Terms of Use

FineRadioCO Terms of Use

1. Introduction

 

2. The FineRadioCO Service Provided by Us

 

3. Your Use of the FineRadioCO Service

 

4. Content and Intellectual Property Rights

 

5. Customer Support, Information, Questions and Complaints

 

6. Problems and Disputes

 

7. About these Terms

 

1. Introduction

Please read these Terms of Use (these “Terms”) carefully as they govern your use of (which includes access to) FineRadioCO’s personalized services for streaming audio and other content, including all of our websites and software applications that incorporate or link to these Terms (collectively, the “FineRadioCO Service”) and any music, videos, podcasts, or other material that is made available through the FineRadioCO Service (the “Content”).

 

Use of the FineRadioCO Service may be subject to additional terms and conditions presented by FineRadioCO, which are hereby incorporated by this reference into these Terms.

 

By signing up for, or otherwise using, the FineRadioCO Service, you agree to these Terms. If you do not agree to these Terms, then you must not use the FineRadioCO Service or access any Content.

 

Service Provider

These Terms are between you and FineRadioCO ℅ Plot 404, Marcus Garvey Street, 5th Avenue, Gwarimpa, Abuja, FCT 900108

 

Age and eligibility requirements

In order to use the FineRadioCO Service and access any Content, you need to (1) be 16 years of age (or the equivalent minimum age in your home country) or older, (2) have parent or guardian consent if you are a minor in your home country, (3) have the power to enter a binding contract with us and not be barred from doing so under any applicable laws, and (4) reside in a country where the Service is available. You also promise that any registration information that you submit to FineRadioCO is true, accurate, and complete, and you agree to keep it that way at all times If you are a minor in your home country, your parent or guardian will need to enter into these Terms on your behalf. You can find additional information regarding minimum age requirements in the registration process. If you do not meet the minimum age requirements then FineRadioCO will be unable to register you as a user.

 

2. The FineRadioCO Service Provided by Us

FineRadioCO Service Options

We provide numerous FineRadioCO Service options. Certain FineRadioCO Service options are provided free-of-charge, while other options require payment before they can be accessed (the “Paid Subscriptions”). We may also offer special promotional plans, memberships, or services, including offerings of third-party products and services. We are not responsible for the products and services provided by such third parties.

 

The Unlimited Service may not be available to all users. We will explain which services are available to you when you are signing up for the services. If you cancel your subscription to the Unlimited Service, or if your subscription to the Unlimited Service is interrupted (for example, if you change your payment details), you may not be able to re-subscribe for the Unlimited Service. Note that the Unlimited Service may be discontinued in the future, in which case you will no longer be charged for the Service.

 

Trials

From time to time, we or others on our behalf may offer trials of Paid Subscriptions for a specified period without payment or at a reduced rate (a “Trial”). By using a FineRadioCO Service via a Trial, you agree to the FineRadioCO Premium Promotional Offer Terms.

 

Third-Party Applications, Devices and Open Source Software

The FineRadioCO Service may be integrated with, or may otherwise interact with, third-party applications, websites, and services (“Third-Party Applications”) and third-party personal computers, mobile handsets, tablets, wearable devices, speakers, and other devices (“Devices”). Your use of such Third-Party Applications and Devices may be subject to additional terms, conditions and policies provided to you by the applicable third party. FineRadioCO does not guarantee that Third-Party Applications and Devices will be compatible with the FineRadioCO Service.

 

Service Limitations and Modifications

We use reasonable care and skill to keep the FineRadioCO Service operational and to provide you with a personalized, immersive audio experience. However, our service offerings and their availability may change from time to time and subject to applicable laws, without liability to you; for example:

 

The FineRadioCO Service may experience temporary interruptions due to technical difficulties, maintenance or testing, or updates, including those required to reflect changes in relevant laws and regulatory requirements.

We aim to evolve and improve our Services constantly, and we may modify, suspend, or stop (permanently or temporarily) providing all or part of the FineRadioCO Service (including particular functions, features, subscription plans and promotional offerings).

FineRadioCO has no obligation to provide any specific content through the FineRadioCO Service, and FineRadioCO or the applicable owners may remove particular songs, videos, podcasts, and other Content without notice.

If you have prepaid fees directly to FineRadioCO for a Paid Subscription that FineRadioCO discontinues prior to the end of your Pre-Paid Period (as that term is defined in the Payments and cancellations section below), FineRadioCO will refund you the prepaid fees for the Pre-Paid Period for any unused part of your then current Paid Subscription after such discontinuation. Your account and billing information must be up to date in order for us to refund you.

