Privacy Policy

1. Introduction

1.1. As part of the Songoroo service, we want to provide you with the best possible experience, so that you can enjoy our services today, tomorrow and in the future. To do this, we need to understand your listening habits and musical preferences so that we can provide an exceptional and unique service specifically for you. At the same time, the protection of your privacy and the security of your personal data will always be extremely important to us. Therefore, we want to transparently explain what, how and why we collect, store, share and use your personal data, and describe what control measures and options are available to you as to when and how you decide to share your personal data. We will further explain the Privacy Policy (“Policy”) in detail and precisely so that you know what we mean by that.

 

2. Principles

2.1. These Principles set out the basic procedures for the handling of your personal data within the relation to Songoroo s.r.o. The Principles apply to all Songoroo services and all associated services (the “Songoroo Service”). The Terms governing your use of the Songoroo Service are defined in our Songoroo Terms of Use (the “Terms of Use”).

2.2. From time to time, we may develop and offer new or additional services. If the introduction of these new or additional services changes the way we collect or process personal information, we will provide you with more information and additional terms or principles. If not stated otherwise, these new or additional services will be governed by these Principles.

2.3. These Principles have the following objectives:

a) Gain assurance that you understand what personal information we collect about you and know the reasons why we collect and use it and with whom we share it.

b) An explanation of how we use the personal information you provide to us so that we can provide you with a great opportunity to use the Songoroo service.

c) An explanation of your rights and choices regarding the personal information we collect and process from you and how to protect your privacy.

2.4. We hope this helps you to understand our privacy obligations to you. Information on how to contact us if you have any questions or concerns can be found in the “How to contact us” section below. However, if you do not agree with the contents of these Principles, please remember that it is entirely up to you whether you choose to use Songoroo or not.

 

3. Your rights and preferences: The right to choose and control

3.1. You may have heard that the new EU law, the so-called The General Data Protection Regulation, or “GDPR”, gives individuals defined rights regarding their personal data. Therefore, we have introduced additional transparency and access control options in our Privacy Center and Privacy Settings that will allow users to exercise these rights. To the extent determined and permitted by applicable law, the rights of the individual include:

a) right of access – the right to be informed of and request access to personal data that we process about you;

b) the right to rectification – the right to request that we change or update personal data if it is inaccurate or incomplete;

c) the right to delete – the right to request that we delete personal data;

d) right of restriction – the right to request that we temporarily or permanently stop processing all or part of your personal data;

e) right to object – the right to object at any time to the processing of your personal data based on specific private circumstances; the right to object to the processing of personal data for the purposes of direct marketing;

f) the right to data transfer – the right to request a copy of your personal data in electronic format and the right to transfer this personal data for use within the service of another party;

g) the right not to be the subject of an automatic decision – the right not to be the subject of a decision based solely on an automatic decision, including profiling, if that decision would have a legal effect on you or lead to a similarly significant effect.

3.2. To allow you to easily exercise these rights and record your preferences about how Songoroo uses your personal information, we offer you access to these settings through the Profile Settings option, which gives you control over some of the categories of personal information we process about you and includes link to the Privacy Center, where you will find: information about how Songoroo uses your personal information and what your rights are; lets you choose what traffic you receive from Songoroo, manage publicly available personal information, and set sharing preferences

3.3. The Privacy Center lets you control how Songoroo processes your personal information. Provides information about what happens when you adjust settings in the Profile Settings section and how you can stop receiving certain messages from Songoroo. If we send you electronic marketing notices based on your consent or applicable laws, you may revoke that consent at any time and free of charge, or state your objection (“unsubscribe”). The electronic marketing announcements you receive from Songoroo (e.g., sent via email) will also include a opt-out mechanism within the message itself (e.g., the unsubscribe link in emails we send you).

3.4. For more information on the GDPR rights described above and the control measures we provide to all Songoroo users in relation to these rights, see the ‘Your Rights’ section. “And in the Privacy Center. If you have any questions about your privacy, rights, or how to enforce them, please contact us through our Support section on our web page. We will respond to your request within a reasonable time after verifying your identity and details of your query. If you are dissatisfied with the way we use your personal information, you can also contact your local privacy office to file a complaint.

 

4. Method of collecting personal data

4.1. We collect personal information in the following ways:

a) By registering for the Songoroo service: when you register for the Songoroo service, we collect certain personal data necessary for you to use the Songoroo service, such as your email address, date of birth, musical preferences, gender, country, etc.

b) While using Songoroo: when you use Songoroo, we collect personal information about your music profile, such as information about favorite songs, favorite artists, music genres, etc..

c) Collection of voluntarily provided personal data: if you wish so, you can also voluntarily provide us with additional personal data, or give us consent to the collection of other personal data, e.g. in order to provide additional functions. We will not collect photos, voice data or any contacts from your device without your prior consent. You can always change your mind and give your consent at any time or revoke it.

d) From Third Parties – We will receive personal information about you and your activities from third parties, including advertisers and partners with whom we work to provide the Songoroo service. We will use this personal information either if you have given the third party or Songoroo consent to share the information, or if Songoroo has a legitimate interest in using the personal information to provide Songoroo services to you.

