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PRIVACY POLICY

LAST UPDATED: May 18, 2018

PlayNetwork, Inc. (“PlayNetwork”) wants you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we collect through www.playnetwork.com (the “Site”).

 

PERSONAL INFORMATION

Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including:

  • Name
  • Title and company
  • Telephone number
  • Email address

 

We may need to collect and process these types of Personal Information in order to respond to your inquiry or request. If you do not provide the information that we request, we may not be able to provide you with the requested information or services.

If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

 

Use of Personal Information

We and our service providers use Personal Information for our legitimate business interests, including:

  • Providing the functionality of the Site and fulfilling your requests.
    • To respond to your inquiries, to fulfill your requests, and to provide you with related customer service.
    • To send administrative information to you, such as changes to our terms, conditions, and policies.

We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

 

  • Providing you with marketing materials we believe may be of interest.
    • To send you marketing communications, with information about our services, new products, and other news about our company.

We will engage in this activity with your consent or where we have a legitimate interest.

 

  • Providing personalized services.
    • To personalize your experience on the Site by presenting content, services, and offers tailored to you.

We provide personalized services either with your consent or because we have a legitimate interest.

 

  • Aggregating and/or anonymizing Personal Information
    • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

 

  • Accomplishing our business purposes.
    • For data analysis, such as to improve the efficiency of our Site;
    • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
    • For fraud and security monitoring purposes, such as to detect and prevent cyberattacks or attempts to commit identity theft;
    • For developing new products and services;
    • For enhancing, improving, or modifying our current products and services;
    • For identifying usage trends, for example, understanding which parts of our Site are of most interest to users;
    • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
    • For operating and expanding our business activities, such as understanding which parts of our Site are of most interest to our users, so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

 

Disclosure of Personal Information

Your Personal Information may be disclosed:

  • To our affiliates, including The Octave Music Group, Inc. and PlayNetwork, Inc., for the purposes described in this Privacy Policy.
    • The Octave Music Group, Inc. is located in United States and PlayNetwork, Inc. is located in the United States.
    • PlayNetwork, Inc. is the party responsible for the management of the jointly-used Personal Information. See Schedule A for a list of our Affiliates.
  • To our third-party service providers, to facilitate services they provide to us.
    • These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, removing repetitive data from customer lists, billing, and other services.
  • When you elect to disclose it.
    • On blogs and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

 

Other Uses and Disclosures

We may also use and disclose your Personal Information as we believe to be necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.
    • These can include laws and regulations outside your country of residence.
  • To cooperate with public and government authorities.
    • To respond to a request or to provide information we believe is important.
    • These can include authorities outside your country of residence.
  • To cooperate with law enforcement.
    • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
  • For other legal reasons.
    • To enforce our terms and conditions; and
    • To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
  • In connection with a sale or business transaction.
    • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

 

OTHER INFORMATION

Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:

  • Browser and device information
  • Information collected through cookies, pixel tags, and other technologies
  • Demographic information and other information provided by you that does not reveal your specific identity

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

 

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Site functions properly.
  • Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Site in order to continually improve its design and functionality, understand how it is used, and assist us with resolving questions regarding it. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Site. We may also use cookies or other technologies in online advertising to track responses to our ads.

 

We do not currently respond to browser do-not-track signals.

 

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Site.

  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Site and email recipients, measure the success of our marketing campaigns, and compile statistics about usage of the Site and response rates.
  • Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • IP Address: Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Site. We may also derive your approximate location from your IP address.

 

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

 

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates.

 

THIRD PARTY ADVERTISING

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Site, based on information relating to your access to and use of the Site and other sites or online services. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

 

SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

 

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

  • Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions contained in each such email.
  • Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by sending a request to us at info@playnetwork.com. Please note that we will not be able to remove your Personal Information from the databases of any affiliate or other third party with which we have already shared your Personal Information prior to implementing your opt-out request.

 

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

 

How you can access, change, or suppress your Personal Information

If you would like to request to review, correct, update, suppress, restrict, or delete Personal Information that you have previously provided to us, object to the processing of Personal Information, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at info@playnetwork.com or 8727 148th Ave. NE, Redmond, WA 98052. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

 

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

 

USE OF SERVICES BY MINORS

The Site is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

 

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Site, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EUROPEAN ECONOMIC AREA (EEA): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures to protect your Personal Information. You may obtain a copy of these measures by contacting us at info@playnetwork.com or 8727 148th Ave. NE, Redmond, WA 98052.

 

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion, or other beliefs, health, biometrics, or genetic characteristics, criminal background, or trade union membership) on or through the Site or otherwise to us.

 

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy.

 

CONTACTING US

PlayNetwork, Inc., located at 8727 148th Avenue NE, Redmond, WA, 98052 is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at info@playnetwork.com customerservice@playnetwork.com or:

 

8727 148th Avenue NE, Redmond, WA 98052

 

Because email communications are not always secure, please do not include sensitive information in your emails to us.

 

ADDITIONAL INFORMATION REGARDING THE EEA

You may also lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.

 

Schedule A

The Octave Music Group, Inc. (f/k/a TouchTunes Interactive Networks, Inc.)

TouchTunes Music Corporation

TouchTunes Digital Jukebox, Inc.

TouchTunes UK Limited

Soundnet Limited

PlayNetwork Limited

PlayNetwork HK, Limited

PlayNetwork Chile, SpA

PlayNetwork (Shanghai) Media and Technology Co., Ltd.