Privacy

Privacy Policy

Scope And Purpose Of This Policy

This Privacy Policy (“Policy”) applies to sodapopradio.com, the Soda Pop Radio mobile application, and any other websites, applications, widgets, products, services, and other on- and offline offerings (collectively, the “Services”) owned and operated by Soda Pop Radio LLC. and our subsidiaries (collectively, “Soda Pop Radio,” “we,” “us,” or “our”). This Policy covers our treatment of the Personal Information we gather through our Services. This Policy explains how Soda Pop Radio may collect, use, process, disclose and safeguard information we obtain through the Services. It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns. Soda Pop Radio is the data controller for the purposes of this Policy. If you are a California resident, please also see our California Resident Privacy Notice. If you wish to opt out of Soda Pop Radio’s “sharing” of your Personal Information for cross-contextual advertising purposes, please click here: Do Not Sell or Share My Personal Information.

How Soda Pop Radio Collects Your Information

For the purpose of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. We obtain Personal Information relating to you from various sources as described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the Services or if we are legally required to collect it.

Personal Information Collected Automatically

Your Activities on the Services. When you use the Services, we collect information about your activities, such as the stations, artists or channels that you listen to, transaction details related to your Subscription, the user profiles that you view, your searches for friends or stations and your other actions and interactions with other users or content on the Services, the stations, content and people that you follow (“Follow Lists”), your comments, any content that you post on the Services, and any other information resulting from your use of the Services that is publicly accessible by other users (“Public Information”). Your Contacts. If you use certain features of our Services, such as the share content feature, we will collect information about your contacts, with your permission. Location Information. Depending on your device settings, we may obtain information about your physical location at regular intervals when you use the Services, such as by use of geolocation features in the device(s) through which you access the Services. In addition, we may infer your location from other information we collect (for example, your IP address indicates the general geographic region from which you are connecting to the Internet). Device Information. We receive information from the device through which you access the Services, such as IP address, web browser type, mobile operating system version, and unique device identifiers. Widget Information. Other websites may integrate Soda Pop Radio widgets (such as the Soda Pop Radio Player or Soda Pop Radio Follow Button). When you visit a site with a Soda Pop Radio widget embedded, we may receive certain information, including information about the web page you visited, your IP address, and other information about your device. Soda Pop Radio and the widget can recognize you across websites containing Soda Pop Radio widgets, and the widget may be used to show personalized content or advertising. We know when you interact with a widget, and websites containing the widgets may receive this information. Cookies and Related Technologies. When you visit the Services, we and our third party service providers receive and record information from your browser and from cookies and similar technologies. Learn more about how we use cookies and related technologies in our Cookie Policy. Google Analytics. We use Google Analytics to obtain information about your behavior on our Services. We may use this information to improve user experience and improve our products. If you’d like to opt-out, we recommend installing Google’s browser add-on that can be found at https://tools.google.com/dlpage/gaoptout.

3. Registration

Other Administrative Purposes • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity • Measuring interest and engagement in our Services • Improving, upgrading or enhancing our Services • Developing new products and Services • Ensuring internal quality control and safety • Authenticating and verifying individual identities, including requests to exercise your rights under this policy • Debugging to identify and repair errors with our Services • Auditing relating to interactions, transactions and other compliance activities • Enforcing our agreements and policies • Complying with our legal and contractual obligations, including using location information to comply with radio stations’ content licenses (which are location-specific) Consent We may also use personal information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent, we also use your information for other purposes as requested by you or as permitted by applicable law. Aggregate Data We may de-identify and aggregate information collected through the Services for statistical analysis and other lawful purposes. How We Disclose Personal Information Station and Channel Partners. We may disclose certain limited information to our station and channel partners regarding listening activity on their stations and channels. The information we disclose may include device information (for example, IP address, web browser type, mobile operating system version, and unique device identifiers); general geographic information (for example, zip code, city, state, region, and/or country); listening session starts, durations, and timestamps; and search terms used to find the station or channel partner’s content. Our station and channel partners may use this information for their research and marketing purposes, or as otherwise disclosed in their respective privacy policies. Advertising Partners. We may share your Personal Information (including IP address) with our third-party advertising partners to provide ads that we think may interest you, such as, LiveRamp Inc. LiveRamp may link this data to data collected from other offline and online sources, including other websites and mobile apps, and provide Soda Pop Radio with an identification code that we may store for in-app, online, and cross-channel advertising, or share with advertising companies to enable interest-based and targeted advertising. For more information about LiveRamp, please click here (https:// liveramp.com/privacy/). To opt-out of LiveRamp-enabled targeted advertising, please click here (https://liveramp.com/ opt_out/). We may share your Personal Information with our third-party advertising partners to provide ads that we think may interest you. For more information about our advertising and marketing practices and those of the third party advertising partners, as well as information regarding how to opt out of interest-based advertising, please see our Cookie Policy. Social Networking and Other Websites. The Services may allow you to share Personal Information with social networking services, such as Facebook. We do not share your Personal Information with third-party websites unless you direct the Services to share it. Third-party websites’ use of your Personal Information is governed by their privacy policies. Other Users. Your Public Information, which includes your Favorites, is viewable by other users, unless you change your account settings to make your Favorites private. However, if you registered for the Services prior to May 7, 2014, then your Favorites will be private unless you change your profile settings to make them publicly accessible. Your profile information, such as any photographs, your username, and any content that you post in your account, is also viewable by other users. We are not responsible for the privacy practices of other users. Accordingly, we recommend that you carefully consider what you post to the Services before doing so. Other Third Parties. We may also share Personal Information about you in the following additional circumstances: • With Your Consent. We may disclose your Personal Information with your permission. We may seek your permission in various ways. For example, we may present you with an “opt-in” prompt when you register to use the Services or access certain content. • To Comply with Legal Obligations. We may access, preserve, and disclose your Personal Information or other account information if we believe doing so is required or appropriate to (i) comply with laws, law enforcement requests, and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety. • In case of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation where the business will not continue as a going concern, receivership, sale of Soda Pop Radio assets, or transition of the Services to another provider, then your Personal Information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of these events should be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

