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:
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all Platforum9 social audio app services as a user. For example this includes:
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your use of the Platforum9 app on any device
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the personalisation of your user experience.
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the infrastructure required to provide our services
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connection of your Platforum9 account with another application
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both our free or paid user options (each a 'Service Option')
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other Platforum9 services which include a link to this Policy. These include the Platforum9 website, Customer Service and the eventual Community Site
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...
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the Platforum9 Terms of Use, which is a separate document. The Terms of Use outline the legal contract between you and Platforum9 for using the Platforum9 Service. It also describes the rules of Platforum9 and your user rights
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about your use of other potential Platforum9 services which have their own privacy policy.
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:
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Privacy Center: We will be building a user-friendly hub with summaries of key topics and helpful loom videos. It includes the 'Your Privacy Controls' video which shows you how to exercise your user rights and make choices about the way we process your data. See Section 2 'Your personal data rights and controls' for more on user rights.
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Privacy Settings: Control the processing of certain personal data, including tailored advertising.
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Notification Settings: Set which marketing communications you get from Platforum9.
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Settings (found in the Desktop and Mobile versions of Platforum9): Control certain aspects of the Platforum9 app.
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Cookies Policy: Information on how we use cookies and how to manage your cookie preferences. Cookies are files saved on your phone, tablet or computer when you visit a website.
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:
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your rights
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circumstances when they apply (such as the legal basis required)
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how to use them
You can also watch our video about Your Privacy Controls.
It’s your right to...
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How?
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Be informed
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Be informed of the personal data we process about you and how we process it.
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We inform you:
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through this Policy
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through information provided to you as you use the Platforum9 Service
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by answering your specific questions and requests when you contact us
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Access
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Request access to the personal data we process about you.
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To request a copy of your personal data from Platforum9, either:
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use the “Download your data” tool in your account Privacy Settings, or
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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.
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Rectification
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Request that we amend or update your personal data where it’s inaccurate or incomplete.
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You can edit your User Data under 'Edit profile’ in your account or by contacting us.
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Erasure
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Request that we erase certain of your personal data. For example, you can ask us to erase personal data:
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that we no longer need for the purpose it was collected for
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that we process based on the legal basis of consent, and you withdraw your consent
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when you object (see section 'Object’ below) and
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you make a justified objection, or
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you object to direct marketing
There are situations where Platforum9 is unable to delete your data, for example when:
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it’s still necessary to process the data for the purpose we collected it for
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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
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Platforum9 has a legal obligation to keep the data, or
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Platforum9 needs the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account
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There are several ways you can erase personal data from Platforum9:
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to remove audio content from your profile select the relevant content and choose to remove it.
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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’
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you can also contact us to request erasure
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Restriction
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Request that we stop processing all or some of your personal data.
You can do this if:
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your personal data is inaccurate
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our processing is unlawful
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we do not need your information for a specific purpose, or
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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.
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You can exercise your right to restriction by contacting us.
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Object
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Object to us processing your personal data. You can do this if:
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Platforum9 is processing your personal data on the legal basis of legitimate interests, or
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Platforum9 is processing your personal data for tailored advertising
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To exercise your right to object, you can:
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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
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contact us
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Data portability
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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.
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For information about how to exercise the right to portability, see 'Access’ above.
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Not be subject to automated decision making
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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.
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Platforum9 does not carry out this type of automated decision making in the Platforum9 Service.
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Withdrawal of consent
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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.
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To withdraw your consent, you can:
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adjust the relevant control on Platforum9
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contact us
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Right to lodge a complaint
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Contact the Irish Authority for Privacy Protection or your local data protection authority about any questions or concerns.
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You can find the Irish Authority’s details here. You can also go to the website of your local data protection authority.
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Tailored advertising controls
What is tailored advertising?
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This is when we use information about you to tailor ads to be more relevant to you. This is also known as interest based advertising.Whilst not currently implemented we reserve the right to do so in the future.
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An example of tailored advertising is when an advertising partner has information suggesting you like cars. This could enable us to show you ads about cars.
How to control tailored advertising:
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You can control tailored advertising in your account Privacy Settings under 'Tailored Ads'.
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You can also control tailored advertising for some podcasts using the link in the episode's show description. This applies where the content provider inserts advertising into the podcast to fund it. The hosting provider, which might not be Platforum9, manages these controls for the podcast.
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:
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The appropriate age for tailored advertising is determined by the country you are in and what rules apply to tailored advertising in that country. You will not receive Tailored Ads unless you have reached the appropriate age.
