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IMPULSE

Impulse

Privacy Policy

Last Updated: 30th March 2026

What Does This Policy Cover?

This privacy policy (“Privacy Policy”) describes Sony Music Publishing (US) LLC and its Affiliates' use of your data. References to “SMP,” “we,” or “us” shall mean Sony Music Publishing (US) LLC.

This Privacy Policy applies to the information collected by SMP both offline and online, including through the SMP website, Impulse website, SCORE website and mobile app, and through any interactive features, applications, widgets, blogs, social networks and other websites, mobile apps, or other digital properties that post a link to this Privacy Policy, whether accessed via computer, mobile device, or other technology (collectively, “SMP Properties”).

Please note that when you enter any sub-sites accessible through the SMP Properties, such sub-sites may have their own specific privacy policies. Additionally, the properties of affiliated SMP companies, including some that are linked to/from the SMP Properties, may have different policies; therefore, please review the privacy policies on those properties if you visit them.

What Information Do We Ask You to Provide Us?

With the exception of information related to establishing an account and login credentials for any of the SMP Properties, SMP does not generally require that you provide us with personal data in order to visit and use the SMP Properties. Please note that in order to participate in some activities, such as sweepstakes, contests, and other promotions (collectively, “Promotions”), and social media, we may ask you to provide information that could reasonably be used to contact you or to identify you personally (such as your name, company name, title, e-mail address, mailing address and telephone number). SMP may also ask you to provide other information about yourself, which may include demographic information such as geographic region, age, etc., or certain information about your preferences and interests. And, to facilitate payments to you, we may ask that you provide us with financial account details and additional associated information to verify your identity and keep required records.

Therefore, in summary, the information that we collect from you and process may include:

  • First name, last name, company name, and title
  • Your log-in credentials for any of the SMP Properties
  • Contact information, such as e-mail address, mailing address, and phone number
  • Demographic information, such as geographic region or age/date of birth
  • Your preferences, including any consents you have given us
  • Your financial account details, tax or government identification numbers, and related information, if needed to facilitate payments to you

We may offer opportunities to enter into Promotions, on our own or jointly with another entity. Such Promotions may require registration and the disclosure of both personal data and non-personal data. In the event that a Promotion is offered jointly with another entity, as a result of your participation in such Promotion, your personal data and non-personal data may be disclosed with such other entity. You will be informed of this disclosure at the time you provide your information. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other entities connected to the Promotion to use your name, voice and/or likeness in advertising and marketing materials. Therefore, always carefully read the rules of the Promotion before entering.

What Information Do We Collect from You Automatically?

In addition to any personal data or other information that you choose to provide to us via the SMP Properties, whenever you visit or interact with the SMP Properties, SMP may automatically collect certain information such as your IP address and/or another unique identifier (“Device Identifier”) for the computer, mobile device, technology, or other device (“Device”) you use to access the SMP Properties and any referring property. A Device Identifier is a number that is automatically assigned to your Device when you access a website, mobile app, or other digital property or its servers. The SMP Properties identify your Device by its Device Identifier.

SMP may also automatically collect information about your Device, such as the platform, operating system, or browser type for the Device you use to access the SMP Properties and any referring property.

In addition, SMP, as well as certain analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use the SMP Properties ("Usage Information"). Usage Information may include, in part, browser type, operating system, IP address, the content served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views.

SMP may receive information about you from other entities. In addition, if you are on another website and you opt-in to receive information from us, that website will forward to us your e-mail address and other personal data about you so that we may contact you as requested.

Therefore, in summary, the information that we may automatically collect from you and process may include:

  • Your IP address and/or another unique identifier, such as a Device Identifier
  • Information related to your Device, such as the platform, operating system, browser type, or physical location
  • Your Usage Information, such as the content served, the time at which the content was accessed and/or the time spent using the content, and the preceding content views

How Do We Use This Information, and What Is the Legal Basis for This Use?

