Privacy Policy

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WURRLYedu Privacy PolicyUpdated: 3.2.2020Welcome to WURRLYedu! WURRLY HOLDINGS, LLC AND IT’S SUBSIDIARIES (“Wurrly”, “we”, “us”, or “our”) has prepared this Privacy Policy to describe to you our practices regarding the Personal Information (as defined below) we collect from users of our website, located at www.wurrlyedu.com (the “Website”) and online services (“Services”), including our WURRLYedu mobile application (“App”). We respect your privacy, value your relationship, and want you to have fun using our website, mobile application and services.A Note to Users Outside of the United States. If you are a non U.S. user of the Website or Services, by visiting the Website and/or providing us with information, you acknowledge and agree that your Personal Information may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country.So we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy Policy, we mean information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, voice or video recording or other likeness as well as any other non-public information about you that is associated with or linked to any of the foregoing information. When we use the phrase “Anonymous Information” in this Privacy Policy, we mean information that is not associated with or linked to your Personal Information. Anonymous Information does not enable identification of or contact with individual persons.Children.Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years of age except with the verified consent of a school district, administrator, teacher or parent as is permitted by the Children’s Online Privacy Protection Act, and no part of our Website or Services is designed to attract people under 13 years of age except with the applicable consent of a school district, administrator, teacher or parent. If we later learn that a user is under 13 years of age and accessed the Website or Services without appropriate school district, administrator, teacher or parent consent, we will take steps to remove that user's Personal Information from our databases and to prevent the user from utilizing the Website and the Services.How We Collect Information.Personal InformationIn general, the Personal Information we gather enables us to provide the Services to you and helps us learn more about the use of the Website and/or Services. We collect Personal Information that you submit to us voluntarily at registration and in the course of your use of the Website and/or Services. To use certain features of the Website, we require you to create an “Account” by providing your name, email address, and a password. When you communicate with us by sending us an email, we will collect and store any information that is contained in your communications with us. Any information you choose to provide for our use should reflect how much you want other Users to know about you. You can choose not to provide us with certain information, but this may limit the features of the Website or Services you are able to use.Wurrly is a music creation platform. When you create songs as part of our Services and make them available to other users, other users will be able to hear them and see information about you. Please remember this and be thoughtful about what you make available.If you tell us where you are (e.g., by allowing your mobile device to send us your location when you search), we may collect, store and use that information. Of course, your location may also be apparent from your content.You have the option of registering with us through a third party, such as school sponsored single sign on or Clever, using your existing account and log-in credentials on such site. When you click on “Connect with us,” or a similar connection on the Services, you will be prompted to enter your third party credentials as required by the third party. By proceeding, you are granting us and our Services access to your information and you are agreeing to the third party’s Terms of Use in your use of the Services. In this case, we receive information from the third party to make it easier for you to create an Account with us. Any information that we collect from your third party account may depend on the privacy settings you have with third party, so please consult the third party’s privacy and data practices.Information Collected from You About Others.If you share content with others, you provide and we collect the email addresses of the people with whom you want to share your song. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above. You or the third party may contact us at privacy@wurrly.com to request the removal of this information from our database.Anonymous InformationWe collect the following types of Anonymous Information:Information Collected by Our Servers. To make our Website and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Website or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. This type of information is collected to make the Website more useful to you and to tailor the experience with us to meet your special interests and needs. If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided below.Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, which are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.Flash LSOs. When we post media, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here:http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.htmlCollection of Information by Advertisers. We may use third parties to serve ads on the Website. Certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our Website (but not your name, address, e-mail address or telephone number). They do this by using Cookies or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Website and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, Cookies or pixel tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.aboutads.info/choices.Mobile Device. We may collect information about the computer or device you use to access our Services, including the hardware model, operating system and version, MAC address, unique device identifier, phone number, and mobile network information. In addition, the Services may access your device's image storage applications, with your consent, to facilitate your use of certain features of the Services. For more information about how you can control our access to these applications, please see "Your Choices" below.Disclosure – Analytics.We may also use third party tracking services to help us analyze how users use the App and Services. These services collect only the unique device identifier assigned to your mobile device, rather than your name or other personally identifying information, and use it to collect information such as how often users open the App and what features they use in the App. We only use this information to improve our App and Services. We do not combine the information generated thereby with your Personal Information and we do not associate you in any way with your device identifier. Only these services know and associate you (on a non-identifiable basis) with your identifier.How We Use Information.Personal InformationWe may use your Personal Information to:
