Privacy Policy

Effective Date: January 23, 2021

This privacy policy explains how BeatsUnion Music Inc. (“BeatsUnion”, “we“, “us”, “our”) collects, uses and discloses personal information of its users (“you”, “your”) through our group of websites, which currently include BeatsUnion.com and others where this policy appears (individually and collectively the “Platform“). BeatsUnion Music Inc. is a Canadian corporation.

Each and every time you access the Platform, including visiting or registering at any Platform, or by engaging with us as a content supplier, you acknowledge that you have read, understood and agreed to be bound by this policy as it may be amended from time to time. If you do not agree to these terms, please do not visit our Platform and do not register, make any purchases or provide us with any personal information about you.

Purpose

This policy applies to you if you interact with our Platform in any way, including if you visit the Platform, register as a user or make purchases on the Platform. We reserve the right to modify this policy at any time. If we do, we will post the updated privacy policy on the Platform. Please check this page regularly for any updates. Our policy should be read together with our Terms of Use. If there is any conflict between this policy and the Terms of Use, the Terms of Use takes precedence.

Collection of Personal Information

Personal information means any information about an identifiable individual or an individual whose identity may be inferred or determined from the information, whether alone or combined with other information. This may include information such as age, name, ID numbers, marital status, opinions, evaluations, and comments. Personal information includes personal health information such as information about medications, vaccinations and allergies.

We collect personal information from you when, for example, you register as a user, make a purchase on our Platform, sell content through our Platform. Below is a chart summarizing the personal information we collect, the purpose for which we collect it, and the source of collection. We also describe our legal basis for processing. We aim to be as complete and transparent about our privacy practices as possible, however, this chart is not exhaustive.

CATEGORY	DESCRIPTION	PURPOSE OF COLLECTION	SOURCE OF COLLECTION	LEGAL BASIS FOR PROCESSING
Landing Page	Full name Artist Name Email address Country Music platforms used. Personal Website Music sample Artistic vision information	Submit an application to possibly join BeatsUnion. Artist vetting and verification. Survey Artist usage of other platform	BeatsUnion	Consent Our legitimate interest to contact you about our Services
Profile Data	Full name Age Email address Address Phone number(s) Gender Musical preferences Purchase, listening and concert-going habits	Create your account Backfacing secured portal information. Verify your identity Personalize your experience Communicate with you, including by email Better understand the demographics of our users and user preferences Improve our recommendation engine Automation of payouts	BeatsUnion	Consent Our legitimate interest to contact you about our Services and your account information.
Digital Persona (Alias)	Alias (Name) Biography Photograph Social media links Genre	Information to be shared with the public through your store(s) A reflection of the creative project that is the digital persona	BeatsUnion	Consent Our legitimate interest to improve our services
Account Activity	Feedback you provide Purchase/Sell history Interactions with the Platform Messages you send to other users	Personalize and enhance your experience Improve our service offerings Inform our artists about the popularity of their works	BeatsUnion Google Analytics Third parties including automated sources such as cookies	Consent Perform our contract with you Our legitimate interest to improve our services
Payment Data (for artists on the Platform)	Name Credit or debit card number, expiration date Billing address and contact information including email and phone number Banking information Social Insurance Number Tax ID number	Automate and Distribute payments to you as an artist	BeatsUnion RBC Express Stripe Paypal	Consent Perform our contract with you
Payment Data (for guests of the Platform)	Name Email address* Credit or debit card number, expiration date	Process your purchase	You	Consent Perform a contract with you
Browsing Data	Usage data Websites you interact with before or after using the Platform Music or other content that you listen to or access while on the Platform	Enhance your browsing experience on our Platform Web analytics purposes Improve the content and design of the website and our service offerings	Google Analytics Third parties including automated sources such as cookies	Our legitimate interest to improve our services, troubleshoot software bugs and operational problems, deliver relevant content to you
Technical Data	Internet Protocol (IP) address Device ID or MAC address Information about the manufacturer, model, settings, and operating system of your device Application version	Provide analytics about usage of the site (aggregated data only)	Third parties including automated sources such as cookies	Our legitimate interest to improve our services and provide appropriate support services to you Our legitimate interest to provide administration and IT services, network security, and to maintain the technical operations of our services
Survey and Opinion Data	Survey or content responses User-generated content including likes, comments on or feedback to individual artists Feedback on bugs and suggested features.	Improve our recommendation system to suggest content that is relevant to your preferences Improve the performance of the Platform Develop new features	BeatsUnion	Consent

*PayPal, a third party payment provider, handles all payment transactions on our behalf and collects and stores your data. We only store your PayPal email address. For further information regarding PayPal please read their Terms of Service here.

