Draft: 22 June 2021
Effective date: 22 June 2021
1. Introduction and Application
(a) TitleWAVz Music LLC, TitleWAVz Enterprises LLC, “TitleWAVz.me” “us”, “we”, or “our”), is committed to protecting your privacy and the security of your personal information.
(c) By using the Service, you agree to the collection and use of personal information and other information in accordance with this policy.
User: a Paid Plan User or a Free Plan User, or a Visitor.
Paid Plan User: a person who has signed up to a Paid Plan.
Free Plan User: a person how has signed up to a Free Plan.
Visitor: a visitor to the Website (i.e. the TitleWAVz.me marketing website).
End User: has the meaning give to it in the Terms of Service.
2. What personal information do we collect?
(a) Personal data means information or data about a living individual who can be identified from that information or data (which includes information or data in our possession or which is likely to come into our possession).
(b) We collect several different types of personal information for various purposes. In the table below we have categorized this personal information and describe what is it and how we may collect it.
(c) Types of Data Collected:
This is the personal information that is provided by you (ie a User) when you sign up for and use the TitleWAVz.me Service.
If you have a Free Plan: Such personal information may include email address, name, username, hashed password, city/country when signing up, any country of last sign-in, Language/browser type, vertical (industry), application data (eg user preference).
If you have a Paid Plan: Such personal information may include all of the information above, plus credit card details (stored by Stripe, not by us), and full name for billing details.
In addition to the above, we may use and store information about Visitors. This is anonymized and aggregated in high quantities, and we remove any personal information as we are interested in the “how” not the “who”.
This includes information on how the TitleWAVz.me Service is accessed and used by Users and End Users, as well as usernames and passwords, internet protocol (“IP”) addresses (and geographic information from an IP address), browser types, time zone settings, the time spent on webpages, unique device identifiers and other diagnostic data.
We may use and store information about your approximate location (e.g. your country, city or postcode) using geographic information from your IP address. We use this data to provide features of the TitleWAVz.me Service, and to improve and customize the TitleWAVz.me Service.
This includes your preferences in receiving marketing communications from us.
(d) Certain aspects of your personal information, for example user data, are required for the TitleWAVz.me Services and if you fail to supply such information as requested for specific TitleWAVz.me Services, we may be unable to provide you with the products and services in full and your enjoyment of such products and services may be more limited.
(e) Sensitive data
We do not collect any sensitive personal information about you (this includes details about your race or ethnic origin, political opinions or associations, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or union, sexual orientation or practices, and criminal record information). Nor do we collect any information about your health, genetic background or biometric personal information.
(f) Children’s data
3. Why do we collect your personal information?
(a) TitleWAVz.me uses the data we collect for various purposes, including for the most common purposes listed below:
4. How do we collect your personal information?
(a) We will collect personal information directly from you wherever it is reasonable and practical to do so. We may collect personal information from you via:
(b) We may also collect your personal information from third parties including:
(c) The legal basis for collecting and using personal information will depend on the specific circumstances in which we collect that data. However we will collect personal information from you where:
5. Who we may disclose your personal information to?
(a) Third party disclosure
We may disclose your personal information to various third parties. These third parties are likely to include:
(b) In relation to 5(a)(7) above, because we provide paid products and/or services within the Service, we use third party services for payment processing. We will not store or collect your payment card details. That information is provided directly to our third party payment processors whose use of your personal information is governed by their privacy policies and their own terms and conditions. These payment processors adhere to the standards set by payment card industry data security standards (“PCI-DSS”) as managed by the Payment Card Industry Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:
(c) Disclosure of personal information to other countries
(d) The TitleWAVz.me Service may also use third party website tools from time to time, for example data analytics and online survey tools. These third parties have access to your personal information only to perform these tasks on our behalf and are prohibited from disclosing or using it for any other purpose. These service providers may change from time to time, but they generally include the following:
(e) Your web browser can also be configured to reject cookies. If you set up your web browser to reject cookies certain functions of the Website may become unavailable to you.
7. Direct marketing communications
8. How long do we retain your personal information?
9. How do we secure your personal information?
(a) We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
(b) In addition we limit access to your personal information to employees, agents, contractors and other third parties who have a business need for access. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
(c) While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Therefore we have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Links to other sites
11. What are your rights in relation to personal information?
(a) Access and correction of personal information
(b) Other rights
Subject to certain limitations and restrictions (e.g. depending on circumstances such as where you reside) you may have the right to exercise additional rights in relation to your personal information. This may include the rights under the General Data Protection Regulation (the “GDPR”). Accordingly, the following rights might be available to you depending on your location and except as limited under applicable law. These may include the right to:
1. Access, update or to delete the information we have on you
2. The right of rectification
You have the right to have your information rectified if that information is inaccurate or incomplete.
3. The right to object
You have the right to object to our processing of your personal information.
4. The right of restriction
You have the right to request that we temporarily or permanently restrict the processing of your personal information.
5. The right to data portability
You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
6. The right not to be subject to automated decision making
You have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect or produce a significant effect on you.
7. The right to withdraw consent
You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
(c) Please note that in order to verify your request or the applicability of any of these right to your circumstances, we may ask you for further information and to verify your identity before responding to such requests.
(b) We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, then we will contact you with the result of that complaint as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may contact the local privacy and data protection authorities in your jurisdiction.
14. Contact Us