 

FineRadioCO has no liability to you, nor any obligation to provide a refund to you, in connection with internet or other service outages or failures that are caused by the actions of government authorities, other third parties or events beyond our control.

 

3. Your Use of the FineRadioCO Service

Creating a FineRadioCO account

You may need to create a FineRadioCO account to use all or part of the FineRadioCO Service. Your username and password are for your personal use only and should be kept confidential. You understand that you are responsible for all use (including any unauthorized use) of your username and password. Notify our Customer Service team immediately if your username or password is lost or stolen, or if you believe there has been unauthorized access to your account.

 

FineRadioCO may reclaim, or require you to change, your username for any reason.

 

Your rights to use the FineRadioCO Service

Access to the FineRadioCO Service

 

Subject to your compliance with these Terms (including any other applicable terms and conditions), we grant to you limited, non-exclusive, revocable permission to make personal, non-commercial use of the FineRadioCO Service and the Content (collectively, “Access”). This Access shall remain in effect unless and until terminated by you or FineRadioCO. You agree that you will not redistribute or transfer the FineRadioCO Service or the Content.

 

The FineRadioCO software applications and the Content are licensed, not sold or transferred to you, and FineRadioCO and its licensors retain ownership of all copies of the FineRadioCO software applications and Content even after installation on your Devices.

 

FineRadioCO’s Proprietary Rights

 

The FineRadioCO Service and the Content are the property of FineRadioCO or FineRadioCO’s licensors. All FineRadioCO trademarks, service marks, trade names, logos, domain names, and any other features of the FineRadioCO brand (“FineRadioCO Brand Features”) are the sole property of FineRadioCO or its licensors. These Terms do not grant you any rights to use any FineRadioCO Brand Features whether for commercial or non-commercial use.

 

You agree to abide by the FineRadioCO User Guidelines and not to use the FineRadioCO Service, the Content, or any part thereof in any manner not expressly permitted by these Terms.

 

Payments and cancellation

Billing

 

You may purchase a Paid Subscription directly from FineRadioCO or through a third party either by:

 

paying a subscription fee in advance on a monthly basis or some other recurring interval disclosed to you prior to your purchase; or

pre-payment giving you access to the FineRadioCO Service for a specific time period (“Pre-Paid Period”).

Tax rates are calculated based on the information you provide and the applicable rate at the time of your monthly charge.

 

If you purchase access to a Paid Subscription through a third party, separate terms and conditions with such third party may apply to your use of the FineRadioCO Service in addition to these Terms. If you purchase a Paid Subscription using a code, gift card, pre-paid offer, or other offer provided or sold by or on behalf of FineRadioCO for access to a Paid Subscription (“Codes”), you hereby agree to the FineRadioCO Card Terms.

 

Price and tax changes

 

FineRadioCO may from time to time change the price for the Paid Subscriptions, including recurring subscription fees, the Pre-Paid Period (for periods not yet paid), or Codes (defined above), and will communicate any price changes to you in advance on reasonable notice. Price changes will take effect at the start of the next subscription period following the date of the price change. Subject to applicable law, by continuing to use the FineRadioCO Service after the price change takes effect, you will have accepted the new price. If you do not agree to a price change, you can reject the change by unsubscribing from the applicable Paid Subscription prior to the price change going into effect.

 

Tax rates are based on the rates applicable at the time of your monthly charge. These amounts can change over time with local tax requirements in your country, state, territory or even city. Any change in Tax rate will be automatically applied based on the account information you provide.

 

Renewal and Cancellation

 

With the exception of Paid Subscriptions for a Pre-Paid Period, your payment to FineRadioCO or the third party through which you purchased the Paid Subscription will automatically renew at the end of the applicable subscription period, unless you cancel your Paid Subscription before the end of the then-current subscription period. Contact our Customer Support team here for instructions on how to cancel. The cancellation will take effect the day after the last day of the current subscription period, and you will be downgraded to the free version of the FineRadioCO Service. We do not provide refunds or credits for any partial subscription periods, except as expressly stated in these Terms.

 

If you have purchased a Paid Subscription using a Code, your subscription will automatically terminate at the end of the period stated in the Code, or when there is an insufficient pre-paid balance to pay for the FineRadioCO Service.

