Privacy Policy

Welcome to Kandle Music, a service provided by Kandle Music Holdings inc. (hereinafter “Kandle Music”). Capitalized terms used in this Privacy Policy that are not specifically defined shall have the meanings given to the applicable capitalized terms in the Kandle Music Terms of Use.

Your privacy is important to us. This Privacy Policy explains how we collect, store, use, disclose and otherwise process your personal data when you use the Kandle Music app and Kandleapp.com (together, the “Website”), our mobile and desktop apps (the “Apps”) and all related sites, players, widgets, tools, data, software, APIs and other services provided by Kandle Music (the “Services”). This Privacy Policy applies to any Website, Apps, or Services by Kandle Music that refers to this Privacy Policy, i.e. by linking to it.

This Privacy Policy explains the following, amongst other things:

• Who Controls Your Data
• Legal Basis for Data Processing
• Personal Data We Collect
• Personal Data You Provide
• Personal Data We Collect Automatically
• Personal Data We Obtain From Third Parties
• How We Use Your Personal Data
• How We Share Your Personal Data
• Cookies and Similar Technology
• Information Security
• Our Activity On Social Networks
• Your Choices and Controls
• Exercising Your US Privacy Rights
• Notice To California Users
• Contact Information
• Changes to this Privacy Policy

Please take some time to read this Privacy Policy, along with our Terms of Use, in order to ensure you understand and are comfortable with our use and disclosure of your personal data.

Please note that this Privacy Policy only applies to the Website, Apps and Services (together, the “Platform”). When using the Platform, you may find links to other websites, apps and services, or tools that enable you to share information with other websites, apps and services. Kandle Music is not responsible for the privacy practices of these other websites, apps and services and we recommend that you review the privacy policies of each of these websites, apps or services before connecting your Kandle Music account or sharing any personal data.

If you do not agree to any of the provisions of this Privacy Policy, you should not use the Platform. If you have any questions or concerns about this Privacy Policy, you can contact us at dataprotection@kandlemusic.com.

Kandle Music is committed to putting its users first and believes you should know what personal data we collect about you, why we collect it, and how we use and share it. That’s why we’ve designed this Privacy Policy to give you simple, clear, and actionable information about our privacy and data protection practices.

We believe users should also have meaningful choices over the personal data we collect, use and share as described in this Privacy Policy. We encourage you to take full advantage of these tools.

Who Controls Your Data

With regard to data processing within the framework of Kandle Music’s internal administration as a sole controller through centralized systems. Kandle Music determines the purposes and means of processing, determines how the respective tasks and responsibilities of the processing of personal data are structured and who fulfills which data protection obligations. Kandle Music as a sole controller, as given the meaning by data protection legislation, is either:

• If you are located in the United States, Kandle Music Holdings Inc., 11900 Shadow Creek Pkwy Pearland, TX, USA, dataprotection@kandlemusic.com,

We may share your data within our corporate group of companies that are related by common ownership or control (“Kandle Music Group”) and the data of US users may be processed by Kandle Music Global Limited & Co. KG on Kandle Music Inc.’s behalf. The personal data of users who have signed up for Kandle Music Direct may be processed by Repost Network Inc. doing business as Kandle Music Direct on behalf of the respective Data Controller.

Legal Basis for Data Processing

The collection and processing of your data is governed by the law applicable to your respective Data Controller, as outlined above.

With that being said, Kandle Music follows US law and the CCPA where applicable to ensure adequate protection of your personal data. Data collection and processing under CCPA may be based on your consent (see Art. 6 lit. a) CCPA), contractual purposes (see Art. 6 lit. b) CCPA) or, in exceptional cases, for legitimate purposes, which we weigh against your data protection interests (see Art. 6 lit. f) CCPA). We have specified the legal bases for individual data processing activities in more detail below.