4.2. We use anonymised and aggregated information for purposes including testing our IT systems, research, data analysis, creating marketing and promotional models, improving Songoroo, and developing new features within Songoroo.

 

5. Collection of personal data

5.1. The following tables list the categories of personal information we collect and use from you:

Personal information collected when you sign in to Songoroo 
Category of personal data Category description
Account registration information  They contain personal information that you provide or that we collect to register and use Songoroo. This includes your email address, year of birth, gender, city, country, education, and musical preferences.
Some of the personal information we ask you to provide is used to help us create your account. You have the option to also provide us with certain additional personal information so that we can further personalise your account and improve the service.
The exact personal information we collect depends on the use of the Songoroo service you sign up to, and whether or not you use a third party service (such as Facebook, Google, etc.) to register for and use the Songoroo service. If you use a third party service to create an account, we will receive personal information through that service, but only if you have agreed that the service will share your personal information with us.

 

Personal data collected when using the Songoroo service 
Category of personal data  Category description 
Information on the use of the Songoroo service 
  • Songoroo user type information.
  • Information about interactions with Songoroo, including a place with further precise specification of the name of business or store area where Songoroo is used, the date, time and length of your requests, the songs you have rated, and communication with other Songoroo users. This may also include details about how you use third-party applications, the ads you receive, and the length of time you stay in certain business area.
  • Content for the user you publish to Songoroo, including messages you send and receive through Songoroo and communication with the Songoroo customer service team.
  • Specifications, which may include URL information, cookies, IP address, types of devices you use to access or connect to Songoroo, unique device IDs, device attributes, network connections (e.g. WiFi, 3G, LTE, bluetooth ) and the provider, network and performance of the device, browser type, digital rights management language information, operating system and version of Songoroo.
  • Mobile device sensor data generated by motion or orientation (e.g., accelerometer or gyroscope) needed to provide specific Songoroo features.

 

Personal information collected with your prior consent, which allow us to provide you with additional features 
Category of personal data  Category description
Voluntary mobile data  In addition to the mobile data we collect to provide you with Songoroo services, you also have the option to give us permission to collect additional personal data from your mobile device so that we can provide you with features that will enhance Songoroo.

We will never access any of the personal information listed below without your consent.

  • Your photos: If you give us permission to access your photos or camera, we will only access the images you specifically choose to share with us and the metadata associated with those images, such as file type and image size. We will never scan or import saved photos.
  • Exact location of your mobile device: granting us permission to access your exact location will allow us to access GPS or Bluetooth to provide location-based functionality in Songoroo. Please note that this does not include your IP address. We use the IP address to determine an inaccurate location, e.g. in which country you are located to ensure compliance with our license agreements.
  • Voice Data: If you give us permission, we will be able to access voice instructions captured through your device’s microphone so you can communicate orally with Songoroo. Please note that you will always be able to turn off the microphone function.
  • Contacts: Giving us permission to access your contacts will allow us to access individual contacts stored on your device to help you find friends who use Songoroo.
  • “Push” type alerts are customised according to your profile, if you have given your consent to individual customisation during the installation of the application or the first time you use the application (Article 6 (1)) letter. a) of the GDPR (Personal Data Protection) Act.
Payment details  We may collect this personal information if you register for the trial service or purchase any of our paid services or make another purchase through Songoroo. The exact personal information collected varies by payment method (such as direct through your mobile service provider or invoice), but will include the following information:

  • name and surname or company name (+ registered office, numerical tax identifier),
  • year of birth,
  • The type of credit or debit card, expiration date, and some digits in your card ID
  • mobile phone number
  • email address
  • details of your transaction history.

If you choose to purchase on invoice, we will provide your personal information to our payment processing subcontractors to allow them to send you invoices.
Data provided in competitions, surveys and lotteries This personal data will allow you to register and participate in various types of promotions. The exact data collected depends on the type of promotion.
Marketing data  This personal information allows Songoroo and our partners (service providers) to send you marketing communications via either:

  1. an email
  2. usage of the Songoroo services
  3. or directly from the third party.