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You will not be able to 'opt-in' to Tailored Ads if you are under the appropriate age.
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You will start to receive Tailored Ads once you reach the appropriate age for your country. When this happens, you will receive a message within the Platforum9 Service to let you know. This message will contain a link to the Privacy Settings where you can change your preferences or 'opt-out' of Tailored Ads at any time.
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
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Category
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Description
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User Data
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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:
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profile name
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email address
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password
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phone number
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date of birth
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gender
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street address (see further details below)
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country
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university/college (for Platforum9 Student)
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Place of work
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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.
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Street Address Data
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We may ask for and process your address for the following reasons:
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to check eligibility for a Service Option
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to deliver notices which are required by law
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to deliver support options
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for billing and tax administration
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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.
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Collected through your use of the Platforum9 Service
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Categories
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Description
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Usage Data
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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:
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information about your Platforum9 Options
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your actions within Platforum9 (including date and time), such as:
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search queries
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forum/Session history
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content you create or share
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your library of bookmarked sessions
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browsing history
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account settings
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interactions with other Platforum9 users
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your use of third party services, devices and applications in connection with the Platforum9 Service
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inferences (i.e., our understanding) of your interests and preferences based on your usage of the Platforum9 Service
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content you provide when participating in Platforum9 promotions, such as contests or sweepstakes
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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:
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URL information
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online identifiers such as cookie data and IP addresses
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information about the devices you use such as:
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device IDs
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network connection type (e.g. wifi, 4G, LTE, Bluetooth)
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provider
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network and device performance
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browser type
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language
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information enabling digital rights management
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operating system
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Platforum9 application version
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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:
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devices on your wifi network (such as speakers) which can connect to the Platforum9 Service
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devices your operating system makes available when connecting via Bluetooth, plugin, and installation
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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:
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meet geographic requirements in our agreements with the owners of content on the Platforum9 Service
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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.
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Additional data you may choose to give us
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Categories
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Description
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Voice Data
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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.
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Payment and Purchase Data
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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:
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name
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date of birth
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payment method type (e.g. credit or debit card)
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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
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postal code
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mobile phone number
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details of your purchase and payment history
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Survey and Research Data
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When you respond to a survey or take part in user research, we collect and use the personal data you provide.
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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
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Categories of third parties
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Description
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Data categories
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Authentication partners
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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.
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User Data
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Third party applications, services and devices you connect to your Platforum9 account
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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:
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social media
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devices including:
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audio (e.g. speakers and headphones)
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smart watches
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mobile phones and tablets
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automotive (e.g. cars)
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services or platforms such as voice assistants or content platforms
We’ll ask your permission before we collect your information from certain third parties.
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User Data Usage Data
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Technical service partners
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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.
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User Data Usage Data
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Payment partners and Merchants
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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:
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send you invoices
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process your payment
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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:
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calculate any commissions owed to us
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analyse the effectiveness of our partnership with these merchant partners
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understand your interests
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Payment and Purchase Data
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Advertising and marketing partners
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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.
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Usage Data
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Acquired companies
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We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.
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User Data Usage Data
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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:
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our purpose for processing your personal data
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our legal justifications (each called a 'legal basis') under data protection law, for each purpose
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categories of personal data which we use for each purpose. See more about these categories in Section 3 'Personal data we collect about you'
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:
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Performance of a Contract: When it's necessary for Platforum9 (or a third party) to process your personal data to:
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comply with obligations under a contract with you. This includes Platforum9's obligations under the Terms of Use to provide the Platforum9 Service to you, or
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verify information before a new contract with you begins.
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Legitimate Interest: When Platforum9 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 Platforum9 users. For example, using your Usage Data to improve the Platforum9 Service for all users. Contact us if you want to understand a specific justification.
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Consent: When Platforum9 asks you to actively indicate your agreement to Platforum9's use of your personal data for a certain purpose.
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Compliance with Legal Obligations: When Platforum9 must process your personal data to comply with a law.
Purpose for processing your data
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Legal basis that permits the purpose
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Categories of personal data used for the purpose
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To provide the Platforum9 Service in accordance with our contract with you. For example, when we use your personal data to:
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set up an account for you
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personalise your account, or
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provide the Platforum9 app when you download it onto your device
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Performance of a Contract
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User Data
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Street Address Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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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.
