RIGHTSIFY

PRIVACY POLICY

Last Updated: December 11th, 2023

Rightsify is committed to protecting your privacy and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices for our website, our mobile app, and the related products and services made available by Rightsify (the “Platform”). The Platform is owned and operated by Rightsify Group, LLC. (“Rightsify”, “we”, “us” or “our”).

This Privacy Policy applies to information Rightsify collects through the Platform, as well as other information provided to us online or offline by third parties when we associate that information with users of the Platform (but not to information collected from our employees, contractors, or vendors). While Rightsify will never sell your Personal Information to any third party for their marketing purposes, certain third parties may also be able to collect information via the Platform. The data collection and use practices of these third parties may be governed by those third parties’ own policies.

This Privacy Policy describes, among other things:

• Personal and other information we collect about you;
• How we use your information;
• How we may share your information with third parties; and
• Your choices regarding the personal information we collect about you.

1. Consent

By accessing or using the Platform, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access, or use the Platform. Information gathered through the Platform may be transferred, used, and stored in the United States or in other countries where our service providers, our affiliates or we are located. If you use the Platform, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Platform or Rightsify are deemed to occur in the United States, where our servers are located.

European Union Residents

If you reside in a country in the European Economic Area or in Switzerland, then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”) and the following additional information is provided for your benefit.

The controller of the personal data collected through the Platform is:

Rightsify Group, LLC

17 East Colorado Boulevard, Suite 600

Pasadena, California, 91105

If you use the Platform, you acknowledge that your personal data is being processed pursuant to the following lawful bases: your consent, Rightsify’s legitimate interests, to fulfil requests made by you, and compliance with applicable law. You further acknowledge and consent to your information that is gathered through the Platform being transferred to, used in, and stored in the United States.

You may withdraw your consent at any time by following the instructions in the Accessing/Updating/Deleting Your Personal Information section below, but this will not affect the lawfulness of processing based on consent before its withdrawal. However, if you withdraw your consent or decline to provide personal data to us, you may be unable to use the Platform. You have the right to file a complaint relating to the processing of personal data with a supervisory authority.

Accessing/Updating/Deleting Your Personal Information

If you would like to delete, update, or access the Personal Information we have collected from you, and/or deactivate or delete your Rightsify account, you may do so by sending an email to help@rightsify.com Additionally, if your Personal Information is subject to the GDPR, you may have certain additional rights, including the right of restriction of processing of personal data, and the right to object to the processing of personal data. Please send e-mail to help@rightsify.com for more information.

2. Collection of Your Personal and Other Information

When you use the Platform we collect Personal Information. By “Personal Information” we mean information that can identify an individual, such as:

• Name;
• Email address;
• Address
• Company Name (if applicable)
• Your Internet Protocol (IP address)

Rightsify also collects any information that you choose to upload or transmit to the Platform including, without limitation, text prompts in connection with Hydra, our generative artificial intelligence music service.

The Platform may integrate with social media and other third-party platforms, including, but not limited to, Google and Meta to enable account creation and login. When you connect your account from a third-party platform to the Platform, then we may collect information from that third-party platform and share information with that third-party platform for account creation and authentication. This collected information may include, but is not limited to, your name, email address, or other content. You acknowledge and agree that Rightsify is not responsible for the data collection or use practices of any such connected third-party platform. You should read each third-party platform’s privacy policy before connecting that third-party account.

You may choose not to provide Personal Information, but this may prevent you from receiving certain features of the Rightsify Platform.

When you use our mobile application, we may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

We may also collect non-Personal Information relating to the Platform, that is, information that does not personally identify an individual. The non-Personal Information we may collect includes how you interact with the Platform, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the Platform.

Examples of the non-Personal Information we may collect are:

• Information about your computer or mobile device, such as its maker or operating system version, and HTTP header information
• The pages of our website that you viewed during a visit;
• What information, or content you view or interact with using the Platform; and
• The city, state, province and country in which you are located;

We will not use non-Personal Information to try to identify you, and if we associate any non-Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather non-Personal Information.

Information collected by the Platform may be collected by us or one of our service providers, but in either case, this Privacy Policy will govern our collection, use, and sharing of the information.

3. Use of Your Information

We may use the information we collect to:

• Assist us in providing, maintaining, and protecting the Platform;
• Set up, maintain, and protect accounts to use the Platform;
• Improve our online operations;
• Process transactions;
• Provide customer service;
• Communicate with you, such as provide you with account or transaction-related communications, or other newsletters, and/or other communications relating to the Platform;
• Send or display offers and other content that is customized to your interests or preferences and to measure its effectiveness;
• Perform research and analysis aimed at improving our products and services and developing new products or services; and
• Manage and maintain the systems that provide the Platform.
• Deliver targeted advertising to you for our business purposes;

4. Disclosure of Your Information

We may disclose your Personal Information to third parties as described below.

We may disclose Personal Information, to provide services to you, or when you authorize or instruct us to do so. We may also disclose Personal Information and non-Personal Information to companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services to you, conducting audits, and performing web analytics).

