Privacy 


1. Introduction

Thanks for choosing Eavesdrop!

At Eavesdrop, we want to give you the best possible experience to ensure that you enjoy our service. To do this we need to understand your streaming habits so we can deliver an exceptional and personalized service specifically for you. Your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.

That is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.


2. About this Policy

This Policy sets out the essential details relating to your personal data relationship with Eavesdrop USA Inc. The Policy applies to all Eavesdrop services and any associated services (referred to as the ‘Eavesdrop Service’). The terms governing your use of the Eavesdrop Service are defined in our Terms and Conditions of Use (the “Terms and Conditions of Use”).

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

The aim of this Policy is to:

    1.    Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;

    2.    Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Eavesdrop Service; and

    3.    Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see Section 13 ‘How to contact us’ below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Eavesdrop Service.


3. Your rights and your preferences: Giving you choice and control

The General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

        Right of access - the right to be informed of, and request access to, the personal data we process about you;

        Right to rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;

        Right to erasure - the right to request that we delete your personal data;

        Right to restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;

        Right to object -

        the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;

        the right to object to your personal data being processed for direct marketing purposes;

        Right to data portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and

        Right not to be subject to automated decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.


In order to enable you to learn more about these rights, exercise these rights with ease, and record your preferences in relation to how Eavesdrop uses your personal data, we provide the following resources:

        Privacy Settings (accessed via your account page) - allows you to exercise choices about the processing of certain personal data, and an automated ‘Download your data’ function to download basic account and usage information.

        Privacy Center - provides a convenient central location where you can find more information about how Eavesdrop uses your personal data, your rights in relation to your personal data, and how to exercise those rights.

        Notification Settings (accessed via your account page) - allows you to choose which marketing communications you receive from Eavesdrop. You may toggle these settings to opt in or out of receiving different types of email and push notifications. Please note that email marketing messages from Eavesdrop include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you). Clicking on the link in an email will opt you out of further messages of that category (e.g. Artist Updates). You can use the Notification Settings page to exercise choices about all categories of email and push marketing communication.

        Cookies Policy - provides more information on how we use cookies, including for interest-based advertising. You will also find information about how you can manage your cookie preferences and opt-out of certain types of tracking; and

        Customer Support resources - We have several pages on our customer support site which provide further guidance about data protection questions. A key source of information is the Data Rights and Privacy Settings article which includes answers to “frequently asked questions” about personal data processing in the Eavesdrop Service.

If you have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the ‘Contact Us’ form on the Privacy Center. If you have concerns around our processing of your personal data, we hope you will continue to work with us to resolve them. However, you can also contact and have the right to lodge a complaint with the Swedish Data Protection Authority (Datainspektionen) or your local Data Protection Authority.

Additional privacy rights under the California Consumer Privacy Act (CCPA) can be found in our supplemental policy “Additional California Privacy Disclosures”, which contains supplemental disclosures relating to the processing of your personal data.


4. Personal data we collect from you

This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Eavesdrop Service. Depending on the type of Eavesdrop Service plan you sign up for, this may include your username, email address, phone number, birth date, gender, street address, and country.


Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with additional personal data in order to make your account more personalized.


Personal data that is collected about you when you’re accessing and/or using the Eavesdrop Service, may include:


    Information about your interactions with the Eavesdrop Service such as your search queries (including the date and time of any requests you make), streaming history, playlists you create, your library, your browsing history, and your interactions with the Eavesdrop Service, content, other Eavesdrop users. This also may include details of your use of third party applications in connection with the Eavesdrop Service.


        Inferences drawn about your interests and preferences based on your usage of the Eavesdrop Service.

        User Content (as defined in the Terms and Conditions of Use) you post to Eavesdrop, such as photos, playlist titles, and interactions with the Eavesdrop Customer Service team. Please note that we will only access your camera or photos from your device if you give us permission to do so, and we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your device’s photo library or camera roll.

        Certain technical data, which may include:

        URL information;

        online identifiers including cookie data and IP addresses;

        information about the types of devices you are using such as unique device IDs, network connection type (e.g. wifi, 3G, LTE, Bluetooth), provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Eavesdrop application version;

        device attributes of devices on your wifi network that are available to connect to the Eavesdrop Service (such as speakers);

        your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device, or payment currency), to comply with geographic requirements in our licensing agreements, and deliver personalized content and advertising to you; and

        motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the Eavesdrop Service to you.


Voice Data

If voice features are available in your market, we collect your voice data with your permission to provide you with additional features and functionalities, such as interacting with the Eavesdrop Service with your voice.


If you register for or log into our services using third party credentials (e.g. Facebook), we will import your information from such third party to help create your account with us.


Technical service partners

We work with technical service partners that provide us with certain data, such as mapping IP addresses to non-precise location data (e.g., city, state), to enable us to provide the Eavesdrop Service, content, and features.



Advertisers and other advertising partners

We may obtain certain data about you, such as cookie id, mobile device id, or email address, and inferences about your interests and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness.


5. What we use your personal data for

When you use or interact with the Eavesdrop Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 4 ‘Personal data we collect from you’ used for these purposes:


To provide and personalize the Eavesdrop Service.

        Performance of a Contract

        Legitimate Interest

        Consent

        User Data

        Usage Data

        Voice Data

To understand, diagnose, troubleshoot, and fix issues with the Eavesdrop Service.

        Performance of a Contract

        Legitimate Interest

        User Data

        Usage Data

To evaluate and develop new features, technologies, and improvements to the Eavesdrop Service.

        Legitimate Interest

        Consent

        User Data

        Usage Data

        Voice Data

For marketing, promotion, and advertising purposes.

