Privacy Policy
Welcome to Brassroots (“Brassroots”), a music organization and sharing application developed by Tuner, Inc., a Delaware Corporation (“Tuner,” “we,” or “us”). We have developed this Privacy Policy (the “Privacy Policy,” as it may be amended from time to time) because your privacy is important to us. This Privacy Policy describes how we collect, use, disclose, transfer, and store your information. We appreciate you as a user and customer, so we want to be transparent. Please review our Privacy Policy and let us know if you have any questions. We reserve the right to modify this Privacy Policy at any time, as we deem necessary or appropriate, so please make sure that you periodically check for such updates to this Privacy Policy.
If you do not agree with the terms set forth in this Privacy Policy, please do not download or use Brassroots. By using Brassroots, you represent to us that you have read our Privacy Policy and understand and agree to its terms.
This Privacy Policy applies to information collected through the download and use of Brassroots and does not apply to any other information.
COLLECTION AND USE OF INFORMATION
“Personal Information” is data that can be used to identify or contact an individual person.
When downloading or playing Brassroots you may be asked to provide Personal Information at any time. Please only provide, the marketplace, or any third-party provider from which you download Brassroots information you are comfortable providing. You are not required to provide the information we, the marketplace, or the third-party provider requests, but if you choose not to provide such information then we may not be able to provide you with our products or services or respond to your questions. We may share the Personal Information you provide with affiliates and third parties, but only to the extent permitted by law.
We strive to comply with any applicable law regarding minors. If you are in a jurisdiction in which you are considered a minor, or are not of the age of majority, you must ask your parent or guardian for permission before downloading or using Brassroots. We do not knowingly disclose any Personal Information about individuals who are under the age of majority. If you are a parent or guardian or otherwise think we may have collected or been provided information by a minor or about a minor, please contact us immediately at support@tunerinc.com so that we may address the matter appropriately.
The Personal Information We Collect
We may collect both personal and non-Personal Information from you. Personal information collected by us is discussed in this section. Non-Personal Information is discussed in the next section.
We may collect the following types of Personal Information when you provide it to us, directly, or indirectly through the marketplace or third-party provider you use to download Brassroots: your name, email address, birthday (excluding year of birth), location, nationality, gender, access to your media library (iOS), access to Motion (iOS), access to your photo library (iOS), read and writing external storage (Android), mobile ID information, and Spotify login and user information. Some information may be provided by you to the marketplace’s or a third-party provider’s application programming interface. We will only collect location information when you are signed in or using Brassroots.
We do not collect Personal Information without your consent, and by downloading or using Brassroots you consent to such collection.
DO NOT provide us with your year of birth. We may permit you to post or publish your own content on Brassroots, such as a link to a website or a short bio, but any information you provide shall be considered “User Generated Content” as that term is defined and used in the Terms of Service (available here https://brassrootsapp.com/terms-of-service/). We reserve the right to collect and store any link or bio that you post or publish.
Brassroots allows you to lock (i.e., keep private) certain information that you provide. Where available, look for an icon that looks like a lock and click or tap it in order to keep specific information private.
The Non-Personal Information We Collect
Non-Personal Information, alone, cannot be used to identify or contact you. We collect non-Personal Information about your use of Brassroots.
We may collect the following types of non-Personal Information when you download or use Brassroots: demographic information including information about your computer, mobile device, hardware, software, internet provider, network status, phone status, WiFi status, and notification status. We also collect other non-Personal Information such as use statistics, user preferences, time spent using Brassroots, and click paths as well as other data that you may provide in surveys. We may also receive information from third parties in connection with market and demographic studies and/or other data that we use to supplement information provided directly by you.
How Do We Use Your Information?
We use your information to fulfill your specific requests, to send you confirmations and other user-related information, and to provide customer support and enhance your user experience. We may also use anonymized or encrypted information for marketing purposes, and provide such information to third parties, and by downloading and using Brassroots you consent to such use (see below for more information on this topic). In addition, the Personal Information you provide will allow us to send you messages about things including new products, features, enhancements, special offers, upgrade and update opportunities, contests and events of interest.
Otherwise, we use personal and non-Personal Information, both individually and combined together, in order to:
- Better enhance your user experience;
- Improve our products and services;
- Understand the behavior and preferences of our customers;
- To troubleshoot technical problems;
- To market our product;
- For authentication purposes;
- To enforce our Terms of Service or other company policies;
- To ensure proper functioning of our products and services as well as to help improve them;
- To provide customer service;
- To fulfill your specific requests, orders, and to send you confirmations; and
- To send messages about new products, features, enhancements, special offers, upgrade and update opportunities, contents, and events of interest.
By use of friend finder tools, networking tools, or third party services that connect you with other individuals, you acknowledge that use of these friend finder tools will help you find your contacts and will also allow your contacts to associate with you. Make sure you always choose your friends carefully. You are responsible for with whom you choose to associate. We cannot monitor all the interactions you might have with these friends, and we are not responsible for those interactions.
Will We Share Your Information With Third Parties?
We will never share information that would identify you with third parties without your consent. When we do have such consent, we may share aggregated, anonymized, and/or public information with third parties. Please remember that by downloading and using Brassroots, you consent to our collection and use of your information.
In the event of a merger, acquisition, or the unlikely event of bankruptcy, management of our customer information may be transferred to our successor or assign.
From time to time, we may employ or utilize third party contractors to collect Personal Information on our behalf to provide services on our sites. Collection of Personal Information for such purposes shall abide by this Privacy Policy or the privacy policy of the third party contractor.
We may also access and disclose Personal Information, including personal communications, in connection with reporting abuse in our products and services, to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual interference with our rights, property, or operations, or potential or actual injury to users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, combat fraud and/or comply with a judicial proceeding, court order, or other legal process.