If you are located in the European Economic Area (“EEA”):

We only process your Personal Information based on a valid legal ground, including when you have consented to the use of your Personal Information, for example, to provide you with tailored advertising. • We need your Personal Information to provide you with the Services, including for account registration, to respond to your inquiries or, if you are a broadcaster, to manage the directory listing and for support. • We have a legal obligation to use your Personal Information, such as the obligation to protect intellectual property rights and restrict content available on the Services based on your location. • We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to personalize our Services and provide you with tailored content, conduct business analytics and otherwise improve the safety, security, fraud prevention, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

Third-Party Websites

This Privacy Policy applies only to the processing of your Personal Information by Soda Pop Radio. The Services may contain links to third-party sites, such as third-party content providers (“Third-Party Sites”). The policies and procedures described in this Privacy Policy do not apply to Third-Party Sites. The links from the Services to any Third-Party Sites do not imply that we endorse or have reviewed the Third-Party Sites or their privacy practices.

Children’s Privacy

We do not knowingly collect, maintain, or use Personal Information, as defined by the Federal Trade Commission’s Children’s Online Privacy Protection Act Rule, from children under 13 years of age, and no part of the Services is directed to children under the age of 13. If you are located in the EEA, we do not knowingly collect, maintain, or use Personal Information from children under 16 years of age, and no part of the Services are directed to children under the age of 16. If you are located in Mexico, we do not knowingly collect, maintain, or use Personal Information from children under 18 years of age, and no part of the Services are directed to children under the age of 18. If you are located in Brazil, we do not knowingly collect, maintain, or use personal sensitive information, as it is defined in the applicable law. We will only collect, maintain, or use any personal sensitive information pursuant to your previous and express consent. If you believe that your child has provided us with Personal Information, please alert us by contacting us below. If we learn that we have collected any Personal Information from a child (as defined by local law), we will promptly take steps to delete such information and terminate the child’s account.

Your Choices And Rights

Your Privacy Rights

Depending on where you are located, you may have the right to: • Access to Data: You may request a copy of Personal Information we have about you in a portable format and/or request us to transfer all or some of this data to a third party. • Correction of Data: You may request that we update, correct, or rectify personal information we have about you. • Deletion of Data: You may request that we delete personal information we have about you. • Restriction of or Object to Processing: You may have the right to opt in or opt out of certain uses of your Personal Information, or to object to all processing of your Personal Information, or to withdraw consent you previously gave for the processing of your Personal Information. • Supervisory Authority: If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law. These rights may be limited in some circumstances by local law requirements. You may exercise these rights by clicking “Make a Privacy Request” at the top of this page, or by contacting us as described below. You have the right not to receive discriminatory treatment for the exercise of your privacy rights. If you wish to appeal a decision relating to your data rights request, please contact us at privacy@sodapopradio.com.

Accessibility

This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF. If you need further assistance regarding the accessibility of this webpage, please contact us as described below.

Updates To This Policy

We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted

Contact Us

If you have any questions, would like to exercise your rights or share suggestions for improving the Privacy Policy or the Services in USA, or otherwise would like to contact us, then please feel free to contact us per the information below. Soda Pop Radio LLC 77 WEST 66TH ST, LOS ANGELES, CA 10023 support@sodapopradio.com Soda Pop Radio LLC 800 Third Avenue 5th floor New York, NY 10022 USA If you are located in the EEA and would like to raise a question to us about your Personal Information, or otherwise exercise your rights in respect of your Personal Information, then you may contact us per the information below. Soda Pop Radio GmbH, LLC. Zimmerstrasse 78, 10117 Berlin, Germany support@sodapopradio.com Soda Pop Radio ApS Turesensgaden 33, 1368 Copenhagen,Denmark support@sodapopradio.com If you are located in the United Kingdom or Switzerland and would like to raise a question to us about your Personal Information, or otherwise exercise your rights in respect of your Personal Information, then you may also contact our respective data protection representative noted below. Soda Pop Radio, Switzerland Leutschenbachstrasse 95 zurich, 8050,Switzerland support@sodapopradio.com Soda Pop Radio,United Kingdom 107-111 Fleet Street London, EC4A 2AB, United Kingdom support@sodapopradio.com