We may also use our user’s personal data under CCPA if:

• Processing is necessary to fulfill a legal obligation to which the person responsible is subject (see Art. 6 lit. c) CCPA);
• Processing is necessary to protect the vital interests of the data subject or another natural person (Art. 6 lit. d) CCPA); or
• Processing is necessary for the performance of a task that is in the public interest or takes place in the exercise of official authority that has been assigned to the person responsible (see Art. 6 lit. e) CCPA).

Personal Data We Collect

Any personal data we collect falls into one of three general categories:

• Personal data you provide to us,
• Personal data we collect automatically,
• Personal data we obtain from third parties.

Personal Data You Provide

We ask for and collect the below personal data when you use the Platform. This personal data is necessary for the adequate performance of the platform, to meet the requirements of the contract present between you and us and to comply with our obligations thereunder.

You don’t need to register for a Kandle Music account in order to visit or use our Platform. However, certain Services require that you register for an account and, by doing so, you will need to provide us with certain personal data:

• Account Information – When you register with any kind of Kandle Music account, you will need to provide your email address (except when you sign-up with Facebook, Google or Apple and don’t give your permission to share it with Kandle Music), your age, a username (which may be your real name or a pseudonym) and a password.
• Profile Information – you may choose, at your discretion, to provide additional personal data for your public profile on Kandle Music – for example:
  • your real name
  • your gender
  • the city and country in which you live
  • a profile picture, profile header image or avatar
  • any content associated with your Track uploads (all audio (including podcasts), text, pictures, graphics, comments, and other content, data or information that you upload, including your compositions, metadata, song names, composer names, creators’ names, performers’ names, group names, producers’ names, album artworks and your name, image, likeness and biographical information) (“Materials”).
  • information about how you categorize yourself with respect to your Materials (for example, whether you are a musician, a label or some other category of creator)
  • details of your other websites and social media profiles, including links to those pages
  • any personally identifiable data from your Tracks or respective meta-data will be published on your profile page in accordance with our Terms of Use. This personal data will be publicly accessible and may be viewed by anyone accessing the Website, or using our API or other Services. Please be aware that a profile picture is mandatory when you request profile verification via your Settings in the “Account” tab.
• Kandle Music Direct – In the event you use the services of Kandle Music Direct, you must provide your real name, payment information and personal data necessary to operate and maintain your monetization and/or distribution with Kandle Music Direct (e.g. content identification information such ISRC codes).
• Music Publishing – In the event you use the services of music publishing administration, you must provide your real name, payment information and personal data necessary to operate and maintain your music publishing administration (e.g. publisher, sub-publisher information as well as performance rights and or mechanical rights organization information and content identification data, such as interested party Information (IPI) numbers, ISWC numbers).
• Communications – When you communicate with Kandle Music by email or through the Platform, or use the Platform to communicate with other users, we collect personal data about your communication and any personal data you choose to provide based on contractual purposes.
• Survey Information – If you participate in any survey, you may provide certain personal data as part of your response, unless you respond anonymously. The personal data you provided is only processed based on your consent.
• Information You Post – You may provide personal data when you upload Tracks to the Platform, when you post comments, or when you contribute to community discussions. This is based on your own choice, and in accordance with our Terms of Use, we may use such data for contractual purposes.
• Information Provided For Tax or Financial Reasons
  • Tax ID/VAT – We also collect your tax ID or VAT number if applicable. If you join Kandle Music Direct as a business, this personal data is required to enable proper tax accounting purposes.
  • Other Tax Payee Information and W9 Certifications (US Only) – If you are located in the U.S., we will collect certain personal data and certifications from you, which enables us to report eligible payouts to the Internal Revenue Service.
  • PayPal Email Address – In order to be able to remit any revenue earned through your monetized tracks to your designated PayPal account, we ask you to provide us with the email address that is connected to the PayPal account in which you wish to receive your eligible payouts.

