PRETZEL PRIVACY POLICY

Our Commitment to Privacy

This Privacy Policy describes the ways in which Pretzel (“we,” “our,” or “us”) collects, uses, and shares information about you through the services offered by Pretzel including the licensing marketplace platform(s) located at www.pretzel.rocks (the “Site”) and any services, features, content, and applications offered from time to time by Pretzel in connection with the Site, and any other future website(s) and/or digital applications controlled or operated by Pretzel or its affiliates, whether accessible via personal computer, mobile device or otherwise (each, a “Service,” and collectively, the “Services”)

The information that you provide us may include a) your name, address, contact information, username, email address, and other registration information; and b) transaction-related information, such as payment or account information, licensing information, or information about when you make purchases or respond to offers. The information that you provide us with respect to payments, purchases or trials may include a) credit or debit card type, b) expiration date, and certain digits of your card number, c) ZIP/postal code, d) mobile phone number, and e) details of your purchase and payment history.

Information We Collect Automatically – We and our service providers automatically collect certain technical information from your computer or mobile device when you access and/or use the Site and/or Services. That information includes a) your Internet Protocol address, b) your browser type and your operating system, c) the pages or content you access, use, view or listen to on the Site and/or Services, d) the pages you view immediately before and after you access the Site and/or Services, e) unique identifiers associated with the devices you use to access the Site and/or Services, f) the search terms you enter on the Services, g) the URL that referred you to the Site and/or Services, and h) standard weblog information.

We and our service providers may collect this information using “cookies,” “web beacons,” and similar technologies. Cookies are small text files that the Services save on your computer or device and access when you return. Cookies can be used to recognize repeat visitors, facilitate your ongoing access to and use of the Site and/or Services, and allow the Site and/or Services to collect information about how the Site and/or Services are used. If you do not want the Site and/or Services to collect information through the use of cookies, most browsers allow you to deny or accept cookies. See your browser’s help menu for more information. Web beacons are small snippets of code embedded in webpages and are typically used to monitor activity on the webpage, collect information, or transfer information to services. Please see our “Cookies Policy” for more information.

Information from Other Sources – We collect information from you and third-party sources and combine it with the information described above. Specifically, we collect information from you about your UGC channels, including but not limited to, types of videos, number of views, and information about viewers of such videos, the number of your UGC channels, subscriber count and other attributes (such as listening data) associated with your UGC channel accounts (such as Twitch, YouTube, Spotify, Facebook, and Instagram), if you allow for integration of those accounts. We may also collect your company data from third party content management systems such as YouTube

We also collect additional contact information from Twitch, Facebook and Google (sign up and/or login using Twitch, Facebook and Google).

If available on the Site, you may be able to use third party login credentials (e.g., Twitch, Facebook and Google) to access the Services. When you do so, we will collect information from the third party associated with the login credentials. You may be able to control the information that the third party shares with us by changing the privacy settings for your account with that third party.

We engage third party service providers to process payments and payment information as well as to make relevant payment methods available to users of the Services. We may obtain data from these service providers. This allows us to process your payment and provide you what you purchased.

We may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations.

How do we use this information?

We, our affiliates, subsidiaries, and service providers use the information we collect for the following purposes:

• providing you with products, services, or information you request;
• facilitating transactions between us, you, and other users;
• providing you with information about the Services;
• contacting you with notices that we are required by law to send;
• where allowed by law, or with your consent, delivering marketing communications, promotional materials, or advertisements that may be of interest to you, including the delivery of targeted advertisements that are based on your previous activities on the Site and/or Services and other websites or applications (e.g., if you access a certain song on our Site and/or Services, you may receive an online advertisement for that song or a related product or service on the Site and/or Services or other websites);
• personalizing the Services based on your interests, such as by providing interactive or tailored content on the Services based on the music you have licensed or the content you have accessed;
• improving the Site and/or Services, such as by learning how our users interact with the Site and/or Services or better tailoring our content to users’ needs and preferences;
• generating and analyzing statistics to understand how people use the Site and/or Services;
• helping advertisers and sponsors better understand our users; and
• detecting, investigating, preventing, and responding to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Site and/or Services.

We also may combine or aggregate any of the information we collect through the Site and/or Services or elsewhere for any of these purposes, including delivering targeted advertisements that are based on your previous online activity on the Site and/or Services and on other websites.

On what basis do we process your information?

For those of you in certain jurisdictions like within a European Union member country, we provide here the legal basis for processing your personal information in accordance with applicable law. In most cases the legal basis will be one of the following:

• to fulfil our contractual obligations to you or for precontractual measures, for example when we license music to you;
• to comply with our legal obligations, for example if we are required to report royalty payments to a regulatory body or to comply with a law enforcement subpoena, a court order, or agency request for information;
• to meet our legitimate interests, for example to ensure that the Site and/or Services operate as intended and are appropriate for your needs, that our Site and/or Services function correctly with your systems, that our records are kept up to date and accurate, and to communicate with you regarding the Site and/or Services; or
• consistent with your consent, for example, if applicable law requires consent for our marketing communications containing third party offers or where you are not a customer of ours.

Under what circumstances do we share this information?

