Effective as of 1 May 2022

1. About this policy

2. Your personal data rights and controls

3. Personal data we collect about you

4. Our purpose for using your personal data

5. Sharing your personal data

6. Data retention and deletion

7. Transfer to other countries

8. Keeping your personal data safe

9. Children

10. Changes to this Policy

11. How to contact us

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1. About this Policy

This Policy describes how we process your personal data at SoundWaves LLC, owner of the Waves application.

It applies to your use of:

• all Waves content and services as a user

• other Waves services which include a link to this Privacy Policy (e.g. Waves websites and Customer Support).

From now on, we'll collectively call these the "Waves Service".

From time to time, we may develop new or offer additional services. They'll also be subject to this Policy, unless stated otherwise when we introduce them.

This Policy is not...

• the Waves Terms & Conditions. That's a separate document, outlining the legal contract between you and SoundWaves LLC for using the Waves Service and application. It also describes the rules of the Waves application and your user rights.

 

2. Your personal data rights and controls

Privacy laws, including the General Data Protection Regulation ("GDPR"), give rights to individuals over their personal data.

See your rights and their descriptions in this table.

 

It’s your right to...

Access

Be informed of the personal data we process about you and to request access to it

Rectification

Request that we amend or update your personal data where it’s inaccurate or incomplete

Erasure

Request that we delete certain of your personal data

Restriction

Request that we temporarily or permanently stop processing all or some of your personal data

Object

Object to us processing your personal data at any time, on grounds relating to your particular situation

Object to your personal data being processed for direct marketing purposes

Data portability

Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service

Not be subject to automated decision-making

Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect

How to exercise your rights with SoundWaves LLC

Access: To request a copy of your personal data from SoundWaves LLC, visit your account settings. There you can email us by using the Contact Us button on your User Profile to request your personal data.

Rectification: You can edit your User Profile under "Edit profile" in your account.

Erasure:

• You can remove Waves content from your profile by selecting the relevant content and choosing to unsubscribe from it. For example, you can remove Waves from your “My Waves” tab.

• To request erasure of your other personal data from the Waves application (e.g. your User Data, Usage Data and other data listed in Section 3 'Personal data we collect about you' below), please reach out to us using the Contact Us button on your User Profile.

• Currently you cannot remove songs from your “My Music,” as this is based on previous interactions and, as the Waves application and Waves Service does not include music streaming, removal of these songs from the library or playlist on your integrated streaming service (e.g. Spotify or Apple Music) requires you to take such actions on that streaming service. Since the integration is currently one-way (from the Waves application to music streaming platforms), actions taken on the streaming services will not register to your user profile on the Waves application and Services.

Your other rights: You can contact SoundWaves LLC directly to exercise your rights at any time (see Section 11 'How to contact us').

You also have the right to contact your local data protection authority about any questions or concerns.

 

3. Personal data we collect about you

These tables set out the categories of personal data we collect and use.

Collected when you sign up for the Waves Service or when you update your account

Category

Description

User Data

Personal data that we need to create your Waves account and enables you to use the Waves Service.

The type of data collected depends on the type of Service Option you have, how you create your account, the country you are in, and if you use third party services to sign in. This may include your:

• profile name

• email address

• phone number

• date of birth

• gender

• street address

• country

We receive some of this data from you e.g. from the sign up form or account page.

We may also collect some of this data from your device e.g. country.

Street Address Data

We may ask for your street address for the following reasons:

• to check eligibility for a Service Option

• for tax administration

• to deliver physical goods or gifts requested by you

In some cases, we may use a third party mapping application (such as Google Maps) to help you verify your address.

 

Collected through your use of the Waves Service

Categories

Description

Usage Data

Personal data collected about you when you’re accessing and/or using the Waves Service.

There are a few types of information this includes, detailed in the following sections.

Information about how you use Waves

Examples include:

• Your actions with the Waves Service (including date and time), such as:

  • search queries

  • streaming history

  • songs you add to the affiliated playlist(s) (e.g. “The Wave Pool”)

  • songs you add to your affiliated streaming platform’s library

  • browsing history

  • account settings

  • Waves you have subscribe to

  • your use of third party services, devices and applications in connection with the Waves Service

• Inferences (i.e., our understanding) of your interests and preferences based on your usage of the Waves Service.

Your technical data

Examples include:

• URL information

• Online identifiers such as cookie data and IP addresses

• Information about the devices you use such as:

  • device IDs

  • network connection type (e.g. wifi, 4G, LTE, Bluetooth)

  • provider

  • network and device performance

  • browser type

  • language

  • information enabling digital rights management

  • operating system

  • Waves application version

• Information (such as the device name, device identifiers, brand and version) which enables us to discover and connect with third party devices and applications such as those listed below:

  • devices on your wifi network (such as speakers) which can connect to the Waves Service

  • devices made available by your operating system when connecting via Bluetooth, plugin, and installation

  • Waves partner applications to determine whether the application is installed on your device

Your general (non-precise) location

This may be understood from technical data (e.g. your IP address or language setting of your device).

