Smart MP3 Player Privacy Policy
This Privacy Notice for __________ (“we,” “us,” or “our”), describes how
and why we might access, collect, store, use, and/or share (“process”)
your personal information when you use our services (“Services”),
including when you: Download and use our mobile application (Smart MP3
Player), or any other application of ours that links to this Privacy
Notice Engage with us in other related ways, including any marketing or
events Questions or concerns? Reading this Privacy Notice will help you
understand your privacy rights and choices. We are responsible for
making decisions about how your personal information is processed. If
you do not agree with our policies and practices, please do not use our
Services.
SUMMARY OF KEY POINTS This summary provides key points from our Privacy
Notice, but you can find out more details about any of these topics by
clicking the link following each key point or by using our table of
contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or
navigate our Services, we may process personal information depending on
how you interact with us and the Services, the choices you make, and the
products and features you use. Learn more about personal information you
disclose to us.
Do we process any sensitive personal information? Some of the
information may be considered “special” or “sensitive” in certain
jurisdictions, for example your racial or ethnic origins, sexual
orientation, and religious beliefs. We do not process sensitive personal
information.
Do we collect any information from third parties? We do not collect any
information from third parties.
How do we process your information? We process your information to
provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent. We
process your information only when we have a valid legal reason to do
so. Learn more about how we process your information.
In what situations and with which parties do we share personal
information? We may share information in specific situations and with
specific third parties. Learn more about when and with whom we share
your personal information.
What are your rights? Depending on where you are located geographically,
the applicable privacy law may mean you have certain rights regarding
your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights
is by submitting a data subject access request, or by contacting us. We
will consider and act upon any request in accordance with applicable
data protection laws.
Want to learn more about what we do with any information we collect?
Review the Privacy Notice in full.
TABLE OF CONTENTS 1. WHAT INFORMATION DO WE COLLECT? 2. HOW DO WE
PROCESS YOUR INFORMATION? 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS
YOUR PERSONAL INFORMATION? 4. WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION? 5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES? 6.
HOW LONG DO WE KEEP YOUR INFORMATION? 7. DO WE COLLECT INFORMATION FROM
MINORS? 8. WHAT ARE YOUR PRIVACY RIGHTS? 9. CONTROLS FOR DO-NOT-TRACK
FEATURES 10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE? 12. HOW CAN YOU CONTACT US ABOUT
THIS NOTICE? 13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to
us In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when
you express an interest in obtaining information about us or our
products and Services, when you participate in activities on the
Services, or otherwise when you contact us.
Sensitive Information. We do not process sensitive information.
Application Data. If you use our application(s), we also may collect the
following information if you choose to provide us with access or
permission: Mobile Device Access. We may request access or permission to
certain features from your mobile device, including your mobile device’s
storage, and other features. If you wish to change our access or
permissions, you may do so in your device’s settings. This information
is primarily needed to maintain the security and operation of our
application(s), for troubleshooting, and for our internal analytics and
reporting purposes.
All personal information that you provide to us must be true, complete,
and accurate, and you must notify us of any changes to such personal
information.
2. HOW DO WE PROCESS YOUR INFORMATION? In Short: We process your
information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to
comply with law. We process the personal information for the
following purposes listed below. We may also process your
information for other purposes only with your prior explicit
consent.
