Platforum9 Privacy Policy

 

1. About this Policy

This Privacy Policy describes how we process your personal data at Platforum9 Limited. From now on, we'll refer to it  as the 'Policy'.

It applies to your use of:

From now on, we'll collectively refer to these as the 'Platforum9 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...

Other resources and settings

Key information about your personal data is here in this Policy. However, you might want to take a look at our other privacy resources and controls:

2. Your personal data rights and controls

Privacy laws give rights to individuals over their personal data. These laws include the General Data Protection Regulation, or 'GDPR'.

Some rights only apply when Platforum9 uses a certain 'legal basis' to process your data. We explain each legal basis, and when Platforum9 uses each one, in Section 4 'Our purpose for using your personal data'.

The table below explains:

You can also watch our video about Your Privacy Controls.

It’s your right to...

How?

Be informed

Be informed of the personal data we process about you and how we process it.

We inform you:
 

  • through this Policy
  • through information provided to you as you use the Platforum9 Service
  • by answering your specific questions and requests when you contact us

Access

Request access to the personal data we process about you.

To request a copy of your personal data from Platforum9, either:
 

  • use the “Download your data” tool in your account Privacy Settings, or
  • contact us


When you download your data you will receive the information about your data that Platforum9 has to provide under Article 15 of the GDPR. If you would like more information about how we process your personal data, you can contact us.

Rectification

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

You can edit your User Data under 'Edit profile’ in your account or by contacting us.

Erasure

Request that we erase certain of your personal data.
For example, you can ask us to erase personal data:
 

  • that we no longer need for the purpose it was collected for
  • that we process based on the legal basis of consent, and you withdraw your consent
  • when you object (see section 'Object’ below) and
    • you make a justified objection, or
    • you object to direct marketing


There are situations where Platforum9 is unable to delete your data, for example when:
 

  • it’s still necessary to process the data for the purpose we collected it for
  • Platforum9’s interest in using the data overrides your interest in having it deleted. For example, where we need the data to protect our services from fraud
  • Platforum9 has a legal obligation to keep the data, or
  • Platforum9 needs the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account

There are several ways you can erase personal data from Platforum9:
 

  • to remove audio content from your profile select the relevant content and choose to remove it.
  • to request erasure of your other personal data from Platforum9, follow the steps on our support page. This data includes your User Data, Usage Data and other data listed in Section 3 'Personal data we collect about you’
  • you can also contact us to request erasure

Restriction

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


You can do this if:
 

  • your personal data is inaccurate
  • our processing is unlawful
  • we do not need your information for a specific purpose, or
  • you object to our processing and we are assessing your objection request. See section 'Object’ below


You can request that we stop this processing temporarily or permanently.

You can exercise your right to restriction by contacting us.

Object

Object to us processing your personal data.
You can do this if:
 

  • Platforum9 is processing your personal data on the legal basis of legitimate interests, or
  • Platforum9 is processing your personal data for tailored advertising

To exercise your right to object, you can:
 

  • use controls on the Platforum9 Service to switch off or adjust some features which process your personal data. See the end of this section on how you can control tailored advertising
  • contact us

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.
You can request us to transmit your data when we are processing your personal data on the legal bases of consent or performance of contract. However Platforum9 will try to honour any request to the extent possible.

For information about how to exercise the right to portability, see 'Access’ above.

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.

Platforum9 does not carry out this type of automated decision making in the Platforum9 Service.

Withdrawal of consent

Withdraw your consent to us collecting or using your personal data.
You can do this if Platforum9 is processing your personal data on the legal basis of consent.

To withdraw your consent, you can:
 

  • adjust the relevant control on Platforum9
  • contact us

Right to lodge a complaint

Contact the Irish Authority for Privacy Protection or your local data protection authority about any questions or concerns.

You can find the Irish Authority’s details here. You can also go to the website of your local data protection authority.

 

Tailored advertising controls

What is tailored advertising?

