Repost Network Privacy Policy

Repost Network Privacy Policy

Welcome to Repost Network, a service provided by Repost Network, Inc. (“Repost”, “we”, “us”, or “our”).

Your privacy is important to us. This Privacy Policy explains how we collect, store, use, disclose and otherwise process your information when you use repostnetwork.com or any other websites operated by us (together, the“Website”), our mobile and desktop applications, including SC Planner and Artist Engine (the “Apps”), and all related software, tools, data and other services provided by Repost (the “Services”).

This Privacy Policy explains the following, among other things:

  • Our Privacy Principles
  • The Information We Collect
  • How We Use Your Information
  • How We Share Your Information
  • Cookies and Similar Technology
  • Your Choices and Controls
  • Contact Information

Please take some time to read this Privacy Policy along with our Terms of Service, in order to ensure you understand and are comfortable with our use and disclosure of your personal information. If you see an undefined term in this Privacy Policy, it has the same meaning given to it in our Terms of Service.

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, owned or controlled by third parties. Repost is not responsible for the privacy practices of these third party websites, apps and services and we recommend that you review the privacy policies of each of these websites, apps or services before connecting your Repost 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 through at dataprotection@repostnetwork.com.

Our Privacy Principles

Repost is committed to putting its users’ privacy first and believes you should know what 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 have meaningful choices over the data we collect, use and share as described in this Privacy Policy. We encourage you to take full advantage of these tools so you can make the best decisions about the data you share.

Information We Collect

The personal information we collect is related to providing, maintaining, and developing the Platform and its features, and falls into three general categories:

  • Information you provide to us
  • Information collected automatically
  • Information we obtain from third parties

Information You Provide

We ask for and collect the personal information described below when you use the Platform. You need to register for a Repost account in order to use most of our Services and by doing so, you will need to provide us with certain information:

  • Application Information - When you apply to Repost, you will need to provide your real name, your email address, your date of birth, your location (city level), and indicate what you are looking to get out of Repost. Optionally, you can provide information on how you heard about Repost.
  • Profile Information - Certain Repost features, including Apps like SC Planner, allow you, at your discretion, to provide additional information in order to create a profile or use the features and/or Apps. For example, the following information may be publicly accessible and may be viewed by anyone accessing the Website, or using our other Services:
    • a user name (which may be your real name or a pseudonym)
    • a profile picture, profile header image or avatar
    • details of your other websites and social media profiles, including links to those pages (but not your email address)
    • any additional information you provide as part of your public profile, such as your real name, information about how you categorize yourself as a creator (e.g., whether you are a musician, a label or some other category of creator), and information about how you categorize your content (e.g., genre)
  • Communications - When you communicate with Repost by email or through the Platform, or use the Platform to communicate with other users, including through any of our Apps, we may collect information about your communication and any information you choose to provide.
  • Survey Information - If you participate in any survey, you may provide certain personal data as part of your response, unless you respond anonymously.
  • Information You Post - You may provide personal data when you upload your Content to the Platform, including metadata, or when you use certain interactive or social features that may be available through the Platform.

This information is necessary for the adequate performance of the contract (e.g., Terms of Service) between you and us and to allow us to comply with our legal obligations. We may also process this information in light of our legitimate interest in improving the Platform and giving our users the best experience. Without it, we may not be able to provide you with all the requested services and features of the Platform.

Information We Collect Automatically

There is certain information that we collect automatically as a result of your use of the Platform, or through the use of cookies and other web analytics services as more fully described below in the Cookies and Similar Technologies section below. This information generally includes:

  • Usage Information - We collect information about your interactions with the Platform, including the pages that you visit and links you click on, 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.
  • Log Data - We automatically collect log information when you use the Platform. That information 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.
  • Cookies - We use cookies and other similar technologies, such as pixels, local storage, and mobile device identifiers and may also allow our business partners to use these tracking technologies on the Platform, or engage others to track your behavior on our behalf. For more information on these technologies, see the Cookies and Similar Technologies section below.
  • Location Data - When you use certain Services or features of the Platform, we or our service providers may collect data about your general location (e.g., an IP address). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings.
  • Device Information - We collect information 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 device identifiers, apps installed, browser type, language, battery level and time zone. This information allows us to recognize and associate your activity, and provide a personalized experience consistently across all of your devices.
  • Software Development Kits - We may engage third parties, including our business partners and service providers, who use mobile SDKs to collect information and information related to how mobile devices interact with the Platform. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented. A mobile SDK is in effect the mobile app version of a pixel tag or beacon. We may use this technology, for instance, to analyze how you interact with the Platform and to enable analytics or other features through mobile devices.