Personal Data We Collect Automatically

There is certain personal data that we collect automatically as the result of your use of the Platform, subject to the choices you make in your settings, or through the use of cookies and other web analytics services. This personal data generally includes:

• Usage Information – We collect personal data about your interactions with the Platform, including the pages that you visit and links you click on, streaming, offline listening or downloading Tracks, uploading or recording Tracks, connecting your Facebook, Google or Apple account, sharing a Track with another user, following or unfollowing another user, posting a comment, performing a search, the time, frequency and duration of your visits to the Platform, and whether you interact with email messages, for example, if you opened, clicked on, or forwarded the email message. This use of your personal data is based solely on contractual purposes should you have accepted our Terms of Use. If you have not registered on Kandle Music, the use of this personal data is based on our legitimate interest. Please be aware that we need such usage data as we are under contractual obligation to track use of content by our content providers.
• Log Data – We automatically collect log information when you use the Platform, even if you have not registered for an account or logged in. That personal data includes, among other things: details about how you’ve used the Platform (including links to third party sites or services), Internet Protocol (IP) address, access times, your browser type and operating system, device information, device event information (e.g., crashes, browser type), and the page you’ve viewed or engaged with before or after using the Platform. This personal data is essential for our service and is therefore either based on contractual purposes or on legitimate interest if no contract exists. Please be aware that we need log data as we are under contractual obligation to track use of content by our content providers.
• Location Data – When you use certain features of the Platform, we may collect personal data about your general location. Physical locations collected through our Platform are associated with non-personally identifiable data including but not limited to device type, browser type, operating system. We use such personal data to deliver personalized location-based services or content. In some instances, you may be permitted to allow or deny such use of your device’s location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized services or content. We use this personal data to provide you with location-based services (such as advertising and personalized content). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings. Such use of personal data is based on your consent, either within our Platform or within your device where you provided your consent when prompted.
• Device Information – We collect personal data from and about the devices you use, including how you interact with the Platform and information about the device itself, such as the hardware model, operating system, IP addresses, cookie information, device settings, mobile carrier information, mobile device and advertising identifiers, apps installed, browser type, language, battery level and time zone. This information allows us to recognize and associate your activity, and provide personalized content and advertising, consistently across all of your devices. Such use of personal data is based on your consent given either within our Platform or within your device.

Personal Data We Obtain From Third Parties

• Service Providers and Business Partners – We may also receive personal data about you from our service providers and business partners, including companies that assist with payment processing, analytics, advertising, marketing, data processing and management (e.g. to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you, including for Kandle Music products) account management, hosting, customer and technical support, content moderation, and other services which we use to personalize your Kandle Music experience. We explain in more detail why and how we use this personal data below.
  • Android IDs – We collect your Google Android’s Advertising ID (“AAID”). You can reset these numbers through the settings of your device’s operating system (we do not control this). Such identifiers will only be used for further analysis subject to your consent.
  • Apple IDs – We collect your Apple Identifier for Advertising (“IDFA”). You can reset these numbers through the settings of your device’s operating system (we do not control this). Such identifiers will only be used for further analysis subject to your consent.
  • Cross App Tracking on Apple Devices – Starting with iOS 14.5, iPadOS 14.5, and tvOS 14.5, we will need to receive your permission through the AppTrackingTransparency framework to access and track you through your device’s advertising identifier (see above “IDFA”). Tracking refers to the act of linking user or device data collected from our app with user or device data collected from other companies’ apps, websites, or offline properties for targeted advertising or advertising measurement purposes. Tracking also refers to sharing user or device data with data brokers. The use of such tracking is subject to your consent and therefore may only be exercised by us with such consent. Apple allows the ID for Vendors (IDFV) to be used for analytics across apps from the same content provider (us). The IDFV may not be combined with other data to track a user across apps and websites owned by other companies unless we have been granted permission to track by you. For further information on how we use the SKAdNetwork for attribution tracking please refer to the documentation that Apple provides here.