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Legitimate Interest Our legitimate interests here include:
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keeping the Platforum9 Service running and functional
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allowing users to access and use the Platforum9 Service
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User Data
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Street Address Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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To provide certain additional voluntary features of the Platforum9 app. When this is the case, we will clearly ask for your consent.
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Consent
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User Data
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Usage Data
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Survey and Research Data
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Payment and Purchase Data
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To diagnose, troubleshoot, and fix issues with the Platforum9 app.
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Performance of a Contract
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To evaluate and develop new features, technologies, and improvements to the Platforum9 app. For example:
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we use personal data to develop and improve our personalised recommendation algorithms in time
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we analyse how our users react to a particular new feature and see whether we should make any changes
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Legitimate Interest Our legitimate interests here include developing and improving products and features for our users.
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User Data
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Usage Data
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Voice Data
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Survey and Research Data
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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.
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Consent
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User Data
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Usage Data
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Survey and Research Data
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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.
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Legitimate Interest Our legitimate interests here include using advertising to fund the Platforum9 Service, so that we can offer much of it for free.
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User Data
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Usage Data
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Survey and Research Data
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To comply with a legal obligation that we are subject to. This might be:
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an obligation under the law of the country / region you are in
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Irish law (because of our headquarters in Ireland), or
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EU law that applies to us
For example, when we use your date of birth when required for age verification purposes.
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Compliance with legal obligations
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User Data
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Street Address Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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Survey and Research Data
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To comply with a request from law enforcement, courts, or other competent authorities.
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Compliance with legal obligations, and legitimate interest Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.
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User Data
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Street Address Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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Survey and Research Data
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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.
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Legitimate Interest Our legitimate interests here include:
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maintaining our relationships with artists so that we can provide the Platforum9 Service
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maintaining our relationships with other third parties for the same reason
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User Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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To take appropriate action with reports of intellectual property infringement and inappropriate content.
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Legitimate Interest Our legitimate interests here include protecting intellectual property and original content.
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User Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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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.
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Legitimate Interest Our legitimate interests here include:
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seeking legal advice
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protecting ourselves, our users or others in legal proceedings
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User Data
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Street Address Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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Survey and Research Data
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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.
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Legitimate Interest Our legitimate interests here include researching and planning so that we can keep running our business successfully.
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User Data
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Usage Data
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Payment and Purchase Data
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To process your payment. For example, when we use your personal data to let you purchase a Platforum9 subscription.
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Performance of a Contract, and consent
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User Data
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Payment and Purchase Data
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Street Address Data
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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.
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Legitimate Interest Our legitimate interests here include protecting the Platforum9 app and our users against fraud and other illegal activity.
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User Data
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Street Address Data
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Usage Data
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Payment and Purchase Data
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To conduct research and surveys. For example, when we contact our users to ask for your feedback.
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Legitimate Interest Our legitimate interests here include to understand more about how users think about and use the Platforum9 app.
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User Data
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Usage Data
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Voice Data
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Survey and Research Data
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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):
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your profile name
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your profile photo
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your forum or session selection
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other content you post on the Platforum9 app, and any associated titles, descriptions and images
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who you follow on the Platforum9 app
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who follows you on the Platforum9 app
You or another user can share certain information on third party services, like social media or messaging platforms. This includes:
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your profile
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any content you post on Platforum9 and details about that content
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:
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where you have chosen to use a Platforum9 feature, or a third party application, service or device, and we need to share personal data to enable this, or
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if you otherwise grant us your permission to share the personal data. For example, you can do it by selecting the appropriate setting in the Platforum9 app or by giving your consent
Categories of recipients
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Categories of data you can choose to share
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Reason for sharing
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Third party applications, services and devices you connect to your Platforum9 account
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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:
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social media applications
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speaker devices
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televisions
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automotive platforms
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voice assistants
You can see and remove many third party connections under 'Apps’ in your account.
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Support community
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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.
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Other Platforum9 users
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User Data
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Usage Data
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Voice Data
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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.
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Artists and record labels
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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.
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Information we may share
See this table for details of who we share to and why.
Categories of recipients
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Categories of data
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Reason for sharing
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Service providers
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User Data
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Street Address Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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Survey and Research Data
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So they can provide their services to Platforum9. These service providers include those we hire to:
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give customer support
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operate the technical infrastructure we need to provide the Platforum9 Service
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assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)
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help market Platforum9’s (and our eventual partners’) products, services, events and promotions
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Payment partners
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User Data
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Payment and Purchase Data
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So they can process your payments, and for anti-fraud purposes.
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Advertising partners
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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.
