BY ACCESSING AND USING OUR SERVICES, YOU ARE AGREEING TO BE BOUND BY THIS AGREEMENT. IF YOU DO NOT AGREE TO ANY CONTENT WITHIN THIS AGREEMENT, YOU MUST NOT ACCESS OR USE OUR SERVICES.
1. Background
1.1 The privacy of your personal information is afforded the highest level of importance by RELEASR. Pty Ltd (ACN: 669 352 318) (Company) and its related entities.
1.2 This privacy policy (Privacy Policy) sets out how the Company and its related bodies corporate (Data Controller, we, our and us) collects, stores, uses, protects, shares and discloses your personal information. This Privacy Policy applies to the provision of our services to you and your customers (Services). By visiting or using our Services you agree to the collection, storage, usage and disclosure of your personal information by us in the manner described in this Privacy Policy.
1.3 From time to time we will review our Privacy Policy. We will notify you about any changes to our Privacy Policy by posting an updated version on our platforms located at releasr.app and app.releasr.app. We do not make any representations about any third party web platforms which may be accessed through our website or through the use of the Services.
1.4 We will refer to the following collectively as the Privacy Laws:
- (a) Privacy Act 1988 (Cth) (Privacy Act); and
- (b) Australian Privacy Principles (APPs).
1.5 The processing of personal information by us will always be in line with the Privacy Laws relevant and applicable to you.
1.6 We have implemented a number of technical and organisational measures to ensure the protection of personal information processed through our Services.
1.7 This Privacy Policy sets out our information handling procedures and the rights and obligations that both you and we have in relation to your personal information. In the event of any inconsistency, the legislative requirements will override the provisions of this document.
2. AI Disclaimer
2.1 Where the Company makes available artificial intelligence or machine learning features as part of the Service, your personal information and content submitted to or processed by such features will not be used to train or improve AI models operated by or on behalf of the Company without your express consent. We will notify you of any AI features that process your data and obtain your consent where required by applicable law.
3. Who Can Use the Platform
3.1 We endeavour to make our Services available to as many people as possible. Use of the Services if you are under the age of 18 is subject to the consent of your parent or legal guardian. As such, if you are under the age of 18, you must ensure that a parent or legal guardian has reviewed and discussed the terms of this Privacy Policy with you.
3.2 If you become aware that a person under the age of 18 has provided us with information or information has been collected without parental or guardian consent, please report this using the 'Contact Us' function on our website. Any information provided that is in breach of this provision will be deleted, removed and disposed of in accordance with this clause.
3.3 The Services are not intended for use by anyone under the age of 13. Users between 13 and 18 may only use the Services with parental or guardian consent as set out above.
4. Personal Information We Collect
4.1 We will, from time to time, receive and store personal information you enter onto our platform, provide to us directly, or give to us in other forms including by third parties.
4.2 We collect, receive and store personal information including but not limited to:
- (a) your contact information, including full name, date of birth, gender, residential addresses, geographical location, telephone numbers, social media handles and email addresses;
- (b) data relating to your activity on our Services, including information about your account and how you use our platform, and information collected via tracking technologies such as cookies;
- (c) professional information you provide in connection with your use of the platform, including artist names, release metadata, collaborator details, and related music industry information; and
- (d) any credentials or access information required to render the Services.
5. Collection
5.1 We will only collect personal information where it is reasonably necessary to do so for the conduct of our business and to provide the Services to you. Any collection of personal information by us will be fair and lawful and will not be intrusive.
5.2 We will collect personal information about you in the following ways:
- (a) if you provide your information by telephone, email, or through our platform;
- (b) if you contact us via email or submit your information through our website;
- (c) if you establish an Account on our platform;
- (d) if you require us to provide Services to you; and/or
- (e) if during the course of using our Services, either you or a third party inputs information about you as part of its functionality.