How We Use Your Personal Data

We use the personal data we collect from you for a range of different business purposes according to different legal bases of processing and subject to the choices you make in your settings. We use your personal data to:

• Provide, Improve, and Develop the Platform – We process your personal data primarily for the adequate performance of our contract with you (e.g. Terms of Use). We may also process your personal data in light of our legitimate interest in improving the Platform and giving our users the best experience. We do this to:
  • Operate and maintain your Kandle Music account, and to provide you with access to and use of the Platform. Your email address and password are used to identify you when you log into the Platform. Your device-IDs are used to ensure that you are in control of the devices that have access to your Subscription.
  • Identify you as the creator of the Tracks that you upload, the comments that you post and/or the other contributions that you make to the Platform.
  • Provide creators with stats and insights about users’ listening behavior of their Tracks, (i.e. streaming and downloading their Tracks or following their profiles).
  • Conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new features, and conduct audits and troubleshooting activities.
  • If purchasing a Subscription, to process your account subscription and renewals and to collect your payment with the use of payment verification information.
  • Send you service updates and notifications about your account, unless you opt out from such notifications.
  • Respond to you about any comment or enquiry you have submitted.
  • Enable age restrictions.
• Maintain a Safe and Secure Environment – We also process your personal data in light of our legitimate interest in improving the security of the Platform (including the security of your personal data) in order to give our users the best experience, and where it is necessary for the adequate performance of our contract with you (e.g. Terms of Use). This includes:
  • The detection and prevention of fraud, spam, abuse, security incidents, and other suspicious activity.
  • The verification and authentication of your identity to prevent unauthorized or illegal activity.
  • The enhancement of the safety and security of our products and services.
  • The conducting of security investigations and risk assessments.
  • The prevention or action against activities that are, or may be, in breach of our Terms of Use, Community Guidelines or applicable law.
  • The ability to provide you with customer and technical support.
• Newsletters – If you register on our website to receive our newsletter, we collect your email address and your name and save this information together with the date of registration and your IP address. You will then receive an email in which you must confirm your decision to subscribe to the newsletter (double opt-in). If you do not confirm your newsletter subscription within 72 hours, it will automatically expire and the personal data will not be processed for sending the newsletter. We will send the newsletter directly using our own system (Braze).Your personal data will not be passed on to third parties or processors. In the case that you do not confirm your subscription within 72 hours, we will delete the personal data that you provided. After successful confirmation, we will save your personal data until you withdraw your consent (unsubscribe from the newsletter) and for technical reasons beyond this for a maximum of 21 days. This processing is based on your consent. By unsubscribing from the newsletter, you can withdraw your consent at any time with future effect.
• Market Research Studies – Based on our legitimate interest, from time to time we will ask you to participate in market research studies and surveys or to do research studies based on anonymized and/or pseudonymized data. There is no obligation to participate in our studies. In the case that you do participate, it will be based on the consent you provide when answering the survey. We deem that the use of anonymized and/or pseudonymized data is covered by our legitimate interest as we will only use such analysis to further improve our research and Platform for the benefit of understanding your needs and enhancing your experience. We will only use the data you provide when answering the market study for other reasons, such as customized product recommendations or notifications based on your consent which you provide ahead of your participation in the market study.
• Operate and Maintain Kandle Music Direct Monetization – In the event you use the services of Kandle Music Direct, we use the personal data provided by you to operate and maintain your monetization and/or distribution with Kandle Music Direct. The personal data will be used to calculate the eligible revenue to be paid out to you and affect the payments into your PayPal account or any other accepted payment provider.

How We Share Your Personal Data

This section describes how the personal data collected or generated through your use of the Platform may be shared by you or by us.