We share the information we collect from you:

• with our affiliates and subsidiaries;
• with service providers that work on our behalf and that have agreed to use the information solely in furtherance of our operations; to provide order and payment processing services; deliver marketing communications, promotional materials, or advertisements that may be of interest to you; analyze how people use the Site and/or Services; or host our Site and/or Services;
• with business partners that deliver marketing communications, promotional materials, or advertisements that may be of interest to you;
• with companies such as online network advertisers that may automatically collect or receive information about your online activities over time and across different websites when you use the Site and/or Services, in order to facilitate the delivery of marketing communications, promotional materials, or advertisements, including targeted advertising for our or others’ products and services on our Services and on third-party sites and applications;
• with marketing partners or others for joint or co-branded promotions;
• to comply with a subpoena or other legal process, or to comply with government reporting or other legal obligations;
• when we believe in good faith that disclosure is necessary a) to protect our rights, the integrity of the Site and/or Services, or your safety or the safety of others, or b) to detect, prevent, investigate, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Site and/or Services; and
• with affiliates, service providers, advisors, and other third parties to the extent we deem reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets, or similar transaction.
• We may also be able to share information about your activities on Pretzel with social media platforms, and other third-party services.
• In addition, we may share de-identified reports on user demographics and traffic patterns, as well as de-identified information, with third parties.
• The Site and/or Services may contain links to third-party websites or other content. You acknowledge and agree that we are not responsible for the collection and use of your information by third parties that are not under our control. We encourage you to review the privacy policies of each website, service, and application you use.

Where is this information transferred and processed?

We process the information associated with the Services and governed by this Privacy Policy in the United States, which may not provide the same level of protection for your personal information as your home country. We store the information in the United States, and the information may be available to the United States government or its agencies under a lawful order made in the United States. We also transfer your information outside the United States to our affiliates, business partners, and service providers located in the United Kingdom, The Netherlands, Germany, Poland, Singapore, Australia, the Philippines, Hong Kong and China. We have put in place certain safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information. For more information on the appropriate safeguards in place and to obtain a copy of such safeguards, please contact us at the contact information set forth below.

Security

We strive to maintain reasonable administrative, technical, and physical safeguards designed to safeguard the information collected by the Site and/or Services. However, no information system can be 100% secure; we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Site and/or Services over networks that we do not control, including the Internet and wireless networks.

Your choices

If your contact information changes or if you wish to inquire about the information we have collected about you, please submit a request at the contact information listed below. You may “opt-out” of receiving marketing emails by using the unsubscribe feature included in the emails or, if available, registering your preferences on your Customer Account Page.

If you do not want the Site and/or Services to collect information through the use of cookies, you can set your web browser to reject cookies from the Site and/or Services. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. If you reject or block cookies from the Site and/or Services, however, the Site and/or Services may not function as intended. In addition, you can register your choices about how certain companies, including us, collect information about your online activities over time and across various websites by using certain third party tools.

Your rights

In addition, you may have certain rights regarding your personal information, subject to local law. These include the following rights to:

• access your personal information;
• rectify the information we hold about you;
• erase your personal information;
• restrict our use of your personal information;
• object to our use of your personal information;
• receive your personal information in a usable electronic format and transmit it to a third party (right to data portability);
• lodge a complaint with your local data protection authority; and,
• where the processing of your information is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Please note that we will likely require additional information from you in order to honor your requests.

If you would like to discuss or exercise such rights, please contact us at the details provided below.

Data Retention

We will keep your personal information for as long as we have a relationship with you for the purposes of providing the Site and/or Services. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators' expectations. We may also retain records to investigate or defend potential legal claims.

YouTube API Services

Pretzel’s API Client uses YouTube API Services. The service is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, United States. YouTube, LLC is a subsidiary of Google Inc. If you are using our Services, you certify that you have read and agree to the YouTube Terms of Service and the Google Privacy Policy.

In addition to Pretzel’s normal procedure for deleting stored data, you can revoke Pretzel’s API Client access to you data using the Google security settings page at https://security.google.com/settings/security/permissions.

Google Analytics

We use a tool called "Google Analytics" to collect information about use of this Site and/or Services. Google Analytics collects information such as how often users visit this Site and/or Services, what pages they visit when they do so, and what other sites they used prior to coming to this Site and/or Services. We use the information we get from Google Analytics to improve this Site and/or Services. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site and/or Services, the cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google Analytics about your visits to this Site and/or Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

Automated decision-making

We may make automated decisions about you based on your personal information in the following circumstances:

Previous activity on Pretzel, including previous licensing activity on Pretzel, number of streams and/or downloads on Pretzel or other distributed 3rd party streaming and download platforms and social media followers and/or subscribers.

Subject to local legal requirements and limitations, you can contact us to object to our use of automated decision-making.

Children’s information

We do not knowingly collect information from children under the age of 13. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below.

Changes to this Privacy Policy

If we update this Privacy Policy, we will post a new Privacy Policy on this page. If we make any revisions that materially change the ways in which we process your personal information, we will notify you of these changes before applying them to that personal information.

Contact us

Pretzel is the controller responsible for the personal information we collect and process. If you have any questions about this Privacy Policy or our use of your information collected through the Site and/or Services, please contact us at:

Address: 8605 Santa Monica Blvd, PMB 40672,
West Hollywood, California, 90069-4109, US
Phone number: +1 424 744 8190
help@pretzel.rocks