Privacy Policy

Last revision date: 1st Jan 2023

What does this policy cover?

This policy describes Sony Music Publishing, LLC and its affiliates' use of your data. References in this policy to SMP, we or us shall mean Sony Music Publishing LLC.

This Privacy Policy applies to the information collected by SMP both offline and online, including through the Sony Music Publishing Website, Impulse Website and SCORE Website and mobile app and through any interactive features, applications, widgets, blogs, social networks and other online or wireless offerings 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 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.

Therefore, 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

· Demographic information, geographic region etc.

• Your age/date of birth

· Contact information, such as email address, mailing address and phone number

• Your bank account details

· Marketing preferences, including any consents you have given us

We may offer opportunities to enter into Promotions, on our own or jointly with a third party. 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 a third party, as a result of your participation in such Promotion, your personal data and non-personal data may be shared with such third party. This sharing will be disclosed to you 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 third parties 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.

Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the SMP Properties.

In addition, SMP, as well as certain third-party 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 third parties. 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. We may also supplement the information we collect about you with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to use our services that we believe may be of interest to you. When we obtain personal data from third parties, we will apply this Privacy Policy to the personal data received, unless we have disclosed otherwise.

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

· Your IP address 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 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

· to provide you with information about Promotions or other offerings that may be of interest to you

· to 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 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).

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 share this data with, and where?

To Affiliates, Other SMP Companies and Third-Parties

SMP may share your personal data with companies affiliated with SMP ("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.

* Affiliates: meaning worldwide affiliate offices, agents and administrators that represent and work with SMP, such as sub-publishers, performance societies, licensees and local agents.

We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share your personal data with third-party service providers that assist us with providing content, fulfilling your requests, improving our content, services or advertising, or otherwise performing services for SMP. As one example, if you access content or services that are published, developed or supported by an Affiliate or third party, your personal data may be shared with that Affiliate or third party for purposes related to that content or those services, including service administration and/or development. Additionally, we may share your information 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 To Have Your Personal Data Shared or Otherwise Request That We Share Your Information

We may offer you the opportunity to consent to the sharing of your information with third parties, for example so you are able to receive information and/or marketing offers from third parties. Additionally, you may request, sometimes through your use of an interactive feature or third- party application, that we share personal data about you with a third party, and we will typically do so in those circumstances. If you consent or request to receive communications from third parties, 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 sharing of personal data with Affiliates and third-party service providers. They do not cover use of personal data that those Affiliates and third-party service providers collect directly from you. Such use of personal data is covered by the relevant Affiliate's and/or third party's privacy policy and not this Privacy Policy.

Business Transactions

We may share 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 Identifier (including IP address)), to third parties: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (iii) at the 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 third parties, 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. Such disclosures may be carried out without notice to you.

Cookies & Other Tracking Technologies

We use cookies and other technologies to track the use of the SMP Properties. We allow third parties to place such technologies on the SMP Properties for analytics and other purposes.

Cookies are files that web servers place on your device. The use of cookies on SMP Properties allows you to enjoy more seamless visits and more accurately measures your behaviour on the SMP Properties. You can learn more about the cookies and web beacons we use and how you can disable cookies and web beacons in 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 share (or the third party to share) 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 and third-party service providers to take steps to protect the confidentiality, security, and integrity of personal data we share with them. However, no electronic data transmission or storage of information can be guaranteed to be 100% private and secure. Please be careful to avoid 'phishing' schemes, where someone may send you an e-mail 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 data?

The SMP Properties are open to all individuals, though some Promotions may have age restrictions. We do not knowingly collect or permit the collection, storage or use of any personal data from anyone under 16 years of age.

For Residents of the United States

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, upon request, we will promptly: (a) provide direct notice to you indicating what, if any, personal data of your child has been collected and how it has been used and/or disclosed; (b) remove your child's personal data or other information from our database, cease the use of such information and direct any other party with access to such information to do the same; and (c) by notice to you, confirm compliance with the foregoing.

Access to your information and your rights

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 Privacy 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 may collect your name, company name, title, account login credentials, contact information, demographic information, preferences, bank account details, 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 collect or process Sensitive Personal Information.

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 that may be considered "Sharing," please go to our Cookie Policy and use the "customize cookies" button to turn off "Targeting Cookies." For more information on SMP’s web tracking practices, please view our Cookie Policy.

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 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 the 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 the CA Personal Information;
  • the specific pieces of CA Personal Information we have collected.
• 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 in order for us to fulfil the purposes described in this Privacy Policy.
• 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 LLC, 25 Madison Avenue, New York, New York 10010, 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 email 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.

For 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 below.

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 below.

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 below. You may be asked to provide some proof of identification so that we can verify that it is you making the request.

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

Retention of personal data

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.

Policy governs use: changes to 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 .