Last Updated: February 8, 2023
This Privacy Policy explains how EBROSE, Inc. (“EBROSE,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes your personal information in connection with our websites (the “Sites”), our online artist partnership platform (“Fringe Market”), and the related content, services, products, and other functionality offered on or through our services (collectively, our “Service”). This Privacy Policy applies to all visitors, users and others who access the Service, including a recording artist, or the company, organization, or other entity, that represents a recording artist, who has created an account to use the Service (an “Artist”) and individuals that use the Service to partner with and provide
support to Artists (“Partners”). By accessing or using our Service, you signify that you have read, understood, and agree to
our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service. Please note that this Privacy Policy does not apply to our processing of information about employees or job applicants.
Section outline:
1. What Information Do We Collect and For What Purpose?
2. How We Use Your Information
3. Sharing of Your Information
4. Third-Party Tracking and Online Advertising
5. Control Over Your Information
6. Children’s Privacy
7. Links to Other Websites and Services
8. Changes to This Privacy Policy
9. How to Contact Us
1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?
We collect personal information in connection with your visits to and use of the Service. When we use the term “personal information,” we mean any information that can be used to identify you, directly or indirectly, as an individual person.
This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically, such as through the use of cookies and other technologies. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
A. Information You Provide to Us Directly
We collect and use personal information you provide in the following ways:
Privileged & Confidential
•Account Registration and Profile Information. We collect personal and/or business information that you provide when you register for an account to use our Service. This may include your first and last name, email, billing and payment card information, and password. We use this information to administer your account, provide you with the relevant services and information, communicate with you regarding your account and the Service, and for customer support purposes. Please note that once you create an account, your profile may be visible to other users on the Service. For information on how you may be able to adjust profile visibility settings, please see the “Control Over Your Information” section below.
• Messages and User Content. Depending on your account type, you may upload or transmit videos, images, data, or information through your communications with us, your communications with other users, or your use of the Service (collectively, “User Content”). User Content and any information contained in the User Content, including personal information you may have included, is stored and collected as part of the Service. We use User Content to operate, improve, personalize, and optimize the Service, and to manage and deliver advertising.
• Inquiries and Other Communications. If you communicate with us directly (e.g., by email) or complete an online form, we may collect your name, email address, mailing address, phone number, and any other personal information you choose to provide to us. We use this information to investigate and respond to your inquiries, communicate with you, enhance our Service, and to manage and grow our organization.
• Payment Information. To allow users to make purchases through the Service, we collect payment information, such as credit card information. Please note that we use third-party payment processors to process payments on our behalf. As such, we do
not retain certain personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice.
B. Information We Collect Automatically through Use of the Service
Privileged & Confidential
We and our third-party providers may also use various technologies to automatically collect certain personal information about your device and browsing actions when you visit or interact with our Service, read our emails, or otherwise engage with us, which may include:
• Log Data. Our web servers keep log files that record data every time a device accesses those servers. As such, when you access our Sites, we will automatically collect information such as your Internet Protocol (IP) address, operating system, browser type, browser ID, date and time of visit, and other such information.
• Analytics Data. We also collect information about the way you use our Service, such as the site from which you came and the site to which you are going when you leave our Sites, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, and other actions you take on the Service.
• Location Information. We may collect general geographic location based on log data we or our third-party providers collect.
We and our third-party providers may use (i) cookies or small data files that are stored on your computer, and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technologies (collectively, “tracking technologies”) to automatically collect this personal information.
We use or may use the data collected through these technologies to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Sites; (ii) recognize and contact you across multiple devices; (iii) provide and monitor the effectiveness of our Service; (iv) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Service; (v) diagnose or fix technology problems; and (vi) otherwise to plan for and enhance our Service.
To manage cookies, you may change your browser settings to: (i) notify you when you receive a cookie, so you can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. For information on how to do this, access the “help” menu on your internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies. However, please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly or at all. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
C. Information From Third Party Sources
Privileged & Confidential
We may receive personal information about you from third parties and combine this information with other information we have. We use this information to operate, maintain, and provide the features and functionality of the Service, to better understand the demographics of our visitors and users, and to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
• Social Media Networks. When you interact with our Services through various social media networks, such as when you “Like” us on Facebook or follow us or share our content on Google, Facebook, Instagram, Twitter, or other social networks, we may
receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include [your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties]. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
• Information from Service Providers. Our service providers that perform services solely on our behalf, such as user authentication service providers and payment processors, collect personal information and often share some or all of this information with us.
• Information from Affiliates. We may receive personal information with other companies and brands owned or controlled by EBROSE, and other companies owned by or under common ownership with EBROSE. This includes our subsidiaries (i.e., any
organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies use your personal information in the same way as we can under this Privacy Policy.
• Information from Other Sources. From time to time, we may obtain information from other sources, including from third-party information providers and business partners, or through transactions such as mergers and acquisitions. We may also collect information about you that is publicly available. We may combine this information with other information we collect from or about you. In these cases, this Privacy Policy governs the handling of the combined personal information.
