Effective as of 30 May 2024

1. About this Policy

This Privacy Policy describes how we process your personal data at Ziki Tunes LTD. From now on, we’ll call it the ‘Policy’.

It applies to your use of:

All Ziki Tunes streaming services as a user. This includes:

• Your use of Ziki Tunes on any device
• The personalization of your user experience
• The infrastructure required to provide our services
• Connection of your Ziki Tunes account with another application
• Both our free or paid streaming options (each a ‘Service Option’)

Other Ziki Tunes services which include a link to this Policy. These include Ziki Tunes websites, Customer Service, and the Community Site

From now on, we’ll collectively call these the ‘Ziki Tunes Service’.

From time to time, we may develop new or offer additional services. They’ll also be subject to this Policy, unless stated otherwise when we introduce them.

This Policy is not:

• The Ziki Tunes Terms of Use, which is a separate document. The Terms of Use outline the legal contract between you and Ziki Tunes for using the Ziki Tunes Service. It also describes the rules of Ziki Tunes and your user rights.
• About your use of other Ziki Tunes services which have their own privacy policy.

Other resources and settings

Key information about your personal data is right here in this Policy. However, you might want to take a look at our other privacy resources and controls:

• Privacy Center: A user-friendly hub with summaries of key topics and helpful videos. It includes the ‘Your Privacy Controls’ video which shows you how to exercise your user rights and make choices about the way we process your data. See Section 2 ‘Your personal data rights and controls’ for more on user rights.
• Privacy Settings: Control the processing of certain personal data, including tailored advertising.
• Notification Settings: Set which marketing communications you get from Ziki Tunes.
• Settings: Control certain aspects of the Ziki Tunes Service such as ‘Social’ or ‘Explicit Content’.

Cookies Policy

Information on how we use cookies and how to manage your cookie preferences. Cookies are files saved on your phone, tablet, or computer when you visit a website.

2. Your personal data rights and controls

Many privacy laws give rights to individuals over their personal data. These laws include the General Data Protection Regulation, or ‘GDPR’.

Some rights only apply when Ziki Tunes uses a certain ‘legal basis’ to process your data. We explain each legal basis, and when Ziki Tunes uses each one, in Section 4 ‘Our purpose for using your personal data’.

Your rights

It’s your right to…

• Be informed: Be informed of the personal data we process about you and how we process it.
• Access: Request access to the personal data we process about you.
• Rectification: Request that we amend or update your personal data where it’s inaccurate or incomplete.
• Erasure: Request that we erase certain of your personal data.
• Restriction: Request that we stop processing all or some of your personal data.
• Object: Object to us processing your personal data.
• Data portability: 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.
• Not be subject to automated decision making: Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
• Withdrawal of consent: Withdraw your consent to us collecting or using your personal data.
• Right to lodge a complaint: Contact the local data protection authority about any questions or concerns.

Tailored advertising controls

This is when we use information about you to tailor ads to be more relevant to you. This is also known as interest-based advertising.

You can control tailored advertising in your account Privacy Settings under ‘Tailored Ads’.

3. Personal data we collect about you

Collected when you sign up for the Ziki Tunes Service or when you update your account

User Data: Personal data that we need to create your Ziki Tunes account and that enables you to use the Ziki Tunes Service. This may include your profile name, email address, password, phone number, date of birth, gender, street address, country, and university/college (for Ziki Tunes Premium Student).

Collected through your use of the Ziki Tunes Service

Usage Data: Personal data collected and processed about you when you’re accessing or using the Ziki Tunes Service. This includes information about your Ziki Tunes Service Option, your actions with the Ziki Tunes Service, technical data, and general location.

Additional data you may choose to give us: This includes voice data and payment and purchase data.

Third party sources that we receive your data from

Authentication partners: If you register for or log into the Ziki Tunes Service using another service, that service will send your information to us.

Third party applications, services and devices you connect to your Ziki Tunes account: If you connect your Ziki Tunes account to a third-party application, service or device, we may collect and use information from them.

4. Our purpose for using your personal data

We use your personal data for the following purposes:

• To provide the Ziki Tunes Service in accordance with our contract with you.
• To provide further parts of the Ziki Tunes Service.
• To provide certain additional voluntary features of the Ziki Tunes Service.
• To diagnose, troubleshoot, and fix issues with the Ziki Tunes Service.
• To evaluate and develop new features, technologies, and improvements to the Ziki Tunes Service.
• For marketing or advertising where the law requires us to collect your consent.
• For other marketing, promotion, and advertising purposes where the law does not require consent.
• To comply with a legal obligation that we are subject to.
• To comply with a request from law enforcement, courts, or other competent authorities.
• To fulfill contractual obligations with third parties.
• To take appropriate action with reports of intellectual property infringement and inappropriate content.
• To establish, exercise, or defend legal claims.
• To conduct business planning, reporting, and forecasting.
• To process your payment.
• To keep the Ziki Tunes Service secure and to detect and prevent fraud.
• To conduct research and surveys.

5. Sharing your personal data

Publicly available information

The following personal data will always be publicly available on the Ziki Tunes Service (except to any user you have blocked):

• Your profile name
• Your profile photo
• Your public playlists
• Other content you post on the Ziki Tunes Service, and any associated titles, descriptions, and images
• Who you follow on the Ziki Tunes Service
• Who follows you on the Ziki Tunes Service

Personal data you may choose to share

We will only share the following personal data with those outlined in the table below:

• Where you have chosen to use a Ziki Tunes Service feature, or a third party application, service or device, and we need to share personal data to enable this, or
• If you otherwise grant us your permission to share the personal data.

Information we may share

Service providers: So they can provide their services to Ziki Tunes.

Payment partners: So they can process your payments, and for anti-fraud purposes.

Advertising partners: So they can help us deliver more relevant advertising to you on the Ziki Tunes Service, and help measure the effectiveness of ads.

Marketing Partners: To promote Ziki Tunes with our partners.

Hosting Platforms: Hosting platforms host podcasts so that they can deliver them to you.

Academic researchers: For activities such as statistical analysis and academic study, but only in a pseudonymized format.

Other Ziki Tunes group companies, including companies that Ziki Tunes acquires: To carry out our daily business operations and so we can maintain, improve and provide the Ziki Tunes Service and acquired companies’ services to you.

Law enforcement and other authorities, or other parties to litigation: When we believe in good faith it’s necessary for us to do so.

Purchasers of our business: If we were to sell or negotiate to sell our business to a buyer or possible buyer.

6. Data retention

We keep your personal data only as long as necessary to provide you with the Ziki Tunes Service and for Ziki Tunes’ legitimate and essential business purposes, such as:

• Maintaining the performance of the Ziki Tunes Service
• Making data-driven business decisions about new features and offerings
• Complying with our legal obligations
• Resolving disputes

7. Transfer to other countries

Because of the global nature of our business, Ziki Tunes shares personal data internationally with Ziki Tunes group companies, subcontractors, and partners in order to provide the Ziki Tunes Service to you. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live.

8. Keeping your personal data safe

We’re committed to protecting our users’ personal data. We put in place appropriate technical and organizational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

9. Children

The Ziki Tunes Service has a minimum ‘Age Limit’ in each country or region. The Ziki Tunes Service is not directed to children whose age:

• Is under the age of 13 years
• Makes it illegal to process their personal data, or
• Requires parental consent to process their personal data

We do not knowingly collect or use personal data from children under 13 years