Question 1

COLLECTION OF INFORMATION

Accepted Answer

The information we collect from you varies depending on the way you use our Platform. When you browse our public website to explore our Platform to learn more about us or purchase our products online (“Website Visitor"), the information we collect and use is different from the information we collect if you are a business owner or agent acting on behalf of a business (“Business Owner") or if you are a songwriter, creator, music user, or publisher (collectively, “Platform User"). Below, we describe the different ways we might collect information from you.

Information You Provide to Us

Website Visitors

If you are a Website Visitor, you may share information directly with us when you sign up for our newsletter, fill out a form, application, or questionnaire, purchase merchandise, or otherwise communicate with us. The types of personal information we may collect include your name, business and personal email address, address, phone number, and any other information you choose to provide.

Business Owners and Platform Users

If you are a Business Owner or Platform User, the information we may collect from you varies depending on how we engage with you. In general, we collect your:

Name
Business and personal email
Address
Phone number
Business name
Job title
Information relating to your application for a licence
Account username and chosen password
Age
Family status
Any other information you submit in connection with our Platform

In some instances, where we need to make payments to you, we might collect your:

Social Security Number
Tax Identification Number
Business number
FCC ID number

We may also collect information that a Business Owner chooses to provide relating to its clients or individuals that it serves. The Company does not directly collect or control this information, but rather, Business Owners determine what information they collect, and to

the extent the Company receives that information, we do so on behalf of our Business Owners. Please review the applicable Business Owner’s privacy policy for disclosures about how they collect, use, and process information.

If you make a purchase from us, we engage third-party payment processors to collect and process your payment information.

Information We Collect Automatically

When you access or use our Platform or otherwise transact business with us, we automatically collect certain information, including:

Device and Usage Information: We collect information about how you access our Platform, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Platform, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Platform.
Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Platform. These technologies help us improve our Platform and your experience, see which areas and features of our Platform are popular, and count visits. For more information about the cookies and other tracking technologies we use, and the choices available to you, see the Your Privacy Rights and Choices section below.

Information We Collect From Other Sources

We obtain information from third-party sources. For example, we may collect information about you from music usage database providers and performance monitoring companies, which includes, for example metadata, names of song writers, interested parties for purposes of paying artists or analytics.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain services based on your browsing behaviour.

Question 2

USE OF INFORMATION

Accepted Answer

We use the information we collect to provide, maintain, and improve our Platform. We also use the information we collect to:

Process and facilitate transactions and send you related information, including registration and licence information, confirmations, receipts, invoices, and customer experience surveys;
Personalise and improve your experience on our Platform, including ads you see;
Send you technical notices, security alerts, and support and administrative messages;
Respond to your comments and questions and provide customer service;
Communicate with you about products, services, and events offered by the Company and others and provide news and information that we think will interest you (see the Your Privacy Rights and Choices section below for information about how to opt out of these communications at any time);
Allow you to send and receive messages and invitations to and from other individuals, through or in connection with the Platform, and to send and receive such messages and invitations on your behalf;
Enable you to participate in message boards or public forums on the Platform;
Monitor and analyse trends, usage, and activities in connection with our Platform;
Provide, manage and enable you to participate in contests, sweepstakes, promotions or rewards programmes;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of the Company and others;
Debug to identify and repair errors in our Platform;
Comply with our legal and financial obligations; and
Carry out any other purpose described to you at the time the information was collected.

Question 3

DISCLOSURE OF INFORMATION

Accepted Answer

We disclose personal information in the following circumstances or as otherwise described in this policy:

We disclose personal information at your direction to other third parties with whom you have directed us to share certain information (e.g., those Business Owners who have invited you to join the Company or Platform Users with whom you have asked us to share or provide access to your information).
We disclose personal information to vendors, service providers, and consultants that perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, IT services and infrastructure, data analysis, e-mail delivery, auditing, information and identity verification, background checks, credit checks, marketing, advertising, and other similar services.
We disclose personal information to identify you to anyone to whom you direct us to send messages or invitations through or in connection with the Platform, including messages and invitations that we may send on your behalf.
We disclose personal information to facilitate business transactions, business relationships and the resolution of disputes and other issues by, within, or among the Company, the Company’s related legal entities, publishers, licensees, and others.
We disclose personal information to our third-party clients to whom we provide licensing and royalty distribution administration services, as needed, in the Company’s sole discretion, to support the clients’ operations or to facilitate business transactions.
If you choose to use integrations we offer on our Platform, such as via third-party social media plugins, (e.g., Facebook “Like" or Google “+1" buttons), we may disclose certain information with the integration partners.
We disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
We disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of the Company, our users, the public, or others.
We disclose personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
We disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Personal information is shared between and among the Company and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
We disclose personal information with your consent or at your direction.

We also process aggregated or de-identified information that cannot reasonably be used to identify you. The Company processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

Question 4

ANALYTICS

Accepted Answer

We engage others to provide analytics-related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Platform and other websites and mobile apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to analyse and track data, determine the popularity of certain content, and better understand your online activity.