We need this to meet geographic requirements in our agreements with the owners of content on the Waves Service, and to deliver content that’s relevant to you.

Your device sensor data

 

Additional data you may choose to give us

Categories

Description

Contests, Surveys, and Sweepstakes Data

When you complete any forms, respond to a survey or questionnaire, or take part in a contest or sweepstake, we collect the personal data you provide.

 

Collected from other (‘third party’) sources

Categories of third parties

Description

Authentication partners

If you register for or log into our services using another service, we’ll receive your information from them to help create your account with us.

Third party applications, services and devices you connect to your Waves account

If you connect your Waves account to a third party application, service and/or devices, we may collect certain information from them to make the integration possible.

These third party apps, services or devices may include:

• music streaming platforms

• social media

• devices including:

  • audio (e.g. speakers and headphones)

  • smart watches

  • televisions

  • mobile phones and tablets

  • automotive (e.g. cars)

  • games consoles

• services or platforms such as voice assistants

We’ll ask your permission before we collect your information from certain third parties.

Technical service partners

We work with technical service partners that give us certain data, such as mapping IP addresses to non-precise location data (e.g., city, state).

This makes it possible for Waves to provide the Waves Service, content, and features.

Advertising and marketing partners

We may get data about you from certain advertising or marketing partners.

This may include:

• cookie id

• mobile device id

• email address

• inferences (i.e., our understanding) of your interests and preferences

 

This allows us to deliver more relevant ads and marketing.

 

4. Our purpose for using your personal data

The table below sets out:

• our purpose for processing your personal data

• our legal justifications (each called a "legal basis") under data protection law, for each purpose

• categories of personal data which we use for each purpose (see more about these categories in Section 3 'Personal data we collect about you')

Here is a general explanation of each "legal basis" to help you understand the table:

• Performance of a Contract: When it's necessary for SoundWaves LLC (or a third party) to process your personal data to:

  • comply with obligations under a contract with you, e.g. SoundWaves LLC’s obligations under the Terms of Use to provide the Waves Service to you

  • or verify information before a new contract with you begins.

• Legitimate Interest: When SoundWaves LLC (or a third party) has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Waves users. For example, using your Usage Data to improve the Waves Service for all users. Contact us if you want to understand a specific justification.

• Consent: When SoundWaves LLC asks you to actively indicate your agreement to SoundWaves LLC’s use of your personal data for a certain purpose(s).

• Compliance with Legal Obligations: When SoundWaves LLC must process your personal data to comply with a law.

Purpose for processing your data

Legal basis that permits the purpose

Categories of personal data used for the purpose

To provide the personalized Waves Service.

• Performance of a Contract

• Legitimate Interest

• Consent

• User Data

• Usage Data

• Payment and Purchase Data

• Street Address Data

• Voice Data

To understand, diagnose, troubleshoot, and fix issues with the Waves Service.

• Performance of a Contract

• Legitimate Interest

• User Data

• Usage Data

To evaluate and develop new features, technologies, and improvements to the Waves Service.

• Legitimate Interest

• Consent

• User Data

• Usage Data

• Voice Data

For marketing, promotion, and advertising purposes.

• Legitimate Interest

• Consent

• User Data

• Usage Data

• Contests, Surveys and Sweepstakes Data

To comply with legal obligations and law enforcement requests.

• Compliance with legal obligations

• Legitimate interest

• User Data

• Usage Data

• Payment and Purchase Data

• Street Address Data

• Voice Data

• Contests, Surveys and Sweepstakes Data

To:

• fulfill contractual obligations with third parties, for example our agreements with owners of content on the Waves Service, and

• take appropriate action with reports of intellectual property infringement and inappropriate content.

 

• Legitimate interest

• User Data

• Usage Data

• Payment and Purchase Data

To establish, exercise, or defend legal claims.

• Legitimate interest

• User Data

• Usage Data

• Payment and Purchase Data

• Street Address Data

• Contests, Surveys and Sweepstakes Data

To conduct business planning, reporting, and forecasting.

• Legitimate Interest

• User Data

• Usage Data

• Payment and Purchase Data

To detect and prevent fraud, including fraudulent use of the Waves Service.

• Performance of a Contract

• Compliance with legal obligations

• Legitimate Interest

• User Data

• Usage Data

• Payment and Purchase Data

• Street Address Data

 

To conduct research, contests, surveys, and sweepstakes.

• Performance of a Contract

• Legitimate Interest

• Consent

 

• User Data

• Usage Data

• Contests, Surveys and Sweepstakes Data

 

5. Sharing your personal data

This section sets out the categories of recipients of the personal data collected or generated through your use of the Waves Service.

Publicly available information

The following personal data may at some point be publicly available on the Waves Service:

• Your profile name

• Your profile photo

• Your library

• Waves you are subscribed to on the Waves Service

Personal data you may choose to share

We will only share the following personal data with those outlined in the table below:

• where sharing of particular personal data is needed for the use of a Waves Service feature, or a third party application, service or device, which you have chosen to use; or

• if you otherwise grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Waves Service or by giving your consent

Categories of recipient

Reason for sharing

Third party applications, services and devices you connect to your Waves Account

To connect your Waves account, and/or allow you to use the Waves Service in connection with third party applications, services or devices.

