Privacy Policy
Last Updated: September 22, 2025
Introduction
Welcome to Sofar Sounds! Sofar Sounds Inc located at 259 Elm Street, Suite 200, Somerville, MA USA 02144 ( “Sofar”, “we” or “us”) understand that privacy is important to you and want you to know that we are committed to safeguarding your Personal Information or Personal Data as set forth below. As a result, we want to provide you with a clear picture of how the Personal Information that you provide to us is processed, managed, and protected by us, and what your choices are with respect to that information. There are two other companies within the Sofar group – Sofar Sounds Limited with its registered address at 52 Tabernacle Street, London, EC2A 4NJ and Sofar Sounds Inc and Sofar Sounds with its registered office at Suite 2400 - 745 Thurlow Street, Vancouver, BC Canada V6E 0C5 (“Group Companies”)
We operate a platform through which independent event organizers around the world and in some instances, Sofar itself, offer tickets for sale to music concerts (the “Platform”). This policy applies to: (i) visitors to the website who have not created an account on the Sofar platform (“Users”), (ii) individuals that sign-up (or have already registered) as members with us (“Members”); (iii) additional guests whose ticket(s) have been purchased by a Member (“Additional Guests”) and (iv) individuals who have provided an email address and joined our mailing list but have not created an account (“Customer Leads”). This policy sets out the basis on which personal data about Users, Members Additional Guests and Customer Leads will be processed and applies to activities occurring on or in connection with our website, https://www.sofarsounds.com/ (“Website”). This privacy policy supplements other notices and privacy policies on the Website and is not intended to override them.
This policy does not cover the processing of personal data of hosts or performers
If you voluntarily provide your information in the course of interacting with our Platform or otherwise using our Services, we will take that as your agreement to our collection, use, and disclosure of your information as set forth in this Privacy Policy.
This Privacy Policy also does not apply to any products, services, websites and Apps, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies.
EU, EEA and UK residents, California residents may have additional rights. Please see our GDPR Privacy Rights and Privacy Notice for California Residents ections following the main Privacy Policy.
PLEASE READ CAREFULLY PRIOR TO CONTINUING TO VIEW OUR WEBSITE, PLATFORM OR USING OUR SERVICES. BY ACCESSING THE PLATFORM AND/OR USING OUR SERVICES, YOU AFFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO ABIDE TO THIS PRIVACY POLICY. YOUR ACCESS TO AND USE OF THE SERVICES IS ALSO SUBJECT TO OUR TERMS OF SERVICE (THE “TERMS OF SERVICE”). IF YOU DO NOT AGREE TO ABIDE BY THIS PRIVACY POLICY, YOU MAY NOT ENTER, ACCESS, OR OTHERWISE USE OUR SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE, YOU REPRESENT TO US THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL TO ACCEPT THIS PRIVACY POLICY AND YOU DO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S BEHALF.
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What Information We Collect
- Information You Provide to Us
The type of information you provide to us depends on the nature of your interaction with the Platform and our Services. We refer to all of this personally identifiable information as Personal Information or Personal Data.
BASIC INFORMATION
We may ask you to provide us (or you may choose to provide us) with information, including
- First and Last Name,
- Email Address,
- Birthdate in order to verify your age,
- Telephone Number or Mobile Number,
- Gender identity,
- Your user ID and password,
- Pictures for profile purposes,
- Audio and visual recordings, such as when you upload a video of your performance, if applicable,
- CCTV Data which include images taken by the CCTV in operation at events.
- Event Data, which include professional recordings of such events by us or our service providers;
- Additional Guest Data, which includes the first name, last name and email address of each Additional Guest,
- Employment related information which you provide in connection with an application for employment, and
- Other information you provide us relevant to the task or requested services.
We do not knowingly collect any Special Categories of Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data) unless you voluntarily provide such Special Categories of Personal Data to us in an email to us, on our Website or social media, or any survey. We also do not collect any information about criminal convictions and offences.
DEMOGRAPHIC INFORMATION
We may collect demographic information, such as your postal zip code.