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- Administer your Account;- Provide you with Services and customer support;- Tailor the features and content of the Services to you;- Respond to your requests, resolve disputes and/or troubleshoot problems;- Verify your compliance with your obligations in our Terms of Use; and- Communicate with you about the Services.We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.Anonymous InformationWe use the Anonymous Information we collect to analyze trends, administer and improve the Services, track users’ movements in the App, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the Log Files may be collected so that when you use the App again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.How We Disclose Information.Personal InformationWe disclose certain Personal Information:Third Parties Designated by You. When you use the Services, the Personal Information you provide will be shared with the third parties that you authorize to receive such information. You may choose to share (or limit the sharing of) any content that you create with other users. Please see instructions on the Services to control this sharing.Third Party Service Providers. We may share your Personal Information with our third party service providers that help us provide Services that we offer you.Affiliates. We may share some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), if we have such Affiliates in the future, in which case we will require our Affiliates to honor this Privacy Policy.Corporate Restructuring. We may share some or all of your Personal Information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.Social Networking Sites.  Some of our Services may enable you to post content to social networks (SNSs) (e.g., Facebook or Twitter).  If you choose to do this, we will provide information to such SNSs in accordance with your elections.  You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs.  We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.Other Disclosures. Regardless of any choices you make regarding your Personal Information (as described below), we may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property or other users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our terms of use.In addition, your teacher will be able to see all your Content and Private Information. If any of your songs are made public, Users in your class may be able see them via the App along with your user profile.We require that all third parties with whom we share identifiable data treat your personal information as fully confidential and to fully comply with all applicable privacy laws and regulations, including but not limited to the EU General Data Protection Regulation, UK Data Protection Act and similar consumer legislation from time to time in place.Please be thoughtful about the songs you provide to the Services. If any of your songs contain any Personal Information or any other information, which you would not like to share, you can control who has access to these songs by accessing privacy settings on the bottom right of any song you post. By setting a song to “private”, rather than “public”, you can limit who has access to it.Anonymous InformationWe reserve the right to disclose Anonymous Information publicly without restriction.YOUR CHOICES REGARDING YOUR INFORMATION.Mobile Device. Certain features of the Services require access to your mobile device's microphone. Although you may decide whether or not to use these features, you can grant or revoke your consent at any time by changing the settings on your deviceEmail Communications. We may periodically send you free newsletters and e-mails that directly promote the use of our App or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our terms of use or Privacy Policy, which you may not opt out of. In addition, if you ask us to remove your name and address from our e-mail or postal mailing list, we will have to maintain your name in a "do not contact" file to ensure that we can honor your request.Cookies. If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided below.Changing or Deleting Your Personal Information. You may review, update, correct or delete the Personal Information in your Account by contacting us via email at privacy@wurrly.com or telephoning us at (424) 325-3171. We will respond promptly to your requests in accordance with applicable law. For your protection, we may only implement requests with respect to the personal information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We may decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Please note - if you completely delete all of your Personal Information, then your account may become deactivated, although your profile and any songs associated therewith will remain on the Services unless you have deleted them. We may also retain an archived copy of your records as required by law or for legitimate business purposes. Certain information is necessary in order for us to provide the Services; therefore, if you delete such necessary information you may not be able to use the Services.Controlling Your Information.You can review and/or change certain of your Personal Information by logging into the Website and accessing your Account. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us.Upon your request, we will close your Account. We may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems,assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law.Information Disclosed to Third PartiesThis Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the Website and Services. If you disclose information to others, or authorize us to do the same under this Privacy Policy, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.The Website and App may contain content or links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Website and go to another site. During this process, another entity may collect Personal Information or Anonymous Information from you. The Website may also contain links to other websites controlled by us but which operates under different privacy policies. Please review the privacy policy of any new site you visit.SecurityWurrly takes data security very seriously. Wurrly takes commercially reasonable technical, physical, and administrative security measures to protect the Personal Information submitted to us, both during transmission and once we receive it. Such measures vary depending on the sensitivity of the information at issue.Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security. In the event that we become aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. If you have any questions about security on our Services, you can email us at privacy@wurrly.comCalifornia Residents - Your CA Privacy RightsPursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties' direct marketing purposes and the categories of personal information the company shares. Alternatively, the law provides that a company that has a privacy policy that provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties' direct marketing purposes may instead provide information on how to exercise that choice. Wurrly qualifies for the alternative option; it has a comprehensive privacy policy that sets forth that Wurrly provides you choice prior to sharing your personal information with third parties for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time Wurrly offers that choice, Wurrly does not share your information with that identified third party for its direct marketing purposes.If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request via email by clicking here or write to us at the following mailing address: Wurrly Holdings, LLC 12301 Wilshire Blvd., Suite #303, Los Angeles CA 90025. You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.Jurisdiction and Cross-Border Data TransferThe website is controlled and operated from the United States and is not intended to subject Wurrly to the laws or jurisdiction of any state, country, or territory other than the United States.  Your personal information may be stored and processed in any country where we have offices or in which our third party service providers reside.Do Not TrackYou have the ability to enable your browser settings to “Do Not Track.” Doing this sends a signal to websites, ad networks and plug-in providers about your browsing preferences. The Website does not respond to the Do Not Track browser signal.Changes to this Privacy Policy.This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here http://www.WURRLYedu.com/privacy and we will change the “Last Updated” date above.  We will obtain valid consent if any changes we make to this Policy affect users under the age of 13 in a way that requires such consent under COPPA.  You should consult this Privacy Policy regularly for any changes.Contact US.Questions regarding this Privacy Policy or the practices of the Services should be directed to Wurrly Holdings LLC by e-mailing such questions to privacy@wurrly.com or calling (424) 325-3171.Wurrly Holdings LLC12301 Wilshire Blvd, Suite 303Los Angeles, CA 90025This Policy was last revised: March 4, 2020.