Bone Pool Radio Privacy Policy, Effective as of October 9, 2018
1. Introduction
Thanks for choosing Bone Pool Radio (“BPR”)!
At BPR, we want to give you the best possible experience to ensure that you enjoy our service today, tomorrow, and in the future. Your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.
That is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.
2. About this Policy
This Policy sets out the essential details relating to your personal data relationship with BPR.
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
The aim of this Policy is to:
• Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
• Explain the way we use the personal data that you share with us in order to give you a great experience when you are using BPR; and
• Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ Section 14’ below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use BPR.
3. Your rights and your preferences: Giving you choice and control
You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. As available and except as limited under applicable law, the rights afforded to individuals are:
• Right of Access - the right to be informed of and request access to the personal data we process about you;
• Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
• Right to Erasure - the right to request that we delete your personal data;
• Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to Object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
• Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
• Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
4. How do we collect your personal data?
When you sign up to BPR, we collect your email address.
We use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving BPR, and developing new features and functionality within BPR.
5. What personal data do we collect from you?
When you sign up to BPR, we may collect your email address.
6. What do we use your personal data for?
When you use or interact with BPR, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data used for these purposes:
01. Description of why BPR processes your personal data (‘processing purpose’)
To provide, personalize, and improve your experience with BPR, for example by providing customized, personalized, or localized content, recommendations, features, and advertising on or outside of BPR (including for third party products and services).
Legal Basis for the processing purpose
Performance of a Contract, Legitimate Interest
Categories of personal data used by BPR for the processing purpose
Account Registration Data, Service Usage Data
02. Description of why BPR processes your personal data (‘processing purpose’)
To understand how you access and use BPR to ensure technical functionality of BPR, develop new products and services, and analyze your use of BPR, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through BPR.
Legal Basis for the processing purpose
Performance of a Contract, Legitimate Interest
Categories of personal data used by BPR for the processing purpose
Account Registration Data, Service Usage Data
03. Description of why BPR processes your personal data (‘processing purpose’)
To communicate with you for BPR-related purposes.
Legal Basis for the processing purpose
Performance of a Contract, Legitimate Interest
Categories of personal data used by BPR for the processing purpose
Account Registration Data, Service Usage Data
04. Description of why BPR processes your personal data (‘processing purpose’)
To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of BPR.
Legal Basis for the processing purpose
Performance of a Contract, Compliance with legal obligations , Legitimate Interest
Categories of personal data used by BPR for the processing purpose
Payment Data
05. Description of why BPR processes your personal data (‘processing purpose’)
To communicate with you, either directly or through one of our partners, for: Marketing, research, participation in contests, surveys and sweepstakes, promotional purposes
Legal Basis for the processing purpose
Consent, legitimate interest
Categories of personal data used by BPR for the processing purpose
Contests, Surveys and Sweepstakes Data, Marketing Data
Voluntary Mobile Data
If you require further information about the balancing test that BPR has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see ‘How to Contact Us’ Section 14’ below for further details on how to contact us.
7. Sharing your personal data
We have set out the categories of recipients of the personal data collected or generated through your use of BPR.
• Information we may share
• Categories of Recipients
• Reason for sharing
• Service Providers and Others
We use technical service providers which may operate the technical infrastructure that we need to provide BPR, in particular providers which host, store, manage, and maintain the BPR application, its content and the data we process.
We use technical service providers to help us communicate with you, as described in Section 6 of this Policy. We use marketing and advertising partners to show you more
Categories of Recipients
Reason for sharing
BPR Partners
Academic Researchers
Other BPR Group Companies
Law Enforcement and Data Protection Authorities
Purchasers of our business
tailored content, or to help us understand your use of BPR, to provide you with a better service. We also may share personal data with certain marketing and advertising partners to send you promotional communications about BPR.
We may share your personal data in a pseudonymised format with our music industry partners to help them understand how the content they license to us is performing and to enable you to listen to streaming content via BPR.
We also share your personal data in a pseudonymised format with marketing partners who help us with promotional efforts and with advertisers that allow us to offer a free service.
We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format.
We will share your personal data with other BPR Group companies to carry out our daily business operations and to enable us to maintain and provide BPR to you.
We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena.
We also will also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, BPR will continue to ensure the confidentiality of your personal data and give you notice before your personal data is
Categories of Recipients
Reason for sharing
transferred to the buyer or becomes subject to a different Privacy Policy.
*8. Data retention and deletion*
We keep your personal data only as long as necessary to provide you BPR and for legitimate and essential business purposes, such as maintaining the performance of BPR, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.
If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
*9. Transfer to other countries*
BPR shares your personal data globally in order to carry out the activities specified in this Policy. BPR may subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.
Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances BPR shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
For further details of the security measures we use to protect your personal data, please see the ‘Keeping your personal data safe’ Section 11 of this Policy.
*10. Links*
We may display advertisements from third parties and other content that links to third- party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving BPR and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.
*11. Keeping your personal data safe*
We are committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
*12. Children*
BPR is not directed to children under the age of 13 years. However, in some countries, stricter age limits may apply under local law.
We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use BPR, and do not provide any personal data to us.
If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to BPR, please contact us.
If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data.
*13. Changes to this Privacy Policy*
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within BPR or by sending you an email. We may notify you in advance.
Please, therefore, make sure you read any such notice carefully.
*14. How to contact us*
Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact us by writing to us at the following address:
Bone Pool Radio, LLC 31 Roosevelt Road Maplewood, NJ 07040 USA
We hope you enjoy BPR!