This Privacy Policy (the “Policy”) describes how Free Your Music app (“Free Your Music”, “we”, and “our”) process, collects, uses, protects, and shares your personal data on our website at https://freeyourmusic.com (the “Site”), in the web app at https://freeyourmusic.com/app, and through the apps for iPhone, iPad, Android and desktop computers (collectively, the “Platform”).

Free Your Music is a company that protects user privacy, and personal data by taking all relevant measures in accordance with applicable legislation, including the EU Regulation 2016/679 – known as General Data Protection Regulation (GDPR).

Data Controller:

Data of the Personal Data Controller:

Hernas OÜ
Kentmanni 4
10116 Tallinn
Estonia

The Data Controller can be contacted via e-mail: gdpr@freeyourmusic.com or in writing at the address of the Controller’s office with the note “Data Protection”.

The purpose of data collection:

We may collect your personal data when you visit our Platform so that we can improve it. We also collect your personal data when you register or use the Platform so you can use our services in proper manner (“Services”). We collect information directly from you, from the third parties, as well as automatically through your use of our Site, Platform and associated services so that enables us to provide and maintain the Platform and, from time to time, develop additional features or functionality. The specific purposes of data collection and use (processing) are the following:

to provide, personalize and improve your experience with the Services;
to ensure proper flow and management of our database;
to understand your listening habits and let you transfer your data between music platforms carefree;
to deliver excellent consumer Services and support;
to provide proper license keys distribution between Platforms users;
to understand how you interact, access and use the Platform;
to analyse trends, statistics, and to measure overall Platform effectiveness;
to produce aggregated, anonymous statistics, scores and insights about music listening and playlist activity (for example, how much a track or artist is being listened to), in which no person can be identified, which we may make available to third parties such as artists, labels and other partners through our analytics services (including Music24 / SmartLinks);
to develop and provide technical updates, new features and functionality;
to communicate with you about the upcoming projects, advertising, new updates, features & functionality of the Services;
to detect, prevent and address the technical and security issues;
to monitor feedback on Free Your Music’s Services;
to pursue legal claims and defence in legal disputes.

We also use the information we collect to analyse, develop and improve the Services. To do this, Free Your Music may use third-party analytics providers to gain insights into how our Services are used in order to improve the Services experience.

Product analytics

Our apps and web app record how the Services are used – for example which screens you open, which steps of a transfer you complete and whether a purchase succeeds. These usage events go to our own analytics service, hosted in the European Union, and not to a third-party analytics provider. Each event carries a random install identifier and, when you are signed in, your account identifier. We use these events only to understand and improve the Services, and we never sell them or use them for advertising.

In the iOS and Android apps you can turn usage analytics off at any time under Account → Share usage analytics. In the web app at https://freeyourmusic.com/app, we record these usage events only after you click Accept in the cookie bar. The analytics of our website are described under “Website analytics” below. When you delete your account, we also delete the usage events linked to it.

Sharing your data is voluntary, however, by using our Site and Platform, you agree on Policy and its terms.

Unless otherwise defined in this Policy, terms used in this Policy have the same meanings as in our Terms of Use, accessible at https://freeyourmusic.com

Information we collect when you use the Platform:

While using our Platform, we may ask you to provide us with certain personal data that can be used to contact or identify you, among others, your e-mail address, license key order identification number, license key payment confirmation.

Free Your Music collects information from electronic devices and music services you connect to with use of our mobile application, including confirmation of the playlist transfer between different music services and tracks used in your playlist.

Listening history. We read your listening history (play history) from a music service only after you turn on Stats in the app and add that service to your Stats. Stats is optional and available on every plan, free and Premium. The listening history is the tracks you listened to and, where the service provides it, when you listened to them. We store it linked to your account, an identifier of the connected music-service account and a device identifier, and we derive an approximate country or region from your IP address at the time of upload. Because it is linked to those identifiers, your listening history is personal data – it is not anonymous when we collect it. We use it to show you your Stats and to produce the aggregated, anonymous statistics described below. When you turn off Stats or its play history, take the service out of your Stats or disconnect the service, we stop reading your listening history. You can delete your stored Stats data in the app at any time, or ask us to delete it by contacting us.