We process this personal data for the following purposes:

  • As required for business purposes or to establish and fulfill a contract with you, for example if you license music from us or enter a Promotion. This may include verifying your identity, communicating with you, and providing services relevant to our business.
  • As required by SMP to enable our business and pursue our legitimate interests, in particular:
    • we will use your information to provide services you or our clients have requested, and respond to any comments or complaints you may send us
    • we monitor use of the SMP Properties, and may use your information to help us monitor, improve, and protect our content, services, and the SMP Properties, both online and offline
    • we may use information you provide to tailor your experience on the SMP Properties or personalize our services for you
    • we may provide you with information about Promotions or other offerings that may be of interest to you
    • we may provide you with support and answer questions or other requests
    • we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law
    • we may use information you provide to investigate any complaints received from you or from others, about the SMP Properties or our services
    • we may also use the information we collect to improve the SMP Properties and our content and services, for internal business purposes, and to contact you with regard to your use of the SMP Properties and, in our discretion, changes to any of our policies
  • Compliance with applicable laws and the protection of SMP's legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, and investigative purposes (including disclosure of such information in connection with legal process or litigation).
  • With your permission, after we have asked for and obtained it, in connection with a new purpose not otherwise described in this policy.

In addition, we may send you direct marketing in relation to our services, or other services provided by our Affiliates and carefully selected partners. You will be able to opt-out of those materials by following the instructions in the communication.

Who Will We Disclose This Information to, and Where?

To Affiliates, Service Providers, and Third-Party Service Providers

SMP may disclose your personal data with other companies in the Sony Group of companies (“Affiliates") so that those Affiliates can (i) assist us with fulfilling your requests or improving our content, services or advertising; and/or (ii) contact you about other content, services or other offerings that may be of interest to you.

In addition, we may disclose your personal data to offices, agents, and administrators that may represent SMP or work with SMP, such as sub-publishers, performance societies, licensees, and local agents (“Business Partners”).

We may from time to time employ Third-Party Service Providers to perform functions on our behalf, and thus, we may also disclose your personal data with these Third-Party Service Providers to assist us with providing content, fulfilling your requests, improving our content, services or advertising, or otherwise performing services for SMP (“Third-Party Service Providers"). Additionally, we may disclose your information to Third-Party Service Providers in order to host or operate the SMP Properties, for data analysis purposes, and for the administration of Promotions, such as in connection with winner selection and prize fulfillment.

When You Consent or Otherwise Request That We Disclose Your Information

We may offer you the opportunity to consent to the disclosing of your information with other entities for example, so you are able to receive information and/or marketing offers from them. Additionally, you may request, sometimes through your use of an interactive feature or application, that we disclose personal data about you with another entity, and we will typically do so in those circumstances. If you consent or request to receive communications from other entities, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications.

The provisions above apply to our disclosing of personal data with Affiliates, Business Partner, and Third-Party Service Providers. They do not cover use of personal data that those Affiliates, Business Partner, and other Third-Party Service Providers collect directly from you. Such use of personal data is covered by the relevant Affiliate’s, Business Partner’s, and/or other Third-Party Service Provider’s privacy policy and not this Privacy Policy.

Business Transactions

We may disclose your personal data with Affiliates for internal reasons, primarily for business and operational purposes, including any corporate reorganization, restructuring or other corporate change. In addition, SMP or any of its assets, including the SMP Properties, may be sold, or other transactions may occur in which your personal data is one of the key business assets in the transaction. In such a case, your personal data may be one of the business assets we transfer. Hence, SMP reserves the right to disclose and transfer user information, including personal data, in connection with any activity and/or transaction described above.

Legal Protections and Law Enforcement

We may transfer and disclose information, including your personal data, (including Usage Information and Device Identifiers, including IP addresses), to other entities: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (iii) at the lawful request of governmental authorities conducting an investigation; (iv) to verify or enforce our Terms & Conditions or other applicable policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of other entities, visitors to the SMP Properties, or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies, in our discretion to fulfil our legal obligations. Such disclosures may be carried out without notice to you.

Cookies & Other Web Tracking Technologies

We use cookies and other web tracking technologies to track the use of the SMP Properties.  For more information on SMP’s web tracking practices, please view our Cookie Policy.

Social Media Applications

Functionality on the SMP Properties may permit interactions between third-party properties, such as enabling you to “like” or “share” content to third-party properties. If you choose to “like” or “share” content or to otherwise post information from or via SMP Properties to a third-party property, feature or application, that information may become public and the third-party property may have access to information about you and your use of the SMP Properties, including personal data.

