Privacy Policy
General
“Personal data” means any information relating
to an identified or identifiable natural person. Personal data
can be factual (for example, a name, address or date of birth)
or it can be an opinion about that person, their actions and/or
behaviour.
In order for SMG Music and Multimedia Limited
(“Snapmuse”) to be able to provide you with the
Service (as defined in the
General Terms and Conditions - Website
) as well as to be able to provide you with individualised
offers regarding the Service and products available from
Snapmuse, Snapmuse collects personal data from you.
SMG Music and Multimedia Ltd, the operator of this website and
provider of the Service, is a subsidiary of SMG MULTİMEDYA VE
PROJE HİZMETLERİ TİCARET A.Ş, (Reşitpaşa Mah. Katar Cad. Arı-8
Binası No:2/11/3 Sarıyer - İstanbul - Türkiye
This Privacy Policy will let you know how we look after the
personal data which we collect from you in connection with the
Service, and any related content, products and services. This
Privacy Policy also informs you as to our obligations and your
rights under data protection law.
It is very important that you read through this Privacy Policy
before you subscribe to our Service.
Who is responsible for your personal data?
For the purposes of the EU General Data Protection Regulation
(EU Regulation 679/2016) (the “GDPR”), Snapmuse is the data
controller with regard to the personal data described in this
Privacy Policy.
“Data controllers” are the people who or organisations which
determine the purposes for which, and the manner in which, any
personal data is processed, who/which make independent decisions
in relation to the personal data and/or who/which otherwise
control that personal data.
If you have any questions about this Policy or about our data
protection compliance please contact us via the details provided
below.
Personal data which we collect
Snapmuse collect the following personal data from you in order to provide the Service:
- Registration information including name, address, country, phone number, e-mail address, IP-address, age and date of birth, gender and other information which you voluntarily may provide when you sign up for our Service;
- Broad, non-specific location, about where you are which we derive from your IP-address;
- Usage data: The music you listen to and your interaction with the Service. This allows us to make recommendations to you and suggest relevant music and Services to you;
- Technical and sensor information necessary to operate the Service. This includes the type of browser and device you use, data from the touchscreen, and information from your device’s accelerometer and gyroscope sensors. This enables you to control the Service and allows us to do simple things like rotate videos and recommend music;
- Cookie data and URL information, network connection type, browser type, language and information enabling digital rights management and operating system (for more details on our use of cookies please see our Cookie Policy);
- Widgets, which may be used to show personalised content or advertising; and
- Payment data, which includes credit or debit card information and other financial data which we need in order to process your payment.
We also collect, use and share aggregated data such as
statistical or demographic data for any purpose. Aggregated data
could be derived from your personal data but is not considered
personal data in law as this data will not directly or
indirectly reveal your identity. For example, we may aggregate
your usage data to calculate the percentage of users accessing a
specific website feature. 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 data which will be used in accordance with this Privacy
Policy.
We do not collect any special categories of personal data about
you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership,
information about your health, and genetic and biometric data).
Nor do we collect any information about criminal convictions and
offences.
The type of personal information listed below is only collected
in order to offer you additional features. We will never process
any of the following information unless you have chosen to share
it with us, or decided to opt out from the features:
- Your specific location; and
- Your photos.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the
terms of a contract we have with you, and you fail to provide
that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for
example, to provide you with goods or services). In this case,
we may have to cancel a product or service you have with us but
we will notify you if this is the case at the time.
How do we collect your personal data?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your
registration information and payment data by filling in forms
or by corresponding with us. This includes personal data you
provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter contests, campaigns and/or surveys; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
- Third parties or publicly available sources.
We will receive personal data about you from various third
parties as set out below:
-
Technical data from the following parties:
- analytics providers such as Google based outside the EU; and
- advertising networks.
- Contact, financial and transaction data from providers of technical and payment services.
-
Technical data from the following parties:
The purposes for collecting personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all
the ways we plan to use your personal data, and which of the
legal bases we rely on to do so. We have also identified what
our legitimate interests are where appropriate.