Examples of such third party applications, services and devices include: music streaming platforms, social media applications, speaker devices, televisions, automotive platforms, or voice assistants, which interact with the Waves Service.

Artists and record labels

To receive news or promotional offers directly from artists, record labels or other partners.

You may choose to share personal data (for example, your email address) for this purpose. You’ll always have the option to change your mind and withdraw your consent at any time.

Information we may share

See this table for details of who we share to and why.

Categories of recipients

Reason for sharing

Service providers

So they can provide their services to SoundWaves LLC.

These service providers may include those we hire to:

• give customer support

• operate the technical infrastructure we need to provide the Waves Service

• assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)

• help market SoundWaves LLC’s (and our partners’) products, services, events and promotions

Marketing Partners

To promote Waves with our partners. We share some personal data with these partners where necessary to:

• enable you to participate in Waves promotions, including trials or other bundled offers

• to promote Waves in media and advertising published on other online services

• help us and our partners to measure the effectiveness of Waves promotions

Examples of partners include:

• marketing or sponsorship partners

• websites and mobile apps who sell us advertising space on their services

• device, app and mobile partners who also offer Waves promotions

Our partners may also combine the personal data we share with them with other data they collect about you (e.g. your use of their services). We and our partners may use this information to present you with offers, promotions, or other marketing activities that we believe will be relevant to you.

Other partner sharing

We may share personal data with partners to help us understand and improve the performance of our products and partnerships.

Academic researchers

For activities such as statistical analysis and academic study, but only in a pseudonymised format. Pseudonymised data is where your data is identified by a code rather than your name or other information that directly identifies you.

Other SoundWaves LLC group companies

Where we have offices, to carry out our daily business operations and so we can maintain and provide the Waves Service to you.

Law enforcement and other authorities

When we believe in good faith it’s necessary for us to do so, for example:

• to comply with a legal obligation

• to respond to a valid legal process (such as a search warrant, court order, or subpoena)

• for our own or a third party’s justifiable interest, relating to:

  • national security

  • law enforcement

  • litigation (a court case)

  • criminal investigation

  • protecting someone’s safety

  • preventing death or imminent bodily harm.

Purchasers of our business

Where we sell or negotiate to sell our business to a buyer or possible buyer.

In this situation, SoundWaves LLC will continue to ensure your personal data is kept confidential. We’ll give you notice before your personal data is transferred to the buyer or a different privacy policy starts to apply.

 

6. Data retention and deletion

Retention

We keep your personal data only as long as necessary to provide you with the Waves Service and for SoundWaves LLC’s legitimate and essential business purposes, such as:

• maintaining the performance of the Waves Service

• making data-driven business decisions about new features and offerings

• complying with our legal obligations

• resolving disputes

Deletion

If you close or request that we close your account, we'll delete or anonymise your personal data so it no longer identifies you, unless we're required to keep something or we still need to use it for a legally justifiable reason.

Here are some examples of situations where we're legally allowed or required to keep some of your personal data:

• if there's an unresolved issue relating to your account, such as an outstanding credit or unresolved claim or dispute

• for our legal, tax, audit and accounting obligations

• for our legitimate business interests such as fraud prevention or to maintain security.

 

7. Transfer to other countries

When carrying out the activities described in this Policy, SoundWaves LLC may share your personal data internationally with SoundWaves LLC group companies, subcontractors and partners. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.

 

8. Keeping your personal data safe

We're committed to protecting our users' personal data. We implement some technical and organizational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

To protect your user account, we encourage you to:

• use a strong password that is unique to your Waves account

• never share your password with anyone

• log out once you have finished using the Waves Service on a shared device

If other individuals have access to your Waves application account (for example if you've given them permission to use your account on a shared device), then they can access personal data, controls and the Waves Service available in your account.

It's your responsibility to only provide individuals with permission to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your Waves application account may impact your personalized recommendations and be included in your data download.

 

9. Children

The Waves Service has a minimum "Age Limit" in each country. The Waves Service is not directed to children whose age:

• is under the age of 13 years

• or, makes it illegal to process their personal data

• or, requires parental consent to process their personal data

We do not knowingly collect personal data from children under the applicable Age Limit. If you're under the Age Limit, please do not use the Waves Service, and do not provide any personal data to us.

If you're a parent of a child under the Age Limit and become aware that your child has provided personal data to SoundWaves LLC, please contact us.

If we learn that we've collected the personal data of a child under the applicable Age Limit, we'll take reasonable steps to delete the personal data. This may require us to delete the Waves account for that child.

When using a shared device on the main Waves Service, you should be cautious about playing or recommending any content to individuals under 18 years old which could be inappropriate for them.

 

10. Changes to this Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Waves Service or send you an email or device notification.

 

11. How to contact us

For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:

• Use the "Reach out to us" form at the bottom of this site