Privacy Policy - Clearly Refined

Privacy Policy

Effective Date: January 1, 2023

Clearly Refined Music Group is the world leader in music-based entertainment. As digital technology refashions the world, our unmatched commitment to lead by developing new services, platforms, and business models for the delivery of music and related content empowers innovators and allows new commercial and artistic opportunities to flourish.

As part of this mission, Clearly Refined Music Group operates websites, applications, stores, and other services (which we refer to in this privacy policy as “Apps”) to help our artists stay connected with fans in new and exciting ways.

This privacy policy describes Clearly Refined Music Group’s data practices, including the collection, use, and sharing of data through Apps that link to this privacy policy, along with the choices and rights you have to control those data practices.

WHO WE ARE

Apps that link to this privacy policy are operated by Clearly Refined Music Group, located at Heaven. As used in this policy, “CRMG,” “we,” and “our” refers to this entity, who acts as a data controller and is responsible for the processing of personal data by the Apps under applicable privacy and data protection laws.

Apps may be operated on behalf of artists and/or partners who may process personal data in connection with the Apps. In such cases we will disclose the relevant third parties on the Apps and/or at the point of data collection.

CONTACT US

Questions or comments about this privacy policy, our data practices, or requests regarding your privacy rights may be submitted through our Privacy Request Form by clicking here. We are only able to respond to requests related to our data practices through this form.

INFORMATION WE COLLECT

In our operation of the Apps, we collect the following categories of data:

Category of Information

Information you choose to provide via the App or through other interactions with CLMG, such as e-mail, social media, SMS, telephone, or other methods

What may be collected

your name,
country of residence,
e-mail address,
phone number,
login information, including certain social media profile information if you login with a social media account,
gender,
age or date of birth,
payment card information,
billing and/or shipping address,
clothing sizes or similar physical descriptions,
personal description,
photographs or images,
comments.

How it is collected, where applicable

Forms you fill out on our App, including subscribing to direct marketing, creating an account, searches, or linking a social media account,
Correspondence with us (e-mails, phone transcripts or otherwise);
Purchases or orders placed on the App;
Participation in forums, chats, or other social media functions on the App;
Entering a competition, promotion, or survey;
Reporting a problem on the App or requesting support.

Information collected through your use of an App

IP address and network information,
location (based on IP lookup),
user agent string including browser and OS version,
language and time zone,
identifiers set by cookies or similar tracking information (see cookies disclosure below),
unique device identifiers and hardware version,
page response times,
download or content errors,
page interaction information (such as scrolling, clicks, and mouse-overs, length of visit, pages viewed),
methods used to browse away from the page.

Visiting our App or interacting with us

Information collected from third parties

name,
age or birthdate,
address,
phone number,
gender,
household income,
device OS,
brand affinities,
consumer profile category,
music intent scores,
music concert spend category,
music genre interests.

Consistent with applicable laws, we may match and supplement information you provide, such as your email address or phone number, with data held by third party data providers or data brokers.

HOW YOUR INFORMATION MAY BE USED

We may use information we collect to:

Respond requests and/or queries, including customer support queries,
Fulfil orders, process payments, and provide order-related updates,
Send requested marketing communications via email, SMS, or direct messages,
Advertise our products or the products of third parties that we believe may be of interest,
Create segments of users with similar features for ad targeting or seeding lookalike audiences,
Operate, measure, and audit online advertisements,
Build user profiles to assist us in understanding your interests, create marketing or advertising segments, and predict likely sales, marketing, or advertising outcomes,
Train AI or machine learning models that analyze or predict sales, marketing, or advertising outcomes,
Personalize and improve our Apps, products, and services,
Administer promotions, contests, or sweepstakes,
Operate and administer our Apps, including troubleshooting, data analysis, testing, research, statistics, and other internal operations,
Manage your access to our Apps, including notifying you of changes to the Apps,
Analyze usage of our Apps,
Secure our Apps and prevent fraud or other illegal activities,
Resolve disputes and/or enforce our agreements,
Comply with legal and regulatory obligations.

HOW YOUR INFORMATION MAY BE SHARED

In compliance with applicable laws, we may share information about you with third parties to facilitate the uses described above, including:

Our affiliates and joint venture partners that we have now or may have in the future,
Our business partners, suppliers, agents, and sub-contractors who provide services on our behalf;
Relevant CRMG artists and/or their representatives,
With other users where you leave comments or otherwise contribute content to an App,
Advertisers, advertising networks and social networks,
As part of an actual or potential corporate sale, merger, or acquisition, or other transfer of all or part of CRMG,
Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, to protect our rights or the rights of third parties, or to protect the safety or security of any person or entity, or
With your consent or as otherwise disclosed at the time of data collection or sharing.

STORAGE AND RETENTION OF INFORMATION

We will retain the information we collect in accordance with applicable laws and as reasonably necessary for our processing purposes set out under this privacy policy, including resolution of disputes, enforcement of agreements, securing the Apps, and to comply with our legal obligations. When personal data is no longer necessary for our purposes we will delete or deidentify the data.

We will also take steps to ensure that the information we collect is treated securely and in accordance with this Privacy Policy. We have put in place technical and organisational procedures designed to safeguard the information we collect.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect the information we collect, we cannot guarantee its security.

DIGITAL ADVERTISING

We use third party partners to enable targeted advertising on third-party social media platforms, websites, and mobile apps. These companies collect information through our Apps to target users and serve ads. Some of these ads may be personalized, meaning that these ads are intended to be relevant to you based on information the companies collect or receive about your use of our App and third-party sites and apps over time, including through the use of cookies and other tracking technologies.

Visit the DAA Webchoices tool at www.aboutads.info to learn more about targeted advertising and how to opt out of targeted advertising by companies participating in the DAA self-regulatory program. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool.

To opt-out of targeted advertising in mobile apps by companies participating in the DAA’s AppChoices program, you can download that app onto your device from https://youradchoices.com/appchoices. You can also limit data collection and use by third parties for targeted advertising in your mobile device settings, where available.

Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.

CHILDREN

Our apps are not directed toward children (as defined by local law) nor does CLMG knowingly collect information from children (as defined by local law) without parental consent except where in compliance with applicable laws.

YOUR RIGHTS

You may have certain rights regarding our processing of personal data about you. These rights may include access to, rectification, erasure, and/or portability of your personal data. You can exercise these rights by contacting us as described in the “Contact” section. We may take steps to verify your identity before completing your request. Our verification measures vary based on the risk to the individual and may involve confirming access to the relevant email account, providing a government-issued ID or other identification documents, or providing other account details or information that indicates a valid request.

You may also be entitled, in accordance with applicable law, to lodge a complaint with a supervisory authority if you consider that our processing of your personal data infringes applicable law.

CHANGES TO OUR PRIVACY POLICY

Any material changes we may make to our privacy policy in the future will be posted here. Please check back frequently to see any updates or changes to our privacy policy.

COOKIES

Our Apps use cookies and other similar technologies to improve your experience and support targeted advertising. For the purpose of this Cookies Policy, cookies, and other similar technologies (like scripts, plug-ins, tags, device fingerprints, Local Stored Objects, beacons, and pixels) are all referred to as “cookies.”

You can find more information about the cookies and other tracking technologies we use, the purposes for which we use them, and make certain choices about cookies through the cookie choices tools available on our Apps.

Most internet browsers are automatically set up to accept cookies. However, if you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. Please note you may not be able to take advantage of all the features of our App, including certain personalised features, if you delete or disable cookies.

For more information on managing cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.eu which has further information about behavioural advertising and online privacy.

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