These laws include the General Data Protection Regulation, or 'GDPR'.

Some rights only apply when Re3 uses a certain 'legal basis' to process your data. We explain each legal basis, and when Re3 uses each one, in Section 4 'Our purpose for using your personal data'.

The table below explains:

  • your rights
  • circumstances when they apply (such as the legal basis required)
  • how to use them

It’s your right to...

How?

Be informed

Be informed of the personal data we process about you and how we process it.

We inform you:

  • through this Policy
  • through information provided to you as you use the Re3 Service
  • by answering your specific questions and requests when you contact us

Access

Request access to the personal data we process about you.

To request a copy of your personal data from Re3, either:

When you download your data you will receive the information about your data that Re3 has to provide under Article 15 of the GDPR. If you would like more information about how we process your personal data, you can contact us.

Rectification

Request that we amend or update your personal data where it’s inaccurate or incomplete.

You can edit your User Data under Profile’ in your account or by contacting us.

Erasure

Request that we erase certain of your personal data.

For example, you can ask us to erase personal data:

  • that we no longer need for the purpose it was collected for
  • that we process based on the legal basis of consent, and you withdraw your consent
  • when you object (see section ‘Object’ below) and
  • you make a justified objection, or
  • you object to direct marketing

There are situations where Re3 is unable to delete your data, for example when:

  • it’s still necessary to process the data for the purpose we collected it for
  • The data is stored on a Blockchain
  • Re3’s interest in using the data overrides your interest in having it deleted. For example, where we need the data to protect our services from fraud
  • Re3 has a legal obligation to keep the data, or
  • Re3 needs the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account

There are several ways you can erase personal data from Re3:

Restriction

Request that we stop processing all or some of your personal data.

You can do this if:

  • your personal data is inaccurate
  • our processing is unlawful
  • we do not need your information for a specific purpose, or
  • you object to our processing and we are assessing your objection request. See section ‘Object’ below

You can request that we stop this processing temporarily or permanently.

You can exercise your right to restriction by contacting us.

Object

Object to us processing your personal data.

You can do this if:

  • Re3 is processing your personal data on the legal basis of legitimate interests, or

To exercise your right to object, you can:

Data portability

Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.

You can request us to transmit your data when we are processing your personal data on the legal bases of consent or performance of contract. However Re3 will try to honour any request to the extent possible.

For information about how to exercise the right to portability, see ‘Access’ above.

Not be subject to automated decision making

Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

Re3 does not carry out this type of automated decision making in the Re3 Service.

Withdrawal of consent

Withdraw your consent to us collecting or using your personal data.

You can do this if Re3 is processing your personal data on the legal basis of consent.

To withdraw your consent, you can:

3. Personal data we collect about you

These tables set out the categories of personal data we collect from you.

Collected when you sign up for the Re3 Service or when you update your account

Category

Description

User Data

Personal data that we need to create your Re3 account and that enables you to use the Re3 Service.

The type of data collected and used depends on the type of Service Option you have. It also depends on how you create your account, the country you are in, and if you use third party services to sign in. This may include your:

  • profile name
  • email address
  • password
  • phone number
  • date of birth
  • gender
  • street address (see further details below)
  • country

We receive some of this data from you e.g. from the sign up form or account page.

We also collect some of this data from your browser e.g. country or region.

Street Address Data

We may ask for and process your street address for the following reasons:

  • to check eligibility for a Service Option
  • to deliver notices which are required by law
  • to deliver support options
  • for billing and tax administration
  • to deliver physical goods or gifts which you have requested

In some cases, we may use a third party application to help you verify your address, such as Google Maps.

Collected through your use of the Re3 Service

Categories

Description

Usage Data

Personal data collected and processed about you when you’re accessing or using the Re3 Service.

There are a few types of information this includes, listed in the following sections.

Information about how you use Re3

Examples include:

  • information about your Re3 Service Option
  • your actions with the Re3 Service (including date and time), such as:
  • search queries
  • downloads history
  • Sounds you minted
  • browsing history
  • account settings
  • interactions with other Re3 users
  • your use of third party services, devices and applications in connection with the Re3 Service
  • inferences (i.e., our understanding) of your interests and preferences based on your usage of the Re3 Service
  • content you provide when participating in Re3 promotions, such as contests or sweepstakes
  • content you post to any part of the Re3 Service. For example: images, audio, text, titles, descriptions, communications, and other types of content

Your technical data

Examples include:

  • URL information
  • online identifiers such email address and IP addresses
  • information about the devices you use such as:
  • network connection type (e.g. wifi, 4G, LTE, Bluetooth)
  • network and device performance
  • browser type
  • language
  • information enabling digital rights management
  • operating system

Your general (non-precise) location

Your general location includes country, region or state. We may learn this from technical data (e.g. your IP address, language setting of your device) or payment currency.