We process your personal information for a variety of reasons, depending
on how you interact with our Services, including:
To save or protect an individual’s vital interest. We may process your
information when necessary to save or protect an individual’s vital
interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION? In
Short: We only process your personal information when we believe it
is necessary and we have a valid legal reason (i.e., legal basis) to
do so under applicable law, like with your consent, to comply with
laws, to provide you with services to enter into or fulfill our
contractual obligations, to protect your rights, or to fulfill our
legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your
personal information. As such, we may rely on the following legal bases
to process your personal information: Consent. We may process your
information if you have given us permission (i.e., consent) to use your
personal information for a specific purpose. You can withdraw your
consent at any time. Learn more about withdrawing your consent. Legal
Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to
cooperate with a law enforcement body or regulatory agency, exercise or
defend our legal rights, or disclose your information as evidence in
litigation in which we are involved. Vital Interests. We may process
your information where we believe it is necessary to protect your vital
interests or the vital interests of a third party, such as situations
involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission
(i.e., express consent) to use your personal information for a specific
purpose, or in situations where your permission can be inferred (i.e.,
implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable
law to process your information without your consent, including, for
example: If collection is clearly in the interests of an individual and
consent cannot be obtained in a timely way For investigations and fraud
detection and prevention For business transactions provided certain
conditions are met If it is contained in a witness statement and the
collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with
next of kin If we have reasonable grounds to believe an individual has
been, is, or may be victim of financial abuse If it is reasonable to
expect collection and use with consent would compromise the availability
or the accuracy of the information and the collection is reasonable for
purposes related to investigating a breach of an agreement or a
contravention of the laws of Canada or a province If disclosure is
required to comply with a subpoena, warrant, court order, or rules of
the court relating to the production of records If it was produced by an
individual in the course of their employment, business, or profession
and the collection is consistent with the purposes for which the
information was produced If the collection is solely for journalistic,
artistic, or literary purposes If the information is publicly available
and is specified by the regulations We may disclose de-identified
information for approved research or statistics projects, subject to
ethics oversight and confidentiality commitments
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? In Short:
We may share information in specific situations described in this
section and/or with the following third parties.
We may need to share your personal information in the following
situations: Business Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion of
our business to another company.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES? In Short: We are not
responsible for the safety of any information that you share with
third parties that we may link to or who advertise on our Services,
but are not affiliated with, our Services.
The Services may link to third-party websites, online services, or
mobile applications and/or contain advertisements from third parties
that are not affiliated with us and which may link to other websites,
services, or applications. Accordingly, we do not make any guarantee
regarding any such third parties, and we will not be liable for any loss
or damage caused by the use of such third-party websites, services, or
applications. The inclusion of a link towards a third-party website,
service, or application does not imply an endorsement by us. We cannot
guarantee the safety and privacy of data you provide to any third-party
websites. Any data collected by third parties is not covered by this
Privacy Notice. We are not responsible for the content or privacy and
security practices and policies of any third parties, including other
websites, services, or applications that may be linked to or from the
Services. You should review the policies of such third parties and
contact them directly to respond to your questions.
6. HOW LONG DO WE KEEP YOUR INFORMATION? In Short: We keep your
information for as long as necessary to fulfill the purposes
outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is
necessary for the purposes set out in this Privacy Notice, unless a
longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymize such
information, or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further
processing until deletion is possible.
7. DO WE COLLECT INFORMATION FROM MINORS? In Short: We do not knowingly
collect data from or market to children under 18 years of age or the
equivalent age as specified by law in your jurisdiction.
We do not knowingly collect, solicit data from, or market to children
under 18 years of age or the equivalent age as specified by law in your
jurisdiction, nor do we knowingly sell such personal information. By
using the Services, you represent that you are at least 18 or the
equivalent age as specified by law in your jurisdiction or that you are
the parent or guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal information
from users less than 18 years of age or the equivalent age as specified
by law in your jurisdiction has been collected, we will deactivate the
account and take reasonable measures to promptly delete such data from
our records. If you become aware of any data we may have collected from
children under age 18 or the equivalent age as specified by law in your
jurisdiction, please contact us at desaiofindia111@gmail.com.
8. WHAT ARE YOUR PRIVACY RIGHTS? In Short: Depending on your state of
residence in the US or in some regions, such as the European
Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada,
you have rights that allow you greater access to and control over
your personal information. You may review, change, or terminate your
account at any time, depending on your country, province, or state
of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have
certain rights under applicable data protection laws. These may include
the right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict
the processing of your personal information; (iv) if applicable, to data
portability; and (v) not to be subject to automated decision-making. If
a decision that produces legal or similarly significant effects is made
solely by automated means, we will inform you, explain the main factors,
and offer a simple way to request human review. In certain
circumstances, you may also have the right to object to the processing
of your personal information. You can make such a request by contacting
us by using the contact details provided in the section “HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?” below.
