Effective May 25, 2018
Our mission to be the trusted platform for promoting pre-release music is rooted in the importance we place on establishing trust with our customers and tastemakers. To earn and maintain that trust, we commit to communicating transparently, providing security, and protecting the privacy of data on our systems.
We keep your personal information personal and private. We will not sell, rent, share, or otherwise disclose your personal information to anyone except as necessary to provide our services or as otherwise described in this Policy without first providing you with notice and the opportunity to consent.
1. POLICY APPLICATION:
This Policy applies to Inflyte’s collection, use, and disclosure of the information of the following categories of individuals:
- Website Visitors: Individuals who visit our Websites and who may opt to provide an email address to receive communications from Inflyte. For the purposes of this Policy, “Websites” shall refer collectively to inflyteapp.com as well as any other websites Inflyte owns and that link to this Policy.
- Customers: Those who register on their own or on behalf of an entity or organization to use any of the Inflyte Services (as defined below), including administrators on a Customer account. For the purposes of this Policy, “Services” shall refer to all music promotion service solutions marketed for subscription at inflyteapp.com.
- End Users: Tastemakers who have subscribed to our Customers’ promotional lists and whose information we process in order to provide the Services to our Customers pursuant to our agreements with them.
Inflyte’s Websites and Services are not intended for, nor designed to attract, individuals under the age of eighteen. Inflyte does not knowingly collect personally identifiable information from any person under the age of eighteen.
2. INFORMATION WE COLLECT
- Name, email address, and other contact information. We ask for and—at your option—collect personal information from you when you submit web forms on our Websites, including opportunities to request further information and agree to receive email communications from us. We will send such communications in accordance with applicable law.
- Log Files. Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Websites, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences.
- Customer Account Information. When you register for a Inflyte account, we collect your email address and Company name. We refer to this information as “Customer Account Information” for the purposes of this Policy. Customer Account Information is required to identify you as a Customer and permit you to access your account(s). By voluntarily providing us with such Customer Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
- Payment Information. You are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. When you sign up for one of our paid Services, you must provide billing information. We do not store full credit card numbers but store an authorisation code after successful validation with our payment processor.
- We collect End Users’ information when they access the Inflyte web application and APIs as a Customer or tastemaker. This information may include but is not limited to IP addresses, system configuration information, and other information about traffic to to the site (collectively, “Log Data”). We collect and use Log Data to operate, maintain, and improve our Services in performance of our obligations under our Customer agreements. For example, Log Data can help us to detect new threats, identify malicious third parties, and provide more robust security for our Customers campaigns.
Legal Basis for Processing (EEA only):
- If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the Inflyte Services you have requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, Inflyte will not be able to provide the requested service to you.
- In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
- Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object.
- If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at firstname.lastname@example.org.
3. HOW WE USE INFORMATION WE COLLECT
Inflyte only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorised. As a general matter, for all categories of data we collect, we may use the information we collect (including personal information, to the extent applicable) to:
- provide, operate, maintain, improve, and promote the Website and Services;
- enable you to access and use the Website and Services;
- process and complete transactions, and send you related information, including purchase confirmations and invoices;
- send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
- send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, newsletters, offers, promotions, and events about us; and send other news or information. See Section 8 below for information on managing your communication preferences.
- monitor and analyse trends, usage, and activities in connection with the Websites and Services;
- comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorised access to the Services, and other illegal activities;
- personalise the Websites and Services, including by providing features or content that match your interests and preferences; and
- process for other purposes for which we obtain your consent.
4. INFORMATION SHARING
In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:
- When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
- Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required to comply with our legal obligations;
- In the event of a merger, sale, change in control, or re-organisation of all our part of our business; or
- as you may otherwise consent from time to time.
We do not sell, rent, or share personal information with third parties.
5. DATA AGGREGATION
Inflyte may aggregate data we acquire about our Customers and their End Users, including the Log Data described above. For example, we may assemble data to identify malicious activity or to compile web traffic reports and statistics.
6. INTERNATIONAL INFORMATION TRANSFERS
Inflyte is a U.K.based company. We primarily store your information in the European Economic Area (the “EEA”). If you are accessing or using our Websites or Services or otherwise providing information to us, you are agreeing to the transfer of your personal information to the EEA.
7. DATA SUBJECT RIGHTS
Website Visitors, Customers and End Users: You have the right to access, correct, update, export, or delete your personal information. You may email us at email@example.com with any such subject access requests (“SAR”), and we will respond within thirty (30) days. Customers also can access, correct, export, or update their Account Information by editing their settings at inflyteapp.com.
8. COMMUNICATION PREFERENCES
You may manage your receipt of commercial communications by clicking on the “unsubscribe” link located on the bottom of such emails, or you may send a request to firstname.lastname@example.org
9. DATA SECURITY, DATA INTEGRITY, AND ACCESS:
We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorised access, disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us at email@example.com.
10. NOTIFICATION OF CHANGES
If we make changes to this Policy that we believe materially impact the privacy of your personal data, we will promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated Policy on this website noting the effective date of any changes.
11. BUSINESS TRANSACTIONS
We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganisation of all our part of our business.
12. CONTACT INFORMATION
The Mount Business Centre,
2 Woodstock Link,
Attention: Data Protection Officer