We may license third party software to include in or use with the Platform, in which case we may disclose Personal Information and/or Non-Personal Information to the licensor. These third parties’ collection and use of Personal Information and non-Personal Information are subject to their own privacy policies, which you can read here:

• Google Analytics
• Cloudfare
• AWS
• Stripe
• Meta
• Adroll

We may also disclose Personal Information to other third parties upon your affirmative consent to such disclosures.

In addition, we may disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Platform, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of Rightsify, our users, or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues.

Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or a portion of the assets of our company relating to the Platform, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example via email or by posting notice on our website.

Lastly, we may also disclose non-Personal Information, aggregated with information about our other users, to our business partners, merchants, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

5. Cookies and Automatic Information Gathering Technologies

Every time you use the Platform, we collect Personal and non-Personal Information (discussed above in Section 2) regarding that use. For example, to improve the Platform, we collect how, when, and which parts of the Platform or its features you use, which third-party platforms you connect to the Platform, and when, how, and what you post to the third-party platforms through the Platform. Also, we may use your device’s unique identifier (UDID), media access control address (MAC Address), or other unique identifiers to assist us in collecting and analyzing this data.

To assist us in collecting and storing this Personal and non-Personal Information, we may employ a variety of technologies, including “Cookies,” local browser storage, and “Web Beacons.” A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website.

Site Cookies may contain user preferences, unique identifiers, and other non-Personal Information. A “Web Beacon” is a small, usually transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a Cookie.

We, or our marketing partners and/or vendors may use Cookies to determine whether you have seen a particular advertisement before on the same or different device and to otherwise control and tailor the display of ads to you based on your preferences, to track the movements of individual users through the Platform and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to record registration and personalization information, and to otherwise administer the Platform.

In addition, Rightsify may use Cookies in our communications with you, such as within email and text messages and push notifications, and to determine which messages have been opened by recipients.

Your operating system and web browser may allow you to erase information stored in Cookies, and local browser storage. But if you do so, you may be forced to login to the Platform again and you may lose some preferences or settings. You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of the Platform may not function properly without it. We may use Cookies to keep you logged in, save your preferences for the Rightsify Platform, and to collect information about how you use the Platform.

More information about managing Cookies is available here. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.

6. Transparency and Choice

You may request access to your Personal Information by sending an email to help@rightsify.com We will provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, we may need to retain it for legal reasons or for legitimate business purposes.

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please be aware that if you request us to delete your Personal Information, you may not be able to continue to use the Platform. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

You can opt out of receiving marketing emails from us by clicking on the “unsubscribe” link in the emails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Also, even if you opt out of marketing emails, we may continue to send you certain account-related emails, such as notices about your account and confirmations of transactions you have requested.

7. Children

The Platform is geared toward a general audience and is not directed to anyone under 18 years of age. We do not knowingly collect Personal Information from anyone under the age of 18. If we become aware that we have collected Personal Information from a person under 18, we will promptly delete the information, unless we are legally obligated to retain such information.  If you believe a person who is under the age of 18 may have provided us with Personal Information, please contact us as specified in the “How to Contact Us” section of this Policy.

8. Information Security

We utilize reasonable information security measures to safeguard your Personal Information against unauthorized access, modification, or destruction. For example, we utilize Secure Socket Layer (SSL), Transport Layer Security (TLS), and similar encryption technology when sensitive data is transmitted over the Internet and use firewalls to help prevent external access into our network. However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. While we use industry standard means to protect your Personal Information, we cannot guarantee its security.

Within Rightsify, we restrict access to Personal Information to our employees, contractors, and agents who need to know that information in order to operate, develop, improve or support the Platform. If we share Personal Information with service providers, we require that they also use reasonable information security measures to safeguard your Personal Information and only use your Personal Information for the purposes for which we share it with them.

9. California Privacy Rights

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered Platform account, you have the right to request removal of unwanted data that you publicly post on the Rightsify Platform. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.  We will make sure the data is not publicly displayed on the Platform, but please be aware that the data may not be completely or comprehensively removed from our systems.

You may request, up to two (2) times per year: (1) the categories and specific pieces of data the that Rightsify has collected from you; (2) the categories of sources from which your data was collected; (3) the categories of third parties to which your data has been disclosed or sold; and (4) the purposes for which the information was disclosed or sold. If you would like to make such a request, please submit your request in writing to us using the contact information provided below.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information Rightsify collects, uses, and discloses about you, (2) request deletion of your Personal Information, (3) opt out of any sales of your Personal Information, and (4) not be discriminated against for exercising these rights. If you would like to make such a request, please submit your request in writing to us using the contact information provided below.

10. Third Party Websites

Please note that the Platform may link or integrate with third-party sites, services, or apps. We are not responsible for the privacy or security policies or practices or the content of such third parties. Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites collect, use, share and protect your information.

11. Changes to this Policy

We may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed. If we make any material changes to this Privacy Policy, we will notify you by reasonable means, which may be by e-mail or posting a notice of the changes on our website prior to the changes becoming effective. We encourage you to check this Privacy Policy from time to time.

12. Questions

To ask questions about our Privacy Policy or to lodge a complaint, contact us at:

Rightsify Group, LLC

17 East Colorado Boulevard, Suite 600

Pasadena, California, 91105

help@rightsify.com