To learn more about the personal information we collect and the control measures available to you in connection with the marketing communications you receive, visit songoroo.com.
6. For what purposes do we use personal data

6.1. When you use or work with Songoroo, we use a variety of technologies to process your personal information for a variety of reasons. The following table sets out the reasons why we use personal data, the relevant legal bases on which we rely and which allow us to process personal data legally, and the categories of personal data used for the following purposes:

Purpose of processing  Legal basis for the purpose of processing  Category of personal data used by Songoroo for processing purposes 
In order to provide you with Songoroo and other Songoroo side services and products, we may personalise them and enhance your user experience, e.g. by providing personalised and localised content, recommendations, features and advertisements, both within and outside Songoroo (including third party products and services). Fulfilling of the contract,        Legitimate interests Account registration information, Service usage information
To understand how you connect to and use Songoroo in order to ensure Songoroo’s technical functionality, develop new products and services, and analyze how you use Songoroo, including your interactions with applications, advertising, products, and services that are provided or offered through the Songoroo service or are connected to it. Fulfilling of the contract,        Legitimate interests Account registration information, Service usage information
Communication with you for Songoroo Products related purposes. Fulfilling of the contract,        Legitimate interests Account registration information, Service usage information
Processing your payment for the purpose of preventing or detecting fraud, including fraudulent payments and fraudulent use of Songoroo. Fulfilling the contract, Compliance with legal requirements, Legitimate interests Payment details
In order to communicate with you, directly or through one of our partners for the following purposes:

  • marketing,
  • research ,
  • participation in competitions, surveys and lotteries
  • promotions

 

via email or other notifications in accordance with any permissions you have notified us (such as account settings).

 Consent, Legitimate interests Data in competitions, surveys and lotteries, Marketing data
Providing features, information, advertising, or other content based on a specific location. Consent Voluntary mobile data
7. Sharing of personal data 

7.1. We have created categories of recipients of personal information that we collect or generate when you use Songoroo.

7.2. The following personal information will always be publicly available on Songoroo: your name and / or username, the profile picture, who do you follow and who is following you on Songoroo, your preferred artists, and public playlists.

7.3. The following personal information will only be shared with the categories of recipients listed in the table below if: you choose to use a specific Songoroo feature where certain personal information is required to properly use the Songoroo feature, or give us permission to share personal information, e.g. by maintaining the settings in Songoroo accordingly.

Category of recipients   Reason for sharing 
Third-party applications that you connect to your Songoroo account  If you connect a Songoroo account to a third-party application, e.g. via social networks, audio, TV, or mobile platforms, Songoroo may share your usage information so that you can sign in to your Songoroo account.
Third-party applications that you use to sign in to Songoroo  If you sign in to a third-party application using your Songoroo account credentials, that third-party application may have access to certain information about your use of the service, such as your playlists, stored content, and activities.

Before you connect to a third-party application, you will receive a notification letting you know what personal information will be shared / accessible to the third-party application.
Community support  When you register a Songoroo support account with the Songoroo support community, we will ask you to create a specific Songoroo support community username. This will be publicly visible to anyone joining the Songoroo support community, along with any questions or comments you post.
People following you on Songoroo  There may also be a situation where you would like us to share certain information about your use of the Service, specifically information about your use of Songoroo with other Songoroo users known as “Followers”.

For example, when you create playlists, you may want other Songoroo users to be able to see those playlists, but you can also switch playlists to private mode at any time.
Artists and Music Labels You may ask us to share personal information (such as your email address) with artists, music publishers, or other partners who may wish to send you news or promotional offers directly, but you may also revoke this consent at any time.

 

Information we may share 
Category of recipients  Reason for sharing 
Service providers and others  We use technical service providers who can operate the technical infrastructure we need to provide the Songoroo service, in particular providers that host, store, manage and maintain the Songoroo application, its content and the data we process.

We use marketing and advertising partners to show you more personalised content or to better understand how you use Songoroo services so that they can help you to use them better. We may also share personal information with certain marketing and advertising partners when sending promotional communications regarding the Songoroo service.
Songoroo partners 
  • If you access Songoroo through an offer that you received or purchased from a third party, such as a mobile network operator, we will share personal information with that third party about how you use Songoroo, such as whether and to what extent you have taken advantage of the offer, activated your Songoroo account, or were actively using the Songoroo service.
  • Depending on how you sign up for Songoroo (e.g., through a third-party service or mobile carrier), we will share your Songoroo username or other registration information as necessary to keep your account running.
  • We may also share personal information in a pseudonymised format with our partners in the music industry to help them understand how the content they license is doing and to enable you to listen to streaming content through Songoroo.
  • We also share personal information in a pseudonymized format with marketing partners who help us with promotion and with advertisers who allow us to offer a free service.
Researchers from academia  We will share personal data for activities such as statistical analysis and academic studies, but only in a pseudonymised format.
 