How long we keep it. We keep your listening history (the raw list of the tracks you played) and the rest of your stored Stats data until you delete it, or until 12 months pass in which you do not use Stats. Then we delete it.

By adding your favourite songs and creating your music playlist you may develop intellectual property rights to your music playlist. Specific details about the playlist, transfer of the playlist between different music services and intellectual rights, you will find in our Terms of Use, accessible at https://freeyourmusic.com.

Aggregated and anonymous statistics

We combine the listening history and playlist activity described above across many users to produce aggregated, anonymous statistics – for example, listening scores and trends for a given track or artist. No person can be identified in these statistics: they show only normalized scores and counts over a sample of users, never your own listening data, and we apply a minimum-audience threshold before any score is shown. The listening history from which they are derived is stored in identifiable (pseudonymous) form as described above, it stays with us, and we keep it only for the period stated above.

We share listening data with artists, labels, rights holders and other partners only as these aggregated, anonymous statistics, as part of our analytics services (such as Music24 / SmartLinks). We never share your own listening history in a form that identifies you, and we do not sell your personal data.

Music metadata and our catalogue

When you transfer your music or connect a music service, we read the tracks, albums and artists in your playlists and library, together with the information the music service returns about them – for example titles, the artists on a track, the album, release dates, identifiers such as ISRC or UPC, and public links. We keep this information in a catalogue of facts about the music itself. This catalogue describes the music, not you: an entry in it is not linked to your account, and no person can be identified from it.

To make this catalogue more complete, we may ask the music service for a little more detail about the artists, albums and tracks that are in your own library – for example an artist’s genres, biography, follower count or public social links. We do this only for items that are already in your library, we spread the requests out so that they stay gentle, and we never do it in a way that slows down your transfer. We use this catalogue to provide and improve our Services and our music analytics (including Music24 / SmartLinks). Because it does not identify you, this catalogue of music facts is not your personal data, and we may share and reuse it.

Cookie policy

We use cookies to collect information and learn your internet behaviour pattern and preferences. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some of the finest features of our Platform.

Cookies are small data files stored on the hard drive of your computer or mobile device by a website. You need to know that there are two kinds of cookies:

session cookies (which expire once you close your web browser) and
persistent cookies (which stay on your computer or mobile device until you delete it).

Website analytics

On our website we use Plausible Analytics, which we host ourselves. Plausible sets no cookies and records no personal data: it counts page views and events without an identifier that follows you, and it does not store your IP address. Plausible runs from your first visit, before you make a choice in the cookie bar, and it stops when you click Decline.

Google Analytics loads only after you click Accept in the cookie bar, and our advertising pixels receive events only after Accept. If you click Decline, or make no choice, Google Analytics does not load. You can change your choice at any time with the “Cookie settings” link at the bottom of every page of the website.

Log files

We collect information that your browser sends whenever you visit our Site, which is not linked to any information that allows to identify you. The information collected by log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks or taps. The information is used to track visitor’s movement on the Site, and to gather visitor’s demographic information.

In addition, after you click Accept in the cookie bar, we use Google Analytics to collect, monitor and analyse such information in order to improve our Platform’s functionality. These third-party service providers have their own privacy policies addressing how they use such information.

Data transfer

We may share your information with our affiliates, however, we take the protection of your privacy and your personal data very seriously. We always try to ensure that our affiliates comply with the terms of our Policy. If Free Your Music becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution, or other similar process, we may share or transfer your information in compliance with applicable regulations.

We may share your personal data to:

Third Parties Designated by You. We may share your personal data with the third parties only when you agree to do so.
Our Third-Party Service Providers and business partners. We may share your personal data with our third-party Service providers for the purpose of payment processing, customer service, email delivery, analytics, data storage, and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide such services to our Platform. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
App stores. When you ask Apple for a refund, or dispute a Google Play payment, we send the store the information that our Terms of Use describe, so that the store can review the request. The store uses this information under its own privacy policy.
Corporate Restructuring. We may share your personal data with our business partners in the event that this is legitimate from a business perspective. For example in the event of transaction negotiation, sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Law reasons. We may disclose your information due to generally applicable rules of law, in particular, due to court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend our rights.

This Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective privacy policies of these third-party ad servers for more detailed information.