How to control tailored advertising:

If you are 'opted out' of Tailored Ads in your Privacy Settings, you may still get advertising. This can include on our free Service Option, as well as our paid Service Option, as applicable (for example, advertising in podcasts). This type of advertising is based on your registration information and what you are currently listening to on our services. For example, if you are listening to a cooking podcast, you may hear an ad for a food processor.

Appropriate age for tailored advertising:

3. Personal data we collect about you

These tables set out the categories of personal data we collect from you.

 

Collected when you sign up for the Platforum9 Service or when you update your account

Category

Description

User Data

Personal data that we need to create your Platforum9 account and that enables you to use the Platforum9 Service.
The type of data collected and used depends on how you signed up to Platforum 9. It also depends on 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
  • password
  • phone number
  • date of birth
  • gender
  • street address (see further details below)
  • country
  • university/college (for Platforum9 Student)
  • Place of work
  • qualification/professional body


We receive some of this data from you e.g. from the sign up form or account page.
We also collect some of this data from your device e.g. country or region. For more information about how we collect and use this data, see 'Your general (non-precise) location’ in the Usage Data category.

Street Address Data

We may ask for and process your address for the following reasons:
 

  • to check eligibility for a Service Option
  • to deliver notices which are required by law
  • to deliver support options
  • for billing and tax administration
  • to deliver physical goods or gifts which you have requested


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

 

Collected through your use of the Platforum9 Service

Categories

Description

Usage Data

Personal data collected and processed about you when you’re accessing or using the Platforum9 Service.
There are a few types of information this includes, listed in the following sections.

Information about how you use Platforum9
Examples include:

  • information about your Platforum9 Options
  • your actions within Platforum9 (including date and time), such as:
    • search queries
    • forum/Session history
    • content you create or share
    • your library of bookmarked sessions
    • browsing history
    • account settings
    • interactions with other Platforum9 users
    • your use of third party services, devices and applications in connection with the Platforum9 Service
  • inferences (i.e., our understanding) of your interests and preferences based on your usage of the Platforum9 Service
  • content you provide when participating in Platforum9 promotions, such as contests or sweepstakes
  • content you post to any part of the Platforum9 app. For example: images, audio, text, titles, descriptions, communications, and other types of content

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
    • Platforum9 application version
  • information which enables us to discover and connect with third party devices and applications. Examples of this information are the device name, device identifiers, brand and version. Examples of third party devices and applications are:
    • devices on your wifi network (such as speakers) which can connect to the Platforum9 Service
    • devices your operating system makes available when connecting via Bluetooth, plugin, and installation
    • Platforum9 partner applications to determine whether the application is installed on your device


Your general (non-precise) location
Your general location includes country, region or state. We may learn this from technical data (e.g. your IP address, language setting of your device) or payment currency.
We need this to:
 

  • meet geographic requirements in our agreements with the owners of content on the Platforum9 Service
  • deliver content and advertising that’s relevant to you


Your device sensor data
Motion-generated or orientation-generated device sensor data if needed to provide features of the Platforum9 Service that require this data. This is data which your device collects about the way you move or hold your device.


 

Additional data you may choose to give us

Categories

Description

Voice Data

We collect and process voice data. Voice data means audio recordings of your voice and transcripts of those recordings which may be used by Platforum 9 for marketing purposes and summarisation of Sessions.
For more information on how different voice features work, and how you can control and turn them off, see our Voice Control Policy.

Payment and Purchase Data

If you are an individual user ,Platforum9 will need to process your payment data through the Appstore or Google play or our web application, either directly or using a third party provider.
The exact personal data collected and used will vary depending on the payment method. It will include information such as:
 

  • name
  • date of birth
  • payment method type (e.g. credit or debit card)
  • if using a debit or credit card, the card type, expiration date, and certain digits of your card number Note: For security, we never store your full card number
  • postal code
  • mobile phone number
  • details of your purchase and payment history

Survey and Research Data

When you respond to a survey or take part in user research, we collect and use the personal data you provide.