We need this to:

  • meet geographic requirements in our agreements with the owners of content on the Re3 Service
  • deliver content and advertising that’s relevant to you

Additional data you may choose to give us

Categories

Description

Payment and Purchase Data

If you make any purchases from Re3 or sign up for a paid Service Option or a trial, we will need to process your payment data.

The exact personal data collected and used will vary depending on the payment method. It will include information such as:

  • name
  • date of birth
  • payment method type (e.g. credit or debit card)
  • if using a debit or credit card, the card type, expiration date, and certain digits of your card number Note: For security, we never store your full card number
  • ZIP/postal code
  • mobile phone number
  • details of your purchase and payment history

Survey and Research Data

When you respond to a survey or take part in user research, we collect and use the personal data you provide.

We receive some of the data mentioned above from third parties. The below table describes the categories of those third parties.

Third party sources that we receive your data from

Categories of third parties

Description

Data categories

Authentication partners

If you register for or log into the Re3 Service using another service, that service will send your information to us. This information helps create your account with us.

User Data

Third party applications, services and devices you connect to your Re3 account

If you connect your Re3 account to a third party application, service or device, we may collect and use information from them. This collection is to make the integration possible.

These third party apps, services or devices may include:

  • social media
  • services or platforms such as voice assistants or content platforms

User Data

Usage Data

Technical service partners

We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g., country or region, city, state).

This makes it possible for Re3 to provide the Re3 Service, content, and features.

We also work with security service providers who help us protect user accounts.

User Data

Usage Data

Payment partners and Merchants

If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners.

This allows us to:

  • send you invoices
  • process your payment
  • give you what you’ve purchased

If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to a creator’s merchandise store on a third party platform or to a third party ticketing website.

Receiving this data allows us to:

  • calculate any commissions owed to us
  • analyse the effectiveness of our partnership with these merchant partners
  • understand your interests

Payment and Purchase Data

Advertising and marketing partners

We receive inferences from certain advertising or marketing partners. These inferences are the partners’ understanding of your interests and preferences.

This allows us to deliver more relevant ads and marketing.

Usage Data

Acquired companies

We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.

User Data

Usage Data

4. Our purpose for using your personal data

The table below sets out:

  • our purpose for processing your personal data
  • our legal justifications (each called a 'legal basis') under data protection law, for each purpose
  • categories of personal data which we use for each purpose. See more about these categories in Section 3 'Personal data we collect about you'

Here is a general explanation of each 'legal basis' to help you understand the table:

  • Performance of a Contract: When it's necessary for Re3 (or a third party) to process your personal data to:
  • comply with obligations under a contract with you. This includes Re3's obligations under the Terms of Use to provide the Re3 Service to you, or
  • verify information before a new contract with you begins.
  • Legitimate Interest: When Re3 or a third party has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Re3 users. For example, using your Usage Data to improve the Re3 Service for all users.
  • Consent: When Re3 asks you to actively indicate your agreement to Re3's use of your personal data for a certain purpose.
  • Compliance with Legal Obligations: When Re3 must process your personal data to comply with a law.

Purpose for processing your data

Legal basis that permits the purpose

Categories of personal data used for the purpose

To provide the Re3 Service in accordance with our contract with you. See Section 1 ‘About this Policy’ for what we mean by the Re3 Service.

For example, when we use your personal data to:

  • set up an account for you
  • personalise your account, or

Performance of a Contract

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data

To provide further parts of the Re3 Service.

For example, when we use your personal data to enable you to share a link to Re3 content with someone else.

Legitimate Interest

Our legitimate interests here include:

  • keeping the Re3 Service running and functional
  • allowing users to access and use the Re3 Service
  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data

To provide certain additional voluntary features of the Re3 Service. When this is the case, we will clearly ask for your consent.

Consent

  • User Data
  • Usage Data
  • Survey and Research Data
  • Payment and Purchase Data

To understand, diagnose, troubleshoot, and fix issues with the Re3 Service.

