Privacy Policy

IntroductionVibe Music Corporation, 8 The Grn Ste A, Dover, DE 19901, USA (Overtune, we or our) is committed to protecting and respecting your privacy.  We will always aim to keep your personal data safe and private, never sell your personal data and allow you to manage and review your marketing choices at any time. 

1. About us and purpose of this privacy policy

This privacy policy sets out how we collect and process information about you which is personally identifiable when you use our Platform and services.  This privacy policy supplements other policies and is not intended to override them. 

2. Why you should read this

You should read this Privacy Policy because we collect and process personal data from you when you use our Platform and any other services we provide. 

3. The basis for the processing of your personal data

We must have a legal basis for using your personal data. Our legal basis is one or more of the following:

Legitimate interest

We process your personal data as necessary for our legitimate interests.  Our interests include providing an innovative and profitable Platform.  We will not process your information if your interests override ours.

Keeping to our contracts with you

We need certain personal data to provide our services and cannot provide them without this information.

Legal obligations

In some cases, we have a legal responsibility to collect and store your personal data.

Consent

Where you've agreed to us collecting your information, for example when you have ticked a box to indicate you are happy for us to use your personal data in a certain way.

4. The information we collect

Personal data means any information about an individual from which a person can be identified. It does not include data where the identity has been removed (anonymous data). This includes the information that you provide to us when registering with our Platform.  We will use the information you provide us to help us maximise your enjoyment of some of our services, for example through analysing your preferences to tailor the content you see where possible. 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
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Contact details – Includes your name and email address. 
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‍Profile information and preferences – Includes your password, your interests, preferences, feedback and survey responses. 
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‍Technical Data – When you use the services, we automatically receive and record information on our server logs from your browser or mobile platform, including the location, IP address, cookie information and details about the page you requested.  We also collect information regarding your use of our services, mobile device information and browser information.
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‍Usage Data – Includes information about how you use and interact with the Platform.
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‍Marketing and Communications Data – Includes your preferences in receiving marketing from us and third parties and your communication preferences.
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We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation or political opinions).  Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

5. Cookies
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree.  Cookies contain information that is transferred to your device hard drive.
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‍Website – Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
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‍Mobile apps – Our mobile apps do not use cookies.
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‍We use the following cookies on our website:Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping basket or make use of e-billing services
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‍Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
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‍Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of city or events viewed).
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‍Targeting cookies – These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Where a marketing purpose is pursued in this regard, we will ask for your consent first.
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You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. 
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6. Use of your personal data
We collect and use the personal data in a manner that is consistent with this Privacy Policy. We may use the personal data as follows: 

• To provide you with access to our Platform and services.
• To contact you when it is necessary to discuss anything relating to the services. 
• To provide customer service, including responding to your queries. 
• To share with another business in the context of a corporate transaction such as a sale or an investment.
• In order to tailor our services appropriately, we may undertake profiling of you on the basis of our legitimate interests. For example, showing you content that we think will be of interest to you.
• To monitor your use of the Platform and investigate any complaints or potential breaches of use of contract.
• To notify you of any changes to our Platfor, or respond to any communications you send us by using the contact details you have provided.
• For other purposes to which you may consent from time to time.
• To comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.

7. Notifications and Marketing. Notifications We may send you notifications including email, text and push notifications.  We will always give you the option to opt-out of receiving notifications by following the unsubscribe instructions on communications sent to you in each communication.
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Service messages. If necessary, we may send you service messages regardless of your preference settings.
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‍Third party marketing. If you have consented to receive information and offers, we may allow carefully selected third parties to send you information directly which you may find useful regarding their products and services.  If you decide to engage with such third parties please note that their terms and conditions and privacy policy will then apply.
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‍Advertisements. We may display advertisements or promotions for our commercial partners on our Platform.
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‍Other Purposes. If we intend to use any personal data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the personal data is collected or we will obtain your consent subsequent to such collection but prior to using it.

8. Your control of your informationThe information you submit is within your complete control.  All of this can be controlled by contacting us.
We will not sell your personal data to anyone without your explicit consent.  However we may share your personal data in accordance with applicable data protection laws and as described below:
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Agents and suppliers – We may employ other companies and individuals to perform functions on our behalf, including payment processing suppliers, development partners and data analytics services providers. We do not share your personal data with our agents or suppliers except as is necessary in order to enable them to provide us with a service.
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Other users – Some of your personal data may be visible to other users of the Platform for example your username.  You should be careful with what data you share via the Platform.
Hosting – We may share your personal data with cloud storage providers.
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Analytics tools – We may share your personal data with analytics and search engine providers.
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Administration, customer service and support tools – We may share your personal data with support tool providers.

Emails, SMS and other communication tools – We may share your personal data with communication tools.

CRM – We may share your personal data with CRM providers.

Payment processing – We may share your personal data with online payment processing providers.

Affiliate companies – This may be other companies within the Overtune group or a potential acquirer or investor.

9. Protecting your personal data
We recognise the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.

Your data is backed up to servers in different geographical locations in order to provide resilience against fire or other disasters.

When moving your data we protect it with multiple layers of security, including leading encryption technology like HTTPS and Transport Layer Security.

No credit or debit card information is stored on our servers.

We use a variety of physical and technical measures to keep your personal data safe and prevent unauthorised access to or use or disclosure of it. We have detailed security and data protection policies which staff are required to follow when they handle your personal data.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our platform and any transmission is at your own risk.

10. Retention of your personal data

We may retain your data for as long as we require for the purposes for which it is processed or as is otherwise required by applicable law. If you terminate your account or our agreement with you under the Terms of Use is terminated, your personal data will be deleted as required under applicable law.

When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed. Once processing has been completed, we may securely delete your personal data.

We may delete accounts or specific information before account deactivation where we believe it may no longer be relevant or where an account has been inactive for a period of a year or more.

11. Your rights

You may request details of the personal data that we hold about you. If you would like a copy of the information held about you, please email us at support@overtune.com.
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If you think any information we have about you is incorrect or incomplete, please write to us or email us at support@overtune.com as soon as possible. We will correct or update any information as soon as we can.
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You have the right to erasure of your data, which you can exercise by means of the deactivation of your account. We are not required to delete the information important for the establishment, exercise or defence of legal claims, or that we need to retain in order to comply with the law.
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You have the right to withdraw your consent to our processing of your personal data at any time.  If you would like to do so please email us at support@overtune.com.

We may amend this policy to reflect any changes to the service. We will let you know about any major changes via email or a notification on the Platform.

12. Complaints

Feel free to contact us if you have any questions, complaints or require a copy of information we hold about you. Should we be unable to resolve your complaint, you may take it further by contacting your local data protection regulator. 
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Last updated: 28 June 2022