TRACKDRIP PRIVACY POLICY
Effective as of 16 May 2019.

BY VISITING, ACCESSING, OR USING THE SERVICES, YOU ACCEPT
THE PRACTICES IN THIS PRIVACY POLICY. PLEASE READ THIS
POLICY AND TRACKDRIP’S TERMS AND CONDITIONS OF USE
CAREFULLY.
1. INTRODUCTION
2. WHO WE ARE
3. CHILDREN AND PRIVACY
4. COLLECTION AND USE OF PERSONAL DATA
5. SHARING INFORMATION WITH THIRD PARTIES
6. SAFEGUARDING OF PERSONAL DATA
7. RETENTION
8. YOUR RIGHTS
9. COMMUNICATIONS
10. MARKETING AND ADVERTISING
11. COOKIES AND SIMILAR TECHNOLOGIES
12. INTEGRATION WITH THIRD PARTY SERVICES
13. INTEGRATION WITH THIRD PARTY WEBSITES
14. DETECTION OF MISUSE OF THE SERVICES
15. ACCESS, RECTIFICATION AND DELETION
16. AMENDMENTS TO THE PRIVACY POLICY
1. INTRODUCTION
This Privacy Policy together with the Terms and Conditions of Use sets out
how TrackDrip and its affiliates (“ANJISA MUSIC”, “us”, “we” or “our”)
process any personal data that we collect about you, or which you provide
to us, when you access and use the TRACKDRIP music streaming service,
mobile and device applications or associated websites (“Services”). Our
policy is to process your personal data at all times in accordance with
applicable data protection laws and regulations.
By “personal data”, we mean any information which enables us to identify
a person either directly or indirectly. By “affiliates”, we mean any member
of our group including our subsidiaries, our holding company and its
subsidiaries.
2. WHO WE ARE
The data controller of your personal data is Anjisa Music NV. a Suriname
company whose registered address Powakkastreet
32b,Paramaribo,Suriname. If you have questions, comments or requests
about this Privacy Policy please feel free to contact us by sending an email
to support@trackdrip.com.
3. CHILDREN AND PRIVACY
We do not knowingly collect or solicit information from children under age
13 or knowingly allow such persons to register for the Services. If you are
under age 13, you are not permitted to use the Services. If you are 13 – 17
years of age, you may visit, browse and use the information on the
websites but you may not register an account or submit any personal data.
If you are 13 – 17 years old, by browsing the website, using or accessing
the Services you confirm that you have the permission of a parent or
guardian to do so. If you are a parent or guardian and believe that we may
have inadvertently collected personal data from your child without your
consent, please notify us immediately by sending an email to
support@trackdrip.com and we will delete such personal data promptly.
4. COLLECTION AND USE OF PERSONAL DATA
We will process your personal data for the purpose of providing the
Services to you and/or for the legitimate purpose of direct marketing
purposes. Specifically, we collect the following types of personal data
relating to you for the following purposes:
(a) Information you provide to us directly. When you register as a user for
the Services and/or use the Services you provide us with certain
information that we store. This may include: username and password
information provided for the Services; your name, contact and any other
user profile information that you may supply, such as your address, phone
number, email address and age; payment information provided to use the
Services; User Content (for example, photos, comments, and other
materials) that you upload or otherwise post on the Services; metadata
associated with such User Content (as defined in Section 9 of TrackDrip’s
Terms and Conditions of Use), which may include content creation date,
formatting information; location information about where the User Content
was recorded (geotags); and communications between us and you. We
process such information for the purposes of providing the Services to you
including account management and to calculate settlement towards the
content owners.
(b) Usage information. When you use the Services, we collect and process
information generated by your use of the Services, such as favourites,
playlists created, tracks played and downloaded, activity in the
TRACKDRIP applications, offlined tracks, time of log-in, what version of the
TRACKDRIP client you use and similar. If you access the Services via a
handheld device, we also store a number that uniquely identifies the
device. We use this information (i) to tailor and/or personalise the Services
to you; (ii) for service improvement purposes; and (iii) for marketing and
advertising purposes (as further described in Section 10 below). We may
also use internal or third party analytics tools, for our own analytics
purposes, to help us measure traffic and usage trends for the Services.