You may also choose to participate in a third-party application or feature (such as one of our Facebook applications or a similar application or feature on a third-party property) through which you allow us to collect and disclose (or the third party to disclose) information about you, including personal data. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. In addition, we may receive information about you if other users of a third-party property give us access to their profiles and you are one of their “connections,” or if information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third-party property or interactive service.

Security

SMP uses commercially reasonable safeguards to help protect and secure your personal data, and we use reasonable efforts to obtain the agreement of our Affiliates, Business Partners, and Third-Party Service Providers to take steps to protect the confidentiality, security, and integrity of personal data we disclose to them. However, no electronic data transmission or storage of information can be guaranteed to be 100% private and secure. Please be careful to avoid social engineering schemes, where someone may send you an e-mail or other message that looks like it is from SMP asking for your personal data. You understand that any message or information you send to a SMP Property may be read or intercepted by others. SMP does not ensure or warrant the security of any information you transmit to us, and you use the SMP Properties and provide us with your information at your own risk.

To help protect you and others, we monitor use of the SMP Properties, and we use the information we collect, including personal data, to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the SMP Properties; ensure compliance with the Terms & Conditions and this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of SMP, its partners, and customers. Monitoring may result in the collection, recording, and analysis of online activity or communications through the SMP Properties. If you do not consent to these conditions, you must discontinue your use of the SMP Properties.

How Do We Treat Children's Personal Information?

The SMP Properties are open to all individuals, though some Promotions may have age restrictions. We do not knowingly target our services to, collect or permit the collection, storage, or use of any personal data from anyone under 13 years of age.  If you are a parent or guardian who knows or has discovered that your child under the age of 13 has submitted his or her personal data or other information without your consent, permission, or authorization, please contact us immediately.

Retention of Personal Information

We will only retain your personal data for as long as is reasonably necessary for the various purposes set out in this policy or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of information.

Changes to This Privacy Policy

The terms of this Privacy Policy will govern the use of any information collected while it is in place. SMP reserves the right to change this Privacy Policy at any time, without prior notice to you, and any changes will become effective immediately upon posting. Thus, please review this Privacy Policy periodically.

Contact Us:

If you have any questions or comments about our practices regarding personal data or about this Privacy Policy, please submit your request via e-mail to: privacy@sonymusicpub.com or write to us at Sony Music Publishing (US) LLC, 25 Madison Avenue, New York, New York 10010, Attn: Business & Legal Affairs.

Notice to California Residents

If you reside in California, we are required to provide additional information to you about how we collect, use, and disclose your information, and your rights with regard to your information.

This California Privacy Notice (“Notice”) supplements this Privacy Policy and applies only to California residents. This Notice sets forth the disclosures and rights for California residents regarding their Personal Information, as required by the California Consumer Protection Act and amended by the California Privacy Rights Act (“CCPA”). Terms (including defined capitalized terms) used in this Notice have the same meanings given in the CCPA and the regulations implementing the CCPA, unless otherwise defined.

CA Personal Information Collection, Source, Purpose of Use, and Retention.

CA Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“CA Personal Information”).

Collection, Use, and Purpose.  We collect your name, company name, title, account login credentials, contact information, demographic information, preferences, financial account information, IP address, other unique identifiers, information related to your device, and Usage Information from you directly or indirectly through your interaction with any system or application.  We collect this CA Personal Information in order to provide you the services.  We do not infer any characteristics from any Sensitive Personal Information we may collect for record keeping purposes.

Retention.  We will keep your CA Personal Information for as long as it is necessary for the relationship with you or the purposes detailed above or necessary to establish or defend legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the relevant CA Personal Information for specific periods.

Selling / Sharing.  We do not Sell your CA Personal Information or Share your CA Personal Information for purposes of cross-context behavioral advertising as part of our business practices.

Please note, depending on your online preferences, SMP may engage in online advertising practices (and certain analytics or similar activities), which may be considered “Sharing” for cross-context behavioral advertising, as defined in the CCPA. To disable Sharing through cookies set by third parties, please go to the Cookie Preference Center and turn off “Targeting Cookies.” For more information on SMP’s web tracking practices, please view our Cookie Policy.