For example, we use your personal data to:

  • respond to your messages when you contact us
  • spot unusual data or behaviour in our logs which might indicate a bug or other issue, or
  • check and verify accounts to find and prevent unauthorised users

Performance of a Contract

  • User Data
  • Usage Data

To evaluate and develop new features, technologies, and improvements to the Re3 Service.

For example:

  • we analyse how our users react to a particular new feature and see whether we should make any changes

Legitimate Interest

Our legitimate interests here include developing and improving products and features for our users.

  • User Data
  • Usage Data
  • Voice Data
  • Survey and Research Data

For marketing or advertising where the law requires us to collect your consent.

For example, when we use cookies to understand your interests or the law requires consent for email marketing.

Consent

  • User Data
  • Usage Data
  • Survey and Research Data

To comply with a legal obligation that we are subject to.

This might be:

  • an obligation under the law of the country / region you are in
  • EU law that applies to us

Compliance with legal obligations

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

To comply with a request from law enforcement, courts, or other competent authorities.

Compliance with legal obligations, and legitimate interest Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

To fulfill contractual obligations with third parties.

Legitimate Interest

Our legitimate interests here include:

  • maintaining our relationships with artists so that we can provide the Re3 Service
  • maintaining our relationships with other third parties for the same reason
  • User Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data

To take appropriate action with reports of intellectual property infringement and inappropriate content.

Legitimate Interest

Our legitimate interests here include protecting intellectual property and original content.

  • User Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data

To establish, exercise, or defend legal claims.

For example, if we are involved in litigation, we need to provide information to our lawyers in relation to that legal case.

Legitimate Interest

Our legitimate interests here include:

  • seeking legal advice
  • protecting ourselves, our users or others in legal proceedings
  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

To conduct business planning, reporting, and forecasting.

For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in.

Legitimate Interest

Our legitimate interests here include researching and planning so that we can keep running our business successfully.

  • User Data
  • Usage Data
  • Payment and Purchase Data

To process your payment.

For example, when we use your personal data to let you purchase a Re3 subscription.

Performance of a Contract, and consent

  • User Data
  • Payment and Purchase Data
  • Street Address Data

To detect and prevent fraud.

For example, when we analyse Usage Data to check for fraudulent use of the Re3 Service.

Legitimate Interest

Our legitimate interests here include protecting the Re3 Service and our users against fraud and other illegal activity.

  • User Data
  • Street Address Data
  • Usage Data
  • Payment and Purchase Data

To conduct research and surveys.

For example, when we contact our users to ask for your feedback.

Legitimate Interest

Our legitimate interests here include to understand more about how users think about and use the Re3 Service.

  • User Data
  • Usage Data
  • Voice Data
  • Survey and Research Data

In jurisdictions where legitimate interest is not recognised as a legal basis, we rely on contractual necessity or consent.

5. Sharing your personal data

This section sets out who receives personal data which is collected or generated through your use of the Re3 Service.

Publicly available information

The following personal data will always be publicly available on the Re3 Service :

  • your profile name
  • your profile photo
  • your public sounds
  • your public collections
  • other content you post on the Re3 Service, and any associated titles, descriptions and images

You or another user can share certain information on third party services, like social media or messaging platforms. This includes:

  • your profile
  • any content you post on Re3 and details about that content
  • your public sounds
  • your public collections

When this sharing occurs, the third party service may store a copy of it to support their features.

Categories of recipients

Categories of data you can choose to share

Reason for sharing

Third party applications, services and devices you connect to your Re3 account

  • User Data
  • Usage Data

To connect your Re3 account, or so that you can use the Re3 Service in connection with third party applications, services or devices.

Examples of such third party applications, services and devices include:

  • social media applications
  • speaker devices
  • televisions
  • automotive platforms
  • voice assistants

Other Re3 users

  • User Data
  • Usage Data
  • Voice Data

To share information about your use of the Re3 Service with other Re3 users. These could include your followers on Re3.

Information we may share

See this table for details of who we share to and why.

Categories of recipients

Categories of data

Reason for sharing

Service providers

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

So they can provide their services to Re3.

These service providers include those we hire to:

  • give customer support
  • operate the technical infrastructure we need to provide the Re3 Service
  • assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)
  • help market Re3’s (and our partners’) products, services, events and promotions

Payment partners

  • User Data
  • Payment and Purchase Data

So they can process your payments, and for anti-fraud purposes.