Information From Other Sources

  • Single-Sign Ons - If you sign-in to Repost through a third party application like SoundCloud, you authorize Repost to collect your authentication information, such as your username and encrypted access credentials, and other information available through the third party application account.
  • Service Providers and Business Partners - We may also receive information about you from our service providers and business partners, including companies that assist with payment processing, analytics, account management, hosting, customer and technical support, and other services which we use to deliver the Platform and improve your Repost experience. We explain in more detail why and how we use this information below.

How We Use Your Information

We use the personal information we collect from you, including with the help of automated systems and decision making, for a range of different business purposes according to different legal bases of processing.

  • Provide, Improve, and Develop the Platform
    • To operate and maintain your Repost 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 account.
    • To identify you as the creator of the Content that you submit and/or distribute and other contributions that you make to the Platform.
    • We 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.
    • Your email will be used to send you service updates and notifications about your account and the Platform.
    • To respond to you about any comment, question, or enquiry you have submitted to us.
    • We use your age to enable age relevant restrictions and comply with applicable laws and regulations.
    • Information you provide when applying to join the Repost is used respond to you regarding your application to join Repost.

We process this information in light of our legitimate interest in improving the Platform and giving our users the best experience, and where it is necessary for the adequate performance of the contract with you (e.g., Terms of Service).

  • Maintain a Safe and Secure Environment
    • Detect and prevent fraud, spam, abuse, security incidents, and other suspicious activity.
    • Verify and authenticate your identity and prevent unauthorized or illegal activity.
    • Enhance the safety and security of our products and services.
    • Conduct security investigations and risk assessments.
    • To prevent or take action against activities that are, or may be, in breach of our Terms of Service or applicable law.
    • To provide you with customer and technical support.

We process this information in light of our legitimate interest in improving the Platform and giving our users the best experience, and where it is necessary for the adequate performance of the contract with you (e.g., Terms of Service).

  • Personalize Your Experience and Marketing
    • To improve your experience and personalize the Platform.
    • To customize marketing content and measure performance of any email, push notification, or in-app message we may send to you.
    • Administer contests or other promotional activities or events sponsored or managed by Repost or its partners.
    • Use automated systems and decision making to profile user characteristics and infer preferences based on information that you provide to us, your interactions with the Platform, your profile information, and information obtained from third parties. This data is used to create groups of users, called segments, who share similar characteristics and interests; we use segments to serve personalized marketing messages. We also use automated systems to associate your activity over time across devices, and may associate activity and accounts under a single user ID, in order to determine that certain devices are related to each other and provide you with a personalized experience across devices and platforms.
    • To deliver targeted marketing for Repost products on and off the Platform and measure the success of those campaigns. When you see our ads on a third party website or apps, we or third party services we engage for this purpose, may collect information that your browser or mobile app makes available when seeing the ad (e.g., IP address, referral URL, browser details, timestamp of request), including whether a click converted to an actual purchase. Please refer to the privacy policy of such third party websites to understand what data may be collected and how to opt-out.
    • Combine information we collect about you with information from business partners and use it to serve more relevant marketing messages and offers.

We may use your data for other purposes, provided we disclose the purposes and use to you at the relevant time, and provided that you consent to the proposed use of your personal data.

Sharing of Your Information

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

  • Through Your Account - In the event you choose to grant other users access to your Repost account, or in the event you set up our Split Pay feature, some personal information, such as your name and email address, will be available to those users. Additionally, if you use SC Planner, your SC Planner profile will be visible to other users in the “Leaderboard” section of the App, unless you elect to make your profile invisible in your settings.
  • With Your Consent - We will disclose your information if you have specifically agreed that we may do so. We will make this clear to you at the point at which we collect your information, including the purpose(s) for which we will use the personal data.
  • Service Providers - We use a variety of third party service providers to provide services to us or to our users on our behalf. These service providers have access to your information 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 at our written direction and then only to the extent necessary to provide their services to us. We share your personal information with such service providers based on our legitimate interests and in order to ensure the adequate performance of our contract with you.
  • Consumer Stores - The Platform allows you to distribute and share a variety of content with Consumer Stores. We may share information with these Consumer Stores that license this content to help them understand how the content you provide is performing, including insights about general user listening trends and preferences. We use technical measures to ensure the data is de-identified and/or aggregated so it does not identify you directly. We share this data based on our legitimate interest in helping Consumer Stores deliver high performing content and to ensure the fulfillment of our contract with those partners.
  • Social Media - For Repost users outside of the EU/EEA, where permissible under applicable law, we may share your email address (in hashed form, so that it does not identify you) with Facebook in order to target you with ads for Repost products on Facebook, including using Custom Audiences, and on third party websites and applications in the Facebook Audience Network. We may also allow Facebook and other social media platforms to collect information through cookies and similar technologies like pixels in order to serve ads for Repost products and services on those third party websites and apps and drive users to our Platform. In order to measure the effectiveness of and optimize these marketing campaigns, these technologies track activity taken across devices after a user sees a Repost ad, in order to determine performance metrics like sign ups, visits to the Platform, and purchases. We undertake these activities based on our legitimate interest in acquiring new customers and offering products we think you may be interested in. Any questions regarding how these social media platform service providers processes your personal data should be directed to such third party platform.
  • Aggregated Data - We may also share aggregated information (information about our users that we render in such a way that it no longer identifies or references an individual user) and other pseudonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and business development, and other business purposes.
  • Third Party Applications - To the extent Repost allows you to connect your account or link information from your account with other third party applications and you choose to do so, you may be sharing certain information, including personal data, with such applications.
  • Compliance with Laws - We may disclose your information 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 Repost, (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 Service and other agreements with users, or (v) to protect the rights, property or personal safety of Repost, its employees, and members of the public.
  • Protecting Our Rights - We may disclose your information if we feel this 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 Repost community.
  • To Our Affiliates - To enable and support us in providing the Platform and Services, we may share your personal information with the SoundCloud Group, as defined in SoundCloud’s Privacy Policy. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Platform globally.
  • Change of Control - We may also share your personal data as part of a sale, merger or change in control of Repost or its Affiliates, 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 data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