Opt-out Preference Signal.  If you have enabled an opt-out preference signal on your browser or extension, we will honor such requests by turning off “Targeting Cookies.”

CA Personal Information Disclosed to Third Parties for Business Purposes.

In the preceding twelve (12) months, we may have disclosed your CA Personal Information for Business Purposes to other Sony Affiliates, Business Partners, or Third-Party Service Providers to provide services on our behalf such as: maintaining or servicing accounts, providing IT services, fulfilling orders, receiving payment, and other similar services on our behalf.

California Consumer Rights.

Subject to certain exceptions, as a California resident, you may have the following rights to request:

  • Access.  You can request access to:
    • the categories of CA Personal Information we have collected about you;
    • the categories of sources from which your CA Personal Information is collected;
    • the business or commercial purpose for collecting or disclosing CA Personal Information;
    • the categories of third parties to whom we disclose your CA Personal Information;
    • the specific pieces of CA Personal Information we have collected about you.
  • Correction.  You can request correction of the CA Personal Information we maintain about you.
  • Deletion.  You can request deletion of the CA Personal Information we have collected from you, but this may result in a disruption to services.  To the extent permitted by applicable law, we may retain some of your CA Personal information and certain CA Personal Information is strictly necessary to retain in order for us to fulfil the purposes described in this Privacy Policy.
  • Restrict Use and Disclosure of Sensitive Personal Information.  We do not infer any characteristics about you based on the Sensitive Personal Information you may provide us.  Therefore, this right does not apply.
  • Nondiscrimination.  We will not discriminate against you based solely upon you exercising your rights under CCPA.

 

Exercising Your California Consumer Rights.

If you are a California resident and wish to exercise any of these rights, please: (i) contact us by sending an email to privacy@sonymusicpub.com or (ii) write to us at Sony Music Publishing (US) LLC, 25 Madison Avenue, New York, New York 10010 USA, Attn: Business & Legal Affairs.  When submitting your request, you must indicate the specific nature of your request, referencing “Your California Privacy Rights,” and include your first and last name, mailing address, zip code, and e-mail address.

When exercising your rights as described above, you may be asked to provide additional proof of identification so that we can verify your identity and validate the request. We are not responsible for requests that are not labeled or sent properly, or do not contain sufficient information to allow us to process your request.

 

Agents.  If you are an authorized representative submitting a request on a resident’s behalf, please complete the applicable request per the instructions above. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and a clear description of the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your e-mail the nature of your request. The resident’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the resident to directly confirm with us that they provided you permission to submit the request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the resident’s behalf, we may deny the request.

 

Notice to Residents of the European Economic Area (EEA)

How can you access your personal data and what are your rights?

If you would like a copy of the personal data that we store about you in our customer databases, please contact us using the details given in the “Contact us” section above.

This is in addition to your legal rights, including the right to access a copy of your personal data, the right to request the deletion or updating of any inaccurate personal data and the right to object, in some cases, to our processing of your personal data. You can exercise these rights by contacting us using the details given in the “Contact us” section above.

Where we are processing personal data based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

You may also have, for some data processed by us, a right to data portability, i.e., the right to receive your personal data in a structured, commonly used machine-readable format and transmit your personal data to another data controller.

You can exercise these rights by contacting us using the details given in the “Contact us” section above. You may be asked to provide some proof of identification so that we can verify that it is you making the request.

SMP and our Affiliates, Business Partners, and Third-Party Service Providers may collect, transfer and/or retain your personal data in jurisdictions, including the United States, that do not have the same level of legal protections for personal data as your local jurisdiction. SMP undertakes appropriate and suitable safeguards to ensure your rights continue to be protected, including by entering the EU Standard Contractual Clauses.

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us or exercise your right to lodge a complaint with your local data protection authority.

Notice to Residents of Germany

If you have any questions about our handling of your personal data, please feel free to contact our external data protection officer. Kontaktdaten unseres externen Datenschutzbeauftragten: E-Mail: sonymusicpub.com@extdsb.org

Or you can contact us at the following address:

Sony Music Publishing (Germany) GmbH

Buelowstrasse 80 Berlin 10783

Phone +49 (0)30 40369 1300

 

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