Blockchain partners

  • User Data

So they can help us deliver the blockchain functionality as part of the Re3 Service

Marketing Partners

  • User Data
  • Usage Data

To promote Re3 with our partners. We share certain User Data and Usage Data with these partners where necessary to:

  • to promote Re3 in media and advertising published on other online services
  • help us and our partners to measure the effectiveness of Re3 promotions

Examples of partners include:

  • marketing or sponsorship partners
  • websites and mobile apps who sell us advertising space on their services

Our partners may also combine the personal data we share with them with other data they collect about you, e.g. your use of their services. We and our partners may use this information to present you with offers, or other marketing that we think you’ll find relevant.

Academic researchers

  • User Data
  • Usage Data

For activities such as statistical analysis and academic study, but only in a pseudonymised format.

Law enforcement and other authorities, or other parties to litigation

  • User Data
  • Usage Data

When we believe in good faith it’s necessary for us to do so, for example:

  • to comply with a legal obligation
  • to respond to a valid legal process (such as a search warrant, court order, or subpoena)
  • for our own or a third party’s justifiable interest, relating to:
  • national security
  • law enforcement
  • litigation (a court case)
  • criminal investigation
  • protecting someone’s safety
  • preventing death or imminent bodily harm

Purchasers of our business

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

If we were to sell or negotiate to sell our business to a buyer or possible buyer.

In this case, we may transfer your personal data to a successor or affiliate as part of that transaction.

6. Data retention

We keep your personal data only as long as necessary to provide you with the Re3 Service and for Re3's legitimate and essential business purposes, such as:

  • maintaining the performance of the Re3 Service
  • making data-driven business decisions about new features and offerings
  • complying with our legal obligations
  • resolving disputes

Here are some of the categories of our retention periods:

  • Data retained until you remove it
  • Data that’s stored on the Blockchain (via partner) will be retained as long as the specific chain is maintained and accessible

It's your right to request that we delete certain of your personal data.

  • Data that expires after a specific period of time

We have set certain retention periods so that some data expires after a specific period of time.

  • Data retained until your Re3 account is deleted
  • Data that’s stored on the Blockchain (via partner) will be retained as long as the specific chain is maintained and accessible, even after your Re3 account is deleted

We keep some data until your Re3 account is deleted. When your Re3 account is deleted, your data is deleted or anonymised.

  • Data retained for extended time periods for limited purposes

After your account is deleted, we keep some data for a longer time period but for very limited purposes.

Criteria used to determine the retention periods include:

  • What is the appropriate retention period to carry out our purpose? Our systems are designed to automatically 'age out' data based on a defined retention period. We choose the retention period based on its legitimate business purpose.
  • Do we need to keep data to ensure the service that users expect? We keep personal data for an appropriate period to deliver the service to our users over time.
  • Are users able to update or delete the data themselves? Where users are able to see and update the personal data themselves, we keep the information for as long as the user chooses.
  • Do we need to keep the data to uphold our rules and keep our service safe? We may keep data that has been removed from the Re3 Service for a limited period of time. This is:
  • to help ensure user safety
  • to protect against harmful content on our platform
  • to take action with reports of intellectual property infringement

This also helps us investigate potential breaches of our User Guidelines and Platform Rules.

  • Is Re3 subject to a legal or contractual obligation to keep or delete the data? Examples include mandatory data retention laws, government orders to preserve data relevant to an investigation or data kept for the purposes of litigation. Conversely, we will remove unlawful content if the law requires us to do so.

7. Keeping your personal data safe

We're committed to protecting our users' personal data. We put in place appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

We have put various safeguards in place to guard against unauthorised access and unnecessary retention of personal data in our systems. These include pseudonymisation, encryption, access, and retention policies.

To protect your user account, we encourage you to:

  • use a strong password which you only use for your Re3 account
  • never share your password with anyone
  • limit access to your computer and browser
  • log out once you have finished using the Re3 Service on a shared device

If other individuals have access to your Re3 account, then they can access personal data, controls and the Re3 Service available in your account. For example, you might have allowed someone to use your account on a shared device.

It's your responsibility to only allow individuals to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your Re3 account may impact your personalised recommendations and be included in your data download.

8. Changes to this Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Re3 Service or send you an email or device notification.

9. How to contact us

For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:

Re3 Music Inc. is the data controller of personal data processed under this Policy.

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