We receive some of the data mentioned above from third parties. The table below describes the categories of those third parties.

Third party sources that we receive your data from

Categories of third parties

Description

Data categories

Authentication partners

If you register for or log into the Platforum9 Service using another service, that service will send your information to us. This information helps create your account with us.

User Data

Third party applications, services and devices you connect to your Platforum9 account

If you connect your Platforum9 account to a third party application, service or device, we may collect and use information from them. This collection is to make the integration possible.
These third party apps, services or devices may include:
 

  • social media
  • devices including:
    • audio (e.g. speakers and headphones)
    • smart watches
    • mobile phones and tablets
    • automotive (e.g. cars)
  • services or platforms such as voice assistants or content platforms


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

User Data
Usage Data

Technical service partners

We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g., country or region, city, state).
This makes it possible for Platforum9 to provide the Platforum9 Service, content, and features.
We also work with security service providers who help us protect user accounts.

User Data
Usage Data

Payment partners and Merchants

If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners.
This allows us to:
 

  • send you invoices
  • process your payment
  • give you what you’ve purchased


If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to an artist’s merchandise store on a third party platform or to a third party ticketing website.
Receiving this data allows us to:
 

  • calculate any commissions owed to us
  • analyse the effectiveness of our partnership with these merchant partners
  • understand your interests

Payment and Purchase Data

Advertising and marketing partners

We receive inferences from certain advertising or marketing partners. These inferences are the partners’ understanding of your interests and preferences.
This allows us to deliver more relevant ads and marketing.

Usage Data

Acquired companies

We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.

User Data
Usage Data

If you download the Platforum9 mobile app and try Platforum9 using a logged out user experience, we will collect limited information about your usage of the Platforum9 Service, including Usage Data. We do this to understand how you are accessing and using the Service. We also do this to ensure we provide the right experience for you, for example based on your country or region. If you decide to create a Platforum9 account to experience our service in full, then we will combine this data with your Platforum9 account data.

4. Our purpose for using your personal data

The table below sets out:

You can also watch our video about Personal Data at Platforum9.

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

Purpose for processing your data

Legal basis that permits the purpose

Categories of personal data used for the purpose

To provide the Platforum9 Service in accordance with our contract with you.
For example, when we use your personal data to:
 

  • set up an account for you
  • personalise your account, or
  • provide the Platforum9 app when you download it onto your device

Performance of a Contract

 

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data

To provide further parts of the Platforum9 Service.
For example, when we use your personal data to enable you to share a link to Platforum9 content with someone else.

Legitimate Interest
Our legitimate interests here include:
 

  • keeping the Platforum9 Service running and functional
  • allowing users to access and use the Platforum9 Service
  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data

To provide certain additional voluntary features of the Platforum9 app. When this is the case, we will clearly ask for your consent.

Consent

  • User Data
  • Usage Data
  • Survey and Research Data
  • Payment and Purchase Data

To diagnose, troubleshoot, and fix issues with the Platforum9 app.

Performance of a Contract

  • User Data
  • Usage Data

To evaluate and develop new features, technologies, and improvements to the Platforum9 app.
For example:
 

  • we use personal data to develop and improve our personalised recommendation algorithms in time
  • we analyse how our users react to a particular new feature and see whether we should make any changes

Legitimate Interest
Our legitimate interests here include developing and improving products and features for our users.

  • User Data
  • Usage Data
  • Voice Data
  • Survey and Research Data

For marketing or advertising where the law requires us to collect your consent.
For example, when we use cookies to understand your interests or the law requires consent for email marketing.
 

Consent

  • User Data
  • Usage Data
  • Survey and Research Data

For other marketing, promotion and advertising purposes where the law does not require consent.
For example, when we use your personal data to tailor advertising to your interests.
 

Legitimate Interest
Our legitimate interests here include using advertising to fund the Platforum9 Service, so that we can offer much of it for free.

