SEPULCHRAL SILENCE ’s Privacy Commitment

We ask for only the least amount of information necessary, gathering only what we
believe is essential for doing business, or for the specific transaction at hand.
The goal of this policy is to make explicit the information we gather, how we will use it,
and how we will not. This policy is unfortunately longer than we would like, but we
must unambiguously address all the relevant cases. We will try and keep the language
simple and direct as much as possible.

This Privacy Policy is divided into three parts:

Part I – Information SEPULCHRAL SILENCE collects and controls

This part deals with how SEPULCHRAL SILENCE collects and uses information about
website visitors, potential customers, users of SEPULCHRAL SILENCE’s products and
services, and others who contact SEPULCHRAL SILENCE through forms or email
addresses published on or linked to our websites.

Part II – Information that SEPULCHRAL SILENCE processes on your
behalf

This part deals with how SEPULCHRAL SILENCE handles data that you entrust to
SEPULCHRAL SILENCE when you use our products and services, or when you share
any personal or confidential information with us while requesting customer support.

Part III – General

This part deals with topics that are relevant to both Parts I and II, and other general
topics such as SEPULCHRAL SILENCE’s security commitments and how we will
inform you when we change this Privacy Policy.

Part I – Information SEPULCHRAL SILENCE
collects and controls

What information SEPULCHRAL SILENCE collects

We collect information about you only if we need the information for some legitimate
purpose. SEPULCHRAL SILENCE will have information about you only if (a) you
have provided the information yourself, (b) SEPULCHRAL SILENCE has
automatically collected the information, or (c) SEPULCHRAL SILENCE has obtained
the information from a third party. Below we describe the various scenarios that fall
under each of those three categories and the information collected in each one.
Information that you provide us

i. Account signup : When you sign up for an account to access one or more of our
services, you’ll be required to use an email address and a password for creating the
account. Once your account is created, you can also add information like your name,
contact number, email address, company name, and country to complete your profile.
ii. Payment processing : When you start to actively use your account, we ask you to
provide your name, contact information, tax ID and credit card information or other
payment account information. In all cases, your credit card information is stored and
processed by the Payment Gateway Service Provider you choose, not by us. During the
payment they inform you about their privacy and security policies, make sure you read
them carefully.

iii. Interactions with SEPULCHRAL SILENCE : We may record, analyze and use your
interactions with us, including email, telephone, and chat conversations with our sales
and customer support professionals, for improving our interactions with you and other
customers.

Information that we collect automatically

i. Information from browsers, devices and servers : When you visit our websites, we
collect information that web browsers, mobile devices and servers make available, such
as the internet protocol address, browser type, language preference, time zone, referring
URL, date and time of access, operating system, mobile device manufacturer and
mobile network information. We include these in our log files to understand more about
visitors to our websites.

ii. Information from first party cookies and tracking technologies : We use temporary
and permanent cookies to identify users of our services and to enhance user experience.
We may also use cookies, beacons, tags, scripts, and other similar technologies to
identify visitors, track website navigation, gather demographic information about
visitors and users, understand email campaign effectiveness and for targeted visitor and
user engagement by tracking your activities on our websites. We use first-party and
third-party cookies on our websites.

iii. Information from application logs and mobile analytics : We or our contractors may
collect information about your use of our services from application logs and in-house
usage analytics tools, and use it to understand how your business use and needs can
improve our products. This information includes clicks, scrolls, features accessed,
access time and frequency, errors generated, performance data, storage utilized, user
settings and configurations, and devices used to access and their locations.

Information that we collect from third parties

i. Signups using OpenID authentication service providers : You can log in to
SEPULCHRAL SILENCE Services using supported OpenID authentication service
providers such as Soundcloud, Facebook and Google. These services will authenticate
your identity and give you the option to share certain personal information with us, such
as your name and email address.

Purposes for using information

In addition to the purposes mentioned above, we may use your information for the
following purposes:

  • To communicate with you (such as through email) about services that you have
    signed up for, changes to this Privacy Policy, changes to the Terms of Service,
    or important notices;
  • To keep you posted on new products and services, upcoming events, offers,
    promotions and other information that we think will be of interest to you;
  • To ask you to participate in surveys, or to solicit feedback on our products and
    services;
  • To set up and maintain your account, and to do all other things required for
    providing our services, such as enabling collaboration, providing website and
    mail hosting, and backing up and restoring your data;
  • To understand how users use our products and services, to monitor and prevent
    problems, and to improve our products and services;
  • To provide customer support, and to analyze and improve our interactions with
    customers;
  • To detect and prevent fraudulent transactions and other illegal activities, to
    report spam, and to protect the rights and interests of SEPULCHRAL SILENCE,
    SEPULCHRAL SILENCE’s users, third parties and the public;
  • To update, expand and analyze our records, identify new customers, and provide
    products and services that may be of interest to you;
  • To analyze trends, administer our websites, and track visitor navigations on our
    websites to understand what visitors are looking for and to better help them;
  • To monitor and improve marketing campaigns and make suggestions relevant to
    the user.