Use of Personal Information

To supplement the table above, we may use your personal information for various purposes, including to:

process your registration, purchases and payments;
maintain your account on an ongoing basis;
make payments to you (if you are a Music supplier);
notify you of contest results and other related communications, such as to deliver prizes, if you enter any contests, promotions, giveaways or other optional programs;
communicate with you about your artist/producer profile page, if you maintain one;
enhance your experience with the Platform and our service, such as sending you e-mails and otherwise providing you with other information, content and material we think you may be interested in;
display content and ads according to your prior browsing history, preferences and location;
fulfill your purchase orders;
provide customer service, technical support and respond to your questions and comments;
communicate with you about your account or about contests, surveys, or other promotions through the Platform;
prevent or take action against activities that are, or may be, in breach of our Terms of Use or applicable law and to otherwise track your compliance with the Platform’ rules and regulations;
analyze usage of our Platform and browsing behavioural patterns to inform better business decisions for the Platform and our users;
maintain a history of chat and email activity;
evaluate the effectiveness and efficiency of certain communications;
evaluate and enhance our Platform and service, e.g. analyze the traffic and usage of our Site, participation rates of our various promotions, offerings, e-mails, and other programs, and the popularity of our content, artists, and participating suppliers;
for product development purposes, such as recommending related labels, artists, products and services our users may be interested in;
for technical purposes, such as monitoring the functionality of our servers and e-mail systems, and ensuring technical security of our Platform;
for advertising, contest sponsorship, promotional and marketing, and other advertising related issues. We will seek your prior consent before sharing your information for marketing and advertising purposes;
to comply with contractual or other legal obligations.

De-identified or Aggregated Data

We may collect, use and share de-identified and aggregated data generated from users who interact with our Service, for research and analytical purposes and/or to improve user experience on our Platform.

De-identified or aggregated data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this policy.

Disclosure of Personal information

We may share your personal information with third parties as described below:

Business Partners and Affiliates: We may share information with affiliated companies and business partners.

Business Transaction: If we are involved in a business transaction such as a merger, asset sale or other business reorganization, your personal information will be one of the assets that will be transferred to our successors-in-interest.

Service Providers: We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the Platform, database storage and management, e-mail management, storage marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the Platform. We will only share your personal information with these third parties to the extent necessary to enable them to perform these services for us and for you.

When we do share your information with our service providers, we do so on the basis of a contractual arrangement that limits their use of personal information for only those purposes for which it was transferred to them by us, on our instruction, and to be destroyed or returned at the end of our engagement with the service provider.

We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the Platform in a shared location, and type of the device used to visit the Platform.

Required by Law: We may disclose your personal information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent or otherwise legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

Publicly Visible Areas of the Platform: Any information or material you may enter in the publicly viewable portion of the Platform, such as on an artist/producer profile page, an online forum or comment section, chat room, or bulletin board, will be readily accessible to the general public.

Cookies and Other Related Technologies

We use cookies to collect Platform usage data and to improve your experience on the Platform and our services generally. A cookie is a small data file transferred to your computer for access on future visits to the Platform, which can tell us that you (or someone using the same computer or IP address) visited our Platform in the past, what clips you have listened to, among other such information. You can stop accepting cookies by setting your Internet browser accordingly, but this will likely result in our not recognizing you or your preferences on future visits, so you may have to re-enter certain information.

The Platform and emails from us may contain electronic images known as “web beacons”. These are files that allow us to count visitors to our Platform, to tell if an ad has been viewed or if an e-mail has been opened or forwarded, or to serve particular content or services. Web beacons collect limited non-personal information, including beacon number, time and date of a page or e-mail view, and a description of the page on which the web beacon resides, all of which we may store and use. Disabling cookies may prevent some beacons’ activity, but generally the beacons will operate if you visit the Platform or open e-mails from us.