• Through Your Profile – Any personal data in your public profile (other than your email address) will be accessible by other users of the Platform, who may view your profile information, listen to and comment on any of your public Tracks, add themselves to your list of followers, and send you messages. Artist profile owners will be able to see in their statistics that you have listened to the Tracks they uploaded along with a ranking of who listened to their Tracks the most. They will also be able to see how many times you have listened to any of their Tracks, and that you are following them. This is to allow creators to track the popularity of their Tracks. Similarly, if you comment on any Tracks on the Platform, your comments will be available to all users of the Platform together with your profile name and picture.
• Service Providers – We use a variety of service providers, some of who may be located outside of the European Economic Area (“EEA”), to provide services to us or to our users on our behalf. These service providers have access to your personal data solely to perform these tasks on our behalf, and are contractually bound to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us. We need to share your personal data in order to ensure the adequate performance of our contract with you. For instance, we work closely with service providers in the area of customer service (i.e. help center, content moderation), with technical service providers (e.g. running computer centers) or music service providers (i.e. rights administration) and payment service providers. These service providers may generally only process your personal data on our behalf under special conditions. When using such service providers, we guarantee an adequate level of data protection and will use any contractual and actual safeguards to comply with respective regulations (like the GDPR, Standard Contractual Clauses or the CCPA).
• Advertising – We share the personal data collected about you, in hashed, aggregated, or de-identified forms with advertisers and advertising service providers and business partners in order to serve ads based on interests of respective segments and to measure the reach and effectiveness of those ads, including whether a user took an action(e.g. purchased a product). We may also share cookie data and device identifiers with service providers for data matching purposes, in order to improve ad targeting. Please be aware that where such personal data of yours is identifiable, we will only use it with your consent.
• Aggregated Data – We may also share aggregated and anonymized personal data (personal data about our users that we render in such a way that it no longer identifies or references an individual user) and other pseudonymized personal data for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
• Third Party Applications – If you choose to connect your Kandle Music account to other apps or social networks such as Facebook, you may be sharing certain personal data with these apps or networks. Materials that you share with social media networks will appear on your timeline (or similar functions) as well as in news feeds that may be viewed by the public or by certain followers, subject to the terms and conditions of such social media networks. In the case of connected apps, you will need to provide the app developer with full access to your Kandle Music account in order to upload and download Tracks, or comment on, favorite, or repost Tracks from within the app. This means sharing your public information, plus access to your private Tracks. Kandle Music is not responsible for these other apps or networks, so please make sure you only connect your account with apps or services that you trust. For information on how to control the personal data that you share, and how to disconnect your account from these apps, please see the Your Choices and Controls section below. If you do not want this information shared with such social media networks or other Third Party Applications, please change your Kandle Music settings on our Platform or in those networks.
• Use of Your Name and Other User Identifiers in Sharing Links – When sharing personal data from our platform on other platforms, especially social media platforms like Facebook or Instagram, we may use your pseudonymized data. If a user clicks on your shared link and is lead to our platform, the user will be presented with a banner telling the user that you (in this context, your profile name will be displayed) are using Kandle Music and/or that you shared this link, and the user will then be asked if they want to follow you. Such use by us is considered a legitimate interest as it enriches our user experience and the way our users connect with each other. As we assume that you share links responsibly with people whom you want to interact with, we also assume that your interest in the safekeeping of your personal data is not affected, especially since we only use pseudonymized data within the link itself. Please be aware that your shared link may be shared further by other parties.
• Compliance with Laws – We may disclose your personal data to courts, law enforcement agencies, and governmental authorities (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Kandle Music, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Use and other agreements with users, or (v) to protect the rights, property or personal safety of Kandle Music, its employees, and members of the public.
• Protecting our Rights – We may disclose your personal data if we feel it is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors, officers, or shareholders, and/or to ensure the safety and security of the Platform and/or the Kandle Music community.
• Change of Control – We may also share your personal data as part of a sale, merger or change in control of Kandle Music, or in preparation for any of these events. Any other entity that buys us or part of our business will have the right to continue to use your personal data, but only in the manner set out in this Privacy Policy.

Cookies and Similar Technology

We use cookies and similar technologies (e.g. pixels, local storage, and device identifiers) to recognize you and/or your device(s) on and off the Platform, and across devices. To the extent allowed by your settings or your device. Please be aware any use of cookies is subject to your consent, except for technical storage or access for transmitting communication, or as strictly necessary to provide a service which was explicitly requested by a user.

