v3.3 Effective Date: April
1, 2024
Here at
Universal Music Group, we take your privacy seriously and we’re dedicated to
providing you with the best possible music experience. To do that, we collect
and use information about you to personalize our sites, stores, and marketing
communications. However, only you know what your best experience is, so we
provide fans with choices about how we collect, use and share your data.
This page
describes specific rights you may have based on where you live, but if you live
somewhere else you can still contact us and we will try to address any
questions or concerns.
To exercise any of
the rights described on this page, or to ask us a question about our data
collection practices, please contact us:
You can exercise
your right to opt out of targeted advertising and/or the sale of personal
information by clicking the “Cookie Choices” link at the bottom of the website
you are interacting with and disabling Online Advertising. You must do this on
each browser and each device you use in order to fully opt out.
US STATE RIGHTS
Residents of
Colorado, Connecticut, Utah, or Virginia have certain rights with respect to
their personal information, including the right to:
·
Confirm
whether we process the consumer’s personal information and to access such
information;
·
Correct
inaccuracies in personal information;
·
Delete
personal information;
·
Data
portability;
·
Opt
out from targeted advertising; and/or
·
Opt
out from the sale of personal information.
Residents of
Virginia, Colorado, and Connecticut have the right to opt out from profiling in
furtherance of decisions that produce legal or similarly significant effects
and to appeal decisions regarding a request to exercise their rights.
California
residents may opt out of having their personally identifiable information
shared with third parties for those third parties' direct marketing purposes by
contacting us as described above.
Do-Not-Track
Signals and Similar Mechanisms.
Some web browsers may transmit “do-not-track” signals to the websites and other
online services with which a user communicates. While there is no comprehensive
industry standard for such signals, certain websites UMG operates attempt to
recognize this signal and, if detected, limit our use of cookies and similar
tracking technologies. Unfortunately, due to the variation in browsers and
detection capabilities and the lack of accepted standards we cannot guarantee
that transmitting a “do-not-track” signal will result in our disabling cookies
and tracking technologies. We recommend using the cookie choices tools on our
sites to control UMG’s use of cookies and tracking technologies.
Personal Data We
Collect and Disclose
In the preceding
12 months, UMG collected and disclosed the following categories of personal
data. UMG shares personal data for targeted advertising but does not otherwise
engage in “sales” of personal data as defined by state laws.
Categories of
personal data |
Disclosed
to the following categories of third parties for business purposes: |
Shared
for targeted advertising purposes with the following categories of third
parties: |
Sold to the
following categories of third parties: |
Identifiers
such as real name,
alias, postal address, unique personal identifier, online identifier, IP
address, email address, account name, social security number, driver’s
license number, passport number, or other similar identifiers. |
UMG affiliates; Business
partners; Service
providers; and Advertising
companies. |
Our business
partners; Our service
providers; and Advertising
companies. |
Data enrichment
providers; |
Commercial
information, including products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies. |
UMG affiliates; Business
partners; Service
providers; and Advertising
companies. |
K.A. |
K.A. |
Gender, a
protected classification under California and federal law. |
UMG affiliates; Business
partners; and Service providers. |
Advertising
companies. |
K.A. |
Internet or
other electronic network activity information, including browsing history,
search history, and information regarding a consumer’s interaction with an
internet website, application, or advertisement. |
UMG affiliates; Business
partners; and Service
providers. |
Advertising
companies. |
K.A. |
Geolocation
data, generally derived from IP address location services, but could also
include presence in a geo-fenced area. |
UMG affiliates; Business
partners; and Service
providers. |
Advertising
companies. |
K.A. |
Audio,
electronic, visual, or similar information. |
Service
providers. |
K.A. |
K.A. |
Inferences
drawn from any of the information identified in this subdivision to create a
profile about a consumer reflecting the consumer’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes. |
UMG affiliates; Business
partners; Service
providers; and Advertising
companies. |
Advertising
companies. |
K.A. |
Other
information about you that is linked to the personal information above |
UMG affiliates; Business
partners; Service
providers; and Advertising
companies. |
Advertising
companies. |
K.A. |
Categories of
Sources:
We collect
personal data from:
·
Individuals
who provide information directly;
·
Affiliates
and business partners, which may include third parties;
·
Third-party
data providers and data brokers;
·
Service
providers; and
·
Advertising
companies.