Other companies of the Songoroo Group 

 We will share personal information with other companies in the Songoroo Group as part of our day-to-day business so that we can maintain and provide the Songoroo service.
Law Enforcement and Data Protection Offices  We will share personal information if we believe in good faith that it is necessary to comply with legal obligations under applicable laws or in response to applicable legal proceedings, such as a search warrant, court order or subpoena.

We will also share personal information when we believe in good faith that it is necessary for the purposes of our own legitimate or third party interests related to national security, law enforcement, litigation, criminal investigation, protection of the security of any person, or to prevent death or imminent harm to health, provided that this interest does not, in our opinion, outweigh your interests within the framework of fundamental rights and freedoms requiring the protection of personal data.
Buyers of our company  We will share personal data if we sell our company to an interested party or negotiate this sale with a potential buyer.

In these circumstances, Songoroo will continue to guarantee the confidentiality of personal information and will send you a notice before personal information is transferred to the buyer or subject to other privacy policies.
8. Data retention and deletion 

8.1. We will only retain personal information for as long as is necessary to provide you with the Songoroo service and for legitimate and basic business purposes, such as maintaining Songoroo’s performance, making business decisions about new features and offerings based on data, fulfilling our legal obligations and resolving disputes. We will retain some personal information for as long as you become a Songoroo user. These include, for example, song preferences, song library, and account information.

8.2. At your request, personal data will be deleted or anonymized so that they no longer identify you, except in situations where we are legally entitled or obliged to retain certain personal data, including the following situations:

a) If there is an unresolved issue with your account, such as an outstanding claim against Songoroo, or an unresolved litigation or claim, we will retain the necessary personal information until it is resolved.

b) Where we are required to retain personal data on the basis of a legal, tax audit or accounting obligation, we will retain the necessary personal data for the period required by applicable law.

c) Where necessary due to our legitimate business interests, such as the prevention of fraud or the maintenance of the security of our users.

 

9. Sharing personal information with other countries 

9.1. Songoroo may subcontract the processing of personal data or share it with third parties in countries outside your country. Personal data may thus be subject to personal data protection laws that differ from the laws of the country where you reside.

9.2. For example, personal data collected within the European Union may be imported and processed by third parties in a country outside the European Union. In such cases, Songoroo warrants that the transfer of personal data is carried out in accordance with applicable data protection laws and, in particular, that all relevant contractual, technical and organizational measures are implemented as standard contractual clauses approved by the EU Commission.

 

10. Links

10.1. We may display third-party ads and other content that link to third-party sites. We are not responsible for or control the practices and content of third parties in the area of personal data. If you click on an ad or a third-party link, please note that this will cease to use the Songoroo service and the personal information you provide will no longer be subject to this Policy. Please read these companies’ privacy policies to find out how they collect and process your personal information.

 

11. Data retention security 

11.1. We are committed to protecting the personal information of our users. We implement appropriate technical and organizational measures to protect the security of personal data. Please note, however, that no system is ever completely secure. We have implemented various principles, including pseudonymisation, encryption, access and retention, that prevent unauthorized access and unnecessary storage of personal data in our systems.

11.2. The user account is protected by a password, so we recommend that you use a unique and strong password, restrict access to your technical device and browser, and log out when you stop using Songoroo.

 

12. Children 

12.1. Songoroo is not intended for use by children under 13 years of age. However, in some countries, local laws may impose stricter restrictions. Further details are given in our Terms of Use.

12.2. We do not knowingly collect personal information from children under the age of 13 or children under the age limit. If you are under the age of limitations, please do not use Songoroo or disclose any personal information to us.

12.3. If you are a parent of a child under the 13 years of age and you find that your child has provided Songoroo with their personal information, please contact us using the Contact form. You can request the exercise of the relevant rights here.

12.4. If we become aware that we have collected the personal data of a child under the age of 13, we will take reasonable steps to delete the personal data. This may require deleting this child’s Songoroo account.

 

13. Changes to the principles of personal data protection

13.1. We may make changes to this Policy from time to time.

13.2. If we make major changes to this Policy, we will notify you of such changes as appropriate, e.g. in the form of a well visible notice, or by requesting your consent within the Songoroo service, or by e-mail.

13.3. We can notify you in advance. Therefore, be sure to read this notice carefully.

 

14. How to contact us

14.1. Thank you for reading the Privacy Policy. If you have any questions about this Policy, please contact us using the form at songoroo.com/contact-us/, or mail us at:

Songoroo s.r.o., Sartorisová 11, 821 08 Bratislava, Slovak republic

The controller of personal data for the purposes of personal data processed in accordance with this Policy is Songoroo s.r.o.

We hope you enjoy Songoroo!

Updated and valid from 1.09.2021