TREBEL PRIVACY POLICY

Effective as of January 1, 2020

This privacy policy governs your use of the software application TREBEL MUSIC (“Application”) for mobile devices that was created by M&M Media, Inc. TREBEL MUSIC is a mobile music application that allows users to search, preview, and download music for consumption on the mobile device.

Table of Contents

  1. User Provided Information
  2. Automatically Collected Information
  3. Does the Application collect precise real time location information of the device?
  4. Do third parties see and/or have access to information obtained by the Application?
  5. Automatic Data Collection and Advertising
  6. What are my opt-out rights?
  7. Data Retention Policy, Managing Your Information
  8. Children
  9. Security
  10. Your Consent
  11. Contact us
  12. Additional California Privacy Disclosures

1. User Provided Information

The Application obtains the information you provide when you download and register the Application. Registration with us is mandatory in order to be able to use the basic features of the Application. When you register with us and use the Application, you generally provide (a) your name, email address, age, user name, password and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications or content from us; (c) information you provide us when you contact us for help; and; (d) information you enter into our system when using the Application, such as contact information and other information that may relate to your tastes and preferences about digital content, your social network friends, age, gender, and other personal information. We may use the information you provided us to contact you from time to time to provide you with important information, required notices, and marketing promotions.

2. Automatically Collected Information

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application. Application has a “filters” feature which uses depth and facial mapping tools provided by augmented reality programming interface. Data collected from depth and facial mapping tools are not used for advertising or other use-based data mining purposes, and are not permanently stored or shared with third parties.

3. Does the Application collect precise real time location information of the device?

When you visit the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order todetermine the city you are located within and display a location map with relevant advertisements and places to check-in to. We will not share your current location with other users or partners, for purposes other than delivering relevant advertising. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.

4. Do third parties see and/or have access to information obtained by the Application?

Yes. We will share your information with third parties only in the ways that are described in this privacy statement. We may disclose User Provided and Automatically Collected Information:

  • as required by law, such as to comply with a subpoena, or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
  • if M&M Media is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
  • to advertisers and third party advertising networks and analytics companies as described in the section below

5. Automatic Data Collection and Advertising

We may work with analytics companies to help us understand how the Application is being used, such as the frequency and duration of usage. We work with advertisers and third party advertising networks, who need to know how you interact with advertising provided in the Application which helps us keep the cost of the Application free or low. Advertisers and advertising networks use some of the information collected by theApplication, including, but not limited to, the unique identification ID of your mobile device and your mobile telephone number. To protect the anonymity of this information, we use an encryption technology to help ensure that these third parties can’t identify you personally. These third parties may also obtain anonymous information about other applications you’ve downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., your zip code), and other non- precise location information in order to help analyze and serve anonymous targeted advertising on the Application and elsewhere. We may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis or advertising related use. We use third-party advertising companies to serve ads when you visit our Web site or user TREBEL MUSIC app. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see: http://www.networkadvertising.org/ managing/opt_out.asp

6. What are my opt-out rights?

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

7. Data Retention Policy, Managing Your Information

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the Application, please contact us at [email protected] and we will respond in a reasonable time frame. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

8. Children

We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected] We will delete such information from our files within a reasonable time.

9. Security

We are concerned about safeguarding the confidentiality of your information. We provide electronic and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

10. Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

11. Your Consent

By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/ hand held device or using or touching information in any way, including, but not limited to collecting, storing, deleting, using, combining and disclosing information.

12. Contact us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at [email protected]

13. Additional California Privacy Disclosures

Effective as of January 1, 2020

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. Beginning January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information”, as described in under the CCPA). This supplement provides additional privacy disclosures and informs you of your additional rights as a California resident, and should be read in conjunction with the Privacy Policy above.

Personal Information Collected and Processed

The Privacy Policy above sets forth the categories of personal information that TREBEL collects and processes about you, a description of each category, and the sources from which we obtain each category.

Requests to Exercise Your Rights

Right to know request. Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

  1. Categories of and specific pieces of personal information we have collected about you.
  2. Categories of sources from which we collect personal information.
  3. Purposes for collecting, using, or selling personal information.
  4. Categories of third parties with which we share personal information.
  5. Categories of personal information disclosed about you for a business purpose.
  6. If applicable, categories of personal information sold about you and the categories of third parties to which the personal information wassold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for information about the personal information we have collected about you, please email us at [email protected] from the same email address you used to sign-up for TREBEL Music.

Right to delete request. You also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete by emailing us at [email protected] from the same email address you used to sign-up for TREBEL Music with a Subject line of “I want to permanently delete my data.”

Household requests. We currently do not collect household data. If all the members of a household makes a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

Requests, generally. Please note, if you do not have a TREBEL account that was created with a valid email address we will not have enough information about you to verify your Right to Know and Right to Delete requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.

Requests made through agents. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, TREBEL has disclosed certain data from the following categories of personal information for one or more business purposes:

  • User Data
  • Usage Data
  • Payment and Purchase Data
  • Contests, Surveys and Sweepstakes Data

Sale of Personal Information

Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information. We have taken substantial steps to identify whether any of our data sharing arrangements would constitute a “sale” under the CCPA. Due to the complexities and ambiguities in the CCPA, we will continue to evaluate some of our third party relationships as we wait for final implementing regulations and guidance. For example, it is currently unclear whether the use of certain types of advertising partners would be considered a sale under CCPA. We provide Usage Data to advertising partners, which enables us to provide you with interest-based advertising. If you prefer not to receive interest-based advertising, please opt out by going to your device Settings - Privacy page and using the Limit Ad Tracking opt out toggle. We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.

Contact Us

You may contact us by emailing us at [email protected]