In all instances, your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Platform’s features or our Services or gain employment.
USAGE INFORMATION
In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Platform (“Usage Information”).
This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Platform. Usage Information may include:
•Your IP address, IDFA, Google Advertising ID, IMEI, or another unique identifier.
•Your Device functionality (including browser, browser language, time zone, operating system, hardware, mobile network information).
•Referring and exit web pages and URLs;
•The areas within our Platform that you visit and your activities there, including remembering you and your preferences;
•Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
•Your Device characteristics; and
• Certain other Device data, including the time of day you visit our Platform.
- Cookie Policy - Information from Cookies and other Tracking Technologies
We may use various methods to store or collect Usage Information (“Tracking Technologies”). A few of the Tracking used on the Platform, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):
- Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Platform may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage. We may use cookies for tracking purposes.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Platform, such as the links you click on.
- ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
- Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
- Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
- To allow you to use and access the Platform, including for the prevention of fraudulent activity and improved security functionality (essential);
- To assess the performance of the Platform, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Platform (non-essential);
- To offer you enhanced functionality when accessing the Platform, including identifying you when you sign into our Platform or keeping track of your specified preferences or to track your online activities over time and across third-party Platforms (non-essential); and
- To deliver content relevant to your interests on our Platform and third-party platforms based on how you interact with our content (non-essential).
You can decline non-essential Tracking Technologies and stop your data being used for advertising by saying 'No' when presented with the banner at the start of your journey. And you can manage your preferences at any time by selecting Manage Tracking Preferences on our website.
Users can opt-out of certain Google®-related tracking technology and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties in connection with the Platform.
Google® is a registered trademark of Alphabet, Inc. ("Google"). Please be advised that we are not in any way affiliated with Google, nor are the Services endorsed, administered or sponsored by Google.
To learn more about how to opt out of the Google Marketing Platform’s use of cookies, visit the opt-out page, here https://support.google.com/ads/answer/2662922?hl=e].
If you would like more information about behavioral advertising practices, go to the Digital Advertising Alliance’s WebChoices tool at www.aboutads.info. To learn about your choices in connection with these practices on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/choices and http://www.aboutads.info/choices.
You may also click on the informational icon contained within each interest-based ad. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the particular website you are viewing (e.g., contextually based ads). Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.
(c) Information We Collect When You Interact with Third-Party platforms
The Services may include functionality that allows certain kinds of interactions between the Platform and your account on a third-party website or application, such as Meta, Instagram, X or websites run by an artist in whom you are interested all of which are hosted by a third party. The use of this functionality may involve the third-party platform providing information to us. For example, we may provide links on the Platform to facilitate sending a communication from the Platform. These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party platforms or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using such third-party tools on our Platform.
- Information from Third Parties.
In addition, we may collect information about you from other sources as described more fully below. For example, we may obtain information about Additional Guests from Members. We may obtain information about you from marketers and market research firms or third-party payment processors. We may combine the information we collect from third parties with information that we have collected from you or through your use of the Services. We also utilize third party APIs to share video content such as YouTube API Services. Third parties such as YouTube can serve content such as advertisements.
(e) Location data
Where you consent, we may obtain information about your location to provide customized Services, content, and other information that may be of interest to you. If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your Device. Consult your Device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content or products may be limited or disabled.
- Inferences.
Using the other pieces of personal information collected about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.
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Why We Collect Personal Information
We may use your Personal Information for various purposes, including:
- Responding to requests for information,
- Fulfilling your requests for services, including access to the features on the Platform,
- Sending you nudges with respect to services you have requested,
- Verifying your identity and for fraud prevention,
- Creating accounts,
- Running competitions for the chance to be invited to a special event,
- Providing you with updates and information about services we provide,
- Creating user preferences regarding emails and other correspondence,
- Sending you marketing information about Sofar and our affiliated entities,
- Sending you email and text communications such as electronic newsletters about our Services and events which may be of interest to you,
- Improving the effectiveness of our Platform, our marketing endeavors, and our product and service offerings,
- Helping us address problems with and improve our Platform and our products and services, including testing and creating new products, features, and services,
- Protecting the security and integrity of the Platform, including understanding and resolving any technical and security issues reported on our Platform,
- Resolving disputes,
- Considering your application for employment,
- Engaging in analysis, research, and reports regarding the use of our Platform and Services,
- For internal business purposes and our legitimate interests.