Information Security

Kandle Music maintains appropriate technical, administrative, and physical safeguards that are designed to prevent unauthorized access, use or disclosure of personal data we collect or store and to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of natural persons that may be involved with our processing operations. We regularly monitor our systems for possible vulnerabilities and attacks. However, it is not possible to guarantee the security of personal data transmitted over the Internet. You use the Platform and provide us with personal data at your own discretion and risk.

Our Activity On Social Networks

To allow us to communicate with you on third party social networks and inform you about our services, we run pages on third party social networks. If you visit our pages on any of these third party social media pages, we and the provider of the third party social media network are joint controllers regarding the processing operations thereby triggered, which concern personal data. We are not the original provider of these pages, but only use them within the scope of the options offered to us by the respective providers.

The processing operations of personal data described are carried out on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you get asked to grant your consent to the respective providers to process your personal data as a user, your consent is the legal basis for this processing.

Since we have no access to these providers’ databases, we would like to point out that you would be best situated to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider.

Your Choices and Controls

We do our best to give you as much choice as possible regarding the amount of personal data you provide to us, and the control you have over that personal data.

• Managing Kandle Music Settings – If you register an account, you may manage the content and personal data you share when you use Kandle Music through your account settings, including for the features explained below. You are solely responsible for keeping your settings up-to-date.
  • Email & Device Notifications – You can adjust your Settings in the “Notification” tab to disable email and device notifications (other than important service updates and essential notifications about the Platform or your account). All commercial emails and newsletters also allow you to unsubscribe at any time.
  • Deleting Your Kandle Music Account – If you have an account and would like to delete it, you may do so by adjusting your Settings in the account tab. If you delete your account, all personal data associated with your account (except for backup copies), including the Tracks that you have uploaded and the usage data associated with those Tracks, will be deleted and may not be recoverable. We therefore advise you to copy or backup all Materials uploaded to your account before deletion. Even if you delete your account, it is possible that your personal data may still show up in some internet search results for a short while afterwards, if the search engine maintains a temporary cache of web pages. Search engines’ caching processes are outside of Kandle Music’s control and therefore we cannot be responsible for any personal data that remains cached by search engines after that personal data has been removed from the Platform. Please note that deleting any Kandle Music Apps, or any third party apps to which your account is connected, will not delete your account. Similarly, if you delete a third party app that is connected to your account over our API, this will not necessarily delete all personal data about your activity on the Platform from within that third party app. You will need to refer to the app provider’s terms of use and privacy policy to find out how to delete personal data about your activity on the Platform from that third party app.
  • Messages From Other Users – If you do not want to receive messages from users you don’t follow, you can adjust your settings in the “Privacy” tab. If you want to block users, you will have to do so on their respective profiles. Any blocked user will be shown in your settings in the “Privacy” tab.

Exercising Your US Privacy Rights

If you are a user residing in the US, you may exercise any of the rights described in this section by contacting us at dataprotection@KandleMusic.com. Please note that we may ask you to verify your identity before taking further action on your request.