  • User Data
  • Usage Data
  • Survey and Research Data

To comply with a legal obligation that we are subject to.
This might be:
 

  • an obligation under the law of the country / region you are in
  • Irish law (because of our headquarters in Ireland), or
  • EU law that applies to us


For example, when we use your date of birth when required for age verification purposes.

Compliance with legal obligations

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

To comply with a request from law enforcement, courts, or other competent authorities.
 

Compliance with legal obligations, and legitimate interest Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

To fulfil contractual obligations with third parties.
For example, when we provide pseudonymised data about our users’ listening because we have an agreement with a Platforum9 rightsholder to do so.
Pseudonymised data means that your data is identified by a code rather than your name or other directly identifying information.
 

Legitimate Interest
Our legitimate interests here include:
 

  • maintaining our relationships with artists so that we can provide the Platforum9 Service
  • maintaining our relationships with other third parties for the same reason
  • User Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data

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

Legitimate Interest
Our legitimate interests here include protecting intellectual property and original content.

  • User Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data

To establish, exercise, or defend legal claims.
For example, if we are involved in litigation and we need to provide information to our lawyers in relation to that legal case.

Legitimate Interest
Our legitimate interests here include:
 

  • seeking legal advice
  • protecting ourselves, our users or others in legal proceedings
  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

To conduct business planning, reporting, and forecasting.
For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in.

Legitimate Interest
Our legitimate interests here include researching and planning so that we can keep running our business successfully.

  • User Data
  • Usage Data
  • Payment and Purchase Data

To process your payment.
For example, when we use your personal data to let you purchase a Platforum9 subscription.

Performance of a Contract, and consent
 

  • User Data
  • Payment and Purchase Data
  • Street Address Data

To keep the Platforum9 app secure and to detect and prevent fraud.
For example, when we analyse Usage Data to check for fraudulent use of the Platforum9 app.

Legitimate Interest
Our legitimate interests here include protecting the Platforum9 app and our users against fraud and other illegal activity.

  • User Data
  • Street Address Data
  • Usage Data
  • Payment and Purchase Data

To conduct research and surveys.
For example, when we contact our users to ask for your feedback.

Legitimate Interest
Our legitimate interests here include to understand more about how users think about and use the Platforum9 app.

  • User Data
  • Usage Data
  • Voice Data
  • Survey and Research Data

 

5. Sharing your personal data

This section sets out who receives personal data which is collected or generated through your use of the Platforum9 app.

Publicly available information

The following personal data will always be publicly available on the Platforum9 app (except to any user you have blocked):

You or another user can share certain information on third party services, like social media or messaging platforms. This includes:

When this sharing occurs, the third party service may store a copy of it to support their features.

 

Personal data you may choose to share

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

Categories of recipients

Categories of data you can choose to share

Reason for sharing

Third party applications, services and devices you connect to your Platforum9 account

  • User Data
  • Usage Data

 

To connect your Platforum9 account, or so that you can use the Platforum9 app in connection with third party applications, services or devices.
Examples of such third party applications, services and devices include:
 

  • social media applications
  • speaker devices
  • televisions
  • automotive platforms
  • voice assistants


You can see and remove many third party connections under 'Apps’ in your account.

Support community

  • User Data

To enable you to use the Platforum9 Support Community service.
When you register for an account on the Platforum9 Support Community, we’ll ask you to create a profile name. This will be publicly displayed to anyone who uses the Platforum9 Support Community. We’ll also display any questions or comments you post.

Other Platforum9 users

  • User Data
  • Usage Data
  • Voice Data

To share information about your use of the Platforum9 app with other Platforum9 users. These could include your potential followers on Platforum9.
For example, under 'Social’ settings you can choose to share your recently played artists and your playlists on your profile. You can also choose to create or join a shared playlist with other users. Shared playlists give you social recommendations based on your listening activity.