- Complying with the law and protecting the safety, rights, property or security of Sofar, the Services, and the general public, and
- For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
When We Disclose Information
We may disclose your Personal Information in the following circumstances:
(a) To Third Parties Providing Services to Sofar. We may use Third-Party Service Providers and our Group Companies to perform certain services on behalf of us or the Platform or Services, such as: (i) creating and updating Platform functionality; (ii) billing or processing credit cards, and/or electronic or manual payments; (iii) assisting us in Platform operations; (iv) managing a database of customer and consumer information; (v) hosting the Platform and improving performance of the Platforms; (vi) designing and/or operating the Platform’s features; (vii) tracking the Platform’s activities and analytics, including marketing and market research; (viii) data enhancement (to learn more about our customers); (ix) enabling us and/or third parties to send you special offers or perform other administrative services, such as billing, customer service, security, tech, operational support, email services; (x) data managers or list managers to send third party email and/or SMS text messages; and (xi) other services designed to assist us in maximizing our business potential.
We share your name, email address and IP address with The Rocket Sciences Group LLC (t/a Mandrill) to send event emails. We may also obtain your personal data from third-party sponsors of Sofar events with whom you already interact.
We may provide these vendors with access to user information to carry out the services they are performing for you or for us. Those vendors may have additional or different privacy policies and/or privacy notices. You should be sure that you read and agree to those policies and Terms.
- To Protect the Rights of Sofar and Others. To the fullest extent permitted by applicable law, we may also disclose your information when required to by law or if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Sofar, its affiliates, third parties or the general public; (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders); or (iii) to respond to claims that any content violates the rights of a third party. This includes exchanging information with other companies and organizations for fraud prevention, spam/malware protection, and other similar purposes. To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest any requests for such disclosures, all without notice to you.
We reserve the right to release current or past personal information: (i) in the event that we believe that the Platform and Services are being or have been used to commit unlawful acts; (ii) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; or (iii) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if we are involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Platform of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.
(d) In connection with a Business Transfer. We also reserve the right to disclose and transfer all information: (i) to a subsequent owner, co-owner or operator of the Platform and/or our Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during any due diligence process.
(e) To Affiliates of Sofar. We may provide information to affiliates and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. (Examples of such disclosures include engaging a records-retention agency to store prior year records.)
(f) On the Basis of Consent. Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Sofar account or participating in promotional activities by Sofar partners or third parties.
(g) Marketing. We share your name, email address, city, IP address and gender with.our third-party email marketing vendors to send direct email marketing about third -party goods and services marketing emails.
You will receive marketing communications from us if you have requested information from us or purchased a ticket on our Platform or provided us with your details when you entered a sweepstake, giveaway, competition, or registered for a promotion, and in each case, you have not opted out of receiving such marketing communications.
(h) Advertising We may display ads on the Website via third-party advertising partners through targeted advertising or interest-based advertising. These third-party advertising partners may collect data about you to create a profile of your preferences when you use our Services. These companies may also automatically collect data when you use our Services, such as, for example, the delivery and measurement of these ads, through the use of cookies, pixel tags, and other online tracker technologies on our Website. These technologies help us better understand ad placement, views, and how often the ads are delivered. Depending on the type of personal data we collect, we will obtain your express opt-in or opt-out consent before sharing your Personal Data with any company outside of Sofar. Please see our Cookie Policy for more information about how the third-party advertising companies collect, use and store personal data, and how we use these cookies and other tracking technologies for our Services. You can also choose to restrict or prevent the collection and use of this data as described in our Cookie Policy. However, it might impact the kind of specialized and tailored advertising you might see on our Website.
Please see Your Choices About the Personal Information We Collect to learn how to opt out of receiving advertisements.
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Aggregated information
We may aggregate, de-identify, and/or anonymize any information collected through the Platform or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.
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Your Choices About the Personal Information We Collect
When you use the Services, you also agree to receive certain communications from us including but not limited to the following:
•Special Offers, Newsletters and Updates. We may occasionally send you information on events. products, special deals, promotions and newsletters.
•Customer Service. Based upon the Personal Information you provide us, we will communicate with you in response to your inquiries and reviews, to provide the services you request and to manage your account.
You may choose to restrict the collection or use of your Personal Information In the following ways:
•Whenever you are asked to fill in a form on our Platform or our other Services, consider what information to include and exclude.
•We may provide you with access to your registration information and the ability to edit this information in your account settings dashboard and profile pages. Please be aware that even after you delete or update information within our Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. Similarly, if and to the extent any information is indexable by search engines (including, without limitation, public profile information), it may not be updated by such search engines when we update it, and old versions may be archived by them or by third parties outside our control.
•Some of our Services may provide you with additional information and choices about your privacy, which you should review.
- If you do not wish to receive advertising or other commercial communications from us, please click here
If you have previously agreed to our using your Personal Information for direct marketing purposes, you may also change your mind at any time by writing to us at privacy@sofarsounds.com.
We will try to comply with your request(s) as soon as reasonably practicable.
Administrative Correspondence. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the Services, and you cannot opt-out from receiving those messages.
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Retention of Personal Information
- Sofar will retain Your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
•Sofar will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.
•To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Children’s Privacy
Our Service is NOT directed at persons under 13 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us. We encourage you to spend time online with your children and to participate and monitor the online activities of your children.
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California / Delaware Do Not Track Disclosures
Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to sites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track at https://allaboutdnt.com]
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Updating Personal Information
We prefer to keep your Personal Information accurate and up to date. You can update or change your Personal Information at any time by going to your account and updating it directly.
If you have provided us with Personal Information, you may request that it be updated, modified or deleted. You may do this by sending your request to privacy@sofarsounds.com.
If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all your information from our databases and that residual data may remain on backup media or for other reasons, such as a legitimate business reason.
In addition, please note that if you implement a deletion request but later sign up for information or Services, your most recent request will control our information relationship with you.
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Links
For your convenience, the Platform and this Privacy Policy may contain links to other websites. Sofar is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Platform should be deemed to imply that Sofar endorses or has any affiliation with the links.
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Your Nevada Privacy Rights
If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our Platform or when you otherwise interact with us online. As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing to privacy@sofarsounds.com with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out.
We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond.
California “Shine the Light” disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. We do not currently share your personal information with third parties for their own direct marketing purposes.
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Security
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Platform, and you provide us with your information at your own risk.
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International Data Transfers
Because Sofar works with global companies, we may transfer your Personal Information outside of the country in which it was originally provided. This may include transfers to third parties, such as developers, service providers or affiliated entities who are located outside the United States, the United Kingdom or the European Union, where data protection laws may not offer the same level of protection as those in the U.S.,U.K., E.U. or European Economic Area. When we transfer personal data outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect your Personal Information by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK ICO;
- Where we use certain service providers outside the UK or EU, we may use specific contracts approved by the ICO and/or European Commission as applicable which give personal data the same protection it has in the UK and/or Europe as applicable.
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Questions / Changes in Privacy Policy
If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacy@sofarsounds.com .We may elect to change or amend our Privacy Policy; in such event, we will post the policy changes in our Privacy Policy on the Platform and send you an email indicating that the terms have changed. Changes will be effective on the date posted. If you are concerned about how your Personal Information is used, please visit our Platform often for this and other important announcements and updates.
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Contact Us
You may contact us in any of the following manners:
By email : privacy@sofarsounds.com
Or by writing to us at:
US: 259 Elm Street, Suite 200, Somerville, MA USA 02144
UK: 52 Tabernacle Street, London, EC2A 4NJ
GDPR Privacy Rights
If you are a resident of or located within the United Kingdom, European Union or European Economic Area (“EEA”), you have certain additional data protection rights under the General Data Protection Regulation and the UK Data Protection Act 2018 (collectively “GDPR”). These rights include:
• The right to access, update or delete the information we have on you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine- readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
Legal Basis for Processing Personal Information under GDPR
For the purposes of GDPR, Sofar Sounds Inc is the “controller” for Personal Information.
Sofar’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.
Sofar may process your Personal Information because:
• We need to perform a contract with you;
• You have given us permission/consent to do so;
• The processing is in our legitimate interests, and it is not overridden by your rights; or
• To comply with the law.
Disclosure of Personal Information under GDPR-Legal Requirements
Sofar may disclose your Personal Information in the good faith belief that such action is necessary to:
• To comply with a legal obligation;
• To protect and defend the rights or property of Sofar;
• To prevent or investigate possible wrongdoing in connection with the Services;
• To protect the personal safety of users of the Services or the public; or
• To protect against legal liability.
Disclosure for Law Enforcement
Under certain circumstances, Sofar may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Exercising Your Rights
If you are a resident of the UK, EU or EEA, you may initiate a request to access, reject, correct, restrict, or erase your Personal Information, or where you may initiate a request for transfer of your Personal Information or initiate a request that we refrain from sending you marketing information by sending us a request at privacy@sofarsounds.com and write “GDPR Request” in the subject line.
Please note that the above individual rights are not absolute, and we may be entitled to refuse requests where certain exceptions apply.
Please note that where our processing of your Personal Information relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our Services to you and/or it may affect the provision of those Services.
Should you wish to raise concern about our use of information (without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority. The Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
We collect certain types of Personal Information about you during your relationship with us as a user or visitor to the Sites.
CATEGORIES OF PERSONAL INFORMATION WE COLLECT:
Under the California Consumer Privacy Act of 2018 (“CCPA”) as revised by the California Privacy Rights Act (“CPRA”) , if you are a resident of California, you have the right to request certain information that we collect about you, including:
- The categories of Personal Information we have collected from you;
- The categories of sources from which we collected the Personal Information;
- The business purpose we have for collecting or sharing that Personal Information;
- The categories of third parties with whom we share such Personal Information; and
- The specific pieces of Personal Information we have collected about you.
- Please note that Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
In particular, we may collect the following categories of Personal Information from consumers:
A. Identifiers.
- Examples - A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
- Collected - YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Examples - A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
- Collected - YES
C. Protected classification characteristics under California or federal law.
- Examples - Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Collected - YES
D. Commercial information.
- Examples - Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Collected - YES
E. Biometric information.
- Examples - Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
- Collected - NO
F. Internet or other similar network activity.
- Examples - Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
- Collected - YES
G. Geolocation data.
- Examples - Physical location or movements.
- Collected - YES
H. Sensory data.
- Examples - Audio, electronic, visual, thermal, olfactory, or similar information.
- Collected - YES
I. Professional or employment-related information.
- Examples - Current or past job history or performance evaluations.
- Collected - YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
- Examples - Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Collected - NO
K. Inferences drawn from other personal information.
- Examples - Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Collected - YES
L. Sensitive Information
- Examples - Account login data and possible health data (such as pregnancy diagnosis) for users of the Service; and for job applicants/employees may include social security number, driver’s license number, racial/ethnic origins, religious or philosophical beliefs, contents of emails or texts to others, genetic/biometric data, sexual orientation data
- Collected - YES
USE OF THE PERSONAL INFORMATION
We may use or disclose the Personal Information we collect for one or more of the following purposes;
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, which may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To consider your employment application.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
Your Rights and Choices
Non- Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Right to Know Information
If you are a California resident and would like to request information about the Personal Information we have collected about you in the prior 12 months, please contact at this email address privacy@sofarsounds.com with “California CCPA Rights” in the subject line and provide your email address and state the nature of your request.
We will provide the requested information free of charge once in a 12-month period, but please note that where we receive unfounded, excessive, or repetitive requests, we may elect to decline the request. Note also that we will not be able to provide information we do not ordinarily retain in the course of our regular business practices.
In order to verify your identity, we will request that you provide a signed declaration under penalty of perjury that you are a California resident and the consumer whose Personal Information is the subject of the request.
Right to Data Portability
In connection with the right to know the data that has been collected, you may also have the right to obtain your data in a portable format that, if technically feasible, will enable you to transmit the information to another entity due to its readily useable format.
Right to Delete Information
The CCPA also gives you the right to request that we delete personal information we have collected about you and for us to direct service providers to do the same, with certain exceptions as set forth in the CCPA. Note that you may also delete certain Personal Information you have provided to us through your online account.
When processing a request to delete, we may erase some information and we may de-identify some information (when we de-identify information, we implement technical safeguards and business processes that prohibit re-identification, business processes to prevent inadvertent release of de-identified information and will make no attempt to re-identify the information).
In order to verify your identity, we will request that you provide a signed declaration under penalty of perjury that you are a California resident and the consumer whose Personal Information is the subject of the request.
Right to Opt-Out of the Sale of Personal Information
The CCPA also provides a right to California residents to request to opt-out of the sale of Personal Information.
As indicated above, we may allow third-party advertising companies to collect data from visitors to our Services, including to better serve you more relevant advertisements. These online advertising practices (and certain analytics or similar activities) may potentially be considered “sales” under the CCPA under certain circumstances. You can limit this type of tracking through industry opt-outs (http://networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices/) and by limiting ad tracking on your mobile device.
You may also be able to limit the access these third-party advertising companies have to information about you when you use our Site by installing a browser or browser extension that can enable you to block the functionality of some tracking technologies
If you use different computers or browsers, you may need to indicate your opt-out choices across those computers and browsers.
Right to Correct Information
In certain circumstances, you may be entitled to have us correct information we hold about you.
Exercising Access, Data Portability, Correction and Deletion Rights
To exercise the access, data portability, correction and deletion rights described above, please submit a verifiable consumer request to us by emailing us at privacy@sofarsounds.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Questions / Changes in Privacy Notice
If you have questions or concerns with respect to this Privacy Notice for California Residents, you may contact us at privacy@sofarsounds.com. We may elect to change or amend our Privacy Notice for California Residents; in such event, we will post the policy changes in our Privacy Notice for California Residents on the Site and send you an email indicating that the terms have changed. Changes will be effective on the date posted.
PRIVACY NOTICE FOR US RESIDENTS
Residents of certain states in the United States may have additional rights in the future and Sofar will update this policy as and when such laws become applicable to us.
This Supplemental Policy describes Sofar’s practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests.
This Notice does not apply to personal information that we process as a service provider on behalf of our customers.
Your Rights to Your Personal Information
Generally, the rights available to residents of the United States under various privacy laws can be categorized as follows:
•Confirm whether we process their personal information.
•Access and delete certain personal information.
•Data portability.
•Opt-out of personal data processing for targeted advertising and sales
•Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
•Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects
Processing of Sensitive Information: We must obtain your express consent prior to collecting and processing certain categories of sensitive personal data such as precise geolocation data, data about protected characteristics and genetic or biometric data.
Non-Discrimination: Sofar will not discriminate against customers who exercise their rights under state privacy laws.
Personal Information of Minors
Our Services are not intended for children or minors under the age of 16. Accordingly, we do not knowingly store information from minors under the age of 16 except as required pursuant to applicable law.
Financial Incentives for Consumers
We do not have any programs which provide financial incentives for consumers.
Exercising Access, Data Portability, and Deletion Rights
To exercise any of these rights, you can submit your request by contacting us at . We will respond to your privacy requests within 30 days’ and notify you of the action(s) we have taken or required steps to fulfill the request.
Only you or a person registered with the appropriate state authority that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
•Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
•Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
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