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Marketing Partners
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To promote Platforum9 with our partners. We share certain User Data and Usage Data with these partners where necessary to:
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enable you to participate in Platforum9 promotions, including trials or other bundled offers
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to promote Platforum9 in media and advertising published on other online services
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help us and our partners to measure the effectiveness of Platforum9 promotions
Examples of partners include:
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marketing or sponsorship partners
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websites and mobile apps who sell us advertising space on their services
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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.
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Hosting Platforms
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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.
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Academic researchers
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For activities such as statistical analysis and academic study, but only in a pseudonymised format.
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Other eventual Platforum9 group companies, including companies that Platforum9 acquires in the future
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User Data
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Street Address Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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Survey and Research Data
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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:
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enabling our employees who work for different group companies to develop and improve features for the Platforum9 app
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sharing data with our measurement companies to measure the effectiveness of ad campaigns that run on the Platforum9 app
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sharing data with our podcast companies to better understand user listening trends
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Law enforcement and other authorities, or other parties to litigation
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When we believe in good faith it’s necessary for us to do so, for example:
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to comply with a legal obligation
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to respond to a valid legal process (such as a search warrant, court order, or subpoena)
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for our own or a third party’s justifiable interest, relating to:
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national security
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law enforcement
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litigation (a court case)
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criminal investigation
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protecting someone's safety
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preventing death or imminent bodily harm
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Eventual Purchasers of our business
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User Data
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Street Address Data
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Usage Data
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Voice Data
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Payment and Purchase Data
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Survey and Research Data
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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.
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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:
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maintaining the performance of the Platforum9 app
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making data-driven business decisions about new features and offerings
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complying with our legal obligations
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resolving disputes
Here are some of the categories of our retention periods, and the criteria we use to determine them:
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Data retained until you remove it
It's your right to request that we delete certain of your personal data. See the section on 'Erasure' in Section 2 'Your personal data rights and controls' for more information, and the circumstances in which we can act on your request.
You can also delete certain personal data directly from the Platforum9 Service: for example, you can edit or delete your profile picture. Where users are able to see and update the personal data themselves, we keep the information for as long as the user chooses unless one of the limited purposes described below applies.
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Data that expires after a specific period of time
We have set certain retention periods so that some data expires after a specific period of time. For example, personal data you may input as part of search queries is generally deleted after 90 days.
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Data retained until your Platforum9 account is deleted
We keep some data until your Platforum9 account is deleted. Examples of this include your Platforum9 username and profile information. We also typically keep streaming history for the life of an account, for example, to provide retrospective playlists that users enjoy and personalised recommendations that take listening habits into account (for example, Your Time Capsule or Your Summer Rewind). When your Platforum9 account is deleted, this category of data is deleted or de-identified.
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Data retained for extended time periods for limited purposes
After your account is deleted, we keep some data for a longer time period but for very limited purposes. For example, we may be subject to legal or contractual obligations that require this. These may include mandatory data retention laws, government orders to preserve data relevant to an investigation, or data kept for the purposes of litigation. We may also keep data that has been removed from the Platforum9 Service for a limited period of time. This could be:
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to help ensure user safety, or
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to protect against harmful content on our platform.
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:
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make sure the data transfer complies with applicable law
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help to give your data the same level of protection as it has in the EU
To ensure each data transfer complies with applicable EU legislation, we use the following legal mechanisms:
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Standard Contractual Clauses ('SCCs'). These clauses require the other party to protect your data and to provide you with EU-level rights and protections. For example, we use SCCs to transfer the personal data described in Section 3 'Personal data we collect about you' to our hosting provider which uses servers in the US. You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.
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Adequacy Decisions. This means that we transfer personal data to countries outside of the European Economic Area which have adequate laws to protect personal data, as determined by the European Commission. For example, we transfer the personal data described in Section 3 'Personal data we collect about you' to vendors based in the United Kingdom, Canada, Japan, Republic of Korea and Switzerland.
We also identify and use additional protections as appropriate for each data transfer. For example, we use:
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technical protections, such as encryption and pseudonymisation
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policies and processes to challenge disproportionate or unlawful government authority requests
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:
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use a strong password which you only use for your Platforum9 account
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never share your password with anyone
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limit access to your computer and browser
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log out once you have finished using the Platforum9 app on a shared device
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read more detail on protecting your account
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:
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email office@Platforum9.com
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write to us at: Platforum9 Limited Dogpatch Labs, The Chq Building, Costom House Quay, Dublin, Ireland