Note that any information you post or communicate on a public forum is publicly available and you should have no expectation of privacy. Please be careful about what you post and say to others. We want to make our products interactive and bring like-minded users and customers together, but in doing so our users and customers need to take responsibility for how they interact with others. Please keep in mind that people have differing opinions and sensitivities.
We will not actively monitor every communication or post, if available, so please contact us immediately if you witness any abuse, discrimination, bullying, or other upsetting content, and we will attempt to address the matter.
How Do We Collect Information?
We collect information you provide to us directly and voluntarily. In addition, third parties may use cookies and other technologies to passively collect non-personal demographic information, personalize your experience on our sites and monitor advertisements and other activities as described below. We may also derive certain facts from collected information, such as the country, state, or city in which you live based on your IP address. We also may collect information you have provided to a third-party marketplace or third-party provider, such as an application store or Spotify, in order to download or use Brassroots.
1. Cookies, Clear Gifs, Tracking Pixels, etc.
Cookies are small files applied to your Internet browser to track movements within websites. Cookies link to information regarding pages you have viewed. You can set your web browser to warn you about attempts to place cookies on your computer, or limit the type of cookies you allow. Brassroots does not directly use Cookies to gather information about you. We also do not directly use Clear Gifs, Tracking Pixels, and other collection tools. Please note that third-parties, including third-parties from which you downloaded, used, or gained access to Brassroots, may be using such collection tools. Tuner does not manage the tools used by third-parties and therefore is not responsible for the way third-parties use such tools.
Information Provided to Us by Third Parties.
We may obtain personal and non-Personal Information from third parties as discussed below. We only use this data for purposes consistent with this Privacy Policy.
We may receive other information from third parties, including in connection with the operation and distribution of our products and services as well as market and demographic studies that we use to supplement personal and anonymous information collected or provided directly by you. Some third party services such as social networking sites and Spotify may also provide us with information.
By using Brassroots through a social network, Spotify, or other third party platform or service or by connecting to such a third party network, platform or service via one of our products and/or services, you are authorizing us to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the social network or other third party platform could provide to us through the social network/third party platform based on your settings on the third party social network or platform. Your agreement takes place when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, “accept” or “allow” (or similar terms) one of our applications through a social network, or other third party platform or service.
Where Is Your Information Held?
The information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which we or our third party agents operate. By using Brassroots, you consent that your information, including your Personal Information, may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.
How Do We Protect Your Information?
We understand the importance of keeping your information safe and secure. We will make commercially reasonable efforts to protect information we have collected, if any, especially your Personal Information, and ensure the security of our systems. We will use encryption or secure access safeguards whenever practical. That said, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We do not assume responsibility or liability for unauthorized access to our servers and systems.
As described elsewhere in this Privacy Policy, sometimes we will work with third parties. These third parties employ their own protection methods and procedures, and we have no control over or liability for those protection methods and procedures.
Please remember that your mobile device and/or software you use may offer security preferences that you may control. We urge you to review these options and utilize such options to your preference, but please note that certain security settings may interfere with or prevent your use of Brassroots.
Review, Correction, and Removal of Your Information
We will be happy to review, update or remove information as appropriate. Please contact us at support@tunerinc.com. If necessary or advisable, we may retain your information in our files to resolve disputes, enforce our user agreement, or as required by technical and legal requirements and constraints related to the security, integrity and operation of our websites, provided, however, that we will retain only as much information as is necessary, legally permitted, and advisable in order to do so. You have the right to request that we delete any of your Personal Information that we may store.
CHILDREN
Brassroots is intended for general audiences. We do not knowingly collect any Personal Information from children. If we discover that a user or customer is under the age of 13, we will either block the user or customer from use of Brassroots, delete such user’s information, or we will ensure consent is obtained from the user’s or customer’s parent or guardian for the collection, use and sharing of the child’s Personal Information.
Parents can review, edit, request the deletion, or prevent further collection or use of their child’s Personal Information or make inquiries regarding this policy by sending an email to support@tunerinc.com. We urge parents and guardians to monitor their child’s use of mobile devices.
THIRD PARTY SITES AND LINKS
Our website may contain advertising or services which link to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. If you click on a link to a third-party site, including on an advertisement, you will leave your current location and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your Personal Information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as us. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to Brassroots, you should consult that site’s privacy policy before providing any Personal Information.
CALIFORNIA RESIDENTS
If you are a resident of California and provide us with Personal Information, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to a third party for such third party’s marketing use. This right granted to California residents applies only to their activities within the State of California. To make such a request, please send an email to: support@tunerinc.com Such a request may be made once per year. A California resident that uses or accesses Brassroots may request that we not share any Personal Information with third parties by contacting us at: support@tunerinc.com.
GENERAL DATA PROTECTION REGULATION
We endeavor to take appropriate action in order to comply with the General Data Protection Regulation (“GDPR”), which is applicable to residents of the European Union. You must provide your consent before we may collect any of your Personal Information. We have also appointed a Data Protection Officer, which may be reached at: spofford@tunerinc.com. Should you have any questions regarding your rights under the GDPR or our privacy practices, please contact us, our Data Protection Officer, or your Data Protection Authority using the information provided below.
CONTACT INFORMATION & COMPLAINT PROCESS
If you have questions or concerns regarding this Privacy Policy, or you need to contact our Data Protection Officer, you should first contact us at support@tunerinc.com. If you are a resident of the European Union, you also have the right to contact your local Data Protection Authority. Contact details for Data Protection Authorities in the European Union are available at: https://edpb.europa.eu/about-edpb/board/members_en.
Last updated: February 25th, 2019