Business or
Commercial Purposes for Processing Personal Data:
We use
and disclose the personal data as described above in the “How Your Information
May Be Used” section of our privacy
policy.
Your Rights:
Residents of
certain states have rights with respect to the personal data collected by
UMG. You may be able exercise the
following rights regarding your personal data:
UMG
does not knowingly sell or share personal data of individuals younger than 16.
Depending on your
state, if you have submitted a request that we have not reasonably fulfilled,
you may contact us to appeal our decision by sending an email with the subject
line “Appeal” to [email protected].
Verification
We may take steps
to verify your identity before completing your request. Our verification
measures vary based on the risk to the individual and may involve confirming
access to the relevant email account, providing a government-issued ID or other
identification documents, or providing other account details or information
that indicates a valid request.
Authorized Agent
You may also
designate an authorized agent to requests on your behalf by
designating such an agent in writing or through a power of attorney. We will
require the agent to provide us with proof that you have authorized the agent
to make requests on your behalf prior to accepting requests from the agent.
EUROPEAN AND UK RIGHTS
This section
of this Privacy Policy applies only if you use the App or UMG websites from a
country that is a Member State of the European Economic Area and supplements
the information in this Privacy Policy.
You may be
entitled, subject to validation of your identity and in accordance with
applicable law, to:
· Confirm
whether we process the consumer’s personal information and to access such
information;
· Correct
inaccuracies in personal information;
· Delete
personal information;
· Data
portability;
· Withdraw
consent you have previously given; and/or
· Object to or
request the restriction of processing of your personal data.
You may also
be entitled, in accordance with applicable law, to lodge a complaint with a
supervisory authority if you consider that our processing of your personal data
infringes applicable law.
Legal Basis
for Data Processing: We process personal data for the purposes set out in the
relevant privacy policy. Our legal bases to process personal data includes
processing that is: necessary for the performance of the contract between you
and us (for example, to provide you with the services you request and to
identify and authenticate you so you may use the App); necessary to comply with
legal requirements (for example, to comply with applicable accounting rules and
to make mandatory disclosures to law enforcement); necessary for our legitimate
interests (for example, to manage our relationship with you and to improve the App);
and based on the consent of our customers (for example, to communicate with you
about our products and services and provide you with marketing information),
which may subsequently be withdrawn at any time (by using preference settings
found in our emails/Apps or by contacting UMG as described above) without
affecting the lawfulness of processing based on consent before its withdrawal.
We may use
automated decision-making technologies, including profiling, to support our
data processing activities. Our automated decision-making capabilities include
logic that attempts to identify artists, music, communications, products, or
offers that we believe may interest you. By using this logic, it helps us
personalize your interactions with UMG and UMG artists. For you, this means
that you may see online advertisements, direct marketing communications (if you
have subscribed), or other advertising or marketing messages or special offers
based on your activity on our Apps or interactions with UMG Companies or our
third-party partners.
In some
instances, you may be required to provide us with personal data for processing
as described above, for us to be able to provide you to use all the features of
the App.
International
transfers
Our sharing
your personal data in accordance with this Privacy Policy, may involve
transferring your data outside the European Economic Area (EEA). Whenever we
transfer your personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by certifying, where required by law, at least one
of the following safeguards is implemented:
· transferring
personal data to countries that have been deemed to provide an adequate level
of protection for personal data by the European Commission;
· consent of the
individual;
· adherence to
the EU-US Data Privacy Framework, the Swiss-US Data Privacy Framework, and UK
Extension to the EU-US Data Privacy Framework (see details below); or
·
using specific contracts approved by the European
Commission which give personal data the same protection it has in Europe.