These tools collect information sent by your device or the Services that
assists us in improving the Services. We collect and combine this
information with analytics information from other visitors and users so that it
cannot reasonably be used to identify any particular individual.
(c) Log file information. This information may be automatically reported by
your browser or device each time you make a request to visit, access or
use the Services. When you visit, access or use the Services, our servers
may automatically record certain log file information, including the time of
log-in, what version of the TRACKDRIP client you may be using, Internet
Protocol (“IP”) address, browser type, referring / exit pages and URLs,
number of clicks and how you interact with links on the Services, domain
names, landing pages, pages viewed, and other such information. We may
also log the Device ID or other unique information for devices used to
access the Services. We may also collect similar information from emails
we send to you, which helps us track which emails are opened and which
links are clicked by recipients. This information is used to (i) analyse the
usage of the Services; (ii) enable more accurate reporting; (iii) improve the
Services; and (iv) calculate settlement with the content owners.
(d) Survey information. If you reply to surveys that we have provided, the
information you provide will be made anonymous and aggregated with the
responses of other users, unless otherwise specified and used for
improvement of the Services.
In addition to the specific uses of information we describe in this Privacy
Policy, we may use your personal data to: (i) process payments for use of
the Services; (ii) help you efficiently access your information and features
of the Services; (iii) remember information so you will not have to re-enter it
during your visit or the next time you use the Services; (iv) provide,
improve, test and monitor the effectiveness of our Services; (v) develop
and test new products and features; (vi) monitor metrics such as total
number of visitors, traffic and demographic patterns; (vii) diagnose or fix
technology problems; and (viii) detect, investigate and take all steps
necessary to address misuse of the Services.
(e) Information collected from third parties. We may receive information
about you from third parties who may have collected and transferred your
personal data to us in accordance with their own privacy policies and/or
terms of use. Examples of such third parties include social media networks
such as Facebook, business partners, advertising networks, analytics
providers or any telecommunications providers through which you may
access the Services (for example through a bundled package). Where we
receive such information from such third parties, we may combine it with
the other personal data that we have collected about you as set out above
and use such information either alone or in combination with the other
personal data we hold for the purposes outlined in this Privacy Policy.
If we intend to process your personal data for any purpose other than
the purposes set out above, we shall notify you of the purpose for
such processing and shall provide any other relevant information,
either by updating this Privacy Policy or (in the case of material
change) notifying you by email/push notification.
5. SHARING INFORMATION WITH THIRD PARTIES
We may share your personal data with those of our affiliates on whom we
rely to provide the Services, for the purposes outlined in this Privacy Policy
(see Sections 4(a) to (e) above for more details).
We may also share your personal data with third parties other than our
affiliates in the following situations:
(a) when you have given us consent to share such personal data. This can,
for instance, be in relation to Facebook or other third parties. Unless you
have otherwise expressly consented, we do not share such personal data
with third parties (e.g. advertisers) for marketing purposes, although we
may provide such third parties with aggregated, anonymised data collected
about you and other users of the Services.
(b) when necessary for billing purposes. We share information with the
billing provider to facilitate billing. Your billing and payment information is
stored by the billing provider and not by TRACKDRIP and the billing
provider processes such information in accordance with its own Privacy
Policy.
(c) when we engage third parties to perform services on our behalf in
relation to the Services. In such cases we will remain responsible for your
personal data and ensure that all handling of such data will be in
accordance with this Privacy Policy and applicable laws.
(d) if we are required to do so (i) by applicable legislation, or to comply with
any legal obligation; (ii) in order to enforce or apply this Privacy Policy or
our Terms and Conditions of Use; or (iii) to protect the rights, property or
safety of TRACKDRIP, our customers or others. This includes exchanging
information with other organisations for the purposes of fraud protection
and credit risk reduction. You expressly consent to our collecting and
sharing such information for fraud protection and credit risk reduction.
(e) if we sell or buy any business or assets, in which case we may disclose
your personal data to the prospective seller or buyer of such business or
assets.