2. HOW WE USE YOUR INFORMATION
We use the information we collect for purposes described in this Privacy Policy or as otherwise disclosed to you on our Service or in connection with our Service. For example, we use your information to:
• Set up your account and deliver the Service to you;
• Send you transactional information, including confirmations, technical notices, product and services information, updates, security alerts, support and administrative messages, and information about your transaction with us;
• Communicate with you such as to respond to your comments and questions, provide customer service, or for any other purposes in connection with the Service;
Privileged & Confidential
• Provide you with news about products and services offered by us;
• Operate, maintain, test, enhance, update, monitor, diagnose, fix and improve our Service;
• Conduct research and analytics to understand our visitors and customers, and tailor our product offerings;
• Provide you with advertisements based on your interests and order history;
• Prevent, investigate or provide notice of fraud or unlawful or criminal activity, unauthorized access to or use of personal information and our data system services;
• Enforce and carry out contracts and agreements with our users;
• Investigate and resolve disputes and security issues;
• Defend, protect, or enforce our rights or applicable contracts and agreements;
• Comply with legal obligations and meet governmental and institutional policy obligations; and
• For any other lawful, legitimate business purpose.
3. SHARING OF YOUR INFORMATION
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
Our Service may allow you to connect and interact with other users on the Service. Please note that Artist profile information, including name, and other personal information and/or business information, may be available publicly to other members of the Service and the public by default when Artists create a profile and interact with others on the Service.
We may share your personal information with:
• Other Users and Visitors on the Service. If you register for an account and engage with our Service, other registered users may be able to see your profile information (e.g., username, profile photo, purchase history, background information, and other preferences and information), view the information and other content you provide about your business, and communicate with you within the Service. For example, if you are an Artist, other users/visitors will be able to see your historical streaming performance, city of residence, and upcoming concerts. If you are a Partner, other users/visitors will be able to see your purchase history, profile picture, and username. Some of your data that is visible to others is dependent upon your
privacy settings. For more information, please see the “Control Over Your Information” section below.
• Affiliates. We may share personal information with other companies and brands owned or controlled by EBROSE and other companies owned by or under common ownership with EBROSE, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns.
Privileged & Confidential
• Service Providers. We may share personal information with third-party service providers that perform services on our behalf, as needed to carry out their work for us, which may include which may include payment processors, user authentication
service providers, marketing automation services, or web platform and hosting providers.
• Business Transaction or Reorganizations. We may disclose personal information with other parties in connection with a business transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings.
• Legal Obligations and Rights. We may disclose personal information to third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) to enforce our agreements or policies and Terms of Service and to protect the security or integrity of our Service; and/or (iii) to exercise or protect the rights, property, or personal safety of EBROSE, our visitors, or others. We may also disclose personal information to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations.
• Otherwise with Consent or Direction. We may disclose personal information about you with any other entity disclosed to you at the time we collect your information or with your consent or at your direction. We may also share information with others in a de-identified, aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
4. THIRD-PARTY TRACKING AND ONLINE ADVERTISING
Privileged & Confidential
We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our Service over time so that they may play or display ads on our Service, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking
technologies. We may share a common account identifier (such as an e-mail address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
To learn more about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative (“NAI”)’s online resources, at http://www.aboutads.info/choices or http://www.networkadvertising.org/choices.
Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again.
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our Sites or Service on your browser, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed e-mail address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google
uses information from sites or apps that use our services” located https://policies.google.com/technologies/partner-sites. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party
cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads
Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.netsworkadvertising.org/choices.
5. CONTROL OVER YOUR INFORMATION
A. Modifying Account Information & Visibility to Others on the Service
Privileged & Confidential
If you have an account for our Service, you may have the ability to modify certain information in your account (e.g., your contact information), as well as what information is visible to others, through the account setting page or a similar option provided on the Service. If you have any questions about modifying or updating any information in your account, please contact us at support@fringe.market.
B. How to Control Your Email Communication Preferences
From time to time, we may send you emails regarding updates to Service, notices about EBROSE, or information about our products or services that we think may be of interest to you (e.g., new Artist partnership opportunities). You can unsubscribe from promotional email communications from us by clicking on the “unsubscribe” link provided in such
communications. We make every effort to promptly process all unsubscribe requests. Please note that you may not be able to opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, and technical and security notices).
6. CHILDREN’S PRIVACY
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information. If you believe that we might have any information from a child under 13, please contact us at support@fringe.market.
7. LINKS TO OTHER WEBSITES AND SERVICES
The Service may contain links to and from third-party sites, and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read the privacy policies and terms and conditions of use of other third parties to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.
8. CHANGES TO THIS PRIVACY POLICY
We will update this Privacy Policy from time to time to reflect the changes in our business and practices, and you should review this page periodically. When we change the policy in a material manner, we will let you know and update the “last updated date” at the top of this page. Continuing to use our Service after we publish changes to this Privacy Policy means
that you are consenting to the changes.
9. HOW TO CONTACT US
If you have any questions about this Privacy Policy or the Service, please contact us at support@fringe.market.