Security Safeguards

We employ appropriate and reasonable administrative, physical, and technical security measures to safeguard your information from unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. All credit card transactions occur in a secure area of the Site using Secure Sockets Layer (SSL) software to process orders, which encrypts the information you input on the Site. For the storage and processing of credit card information, we engage a third party, PayPal, certified as compliant with the Payment Card Industry Data Security Standard (PCI DSS).

In addition, all personal user information is stored behind a firewall with limited administrative access. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable, therefore we cannot warrant the security of any information you transmit to us, and you do so at your own risk.

We work with you to keep your personal information secure. You are responsible for safeguarding your username and password in accordance with the Terms of Use. We encourage you to take active measures to protect your account, including by choosing a unique username and password, as well as a strong password on your computer and/or mobile device.

We also encourage you not to enter in the publicly viewable areas of your profile on the Platform any personal information (e.g., your name, e-mail or postal address, credit card details) or other information or materials that you would not wish to be publicly available. This also applies to any communications you may have directly with other users of the Platform.

Emails that you receive from us will include specific instructions on how to unsubscribe from receiving certain communications. We will never send email messages to you that request confidential information such as passwords, credit card numbers, or social insurance numbers. Do not act on any such emails as you may compromise your personal information by replying or by following links to a fraudulent website [NTD: Please verify if this fits with your current practices].

If you have a security related concern, please contact us at privacy@beatsunion.com. We will work closely with you to ensure a quick and personal response to your concerns.

Children’s Information

Our Platform is not directed at or marketed to persons under 16 years of age. Persons under the age of 16 are not allowed to register with or use the Service or provide personal information. Any personal information that is provided during the registration process that does not result in an active account is automatically deleted from our servers.

Links to Other Websites

There are third-party links on our Platform that will send you to third party websites, the contents of which we have no control over. Clicking on a third-party link is done at your own discretion and risk. We strongly advise you to review the privacy policy of every third-party website you visit. By clicking on a third-party link, you understand and agree that you will be solely responsible for any loss or damage that may result from such activities.

International Data Transfers

BeatsUnion engages third party data processors to fulfill specific tasks on our behalf. These tasks may include customer service support, technical support, or administrative tasks, among others, that may require the transfer of your personal information to our data processors outside of your jurisdiction. Whenever we engage a data processor, we enter into a contractual arrangement with that limits their use of the data and that requires them to return or securely delete the data as soon as our engagement is over. We do not permit our data processors to retain or use personal information we transfer to them for any reason other than as instructed in our contract with them.

We store all data collected through BeatsUnion in data centres located in [NTD: Please complete]. Our service providers may be located outside of Canada. If our service providers are located outside Canada, your personal information may be transferred to a jurisdiction with privacy laws that are less protective than the ones in Canada or in your home country. You understand and acknowledge this data transfer to our service providers.

By using our Service, you consent to the transfer of your personal information outside of your jurisdiction for the purpose of storing your personal information or processing it. We may transfer your personal information to the following countries and using the following safeguards outside the European Economic Area (“EEA”) if your personal information is transferred to outside the EEA:

Canada – European Commission Adequacy Decision
United States – Model Contract Clauses

Where your personal information is transferred outside the EEA, we will take steps reasonably necessary to ensure that your personal information is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism if applicable, Model Contractual Clauses approved by the European Commission or other approved or legal method, and that it is treated securely and in accordance with this privacy policy.

Retention of Personal Information

We retain the data we collect from and about you in compliance with local data protection laws, as long as necessary to fulfill the purpose for which it was collected, and as otherwise permitted and required by law.

Correcting or Accessing Your Personal Information

We rely on you to ensure that the personal information you enter into the Platform is as accurate, complete and up-to-date as necessary for the purposes for which it is intended to be used. You may review and update your personal information on your personal profile on the Platform. You may also send an email to us at privacy@beatsunion.com to update or correct the personal information we have on file for you or to be unsubscribed from marketing or promotional emails. We reserve the right, as may be permitted by applicable privacy laws, to charge a reasonable fee for copying the requested information. Unless required by law, we may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or for other legal basis as the case may be.

Any information that you cannot change or access yourself, you can contact us at privacy@beatsunion.com and we will do our best to assist you.