(f) if we or substantially all of our assets are acquired by or sold to a third
party, in which case personal data held by us about our users will be one of
the transferred assets.
(g) with third party rights holders, whose content is licensed to us. The data
that TRACKDRIP shares with the rights holders is in a de-identified format
that does not identify you directly, unless you opt into the sharing of your
personal data.
(h) if you contest or dispute any of our charges, we may share your
personal data with your credit card company or financial institution in order
to help you try to resolve such dispute.
(i) where you have expressly consented, we may share certain information
such as cookie data and streaming data (e.g., the number of plays of a
particular song or playlist by all users) with third party advertising partners
in order to (a) allow third party ad networks to, among other things, deliver
targeted advertisements that they believe will be of most interest to you;
and (b) deliver targeted emails and other communications to you
concerning such advertisers, their products or services and/or TRACKDRIP
events sponsored or hosted by such advertisers.
We may remove parts of data that can identify you and share anonymised
data with other parties. We may also combine your information with other
information in a way that it is no longer enables you to be identified and
share that aggregated, anonymized information with third parties, which
may include demographic data such as how many users constitute a
particular age group, general locations of where groups of users reside for
purposes of, e.g., determining who may be interested in attending a
TRACKDRIP event and similar anonymized data.
Some of our affiliates and/or third parties may be located outside the
European Economic Area in countries whose laws may not provide
adequate protection for your personal data. Prior to your personal
data being shared with such affiliates or third parties (as applicable),
we will take contractual or other steps reasonably necessary to
ensure that your personal data is treated securely by such affiliates or
third parties in accordance with this Privacy Policy.
Except as otherwise described in this Privacy Policy, we will never sell your
personal data to third parties or allow third parties to have access to your
personal data for their own purposes.
6. SAFEGUARDING OF PERSONAL DATA
We use appropriate technical and organizational measures to protect your
personal data against unauthorized or unlawful processing and against
accidental loss, destruction or damage. Your personal data is stored in a
secure manner on protected equipment. Only a limited number of
personnel have access to this equipment and only persons with a
legitimate reason have access to your personal data. Unfortunately, the
transmission of your personal data via the internet is not completely secure.
While we will endeavor (through the use of appropriate security measures)
to protect your personal data, we cannot guarantee the security of such
data when it is transmitted to us via the internet: you accept that any such
transmission of your personal data is at your own risk.
7. RETENTION
We will retain your personal data only for the period necessary to fulfil the
purposes for which such data was collected or for so long as we are
required by law to do so. When it is no longer necessary for us to retain
such data, it will be deleted or made anonymous in a safe and permanent
manner or access to it will be blocked to the extent that statutory data
retention requirements apply.
8. YOUR RIGHTS
You have a number of rights in relation to how we process your personal
data. These include the right to:
• be informed about any personal data held about you by us;
• request access to your personal data;
• request us to have any inaccurate personal data amended or erased;
• request us to restrict processing of the personal data on certain
grounds;
• receive a copy of your personal data in a machine-readable format
and have it sent to another company;
• object to the processing of your personal data on certain grounds;
and
• file a complaint with the relevant supervisory authority if you think we
have violated data protection laws.
If you have any concerns or complaints about how we handle your
personal data, or to exercise the above rights, please contact our Data
Protection Officer at support@trackdrip.com.
9. COMMUNICATIONS
If you have provided us with your email address or your phone number, we
will use this information to communicate with you in matters relevant to the
Services, consistent with your preferences, this Privacy Policy and
applicable law. Such information includes receipts for payment, information
about changes in the Services, changes in the end user agreement and
this Privacy Policy. You may not be able to opt out of certain important
email communications (e.g., account verification, payment receipts,
technical and security notices).
10. MARKETING AND ADVERTISING
We may provide you with details of our products, services and events,
which we consider may be of interest to you, including details of
forthcoming streaming content, artist information and/or copies of our
newsletter. We may also deliver promotional offers and communications on
behalf of third party advertisers concerning their products or services
and/or events sponsored or hosted by such advertisers, where you have
opted in to receiving such information from us. We do not sell or give your
email address to other companies for their own marketing purposes. In
your account settings, you can elect to opt-out of some or all of these types
of communications. You may unsubscribe from such email communications
at any time by clicking on the “unsubscribe link” provided in such
communications.
11. COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small file that is placed on your device that allows
TRACKDRIP and our partners to recognize your device when you return to
the web page. We use cookies to offer log-in functionality, to remember
user preferences and to understand how our web pages are used.
We use both temporary (“session”) and persistent cookies. We use the
following cookies:
Strictly necessary cookies. These are cookies that are required for the
operation of our website. including, for example, cookies that enable you to
log into secure areas of our website.
Analytical/performance cookies. These allow us to recognize and count the
number of users and to see how users move around our website when they
are using it. This helps us to improve the way our website works, for
example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return
to our website. This enables us to personalize our content for you, greet
you by name and remember your preferences (for example, your choice of
language or region).
Targeting cookies. These cookies record your visit to our website, the
pages you have visited and the links you have followed. We will use this
information to make our website more relevant to your interests. Where you
have expressly consented, we may also share this information with third
parties for this purpose, as detailed above in Section 5(i).
You may delete cookies in your browser anytime and you can also block
cookies from being placed by activating the setting on your browser that
allows you to refuse the setting of all or some cookies. However, if you use
your browser settings to block all cookies (including essential cookies) you
may not be able to access all or parts of our site.
In addition to our own, cookies are also placed by Google Analytics as
described below.
12. INTEGRATION WITH THIRD PARTY SERVICES
Google Analytics: We use Google Analytics from Google on our web
pages to create anonymous usage statistics. If you have concerns relating
to the usage of Google Analytics be informed that it is possible to block
Google Analytics by installing a plug-in to your browser. A plug-in for the
most common browsers can be found
here: http://tools.google.com/dlpage/gaoptout. Please refer to Google’s
privacy policy to understand how Google processes your personal data.
Facebook: If you enable the function “Connect to Facebook” in the settings
of your TRACKDRIP client we will share your favourites with Facebook
enabling your Facebook friends to see your favourites and enabling you to
see your Facebook friends’ favourites. Further if you use the function
“share” you can post to your Facebook account directly from the
TRACKDRIP client. Please refer to Facebook’s privacy policy to
understand how Facebook processes your data.
Twitter: If you use the function “share” you can post to your Twitter
account directly from the TRACKDRIP client. Such posting might involve
sharing personal data. Please refer to Twitter’s privacy policy to understand
how Twitter processes your data.
13. INTEGRATION WITH THIRD PARTY WEBSITES
We may link to third party websites. TRACKDRIP cannot control or be held
liable for third parties’ privacy policies and content. Please refer to the third
party site’s privacy policy to understand how such third party processes
your personal data.
We are not responsible for the practices employed by any websites or
services linked to or from the Services—such as, but not limited to,
Facebook and Twitter—including the information or content contained
within them. When you use a link to go from our Services to another
website or service, our Privacy Policy does not apply to those third party
websites or services. Your browsing and interaction on any third party
website or service, including those that have a link on our Services, are
subject to that third party’s own rules and policies. In addition, you
understand and agree that we are not responsible and do not have control
over any third parties that you authorize to access your personal data
(including User Content).
14. DETECTION OF MISUSE OF THE SERVICES
If we suspect misuse of the Services, we may combine the personal data
we have collected in accordance with this Privacy Policy with other
information in order to investigate the extent of the misuse and who is
responsible.
15. ACCESS, RECTIFICATION AND DELETION
If you have questions regarding your personal data stored with us,
including a request for access rectification or deletion, or you object to
certain uses, please feel free to contact us e.g. by sending an email to
support@TrackDrip.com.
16. AMENDMENTS TO THE PRIVACY POLICY
The Services are subject to constant improvement and future changes may
influence what personal data we store and how we process it. This Privacy
Policy may be updated to reflect such changes, changes in legal framework
or improvements in how we handle personal data. Please check back
frequently for any updates to the Privacy Policy. When we make material
changes to the Privacy Policy, we will provide you with notice as
appropriate under the circumstances, for example, by sending you an
email.