Legal bases for collecting and using information

Legal processing bases applicable to SEPULCHRAL SILENCE : If you are an
individual from the European Economic Area (EEA), our legal basis for information
collection and use depends on the personal information concerned and the context in
which we collect it. Most of our information collection and processing activities are
typically based on (i) contractual necessity, (ii) one or more legitimate interests of
SEPULCHRAL SILENCE or a third party that are not overridden by your data
protection interests, or (iii) your consent. Sometimes, we may be legally required to
collect your information, or may need your personal information to protect your vital
interests or those of another person.

Withdrawal of consent : Where we rely on your consent as the legal basis, you have the
right to withdraw your consent at any time, but this will not affect any processing that
has already taken place.

Legitimate interests notice : Where we rely on legitimate interests as the legal basis and
those legitimate interests are not specified above, we will clearly explain to you what
those legitimate interests are at the time that we collect your information.

Your choice in information use

Opt out of non-essential electronic communications : You may opt out of receiving
newsletters and other non-essential messages by using the ‘unsubscribe’ function
included in all such messages. However, you will continue to receive notices and
essential transactional emails.

Disable cookies : You can disable browser cookies before visiting our websites.
However, if you do so, you may not be able to use certain features of the websites
properly.

Optional information : You can choose not to provide optional profile information such
as your photo. You can also delete or change your optional profile information.

Who we share your information with

We share your information only in the ways that are described in this Privacy Policy,
and only with parties who adopt appropriate confidentiality and security measures.

Employees and independent contractors : Employees and independent contractors have
access to the information covered in Part I on a need-to-know basis. We require all
employees and independent contractors of SEPULCHRAL SILENCE group entities to
follow this Privacy Policy for personal information that we share with them.

Third-party service providers : We may need to share your personal information and
aggregated or de-identified information with third-party service providers that we
engage, such as marketing and advertising partners, event organizers, web analytics
providers and payment processors. These service providers are authorized to use your
personal information only as necessary to provide these services to us.

Other cases : Other scenarios in which we may share the same information covered
under Parts I and II are described in Part III.

Your rights with respect to information we hold about you as a controller

If you are in the European Economic Area (EEA), you have the following rights with
respect to information that SEPULCHRAL SILENCE holds about you. SEPULCHRAL
SILENCE undertakes to provide you the same rights no matter where you choose to
live.

Right to access : You have the right to access (and obtain a copy of, if required) the
categories of personal information that we hold about you, including the information’s
source, purpose and period of processing, and the persons to whom the information is
shared

Right to rectification : You have the right to update the information we hold about you
or to rectify any inaccuracies. Based on the purpose for which we use your information,
you can instruct us to add supplemental information about you in our database.
Right to erasure : You have the right to request that we delete your personal information
in certain circumstances, such as when it is no longer necessary for the purpose for
which it was originally collected.

Right to restriction of processing : You may also have the right to request to restrict the
use of your information in certain circumstances, such as when you have objected to our
use of your data but we need to verify whether we have overriding legitimate grounds to
use it.

Right to data portability : You have the right to transfer your information to a third party
in a structured, commonly used and machine-readable format, in circumstances where
the information is processed with your consent or by automated means.
Right to object : You have the right to object to the use of your information in certain
circumstances, such as the use of your personal information for direct marketing.
Right to complain : You have the right to complain to the appropriate supervisory
authority if you have any grievance against the way we collect, use or share your
information. This right may not be available to you if there is no supervisory authority
dealing with data protection in your country.

Retention of information

We retain your personal information for as long as it is required for the purposes stated
in this Privacy Policy. Sometimes, we may retain your information for longer periods as
permitted or required by law, such as to maintain suppression lists, prevent abuse, if
required in connection with a legal claim or proceeding, to enforce our agreements, for
tax, accounting, or to comply with other legal obligations. When we no longer have a
legitimate need to process your information, we will delete or anonymize your
information from our active databases. We will also securely store the information and
isolate it from further processing on backup discs until deletion is possible.