We will consider and act upon any request in accordance with applicable
data protection laws.
If you are located in the UK and are unhappy with how we have handled
your personal information, you can make a complaint directly to us. This
is in addition to the rights you have under the UK General Data
Protection Regulation and the Data Protection Act 2018.
How to contact us:What happens after you complain We will acknowledge
your complaint within 30 days of receiving it.
We will investigate without unjustifiable or excessive delay.
We will keep you informed of progress and explain the outcome. If you
are not happy with our final response, you can refer your complaint to
the Information Commissioner’s Office, the UK supervisory authority.
Website: ico.org.uk/make-a-complaint
Helpline: 0303 123 1113
Post: Information Commissioner’s Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF If you are located in the EEA or UK and you
believe we are unlawfully processing your personal information, you also
have the right to complain to your Member State data protection
authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data
Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process
your personal information, which may be express and/or implied consent
depending on the applicable law, you have the right to withdraw your
consent at any time. You can withdraw your consent at any time by
contacting us by using the contact details provided in the section “HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
However, please note that this will not affect the lawfulness of the
processing before its withdrawal nor, when applicable law allows, will
it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
9. CONTROLS FOR DO-NOT-TRACK FEATURES Most web browsers and some mobile
operating systems and mobile applications include a Do-Not-Track
(“DNT”) feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities
monitored and collected. At this stage, no uniform technology
standard for recognizing and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your
choice not to be tracked online. If a standard for online tracking
is adopted that we must follow in the future, we will inform you
about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser
DNT signals. Because there currently is not an industry or legal
standard for recognizing or honoring DNT signals, we do not respond to
them at this time.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? In Short:
If you are a resident of California, Colorado, Connecticut,
Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota,
Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island,
Tennessee, Texas, Utah, or Virginia, you may have the right to
request access to and receive details about the personal information
we maintain about you and how we have processed it, correct
inaccuracies, get a copy of, or delete your personal information.
You may also have the right to withdraw your consent to our
processing of your personal information. These rights may be limited
in some circumstances by applicable law. More information is
provided below. Categories of Personal Information We Collect The
table below shows the categories of personal information we have
collected in the past twelve (12) months. The table includes
illustrative examples of each category and does not reflect the
personal information we collect from you. For a comprehensive
inventory of all personal information we process, please refer to
the section “WHAT INFORMATION DO WE COLLECT?”
Category Examples Collected A. Identifiers Contact details, such as real
name, alias, postal address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol address, email
address, and account name
NO
B. Personal information as defined in the California Customer Records
statute Name, contact information, education, employment, employment
history, and financial information
NO
C. Protected classification characteristics under state or federal law
Gender, age, date of birth, race and ethnicity, national origin, marital
status, and other demographic data
NO
D. Commercial information Transaction information, purchase history,
financial details, and payment information
NO
E. Biometric information Fingerprints and voiceprints
NO
F. Internet or other similar network activity Browsing history, search
history, online behavior, interest data, and interactions with our and
other websites, applications, systems, and advertisements
NO
G. Geolocation data Device location
NO
H. Audio, electronic, sensory, or similar information Images and audio,
audio or call recordings created in connection with our business
activities
NO
I. Professional or employment-related information Business contact
details in order to provide you our Services at a business level or job
title, work history, and professional qualifications if you apply for a
job with us
NO
J. Education Information Student records and directory information
NO
K. Inferences drawn from collected personal information Inferences drawn
from any of the collected personal information listed above to create a
profile or summary about, for example, an individual’s preferences and
characteristics
NO
L. Sensitive personal Information
NO
We may also collect other personal information outside of these
categories through instances where you interact with us in person,
online, or by phone or mail in the context of: Receiving help through
our customer support channels; Participation in customer surveys or
contests; and Facilitation in the delivery of our Services and to
respond to your inquiries. Sources of Personal Information Learn more
about the sources of personal information we collect in “WHAT
INFORMATION DO WE COLLECT?” How We Use and Share Personal Information
Learn more about how we use your personal information in the section,
“HOW DO WE PROCESS YOUR INFORMATION?”