Note that we may process your personal data for more than one
lawful ground depending on the specific purpose for which we are
using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal
data where more than one ground has been set out in the table
below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer |
| Performance of a contract with you |
To process and deliver your order including:
|
|
|
To manage our relationship with you which will
include:
| Registration information |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in contests, campaigns and/or surveys | Registration information |
Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
Necessary for our legitimate interests (for running our
business, provision of administration and IT services,
network security, to prevent fraud and in the context of a
business reorganisation or group restructuring
exercise) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
| Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
| Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
| Necessary for our legitimate interests (to develop our products/services and grow our business) |
PROMOTIONAL OFFERS FROM US
We may use your registration information, usage data, cookie
data and widgets to form a view on what we think you may want or
need, or what may be of interest to you. This is how we decide
which products, services and offers may be relevant for you (we
call this marketing).
You will receive marketing communications from us if you have
requested information from us or purchased services from us and
you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your
personal data with any third-party for marketing purposes.
OPTING OUT
You can ask us or third-parties to stop sending you marketing
messages at any time by following the opt-out links on any
marketing message sent to you.
Where you opt out of receiving these marketing messages, this
will not apply to personal data provided to us as a result of a
product/service purchase, product/service experience or other
transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which
we collected it, unless we reasonably consider that we need to
use it for another reason and that reason is compatible with the
original purpose. If you wish to get an explanation as to how
the processing for the new purpose is compatible with the
original purpose, please contact us.
If we need to use your personal data for an unrelated purpose,
we will notify you and we will explain the legal basis which
allows us to do so.
Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where
this is required or permitted by law.
Cookies
Snapmuse also use cookies in order to provide the Service. Information about how we use cookies can be found in our Cookie Policy . Information stored in cookies may be stored and processed for as long as necessary if you accept this Policy and create an account.
YouTube API Services
Snapmuse’s API Client uses YouTube API Services. If you are using our Service on YouTube, you hereby by agreeing to our Privacy Policy also certify that you have read and agree to YouTube terms of Services and Google’s Privacy Policy.
How long personal data is stored
We will only retain your personal data for as long as reasonably
necessary to fulfil the purposes we collected it for, including
for the purposes of satisfying any legal, regulatory, tax,
accounting or reporting requirements. We may retain your
personal data for a longer period in the event of a complaint or
if we reasonably believe there is a prospect of litigation in
respect to our relationship with you.
Where you ask to be unsubscribed from marketing communications
we may keep a record of your email address and the fact that you
have unsubscribed to ensure that you are not sent any further
emails in the future.
To determine the appropriate retention period for personal data,
we consider the amount, nature and sensitivity of the personal
data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those
purposes through other means, and the applicable legal,
regulatory, tax, accounting or other requirements.
Who we share information with
We may further share information with our music industry
partners, customers and other cooperation partners in order to
help them understand how the content is performing, with
marketing partners who help us with promotional efforts, and
with advertisers that allow us to offer services and promotional
communication and help us understand how the users interact with
advertisements.
We may also share information with analytical providers in order
for us to analyse how our users use the Service and to improve
their user experience.
We may also share certain information with other companies
within the Snapmuse group and with third-parties to whom we may
choose to sell, transfer or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses
or merge with them. If a change happens to our business, then
the new owners may use your personal data in the same way as set
out in this Privacy Policy.
We require all third-parties to respect the security of your
personal data and to treat it in accordance with the law. We do
not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our
instructions.
Financial data and payment information is further collected and stored by us and/or our payment processor.
We may also share information for the purpose of responding to legal process (e.g. a court order), if we believe in good faith that it is necessary to do so; to comply with requirements of mandatory applicable law; to protect the safety of any person; and to address fraud, security, or technical issues.