For Residents in the European Union

European Data Protection Rights

For all European data subjects, you have specific legal rights. We do not collect any “sensitive” or “special category” data (as defined under the General Data Protection Regulation (GDPR)). In this section “personal data” means personal information and any other information which is personal data under the GDPR.

Data Controller

For the purposes of the GDPR, BeatsUnion Music Inc., is the data controller of any personal data collected from or about you. BeatsUnion Music Inc. will be acquiring an EU representative in the future to comply with GDPR.

Your legal rights

Under the GDPR European data subjects have a number of legal rights in relation to their personal information.

Subject to certain regulatory limitations, European data subjects have the following rights:

Right to be informed: You may have the right to be provided with clear, transparent and accessible information about your rights and how we use your personal information.

Right of access: You may have the right to be provided with a copy of your personal information held by us. If you wish to access the information we hold about you, please contact us at privacy@beatsunion.com.

Right to rectification: You may have the right to request the rectification of your personal information. You can request that we rectify any errors in information that we hold by contacting us at privacy@beatsunion.com.

Right of erasure: You may have the right to request the deletion or removal of certain of the personal information that we hold about you. By deleting your data from the Platform, you understand that you may no longer be able to optimize our services. Furthermore, we may retain de-identified and/or aggregated after it has been deleted from the Platform. You can request that we delete or remove certain information that we hold by contacting us at privacy@beatsunion.com.

Right to restrict processing: You may have the right to request that we restrict the processing of your personal information. You can request that we restrict the processing of your personal information by contacting us at privacy@beatsunion.com.
Right to object to certain processing: You may have the right to object to certain processing of your personal information, including the right to object to marketing, and request that your personal information be moved to a third-party. You can object by changing your marketing and email preferences, disabling cookies as set out above, and opting out at any time from allowing further access by us to your location data by updating settings on your device. You can also stop all information collection by un-installing the App. You may use the standard uninstall processes as may be available for your mobile device. You can also request certain changes to our data processing by contacting us at privacy@beatsunion.com.
Right to data portability: You may have the right to obtain your personal information in an accessible and transferable format so that you can re-use it for your own purposes with other service providers. This is not a general right however and there are exceptions. You can request that we provide you the data we hold on you by contacting us at privacy@beatsunion.com.
Right to withdraw consent: Where we rely on your consent to process personal information, you may have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object (as noted above). Withdrawing consent will not however make unlawful our use of your information while consent had been apparent. If you have any questions about the lawful bases upon which we collect and use your personal information, or if you wish to withdraw your consent, please contact us at privacy@beatsunion.com.

You have the right to lodge a complaint about the way we handle or process your information with the national data protection authority. For more information about your rights or to lodge a complaint, please visit the data protection authority in your jurisdiction.

Any request from you for access to or a copy of your personal data must be in writing and we will endeavor to respond within a reasonable period and in any event within one month in compliance with European data protection legislation. We will comply with our legal obligations as regards your rights as a data subject. Please be advised that certain data is required to operate your account and if you seek to withdraw consent you may be disabling our ability to manage your account and as a result your account may be terminated. We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, please let us know if any of your personal details change at by contacting us at privacy@beatsunion.com. You also have the right to make a complaint at any time to the supervisory authority in the country you are situated in.

You can find the details of your local supervisory authority here:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Changes to This Policy

We are committed to respecting the privacy rights of our users. As our Platform continues to develop, we may add new services or features. In the event that these additions affect our privacy practices, we will update this privacy policy to notify you of all material changes. We do, however, recommend that you read this privacy policy each time you use our Platform in case you missed our notice of changes to the privacy policy

Contact Us and Lodging a Complaint

Privacy is an important value of our company. You can contact us at any time to offer your feedback or questions about our privacy practices. We can be reached at privacy@beatsunion.com.

If you have any questions or queries regarding our policy then please do not hesitate to get in touch. If our representative is unable to resolve the concern, or if there is a further complaint, you have the option to contact the Privacy Commissioner of Canada at (www.privcom.gc.ca) or at 112 Kent Street, Ottawa, ON, K1A 1H3, Toll Free: 1-800-282-1376, Fax: (613) 947-6850.

If you are in located in the EEA, you also have the right to complain to the relevant supervisory authority in the EEA.