5.3 In order to maintain and continue to improve our platform, Services and user experience, we may automatically collect information about how you use our platform, including the areas you visit, your IP address, device ID, physical location, browser and operating system type, and referring URLs, via cookies and other tracking technologies. We may also collect information about you through analysing your actions with electronic communications we send to you from time to time. This information is used for providing personalised content, analysing usage, troubleshooting problems, preventing fraud, and improving our Services.
5.4 In the course of operating our business, we may collect personal information from third parties such as advertisers and mailing lists.
6. Use of Personal Information
6.1 We will only use or disclose your personal information for the purposes for which we advised you we were collecting it (as set out in this Privacy Policy) or a related purpose which would reasonably be expected, or otherwise with your permission.
6.2 Generally we will use your personal information:
- (a) to operate our platform and provide the Services to you, generate content, and provide customer support (including updates and improvements);
- (b) for our administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes;
- (c) to provide, administer, market and manage our business, including providing you with our Services and enhancing your experience;
- (d) to provide you with access to protected areas of the platform and to authenticate your account;
- (e) to conduct surveys to determine use and satisfaction with our Services;
- (f) to enforce any contract with you or third parties, this Privacy Policy or any other policy related to us or our platform;
- (g) to verify your information for accuracy or completeness;
- (h) to comply with our legal obligations, a request by a governmental agency or regulatory authority, or a legally binding court order;
- (i) to combine your personal information with information we collect from third parties and use it for the purposes set out in this Privacy Policy;
- (j) to aggregate and/or de-identify your personal information so that it cannot be used to identify you;
- (k) to resolve disputes and to identify, test and resolve problems;
- (l) to notify you about updates, improvements and changes to our Services; and
- (m) to protect a person's rights, property or safety.
6.3 The platform may make third party social media features available to its Users. We cannot ensure the security of any information you choose to make public in a social media feature. We cannot ensure that parties who have access to such publicly available information will respect your privacy.
6.4 In the event that we hold sensitive information about you, we will only disclose or use that information with your consent or if another exception applies under applicable laws.
7. Disclosure of Personal Information
7.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy.
7.2 We use third-party service providers (sub-processors) to deliver the Services, including for cloud hosting, payment processing, email delivery, and analytics. A current list of our sub-processors is available upon request. By using the Services, you consent to the processing of your personal information by these sub-processors in accordance with their respective terms.
7.3 We may disclose your information to third parties for the purposes contained in this Privacy Policy, including but not limited to:
- (a) Affiliates and Acquirers — We may share some or all of your personal information with our subsidiaries or other companies under common control (Affiliates), in which case we will require our Affiliates to honour this Privacy Policy. In the event we are involved in a merger, acquisition or sale of assets, we may disclose personal information to such entities and they will assume the rights and obligations regarding your personal information as described in this Privacy Policy.
- (b) Third parties you choose to share with — We may disclose your personal information to third parties to whom you expressly ask us to send it, or to others you directly or indirectly choose for us to disclose your personal information to.
- (c) Authorised Users within your Workspace — Where you operate an Artist Account on the platform, personal information and content you upload may be accessible to Authorised Users of that Artist Account at the Permission Level assigned by the Account Owner. By inviting Authorised Users to your Workspace, you consent to this disclosure.
7.4 We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
7.5 We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of us, our platform, website, and customers or third parties.
7.6 We will not share, sell, rent or disclose your personal information in ways different from what is disclosed in this Privacy Policy.
8. If We Cannot Collect Your Personal Information
If you do not provide us with the personal information described above, some or all of the following may happen:
- (a) We may not be able to provide the Services to you, either to the same standard or at all;
- (b) We may not be able to provide you with information about Services that you may require; or
- (c) We may be unable to tailor the Services to your needs.
9. Security of Personal Information
9.1 We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable technical and organisational procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
9.2 The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
9.3 We follow reasonable technical and management practices to help protect the confidentiality, security and integrity of data stored on our systems. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.
10. Complaints About Privacy
10.1 If you have any complaints about our privacy practices, please contact us at hello@releasr.app. We take complaints very seriously and will respond promptly after receiving written notice of your complaint.