• Data Access and Portability – You may be entitled to request copies of your personal data held by us. While a lot of the personal data you provide to us can be accessed in your account settings, you may also be entitled to request copies of personal data you have provided to us in machine-readable format.
• Change or Correct Data – Where you cannot update personal data yourself through an account, you have the right to ask us to correct, change, update or rectify your personal data.
• Data Retention and Deletion – We generally retain personal data for as long as is necessary to provide services to you under your account, i.e. as long as your contract is ongoing and for the sake of legal obligations, for 3 years following the end of the year in which your contract was canceled – or, for as long as is necessary to provide the Platform to you as a unregistered user. You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also delete your account through the Settings at any time as described below. We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (e.g. under applicable tax or commercial law or to prevent fraud and abuse and maintain and enhance security). Afterwards, we delete the personal data immediately, unless we need the personal data until the expiry of the statutory period of limitation for the purpose of providing evidence for civil law claims or because of statutory storage obligations (e.g. for accounting reasons).
• Objection to Processing – You have the right to object to processing your personal data on grounds relating to your particular situation at any time (in particular, where we don’t have to process the personal data to meet a contractual or other legal requirement, or where we are using the personal data on the basis of our legitimate interests). If you object to such processing, Kandle Music will no longer process your personal data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims or obligations. Where your personal data is processed for direct marketing purposes, you have the right to object to such processing of your personal data at any time and ask Kandle Music to cease processing your data for these direct marketing purposes. However, please be aware that any objection to processing will not necessarily have an impact on the personal data processing before such objection was made, thus such processing will generally be deemed as permissible and will be subject to the usual retention and deletion periods.
• Restriction of Processing – You have the right to restrict the processing of your personal data where one of the following applies: your personal data is not accurate anymore; the processing is unlawful and instead of erasing the personal data you request the restriction of use; the personal data is no longer needed by us but required by you for the establishment, exercise or defense of legal claims; you have objected to the use and the decision on the legitimate grounds for objection is pending.
• Withdrawing Consent – Where you provide consent to the processing of your personal data by Kandle Music, you may withdraw your consent at any time by changing your account settings or by sending a communication to Kandle Music specifying the specific consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
• Lodging Complaints – You have the right to lodge complaints about the data processing activities carried out by Kandle Music before a competent data protection authority. A list of EU data protection authorities is available here.

Notice To California Users

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws, we are providing the following additional details regarding the categories of personal data about California residents we have collected or disclosed within the preceding 12 months.

Collection, Disclosure and Sale of Personal Information

The following chart includes: (1) the categories of personal data, as listed in the CCPA, that we plan to collect and have collected and disclosed within the preceding 12 months; and (2) the categories of third parties to which we disclosed personal data for our operational business purposes or to which we sold personal data within the preceding 12 months.

Categories of Personal Data	Disclosed to Which Categories of Third Parties for Operational Business Purposes	Sold to Which Categories of Third Parties
Identifiers, such as your name, email address, residential address, date of birth, profile picture, social security number, as well as IP addresses, device IDs, anonymous Repost user IDs, and other similar identifiers	Affiliates; service providers; business partners; joint marketing partners; content partners; social networks; contest sponsors; legal authorities	Advertising partners
Personal data as defined in the California customer records law, such as name, contact information, financial information, and tax identification number	Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities	None
Characteristics about you that you choose to provide when you register an account on the Platform, which may include characteristics of protected classifications under California or federal law, such as (sex, age, gender, and race, and marital status) like any gender information	Affiliates; service providers; business partners; joint marketing partners; social networks; contest sponsors	Advertising partners
Commercial information, such as revenue and/or transaction information related to your content and use of the Platform and Kandle Music Direct Monetization	Affiliates; service providers; business partners; joint marketing partners; contest sponsors	None
Financial, tax, and payment information you provide when you create an account or use certain features of the Platform	Affiliates; service providers; business partners; legal authorities	None
Internet or network activity information, such as (browsing history, search history and interactions with our online properties or ads)	Affiliates; service providers	None
General geolocation data, such as approximate location derived from IP address	Affiliates; service providers; contest sponsors	Advertising partners
Audio, images, text, and other electronic information, such as the content you distribute through the Platform	Affiliates; service providers; operating systems and platforms	None
Inferences drawn from any of the personal data listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	Affiliates; service providers; ad networks	Advertising partners