Artists and record labels

  • User Data

To receive news or promotional offers from artists, record labels or other partners.
You may choose to share your User Data 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

Categories of data

Reason for sharing

Service providers

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

So they can provide their services to Platforum9.
These service providers include those we hire to:
 

  • give customer support
  • operate the technical infrastructure we need to provide the Platforum9 Service
  • assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)
  • help market Platforum9’s (and our eventual partners’) products, services, events and promotions

Payment partners

  • User Data
  • Payment and Purchase Data

So they can process your payments, and for anti-fraud purposes.

Advertising partners

  • User Data
  • Usage Data

So they can help us deliver more relevant advertising to you on the Platforum9 app, and help measure the effectiveness of ads.
For example, our ad partners will help us facilitate tailored advertising.

Marketing Partners

  • User Data
  • Usage Data

To promote Platforum9 with our partners. We share certain User Data and Usage Data with these partners where necessary to:
 

  • enable you to participate in Platforum9 promotions, including trials or other bundled offers
  • to promote Platforum9 in media and advertising published on other online services
  • help us and our partners to measure the effectiveness of Platforum9 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 Platforum9 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 that we think you’ll find relevant.

Hosting Platforms

  • Usage Data

Hosting platforms host podcasts so that they can deliver them to you. We share certain data, such as your IP address, with the hosting platforms when you play a podcast. We also allow you to stream podcasts available from other hosting platforms not owned by Platforum9.

Podcast providers should explain in the show or episode description which platform is hosting the podcast. See the hosting platform’s own privacy policy for how they use data shared with them.

Academic researchers

  • User Data
  • Usage Data

For activities such as statistical analysis and academic study, but only in a pseudonymised format.

Other eventual Platforum9 group companies, including companies that Platforum9 acquires in the future

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

 

To carry out our daily business operations and so we can maintain, improve and provide the Platforum9 app and acquired companies’ services to you.
For example:
 

  • enabling our employees who work for different group companies to develop and improve features for the Platforum9 app
  • sharing data with our measurement companies to measure the effectiveness of ad campaigns that run on the Platforum9 app
  • sharing data with our podcast companies to better understand user listening trends

Law enforcement and other authorities, or other parties to litigation

  • User Data
  • Usage Data

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

Eventual Purchasers of our business

  • User Data
  • Street Address Data
  • Usage Data
  • Voice Data
  • Payment and Purchase Data
  • Survey and Research Data

If we were to sell or negotiate to sell our business to a buyer or possible buyer.
In this case, we may transfer your personal data to a successor or affiliate as part of that transaction.

 

 

 

6. Data retention

We keep your personal data only as long as necessary to provide you with the Platforum9 app and for Platforum9's legitimate and essential business purposes, such as:

Here are some of the categories of our retention periods, and the criteria we use to determine them:

This helps us investigate potential breaches of our User Guidelines and Platform Rules. On the other hand, we will remove unlawful content if the law requires us to do so.

7. Transfer to other countries

Because of the global nature of our business, Platforum9 shares personal data internationally with Platforum9 subcontractors and partners when carrying out the activities described in this Policy. 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.

Whenever we transfer personal data internationally, we will use tools to:

To ensure each data transfer complies with applicable EU legislation, we use the following legal mechanisms:

We also identify and use additional protections as appropriate for each data transfer. For example, we use:

8. Keeping your personal data safe

We're committed to protecting our users' personal data. We put in place appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

We have put various safeguards in place to guard against unauthorised access and unnecessary retention of personal data in our systems. These include pseudonymisation, encryption, access, and retention policies.

To protect your user account, we encourage you to:

You can log out of Platforum9 in multiple places at once by using the 'Sign out everywhere' function on your account page.

If other individuals have access to your Platforum9 account, then they can access personal data, controls and the Platforum9 Service available in your account. For example, you might have allowed someone to use your account on a shared device.

It's your responsibility to only allow individuals to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your Platforum9 account may impact your personalised recommendations and be included in your data download.

9. 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 Platforum9 app 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: