Effective Date: May 25, 2018
SKIO complies with the Personal Information Protection and Electronic Documents Act and the Personal Information Protection Act (British Columbia) (the “Applicable Privacy Legislation”). The Applicable Privacy Legislation regulates the way private sector organizations operating in Canada may collect, use, keep, secure and disclose personal information. “Personal Information” means information about an identifiable individual, including an individual’s name, home address, telephone number, social insurance number and gender. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. We will only collect, use or disclose personal information in accordance with Applicable Privacy Legislation. To learn more about the Applicable Privacy Legislation please visit http://www.priv.gc.ca/leg_c/leg_c_p_e.asp or https://www.oipc.bc.ca/about/legislation.aspx.
II. Information collection and use practices
1. What personal information does SKIO collect?
1.1 Information that you give us
Personal information that you may provide us through the Site or through other communications with us includes:
Identity and contact information, such as your name, postal address, and email address;
Profile information, such as your username, password, profile picture, interests, and preferences;
Transaction information, such as details about purchases or transactions you make through the Site, but not including credit card information, which we pass directly to our payment processor and do not store;
Feedback and communications, such as information you provide in interactions with customer support, in response to surveys, in feedback, or in other communication with us; and
Social information, in the case where we have provided you with the option of logging onto or accessing the Site using other social media platforms and online services, including Facebook, Google, Twitter, SoundCloud, and Spotify (the “Third Party Platforms”). If you choose to log in using a Third Party Platform or connect your Third Party Platform account with your SKIO Account, you agree to share certain information related to your account on these Third Party Platforms with SKIO, including your name, profile picture, email address, contacts, followers or friends list, and other information contained on your Third Party Platform accounts or profiles.
1.2 Information we collect from your use of our services
We collect certain types of information from your interactions with the Site, including:
Usage and link information, such as information about how you use and interact with the Site and how you engage with our marketing materials, including how you interact with links (on the Site, in emails that we send you, and in ads); and
Log data, which includes technical information such as the type of device, browser, and operating system with which you interact with the Site; your IP address and cookies; and your usage of the Site, including links clicked and search queries. Our servers collect this information by automatic means when you view content on or otherwise interact with the Site, even if you have not created an account.
2. How do we use your information?
2.1. To provide you with our services
We typically collect personal information that you provide to us on a voluntary basis, and you may visit areas on the Site without choosing to do so. However, in order to use or access certain portions of the Site, you will be required to create an account by providing us your email address, legal name, and desired username (an “Account” and you as an account holder a “Member”).
We use your personal information:
- to provide you with the services offered by us;
- to verify your identity, qualifications, and title to copyright;
- to manage and personalize your Account and Site experience;
- to process transactions you make through the Site;
- to provide direct invoicing to you for additional membership services and fees;
- to create and administer records about your Account; and
- to communicate with you regarding your Account and the Site, such as informing you of changes to the Site or sending you additional information about SKIO.
When you execute a legal agreement on the Site, such as purchasing a license to remix a master recording, we may collect and store your legal name and postal address in order to identify you as a party to the agreement and to be able to validate your claim to any rights you may be granted through the agreement.
Third Party Platforms
For users who have a fan page on a Third Party Platform (an “Artist Page”), logging into the Site using a Third Party Platform or connecting your SKIO account to that Third Party Platform account will grant us access to information available on your Artist Page, including the number of followers you have and analytic information about your fan base. We use this information to allow members to view social and geographical demographics about the followers or fans of their Artist Page and the Artist Pages of others, enabling members to more accurately tailor their marketing and self-promotion.
We may make certain data and information from your Artist Page, including the number of fans or followers you have and analytic information about your fan base, publicly available on the Site. We may also use this information to improve Site functionality and analyze usage patterns by Site users.
We may also use information obtained from Third Party Platforms to improve your experience using the Site and improve Site functionality. This includes analyzing your usage patterns in regard to the Site and its features, as well as providing you with notifications regarding your Account and our services through email or instant messaging.
You may disconnect your Third Party Platform accounts from your SKIO Account at any time through functionality provided by the Site or through functionality provided by the relevant Third Party Platforms. If you do so, we will no longer be able to access information about you from these Third Party Platforms.
2.2. To communicate with you
You may desire to contact us via email at email@example.com to request customer support, to request our newsletter, or for other reasons. In contacting us, you might be requested to provide additional information beyond your email address, including your name, full address and phone number for identification and contact purposes.
We use your personal information:
- to respond to your requests and feedback;
- to provide you with technical support tailored to you;
- where you have consented and in accordance with your marketing preferences, to send periodic marketing and promotional emails, from which you may unsubscribe at any time; and
- for recruitment purposes, when you apply for a job with us.
2.3. For compliance, security, and integrity
We may use your personal information as we believe necessary or appropriate to
- defend the rights of our members, artists, and SKIO proprietors, directors, employees and affiliates;
- protect against and investigate fraudulent, harmful, or unauthorized activity; and
- protect and defend the security and integrity of the Site.
2.4. To operate and improve the Site
We may use your personal information, in aggregated or anonymized form where reasonably possible, for
- website and systems administration, security, and general operation of the Site; and
- general business purposes, including to improve the navigation, usability, content, and functionality of the Site.
2.5. For analytics
3. How do we share your personal information?
We will not share your personal information with any third parties without your consent, as described in this Policy.
3.1. Law and safety
We may disclose your personal information in accordance with legal requirements, where compelled by law, or to protect the safety of any person.