Cookies and Similar Technologies

  • What Are Cookies and Similar Technologies - Like most companies, when you visit or interact with the Platform, we and our service providers may place small text files known as “cookies” and other tracking technologies which are used to record storing information on your device about your activity on the Platform, including pixels (also known as a “web beacon” or “clear GIFs”), local storage, and device identifiers, to help provide, protect, and improve the Platform. For example, to save your preferences, personalize your experience, target you with ads for Repost products and services, combat fraud and abuse, and streamline the functioning of and your access to the Platform. Cookies can be “persistent” or “session” cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. A pixel is a small amount of code on a web page or in an email notification that typically work in conjunction with cookies to identify our users and record user behavior. As many services do, we use pixels to learn whether you’ve interacted with certain web or email content. This helps us measure and improve our services and personalize your experience. Local storage is an industry-standard technology that allows a website or application to store information locally on your computer or mobile device. We use local storage, including HTML5, to customize what we show you based on your content consumption and other past interactions with the Platform. We also use mobile device identifiers for the same purposes articulated in this policy, for example to recognize your device when you return to the Platform or otherwise use the Platform. We use “cookies” and “similar technologies” interchangeably to refer to all of these technologies throughout this Privacy Policy.
  • How We Use Cookies - While we use cookies to deliver, measure, and improve the Platform in various ways, the cookies we use generally fall into one of the following categories:
    • Operational - These cookies are necessary to allow us to operate the Platform as you have requested. For example, they let us authenticate your account and recognize what type of subscriber you are, so we can provide you with the Platform accordingly.
    • Security/Abuse - These cookies enable and support our security features and help us detect malicious or unauthorized activity. We also use cookies to combat fraud and other activity that violates our policies or otherwise degrades our ability to provide the Platform. Cookies also help us fight spam and phishing attacks by enabling us to identify computers or devices that are used to create fake Repost accounts or the like.
    • Functional/Preferences - These cookies let us operate certain functions of the Platform in line with the choices you make. These cookies enables us to remember you in-between visits. For example, when you continue to use or come back to the Platform, we will recognize your user name and remember your settings and content preferences. Deletion of these types of cookies will result in limited functionality of the Platform.
    • Performance/Analytics - We use these cookies to monitor and assess how the Platform is performing and where it can be improved. For example, we use these cookies to test different versions of our Platform to learn which features or content users prefer. We also use these cookies to analyse how people access and use our Platform. For instance, we may obtain information about your device and how users engage with the Platform or from email newsletters, including whether you opened or forwarded a newsletter or clicked on any of its content. This information tells us about our newsletters’ effectiveness and helps us ensure that we’re delivering information you find interesting.
    • Repost Marketing - We also work with third party business partners, such as Google and Facebook to track user activity and market the Platform by showing you personalized ads for Repost products and services on the Platform and third party websites and applications. We also use cookies to prevent subscribers from seeing ads for any Repost products they have already purchased.
  • Third Party Cookies - We allow certain service providers to place cookies and similar technologies on the Platform for the same purposes listed above, including collecting information about your online activities over time and across different websites and devices in order to provide you with more relevant advertising. For instance, to help us better understand how people engage with the Platform, we work with third party analytics partners, including Google Analytics. To opt out of Google Analytics, you may install the Google Analytics Opt-Out Browser here. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. You may also encounter cookies and tracking technologies from our third-party marketing service providers, including (1) Facebook to provide marketing services through Facebook’s advertising platforms (e.g. Audience Network, Custom Audiences, and Facebook Pixel) and other social networks, and (2) Google to provide marketing services through Google’s search advertising platforms (e.g. Adwords). Please refer to the Privacy Policy for how to opt out of cookies from these service providers. Third-party cookies are covered by the third parties’ privacy policy.