Will your information be shared with anyone else?
We may disclose your personal information with our service providers
pursuant to a written contract between us and each service provider.
Learn more about how we disclose personal information to in the section,
“WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”
We may use your personal information for our own business purposes, such
as for undertaking internal research for technological development and
demonstration. This is not considered to be “selling” of your personal
information.
We have not disclosed, sold, or shared any personal information to third
parties for a business or commercial purpose in the preceding twelve
(12) months. We will not sell or share personal information in the
future belonging to website visitors, users, and other consumers. Your
Rights You have rights under certain US state data protection laws.
However, these rights are not absolute, and in certain cases, we may
decline your request as permitted by law. These rights include: Right to
know whether or not we are processing your personal data Right to access
your personal data Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data Right to obtain a
copy of the personal data you previously shared with us Right to
non-discrimination for exercising your rights Right to opt out of the
processing of your personal data if it is used for targeted advertising
(or sharing as defined under California’s privacy law), the sale of
personal data, or profiling in furtherance of decisions that produce
legal or similarly significant effects (“profiling”) Depending upon the
state where you live, you may also have the following rights: Right to
access the categories of personal data being processed (as permitted by
applicable law, including the privacy law in Minnesota) Right to obtain
a list of the categories of third parties to which we have disclosed
personal data (as permitted by applicable law, including the privacy law
in California, Delaware, and Maryland) Right to obtain a list of
specific third parties to which we have disclosed personal data (as
permitted by applicable law, including the privacy law in Minnesota and
Oregon) Right to obtain a list of third parties to which we have sold
personal data (as permitted by applicable law, including the privacy law
in Connecticut) Right to review, understand, question, and depending on
where you live, correct how personal data has been profiled (as
permitted by applicable law, including the privacy law in Connecticut
and Minnesota) Right to limit use and disclosure of sensitive personal
data (as permitted by applicable law, including the privacy law in
California) Right to opt out of the collection of sensitive data and
personal data collected through the operation of a voice or facial
recognition feature (as permitted by applicable law, including the
privacy law in Florida) How to Exercise Your Rights To exercise these
rights, you can contact us by submitting a data subject access request,
by emailing us at desaiofindia111@gmail.com, or by referring to the
contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an
authorized agent to make a request on your behalf. We may deny a request
from an authorized agent that does not submit proof that they have been
validly authorized to act on your behalf in accordance with applicable
laws. Request Verification Upon receiving your request, we will need to
verify your identity to determine you are the same person about whom we
have the information in our system. We will only use personal
information provided in your request to verify your identity or
authority to make the request. However, if we cannot verify your
identity from the information already maintained by us, we may request
that you provide additional information for the purposes of verifying
your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to
collect additional information to verify your identity before processing
your request and the agent will need to provide a written and signed
permission from you to submit such request on your behalf. Appeals Under
certain US state data protection laws, if we decline to take action
regarding your request, you may appeal our decision by emailing us at
__________. We will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the
reasons for the decisions. If your appeal is denied, you may submit a
complaint to your state attorney general. California “Shine The Light”
Law California Civil Code Section 1798.83, also known as the “Shine The
Light” law, permits our users who are California residents to request
and obtain from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all
third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident
and would like to make such a request, please submit your request in
writing to us by using the contact details provided in the section “HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?”
11. DO WE MAKE UPDATES TO THIS NOTICE? In Short: Yes, we will update
this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version
will be indicated by an updated “Revised” date at the top of this
Privacy Notice. If we make material changes to this Privacy Notice, we
may notify you either by prominently posting a notice of such changes or
by directly sending you a notification. We encourage you to review this
Privacy Notice frequently to be informed of how we are protecting your
information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? If you have questions or
comments about this notice, you may email us at
desaiofindia111@gmail.com or contact us by post at:
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13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You have the right to request access to the personal information we
collect from you, details about how we have processed it, correct
inaccuracies, or delete your personal information. You may also have
the right to withdraw your consent to our processing of your
personal information. These rights may be limited in some
circumstances by applicable law. To request to review, update, or
delete your personal information, please fill out and submit a data
subject access request.
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