        Legitimate Interest

        Consent

        User Data

        Usage Data

        Voice Data

To comply with legal obligations and law enforcement requests.

        Compliance with legal obligations

        Legitimate interest

        User Data

        Usage Data

        Voice Data

        Contests, Surveys and Sweepstakes Data

To fulfill contractual obligations with third parties, for example licensing agreements and to take appropriate action with respect to reports of intellectual property infringement and inappropriate content.

        Legitimate interest

        User Data

        Usage Data

To establish, exercise, or defend legal claims.

        Legitimate interest

        User Data

        Usage Data

        Voice Data

        Contests, Surveys and Sweepstakes Data

To conduct business planning, reporting, and forecasting.

        Legitimate interest

        User Data

        Usage Data

To conduct research, contests, surveys, and sweepstakes.

        Performance of a Contract

        Legitimate Interest

        Consent

        User Data

        Usage Data

        Contests, Surveys and Sweepstakes Data

If you require further information about the balancing test that Eavesdrop has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 13 ‘How to contact us’ for further details on how to contact us.


6. Sharing your personal data

We have set out the categories of recipients of the personal data collected or generated through your use of the Eavesdrop Service.

Publicly available information

The following personal data will always be publicly available on the Eavesdrop Service: your name and/or username, profile picture, who you follow and who follows you on the Eavesdrop Service, your recently played artists, and your public playlists.


Third party applications and devices you connect to your Eavesdrop Account

If you connect your Eavesdrop account to a third party application and/or device(s), such as, social media, audio, television, or automotive platforms and services, Eavesdrop shares technical data with the operator of that third party application and/or device in order to connect your Eavesdrop account, and/or facilitate playback of the Eavesdrop Service. With respect to certain third parties which may request or require that we share your information with them, your permission will be requested before we provide your information to such third parties.


Your Eavesdrop followers

There may be times when you want us to share information about your use of the Eavesdrop Service with other Eavesdrop users known as ‘Your Eavesdrop Followers’. For example, you have the ability to make both private and public playlists. If you share your private playlists with others, please be aware that the recipients of your private playlists can further share those playlists with others.


Podcast authors

You may choose to share personal data (for example, your email address) with artists, record labels, or other partners who may want to directly send you news or promotional offers. You will always have the option to change your mind and withdraw your consent at any time.

Learn more about how to manage notifications, your publicly available information, and what you share with others in Section 3 ‘Your rights and your preferences: Giving you choice and control’ of this Policy and on the Privacy Center.


We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we've hired to provide customer service support, operate the technical infrastructure that we need to provide the Eavesdrop Service, assist in protecting and securing our systems and services, and help market Eavesdrop’s own products and services as well as partner products, services, events, and co-branded promotions in which Eavesdrop is involved.


Advertising partners

We work with advertising partners to enable us to customize the advertising content you may receive on the Eavesdrop Service. These partners help us deliver more relevant ads and promotional messages to you, which may include interest based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the Eavesdrop Service. We and our advertising partners may process certain personal data to help Eavesdrop understand your interests or preferences so that we can deliver advertisements that are more relevant to you.


Eavesdrop partners

Depending on how you sign up for the Eavesdrop Service (e.g. through a third party service or a mobile provider), we share your Eavesdrop username or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the Eavesdrop Service, such as whether and to what extent you have used the offer, activated a Eavesdrop account, or actively used the Eavesdrop Service. We also may share your personal data in a pseudonymised format with our music industry partners to help them understand how the content they license to us is performing and to enable you to listen to streaming content via the Eavesdrop Service.


Academic researchers

We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format.


Other Eavesdrop group companies

We will share your personal data with other Eavesdrop group companies to carry out our daily business operations and to enable us to maintain and provide the Eavesdrop Service to you.


Law enforcement and data protection authorities

We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.


Purchasers of our business

We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Eavesdrop will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.


7. Data retention and deletion

We keep your personal data only as long as necessary to provide you with the Eavesdrop Service and for legitimate and essential business purposes, such as maintaining the performance of the Eavesdrop Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Eavesdrop Service. For example, we keep your playlists, podcast library, and account information.


If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

        If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;

        Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,

        Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.


8. Transfer to other countries

Eavesdrop shares your personal data globally with Eavesdrop group companies in order to carry out the activities specified in this Policy. Eavesdrop may also subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country.


Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances Eavesdrop shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.


9. Links

We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Eavesdrop Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.


10. Keeping your personal data safe

We are committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.


Your password protects your user account, so we encourage you to use a strong password that is unique to your Eavesdrop account, never share your password with anyone, limit access to your computer and browser, and log out after having used the Eavesdrop Service.


11. Children

The Eavesdrop Service is not directed to children under the age of 13 years. The Eavesdrop Service is also not offered to children whose age makes it illegal to process their personal data or requires parental consent for the processing of their personal data under the GDPR or other local law.


We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Eavesdrop Service, and do not provide any personal data to us.

If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Eavesdrop, please contact us using the ‘Contact Us’ form on the Privacy Center, and you may request exercise of your applicable rights detailed in Section 3 ‘Your rights and your preferences: Giving you choice and control’ of this Policy.


If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the Eavesdrop account for that child.


12. Changes to this Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Eavesdrop Service or by sending you an email and/or a device notification. We may notify you in advance.

Please, therefore, make sure you read any such notice carefully.


13. How to contact us

Thank you for reading our Policy. If you have any questions about this Policy, please contact our Data Protection Officer by using the ‘Contact Us’ form on the Privacy Center, emailing privacy@eavesdrop.club.


We hope you enjoy Eavesdrop!

© Eavesdrop Inc.