3.2. Service providers
Please note that SKIO uses Amazon Web Services (“Amazon”) as a service provider. To the extent that SKIO uses Amazon as a service provider, some of your personal information may be stored in servers outside of Canada, including but not limited to the United States. Any personal information stored in these servers will be subject to the legislation and privacy laws applicable in such jurisdictions.
3.3. Business transfers
3.4. Business partners and advertisers
SKIO may share traffic and transaction information with business partners and advertisers on an aggregate and anonymous basis. Such data will be anonymized and will not include your Personal Information.
3.5. Public information
Any information that you choose to include in a public area of the Site, such as on your public profile page, will be accessible to any visitor with access to the Site. Some other information, such as your artist name, username, and profile picture, is always public on the Site, unless you delete your Account, as described below. Such publicly-disclosed information may also be indexed and stored by search engines. We take no responsibility for the use, storage, or dissemination of such publicly-disclosed information.
III. Your choices
1. Accessing, updating, correcting, or deleting your information
You may also contact our Privacy Officer with such requests or questions via email to firstname.lastname@example.org or as described below. To respond to such requests we may request additional information from you to verify your identity and the legitimacy of the request. We will respond to your request for access within 30 business days.
Because we aim to operate our services in a manner that prevents accidental or malicious deletion of data, when you delete information from the Site, we may not immediately delete residual copies from our servers or backup systems.
2. Deleting your account
If you no longer desire our service, please contact our Privacy Officer or use the functionality provided in your Account settings on the Site to delete your Account and remove your information from our databases. Please note that the deletion of your data will lead to the termination of your Account and applicable services. Please also note that when you delete your Account, we may retain your Account information for a reasonable period of time afterward for the purpose of internal account management and fraud prevention activities.
3. Declining to provide certain information
4. Objecting to the processing of your personal information
If you wish to object on legitimate grounds to the processing of your personal information, or if you believe that the right to privacy granted to you by applicable data privacy laws has been infringed upon, please contact our Privacy Officer.
5. Opting out of Google Analytics
You may opt-out from the collection of information about your visit to the Site by Google Analytics by using the Google Analytics Opt-Out Feature. For more information, please see https://tools.google.com/dlpage/gaoptout.
6. Opting out of newsletters and marketing communications
If you wish to subscribe to our newsletter(s), we will use your Account name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails at any time by following the unsubscribe instructions included in these emails or by contacting us at email@example.com.
7. Transferring your personal information
You may request a machine-readable copy of your personal information by contacting our Privacy Officer.
IV. Data retention
We may retain your personal information (including information about licenses granted through SKIO, transactions made through SKIO, your usage of SKIO, and agreements made between you and SKIO) for as long as you continue to use the Site or maintain an Account with SKIO, or for as long as necessary to fulfill the purposes outlined in this Policy.
We may further retain your personal information where required under applicable laws, for legal, regulatory, accounting, or tax reasons, or for legitimate and lawful business purposes.
In some circumstances we may anonymize your personal information, in which case we may use this information indefinitely, without further notice to you, to understand and improve the Site. This anonymized information will not contain any Personal Information identifiable to You.
V. How we protect your information
SKIO implements a variety of security measures to ensure the safekeeping of your personal information, both during transmission and once we have received it. We use industry-standard Secure Socket Layer (SSL) technology to encrypt connections between your device and our servers. We maintain administrative and technical safeguards to protect your personal information against unauthorized access or disclosure and to preserve it from accidental or malicious alteration or deletion.
However, no computer system, network, or method of electronic storage is 100% secure. To this extent, we cannot represent nor warrant the safety of any information provided to us. Additionally, SKIO cannot represent nor warrant the safety of any personal information as disclosed between artists and members. Please keep in mind that when you share information with other members on the Site, they can copy, preserve, or share that information.
By agreeing to the terms of this Policy, you confirm that you are at least 18 years old or the age of majority in your jurisdiction, and have the legal ability to consent to the collection and processing of your Personal Information on Our Site, or that Your parent or legal guardian has authorized Your use of the Site and the collection and processing of Your Personal Information pursuant to this Policy.
VI. Rights of EU citizens
- A right to access your data;
- A right to rectify to rectify to your Personal Information or correct any errors in the same;
- A right to withdraw your consent for the processing of your Personal Information at any time;
- a right to lodge a compliant about our conduct with any supervisory authority overseeing the GDPR;
- A right to have a machine-readable copy of your Personal Information transferred to a third party;
- A right to restrict the processing of your data in certain circumstances;
- A right to have your Personal Information erased.
If you have any concerns about your rights under the GDPR or wish to exercise any of these rights please contact our Data Protection Officer, whose contact information is Provided in section VIII(1) of this Policy.
VII. Website areas beyond our control
The Site may contain links to other websites. If you choose to visit other websites or link your Account to other social media platforms, we are not responsible for the privacy practices or content of those other websites. The Site may also include social media features, such as buttons to share content to social media. These features may collect your personal information. You are advised to review the privacy policies at those websites to confirm that you understand and agree with their policies before sharing your information or using such functionality.
VIII. Contact information and policy updates
1. Contacting Us
If you have any questions about this Policy or our practices regarding your personal information related to the Site, or if you would like to exercise one of your rights as described above in “Choices,” please contact our Privacy Officer at firstname.lastname@example.org. You may also address postal mail to:
Attn: Privacy Officer
1144 Robson St
Vancouver, B.C., Canada
2. Updates and Changes