Transferring of personal data to third countries
There are circumstances in which we will have to transfer your
personal data out of the European Economic Area
(“EEA”) for the purposes of carrying out the
services we provide to you. We share your personal data within
the Snapmuse group. This will involve transferring your data
outside the EEA. We may also use external third-party service
providers based outside the EEA so their processing of your
personal data will involve a transfer of data outside the
EEA.
Where the need for such transfers arises we will always ensure
that there are appropriate safeguards in place to protect your
personal data such as:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Information shared by you
The Snapmuse Service is a social Service that offers the user many ways to find, enjoy and share content. You as a user may choose to share playlists, music or other content with other users who have subscribed for the Service. This information will, if shared, be publicly available to the user(s) you accept to share it with. You may change your settings and limit the information which you have made publicly available.
Third party applications
If you connect your account to a third-party application,
Snapmuse may automatically share your activity and
activity-related stories with that service, including the
content you consume. You understand and agree that such
information may be attributed to your account on the third-party
application and may be published on such service.
You understand and agree that a third-party application’s use of
information collected from you (or as authorised by you) is
governed by the third-party application’s privacy policies and
your settings on the relevant service, and Snapmuse’s use of
such information is governed by this Privacy Policy and your
account settings.
Contests, campaigns and surveys
From time to time, Snapmuse may offer you to take part in contests, campaigns and/or surveys. This Privacy Policy shall apply to such special promotions as well, unless otherwise is stated in the specific information provided for each promotion.
Security
Snapmuse, and if applicable its cooperation partners, have taken
several safety measures in order to protect personal data from
loss, misuse, unauthorised access, disclosure, alteration or
destruction. Personal data collected from you and processed by
us will only be accessed by employees and companies that are in
need to process such information.
Snapmuse is committed to protect user information. Your password
protects your user account, so you should use a unique and
strong password, limit access to your computer and browser, and
log out after having used the Service. However, even if we take
data protection precautions, no security measures are completely
secure, and we do not guarantee the security of user
information.
Links
Snapmuse may display advertisements from third-parties and other content that links to third-party websites. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. Snapmuse do not control and will not be held responsible for third-parties’ processing of personal data. We strongly advise that you carefully review the terms and conditions and privacy policies of all linked third-party websites. We also reserve our right to discontinue any and all links to our website from third-party websites, at any time, at our sole and exclusive discretion.
Children
The Service offered by Snapmuse is not directed to children
under the age of 16. A person under the age of 16 will not be
able to register for an account or be able to use the Service
provided by Snapmuse. We do not knowingly collect personal
information from children under 16 unless prior consent has been
obtained from the holder of parental responsibility over the
child.
If you are under the age of 16, do not use the Service and do
not provide any personal information to us without providing us
with parental consent first. If you are the holder of parental
responsibility over a child under the applicable age limit and
become aware that the child you are responsible for has provided
personal information to Snapmuse, please contact us via the
details provided below and you may request exercise of your
applicable access, rectification, cancellation, and/or objection
rights.
Your data protection rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be the subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw your consent, where we are relying on it to use your personal data.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
HOW TO MAKE A COMPLAINT
In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance:
| Contact | Data Protection Commission |
| Telephone | +353 57 8684800 / +353 761 104 800 |
| info@dataprotection.ie | |
| Post |
Data Protection Commission 21 Fitzwilliam Square South Dublin 2 D02 RD28 Ireland |
Changes to this privacy policy
Our Privacy Policy may change from time to time, and any changes
to this Privacy Policy will be posted on our website and will be
effective when posted. As your use of the Service is subject to
your acceptance of this Privacy Statement, and any amendments
thereto, please check back regularly.
If you do not wish to continue using the Service under the new
version of the Privacy Policy, you may terminate your
subscription with us by contacting us via the details provided
below.
Additional information or questions
You can contact us with any queries, complaints or requests to exercise your data protection rights using the details below:
| Contact | SMG Music and Multimedia Ltd |
| Email: | hello@snapmuse.com |
| Post: | 5th Floor Rear, Connaught House, 1 Burlington Road, Dublin 4, Ireland |