"Do Not Track Signals"

Your browser settings may allow you to automatically transmit a “Do Not Track” signal. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we are not configured to respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

Information Security

Repost maintains appropriate technical, administrative, and physical safeguards that are designed to prevent unauthorized access, use or disclosure of personal information 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. Repost regularly monitors our systems for possible vulnerabilities and attacks. However, it is not possible to guarantee the security of information transmitted over the Internet. You use the Platform and provide us with information at your own discretion and risk.

International Data Transfers

The Platform is operated in the United States. If you are located in the European Union (EU) or European Economic Area (EEA), please be advised that Information collected within the EU or EEA may, for example, be transferred to and processed in countries outside of the EU or EEA for the purposes as described in this Privacy Policy. By using the Platform or providing personal information, you hereby consent to this transfer, processing and storage of your personal information in the United States.

Use of Repost By Children

Repost is not intended for use by children. We do not knowingly collect any personal information from any person who is under the age of 16 in the EU or EEA, or 13 in the United States and throughout the rest of the World, as the case may be, or allow them to register an account without obtaining parental consent in accordance with applicable law. If it comes to our attention that we have collected personal data from a person under the age of 16 or 13 without parental consent, we will either obtain parental consent or delete this information as quickly as possible in accordance with applicable law. If you have reason to believe that we may have improperly collected any such personal data, please notify us immediately at dataprotection@repostnetwork.com.

Your Choices and Controls

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

  • Managing Repost Settings - Repost allows you to manage some of the information you share and the ways in which we communicate with you when you use Repost, including as further described below. Please note you are solely responsible for your choices and keeping your settings up-to-date.
    • Emails - Other than important service updates and essential notifications about the Platform or your account, you may opt-out of or unsubscribe from all Repost commercial emails and newsletters.
    • Updates - If you don’t want to receive products announcements and other Repost news and updates by email, you can adjust your settings accordingly under the Notifications Preferences tabs.
    • Marketing - If you do not want to receive personalized marketing messages for Repost products or services, or those of our partners, you can adjust your settings accordingly under the Notifications Preferences tab.
    • Deleting Your Account - Subject to the Terms of Service, if you would like to delete your account, you may do so by contacting us at support@repostnetwork.com. If you delete your account, data associated with your account (except for backup copies) will be deleted and may not be recoverable. We therefore advise you to copy or backup all Content uploaded to your account before deletion.
  • Managing Device Settings
    • To opt-out of location data collection that may occur when using our Apps, you can use the settings of your device.
  • Managing Browser Settings
    • You have a number of options to control or limit how we, our partners, and other third parties use cookies. However, note that cookies are important to certain aspects for the Platform – if you disable cookies, you may not be able to enjoy all of the features of the Platform. To control cookies, you can modify your settings as described below. in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that if you choose to block cookies, doing so may impair the Platform or prevent certain elements of it from functioning.

Exercising Your Rights

In some jurisdictions, including the EU or EEA, you may exercise the rights described in this section, by sending an email to dataprotection@repostnetwork.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 information held by us and that they be provided in machine-readable format.
  • Change or Correct Data
    • Where you cannot update data yourself through your account settings, you have the right to ask us to correct change, update or rectify your data.
  • Data Retention and Deletion
    • We generally retain data for as long as your account is in existence or as needed to provide the Platform. However, specific retention times can vary based on the context of the processing we perform and on our legal obligations.
    • You have the right to ask us to delete all or some of the personal data we hold about you, except to the extent such personal data is necessary to fulfill our obligations under the Terms of Service.
    • 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, or where we have a legitimate interest in doing so (e.g., to prevent fraud and abuse and maintain and enhance security).
  • Objection to Processing
    • You may object to processing your personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing).
    • If you object to such processing Repost will no longer process your personal information 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 information is processed for direct marketing purposes, you may, under certain circumstances, ask Repost to cease processing your data for these direct marketing purposes.
  • Restriction of Processing
    • Under certain circumstances, you may have the right to limit the ways in which we use your personal information.
  • Withdrawing Consent
    • Where you provide consent to specific processing of your personal information by Repost, you may withdraw such consent at any time by sending a communication to Repost 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 Repost before a competent data protection authority. A list of EU data protection authorities is available at:
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Contact Information

If you have questions or complaints about this Privacy Policy or our practices, please contact dataprotection@repostnetwork.com or write to us at 1516 S. Bundy Drive, Los Angeles, CA 90025, Suite 200/202.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time in 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: June 11, 2019