International data transfer

Your information, including personal data, may be processed and transferred by us and our third-party Service providers to the countries outside the EEA region, in particular the United States where personal data protection and privacy regulations may not offer the same level of protection as in the EEA region. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Policy. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer.

General Data Protection Regulation (GDPR)

We would like to ensure you are fully aware of all of your data protection rights in accordance with the GDPR laws. Therefore, you have the following rights:

the right to access your personal data: You can request and you are entitled to obtain any of your personal data we process, where it comes from and what we use it for. You can obtain information about how long we store your data and who receives data about you. Your right to access may, however, be restricted by legislation, protection of other persons’ privacy, and considerations for our business and practices.
the right to rectification and ensure of data: If you have discovered that the personal information we have about you is incorrect, incomplete or irrelevant, you are entitled to have the data corrected or erased subject to the restrictions that follow from existing legislation and rights to process data.
the right to the restriction of use: If you believe that the data we have processed is incorrect or incomplete, or if you have objected to the use of the data, you have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned.
the right to data portability: If you ask us to do so, we will pass on your personal information in a structured, usable format.
the right to object to processing: You have the right to object to the processing of your personal data if we process it for direct marketing purposes.
the right to make a decision about automated individual profiling: You also shall have the right to object to a decision based solely on automated processing, including profiling. In these situations, FreeYourMusic will guarantee suitable measures to safeguard your rights, mainly the right to human intervention when reviewing such cases. You will be notified if any automated decision-making is performed in relation to your personal data.
the right to withdrawal of consent: If we process personal data based on your consent, you can withdraw your consent to disclose data at any given time. Please also note that we will continue to use your personal data if we have to fulfil a legal or contractual obligation.
the right to be forgotten: The right to obtain from us the erasure of all your personal data given to us under the Policy without undue delay. If you will make such a request, we shall have the obligation to erase all your collected and processed personal data without undue delay.

In case of any concerns of your personal information, feel free to contact us by sending an email at gdpr@freeyourmusic.com or in writing at the address of the Controller’s office with the note “Data Protection”. We will reply to your request as soon as possible.

Security

The security of your personal data is important to us, unfortunately, the transmission of information via the internet is not completely secure, nor can we guarantee the security of any transmission or storage system. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. If you have reason to believe that your interaction with the Site or Platform is no longer secure, please immediately notify us of the problem by contacting us, by sending an email at gdpr@freeyourmusic.com or in writing at the address of the Controller’s office with the note “Data Protection”.

Data Retention

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information in a manner consistent with the lawful bases as outlined in the GDPR. Please remember that we retain your given information and data as long as we are legally required or permitted to do so. What is important, we can also retain your personal data as long as it results from generally applicable law. Information may persist in copies made for backup and business continuity purposes for additional time. The information we retain will be handled in accordance with this Policy.

Your listening history and the rest of your stored Stats data are kept until you delete them, or until 12 months pass in which you do not use Stats, as described under “Listening history” above.

Children's Information

No one under 13 is authorized to use our Platform. If you are a parent or guardian and you are aware that your Children has shared with us personal data, please immediately contact us by sending an email at gdpr@freeyourmusic.com or in writing at the address of the Controller’s office with the note “Data Protection”. If we become aware that we have collected personal data from children under age of 13 without verification of parental consent, we take steps to remove that information from our servers and we will delete such information from our files as soon as reasonably practicable.

Complaints and disputes

We are committed to resolving any complaints about your personal data. If you would like to lodge a complaint regarding this Policy or our business practices in relation to your personal data, please contact us by sending an email at gdpr@freeyourmusic.com or in writing at the address of the Controller’s office with the note “Data Protection”. We will reply to your complaint as soon as we can.

Changes to this policy

We will post any modifications or changes to the Policy on this page. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently.

Contact information

We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

If you have any questions, comments, or concerns regarding our Policy and/or practices, please contact us by sending an email gdpr@freeyourmusic.com or in writing at the address of the Controller’s office with the note “Data Protection”.

External services

The Platform and Mobile App uses YouTube API Services to facilitate transfer of playlists to and from YouTube. Please read Google Privacy policy before authenticating your YouTube account.

Polityka Prywatności