10.2 If we do not resolve your enquiry, concern or complaint to your satisfaction, or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commissioner:
- Telephone: 1300 363 992;
- Email: enquiries@oaic.gov.au;
- Website: www.oaic.gov.au.
11. Cookies Policy
11.1 Cookies may collect and store your personal information. This Privacy Policy applies to personal information collected via cookies. You consent and acknowledge that we collect your personal information through cookies.
11.2 We sometimes use cookies to show remarketing communications via third party networks including Google Display Network and Facebook.
11.3 We may also use analytics tools, including but not limited to product analytics platforms, to collect information about how you use the Services. This information is used to improve our platform and user experience and is subject to the terms of the relevant analytics provider.
11.4 You can control and/or delete cookies manually at any time via your browser settings.
12. Managing Your Personal Information
12.1 Accessing your personal information
(a) You may request details of personal information that we hold about you in accordance with the provisions of the relevant Privacy Laws. A small administrative fee may be payable for the provision of information. If you would like a copy of the information which we hold about you, or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at hello@releasr.app.
(b) We reserve the right to refuse to provide you with information that we hold about you in certain circumstances set out in the relevant Privacy Laws. If we cannot give you access, we will tell you why in writing and how you can make a complaint about our decision.
(c) If your personal information has been de-identified in a manner consistent with the Privacy Laws, we are unable to provide you with access to that personal information.
12.2 Rectifying your personal information
We may, where required, provide you with tools and account settings to access, correct, delete, or modify the personal information you provided to us. You can find out more by contacting us at hello@releasr.app. Rectifications, deletions or modifications will be processed within a reasonable time.
12.3 Deletion
(a) We keep data for as long as it is needed for our operations. Please keep in mind that third parties may still retain copies of information you have made public through our platform.
(b) Upon termination of your Account, we will retain your personal information and content for a period of 30 days, after which it may be permanently deleted. We may retain aggregated, de-identified data for longer periods for the purpose of improving the Services.
(c) If we have de-identified your data in accordance with Privacy Laws, we may be unable to delete that data.
(d) If you wish to have us delete your data, please contact us at hello@releasr.app.
13. Storage and Security of Personal Information
13.1 We are committed to protecting the security of your personal information. We (and our third-party service providers) use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. We use secure web services to collect your information and store certain kinds of data in encrypted form.
13.2 We encourage you to be vigilant about the protection of your own information when using digital services. While we will endeavour to ensure that any relationships we have with third parties include an appropriate level of protection for your privacy, we will be limited in our ability to control any electronic platform operated by a third party.
14. International Transfer and Disclosure of Personal Information
14.1 Where we transfer personal information outside of Australia, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country's data protection laws.
14.2 We may disclose personal information to our related bodies, corporate and third-party service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
14.3 We may disclose your personal information to entities located outside of Australia, including:
- (a) our related bodies corporate;
- (b) our data hosting and other IT service providers, located in various countries; and
- (c) other third parties located in various foreign countries.
14.4 We may disclose your personal information to entities within Australia who may store or process your data overseas.
15. Integrity and Retention of Data
15.1 We take all reasonable steps to ensure that the personal information we collect about you is accurate, up to date and complete. Where we collect that information from you directly, we rely on you to supply accurate information. We make it easy for you to keep your personal information accurate, complete, and up to date.
15.2 We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Upon termination of your Account, personal information and content will be retained for 30 days before deletion, consistent with the data retention provisions in our Terms and Conditions.
16. Contact Information
We welcome your comments or questions regarding this Privacy Policy. You can contact us at:
- Email: hello@releasr.app;
- Website: releasr.app.
If we do not resolve your enquiry, concern or complaint to your satisfaction, or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commissioner:
- Telephone: 1300 363 992;
- Email: enquiries@oaic.gov.au;
- Office Address: Level 3, 175 Pitt Street, Sydney NSW 2000;
- Postal Address: GPO Box 5218, Sydney NSW 2001;
- Website: www.oaic.gov.au.