Question 5

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Accepted Answer

The Company is located in the United States and has operations and service providers in the United States and other countries. Therefore, we and our service providers process data in the United States and may transfer your personal information to, or store or access it in, jurisdictions that may not provide similar levels of data protection. Where required by law, we provide adequate protection for the transfer of personal information in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, executing Standard Contractual Clauses, or complying with another approved data transfer mechanism. Where relevant, you may request a copy of these Standard Contractual Clauses by emailing us at privacy@cvli.com.

Question 6

DATA RETENTION

Accepted Answer

We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.

Question 7

YOUR PRIVACY RIGHTS AND CHOICES

Accepted Answer

Access, Correction, and Deletion

Depending on where you reside, you may have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, and (4) not be discriminated against for exercising these rights.

To request access, correction, or deletion of your personal information, email us at privacy@cvli.com. You can also access, correct, or delete certain information stored within your online account by logging into your account. We may verify your request by asking you to provide information related to your recent interactions with us or other information we may have about you.

Marketing Communications

If you no longer want to receive marketing-related e-mails from us, you may opt out of receiving such communications by clicking the “unsubscribe" link that is included at the end of marketing-related emails or emailing us at privacy@cvli.com. Please also note that if you opt out of receiving marketing-related communications from us, we may still send to you non-marketing related communications, such as those about your account or our ongoing business relations.

Use of Personal Information

If personal information covered by this privacy policy is to be used for a new purpose that is materially different from that for which the personal information was originally collected or subsequently authorised, or is to be disclosed to a third-party not acting as a service provider or vendor in a manner not specified in this policy, we will provide you with an opportunity to choose whether to have your personal information so used or disclosed. Requests to opt-out of such uses or disclosures may be sent to us by email at privacy@cvli.com.

Cookies and Similar Tracking Technologies

The Company uses cookies and similar tracking technologies to analyse visits to and use of our Platform and how consumers are interacting with our marketing communications. If you prefer, you can usually adjust your browser settings to remove or reject all or some browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Platform.

Cloudflare Turnstile

We use Cloudflare Turnstile to protect our website against fraud, abuse, and automated attacks. Turnstile analyses certain technical and behavioral information to verify that a visitor is a genuine human user.

Cloudflare acts as a service provider in connection with this functionality. Further information is available in Cloudflare's Privacy Policy.

Question 8

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN CALIFORNIA

Accepted Answer

The California Consumer Privacy Act, as amended by the California Privacy Rights Act, affords consumers residing in California certain rights with respect to their personal information. Accordingly, if you are a Website Visitor, Business Owner, or Platform User that resides in California, this section applies to you.

Additional Disclosures

The Company collects different categories of personal information depending on how you engage with us. The categories of personal information we may collect from you could include identifiers, characteristics of protected classifications under California or federal law, commercial information, internet or other electronic network activity information, and inferences. For details about the categories of personal information and precise data points we collect, as well as the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal Information	Categories of Recipients
Identifiers (such as name, email, address, and IP address)	Service providers and contractors, including internet service providers, cloud storage service providers, payment processing providers, fraud prevention partners, data analytics providers, direct marketing and advertising providers Third parties with whom you have directed us to share certain information (e.g., those Business Owners who have invited you to join the Company or Platform Users with whom you have asked us to share or provide access to your information
Characteristics of protected classifications under California or federal law (such as age)	Service providers and contractors, including internet service providers, cloud storage service providers
Commercial information (such as transaction data)	Service providers and contractors, including internet service providers, cloud storage service providers, payment processing providers, fraud prevention partners, data analytics providers
Internet or other electronic network activity information (such as technical and usage data)	Service providers and contractors, including internet service providers, cloud storage service providers, payment processing providers, fraud prevention partners, data analytics providers
Inferences	Service providers and contractors, including internet service providers, cloud storage service providers, data analytics providers, direct marketing and advertising providers

Your Privacy Rights

Please see the Your Privacy Rights and Choices section above for more information about the privacy rights you have as a California resident, how to exercise your rights, and how we will verify your requests. If you are submitting a rights request as an authorized agent for a consumer that resides in California, we may ask for proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive personal information in connection with this request, such as a driver’s license or other government-issued ID. In some cases, we may contact the individual who is the subject of the request to verify his or her own identity or confirm you have permission to submit this request. If you are an authorized agent seeking to make a request, please email us at privacy@cvli.com.

Do Not Track

Note that the Platform will continue to operate as described in this Privacy Policy, whether or not a “Do Not Track" signal or similar mechanism is received from your browser.

Question 9

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

Accepted Answer

If you are located in the European Economic Area (“EEA"), the United Kingdom, or Switzerland, the following section applies to you.

Legal Basis for Processing

When we process your personal data as described above, we do so in reliance on the following lawful bases:

To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Subject Requests

Please see the Your Privacy Rights and Choices section above for more information about your privacy rights and how to exercise them. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please email us at privacy@cvli.com.

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

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Your privacy is important to CVLI