Data Policy

This policy describes the information we process to support Livedub and other products and features offered by Livedub Midia Digital LTDA.

I. What kinds of information do we collect?

To provide Livedub Product, we must process information about you. The types of information we collect depend on how you use our Product. 

Things you and others do and provide.

• Information and content you provide. We collect the content, communications and other information you provide when you use our Product, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. It can also include what you see through features we provide, such as our mic, so we can do things like suggest masks and filters that you might like, or give you tips on using audio formats. Our systems automatically process content and communications you and others provide to analyze context and what's in them for the purposes described below. Learn more about how you can control who can see the things you share.
• Data with special protections: You can choose to provide information in your Livedub profile fields or Life Events about your religious views, political views, who you are "interested in," or your health. This and other information (such as racial or ethnic origin, philosophical beliefs or trade union membership) could be subject to special protections under the laws of your country.
  
• Networks and connections. We collect information about the people, accounts, songs, hashtags and groups you are connected to and how you interact with them across our Product, such as people you communicate with the most or groups you are part of. We also collect contact information if you choose to upload, sync or import it from a device which we use for things like helping you and others find people and songs you may know and for the other purposes listed below.
  

• Your usage. We collect information about how you use our Product, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Product, and what jam, tracks and other content you view on our Product. We also collect information about how you use features like mic or audio.
  
  
• Things others do and information they provide about you. We also receive and analyze content, communications and information that other people provide when they use our Product. This can include information about you, such as when others share a jam of you, or upload, sync or import song information.
  
  

Device Information

As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Product, and we combine this information across different devices you use. For example, we use information collected about your use of our Product on your phone to better personalize the content or features you see when you use our Product on another device, such as your laptop or tablet, or to measure whether you took an action in response to an feature we showed you on your phone on a different device.

Information we obtain from these devices includes:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
  
  
• Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
  
  
• Identifiers: unique identifiers, device IDs, and other identifiers, such as from apps or accounts you use.
  
  
• Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
  
  
• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your mic, camera or photos.
  
  
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.
  

II. How do we use this information?

Provide, personalize and improve our Product.

We use the information we have to deliver our Product, including to personalize features and content and make suggestions for you (such as jams you may be interested in or topics you may want to follow) on and off our Product. To create personalized Product that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others; how you use and interact with our Product; and the people, or things you're connected to and interested in on and off our Product. Learn more about how we use information about you to personalize your Livedub experience, including features and content;

• Information across Livedub Product and devices: We connect information about your activities on different devices to provide a more tailored and consistent experience to your use, wherever you use them. For example, we can suggest that you join a jam that includes people you follow or communicate with. We can also make your experience more seamless.
  
• Product research and development: We use the information we have to develop, test and improve our Product, including by conducting surveys and research, and testing and troubleshooting new Product and features.
  
• Ads and other sponsored content: We use the information we have about you-including information about your interests, actions and connections-to select and personalize ads, offers and other sponsored content that we show you.

Provide measurement, analytics, and other business services.

We use the information we have (including your activity off our Product) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services.

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Product, and promote safety and security on and off of Livedub Product. For example, we use data we have to investigate suspicious activity or violations of our terms or policies.

Communicate with you.

We use the information we have to send you marketing communications, communicate with you about our Product, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Research and innovate for social good.

We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

III. How is this information shared?

Your information is shared with others in the following ways:

Sharing on Livedub Product

People and accounts you share and communicate with

When you share and communicate using our Product, you choose the audience for what you share. For example, when you record on Livedub, you select the audience for the post, such as a customized list of people. Similarly. Your network can also see actions you have taken on our Product, including engagement with other jams, ads and sponsored content. We also let other accounts see who has viewed their Livedub jams.

Public information can be seen by anyone, on or off our Product. This includes your Livedub username; any information you share with a public audience; You, other people using Livedub, and we can provide access to or send public information to anyone on or off our Product, in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Product.

Content others share or reshare about you

You should consider who you choose to share with, because people who can see your activity on our Product can choose to share it with others on and off our Product, including people and businesses outside the audience you shared with. For example, when you share a jam to specific friends or accounts, they can reshare that content to others across or off our Product. 

Information about your active status or presence on our Product.

People in your networks can see signals telling them whether you are active on our Product, including whether you are currently active on our Product.

Sharing with Third-Party Partners

We work with third-party partners who help us provide and improve our Product, which makes it possible to operate our companies and provide free services to people around the world. We don't sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:

Partners who use our analytics services.

We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their jams and videos and other content on and off the Livedub Product.

Advertisers.

We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we provide general demographic and interest information to advertisers (for example, that an ad was seen by a woman between the ages of 25 and 34 who lives in Madrid and likes playing drummer) to help them better understand their audience. We also confirm which Livedub ads led you to make a purchase or take an action with an advertiser.

Measurement partners.

We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.

Partners offering goods and services in our Product.

When you subscribe to receive premium content, or buy something from a seller in our Product, the content creator or seller can receive your public information and other information you share with them, as well as the information needed to complete the transaction, including shipping and contact details.

Vendors and service providers.

We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Product are used, providing customer service, facilitating payments or conducting surveys.

Researchers and academics.

We also provide information and content to research partners and academics to conduct research that advances scholarship and innovation that support our business or mission, and enhances discovery and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

Law enforcement or legal requests.

We share information with law enforcement or in response to legal requests in the circumstances outlined below.

IV. How can I manage or delete information about me?

We provide you with the ability to access, rectify, port and erase your data.

We store data until it is no longer necessary to provide our services and Livedub Product, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. 

When you delete your account, we delete things you have posted, such as your photos and status updates, and you won't be able to recover that information later. Information that others have shared about you isn't part of your account and won't be deleted. If you don't want to delete your account but want to temporarily stop using the Product, you can deactivate your account instead. 

V. How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others:

• In response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
  
• When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of the Product, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Product), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Product.
  

Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

VI. How do we operate and transfer data as part of our global services?

We share information globally and externally with our partners and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide the services set forth in the Terms of Use and to globally operate and provide our Product to you. We utilize standard contract clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States and other countries.

VII. How will we notify you of changes to this policy?

We'll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Product.

VIII. How to contact Livedub with questions

You can learn more about how privacy works. If you have questions about this policy, you can contact us as described below. We may resolve disputes you have with us in connection with our privacy policies and practices through TrustArc. You can contact TrustArc through its website.

You can contact us by mail at:

Livedub Midia Digital LTDA.

71 Faustino Augusto Cesar street, 

Vila Marari, Sao Paulo, SP

Brazil 

04402120

Date of Last Revision: April 20, 2020