Part II – Information that indepent contractors or
providers processes on our behalf

Information entrusted to indepent contractors or providers and purpose

Information provided in connection with services : We may entrust your information to
indepent contractors or providers we use in connection with providing our services or
for providing technical support for our services. The data may either be stored on our
servers when you use our services, or transferred or shared to us as part of a the services
provided.

Who we share service data with

Third party sub-processors : In order to provide services and technical support for our
products, SEPULCHRAL SILENCE engages other third parties.

Employees and independent contractors : We may provide access to your service data to
our employees and individuals who are independent contractors SEPULCHRAL
SILENCE involved in providing the services (collectively our “employees”) so that they
can (i) identify, analyze and resolve errors, (ii) manually verify emails reported as spam
to improve spam detection, or (iii) manually verify scanned images that you submit to
us to verify the identities of rightsholders of distributed content. We ensure that access
by our employees to your service data is restricted to specific individuals, and is logged.
Our employees will also have access to data that you knowingly share with us for
technical support or to import data into our products or services. We communicate our
privacy and security guidelines to our employees and strictly enforce privacy safeguards
within SEPULCHRAL SILENCE.

Third-party integrations you have enabled : Most of our products and services support
integrations with third-party products and services. Through these third-party
integrations, you may be allowing the third party to access your service information and
personal information about you. We encourage you to review the privacy practices of
the third-party services and products before you enable integrations with them.
Other cases : Other scenarios in which we may share information that are common to
information covered under Parts I and II are described in Part III.

Retention of information

We hold the data in your account as long as you choose to use SEPULCHRAL
SILENCE Services. Once you terminate your SEPULCHRAL SILENCE user account,
your data will eventually get deleted from active database during the next clean-up that
occurs once in 6 months. The data deleted from active database will be deleted from
backups after 3 months.

Data subject requests

If you are from the European Economic Area and you believe that we store, use or
process your information on behalf of one of our customers, please contact us if you
would like to access, rectify, erase, restrict or object to processing, or export your
personal data.

Part III – General

Children’s personal information

Our products and services are not directed to individuals under 16. SEPULCHRAL
SILENCE does not knowingly collect personal information from children who are
under 16 years of age. If we become aware that a child under 16 has provided us with
personal information, we will take steps to delete such information. If you believe that a
child under 16 years has provided personal information to us, please write to us with the
details, and we will take the necessary steps to delete the information we hold about that
child.

How secure is your information

At SEPULCHRAL SILENCE, we take data security very seriously. We have taken
steps to implement appropriate administrative, technical & physical safeguards to
prevent unauthorized access, use, modification, disclosure or destruction of the
information you entrust to us.

Disclosures in compliance with legal obligations

We may be required by law to preserve or disclose your personal information and
service data to comply with any applicable law, regulation, legal process or
governmental request, including to meet national security requirements.
Enforcement of our rights

We may disclose personal information and service data to a third party if we believe
that such disclosure is necessary for preventing fraud, investigating any suspected
illegal activity, enforcing our agreements or policies, or protecting the safety of our
users.

Business Transfers

In the event that we sell our business or get acquired or merged, we will ensure that the
acquiring entity is legally bound to honor our commitments to you. We will notify you
via email or through a prominent notice on our website of any change in ownership or
in the uses of your personal information and service data. We will also notify you about
any choices you may have regarding your personal information and service data.

Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that personal information
you provide is used in conformity with this Privacy Policy. If you have any concerns
about our adherence to this Privacy Policy or the manner in which your personal
information is used, kindly write to us. We’ll contact you, and if required, coordinate
with the appropriate regulatory authorities to effectively address your concerns.

Notification of changes

We may modify the Privacy Policy at any time, upon notifying you through a service
announcement or by sending an email to your primary email address. If we make
significant changes to the Privacy Policy that affect your rights, you will be provided
with at least 30 days’ advance notice of the changes by email to your primary email
address. If you think that the updated Privacy Policy affects your rights with respect to
your use of our products or services, you may terminate your use by sending us an email
within 30 days. Your continued use after the effective date of changes to the Privacy
Policy will be deemed to be your agreement to the modified Privacy Policy. You will
not receive email notification of minor changes to the Privacy Policy.

Our contact information:

SEPULCHRAL SILENCE
08224 Terrassa (Spain)
Email: info@sepulchralsilence.com