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  Sales of Personal Data – For purposes of the CCPA, the disclosure of personal data to our advertising partners to provide you with personalized ads may constitute a “sale” in some instances. We do not knowingly sell the personal data of individuals under the age of 16.
• Sources of Personal Data – As described above, we collect this personal data from you, from affiliates (e.g., Kandle Music) via single-sign ons, and from our trusted third-party service providers and business partners.
• Use of Personal Data – We may use this personal data to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to:
  • To operate and maintain the Platform and your Kandle Music account and to provide you with access to and use of the Platform;
  • To identify you as the creator of the Tracks that you upload and the comments that you post;
  • To provide our newsletter to subscribers;
  • To market and sell our products and services;
  • To provide personalized content and ads;
  • To perform market research studies and development;
  • To perform data and business analytics;
  • To detect and prevent fraud, spam, abuse, security incidents, or other suspicious activity;
  • To perform identity verification and authentication and prevent unauthorized or illegal activity;
  • To process Subscription payments;
  • To operate and maintain Kandle Music Direct Monetization
  • To process user inquiries and requests;
  • To perform security investigations and other risk assessments;
  • To undertake quality assurance measures;
  • To maintain our systems and infrastructure;
  • To comply with law or exercise or defend legal claims;
  • To prevent or take action against activities that are, or may be, in breach of our Terms of Use, Community Guidelines or applicable law;
  • To perform accounting, conduct audits and other internal functions; and
  • To otherwise operate our business and achieve our business objectives

CCPA Rights and Requests

If you are a California resident, you may make the following requests:

• Request to Know – You may request that we disclose to you the following information covering the 12 months preceding your request:
  • The categories of personal data we’ve collected about you; and he categories of sources from which we collected such personal data;
  • The specific pieces of personal data we collected about you;
  • The business or commercial purpose for collecting or selling personal data about you;
  • The categories of personal data about you that we sold and the categories of third parties to whom we sold such personal data; and
  • The categories of personal data about you that we otherwise shared or disclosed; he categories of third parties with whom we shared or to whom we disclosed such personal data;
• Request to Delete – You may request that we delete personal data we have collected from you. To make a Request to Know or a Request to Delete, please use the Help Center or contact us at dataprotection@KandleMusic.com . We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal data subject to the request. We may request additional personal data from you in order to verify your identity and protect against fraudulent requests, such as your email address or a picture and then use that information to match it with information we already have. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your personal data. If you make a Request to Delete, we may ask you to confirm your request before we delete your personal data. If you want to make a Request to Know or Request to Delete as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include:
  • Proof of your registration with the California Secretary of State to conduct business in California;
  • Proof of a power of attorney from the resident pursuant to Probate Code sections 4121-4130.
• If you are an authorized agent and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:
  • Verify the resident’s own identity directly with us; or
  • Directly confirm with us that the resident provided you permission to make the request.
• Request to Opt Out – You may request to opt-out of any future “sale” of personal data about you by contacting us at dataprotection@KandleMusic.com or +1 833 993 2002. If you want to make a Request to Opt Out as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request, as applicable:
  • Proof of your registration with the California Secretary of State to conduct business in California;
  • Signed permission that the resident has authorized you to make a Request to Opt-Out on the resident’s behalf. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.
• Right to None-Discrimination – You also the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.
• Your Right to Request Removal of Content – Pursuant to California Business & Professions Code section 22581, if you are a resident of California, under 18, and a registered user of the Platform, you may ask us to remove content or information that you have posted to the Platform by writing to dataprotection@KandleMusic.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
• Other Rights – You can request certain information about our disclosure of personal data to third parties for their own direct marketing purposes during the preceding calendar year. This request may be made once a year.
• Do-Not-Track Signals – We do not currently respond to browser do-not-track signals.

Contact Information

If you have questions or complaints about this Privacy Policy or our practices, please contact our Data Protection Officer by email at dataprotection@KandleMusic.com

Changes to this Privacy Policy

We may update this Privacy Policy from time to time at our sole discretion. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Platform and update the “Last Amended” date below. Please be sure to periodically check this page to ensure that you are aware of any changes to this Privacy Policy. Any material changes to this Privacy Policy will be communicated to registered users by a notification to their account and/or by posting a notice of the change on the Website. Your continued access to or use of the Platform after the effective date of such changes will be subject to the revised Privacy Policy.

Last Amended: May 10th, 2023