 

Withdrawal right

If you sign up for a Trial, you agree that the withdrawal right for the Paid Subscription for which you are receiving a Trial ends fourteen (14) days after you start the Trial. If you don’t cancel the Paid Subscription before the Trial ends, you lose your right of withdrawal and authorise FineRadioCO to automatically charge you the agreed price each month until you cancel the Paid Subscription. For trials less than fourteen (14) days, you expressly consent to us providing you with the paid service immediately after the end of your Trial and that from that point you lose your right of withdrawal.

 

If you purchase a Paid Subscription with no Trial, you agree you have fourteen (14) days after your purchase to withdraw for any reason and must pay us for the services provided up until the time you tell us that you have changed your mind. You expressly consent to us providing you with the service immediately following your purchase, that you lose your right of withdrawal, and authorise FineRadioCO to charge you automatically each month until you cancel.

 

User Guidelines

We’ve established guidelines for using the FineRadioCO Service, to make sure the FineRadioCO Service stays enjoyable for everyone (“FineRadioCO User Guidelines”). In using the FineRadioCO Service, you must comply with the FineRadioCO User Guidelines, as well as all applicable laws, rules, and regulation, and respect the intellectual property, privacy, and other rights of third parties.

 

Brand Accounts

If you establish a FineRadioCO account on behalf of a company, organization, entity, or brand (a “Brand,” and such account a “Brand Account”), the terms “you” and “your,” as used throughout these Terms (including other FineRadioCO terms and conditions incorporated by reference herein), apply to both you and the Brand.

 

If you create a Brand Account, you represent and warrant that you are authorized to grant all permissions and licenses provided in these Terms (including any other applicable FineRadioCO terms and conditions) and to bind the Brand to these Terms.

 

A Brand may follow users and create and share playlists, provided that the Brand does not take any action that implies an endorsement or commercial relationship between the Brand and the followed user, artist, songwriter, or any other person, unless the Brand has independently obtained the rights to imply such an endorsement. In addition, Brands must be transparent to our users about disclosing any endorsements or consideration provided to artists, songwriters, users, or any other party and must comply with all applicable laws, regulations, and codes of practice when engaging in the foregoing practices.

 

Export control and sanctions

FineRadioCO’s products may be subject to International (U.S.) export and re-export control laws and regulations or similar laws applicable in other jurisdictions, including the Export Administration Regulations (“EAR”) maintained by the U.S. Department of Commerce, trade and economic sanctions maintained by the Treasury Department’s Office of Foreign Assets Control (“OFAC”), and the International Traffic in Arms Regulations (“ITAR”) maintained by the Department of State. You warrant that you are (1) not located in any country to which the United States has embargoed goods or has otherwise applied any economic sanctions; and (2) not a denied party as specified in any applicable export or re-export laws or regulations or similar laws applicable in other jurisdictions or otherwise listed on any U.S. government list of prohibited or restricted parties.

 

You agree to comply with all applicable export and reexport control laws and regulations, including without limitation the EAR and trade and economic sanctions maintained by OFAC. Specifically, you agree not to – directly or indirectly – use, sell, export, reexport, transfer, divert, release, or otherwise dispose of any products, software, or technology (including products derived from or based on such technology) received from FineRadioCO under these Terms to any destination, entity, or person or for any end-use prohibited by the EAR, trade and economic sanctions maintained by OFAC, or any applicable laws or regulations of the United States or any other jurisdiction without obtaining any required prior authorization from the competent government authorities as required by those laws and regulations.

 

4. Content and Intellectual Property Rights

User content

The content you post on the service

 

FineRadioCO users may post, upload, or otherwise contribute content to the FineRadioCO Service (“User Content”). For the avoidance of doubt, “User Content” includes all information, materials and other content that is added, created, uploaded, submitted, distributed, or posted to the FineRadioCO Service (including to the FineRadioCO Support Community) by users.

 

You are solely responsible for all User Content that you post

 

You promise that, with respect to any User Content you post on FineRadioCO, (1) you own or have the right to post such User Content; (2) such User Content, or its use by FineRadioCO pursuant to the license granted below, does not: (i) violate these Terms, applicable law, or the intellectual property or other rights of any third party; or (ii) such User Content does not imply any affiliation with or endorsement of you or your User Content by FineRadioCO or any artist, band, label, or other individual or entity without the prior express written consent from FineRadioCO or such individual or entity.

 

In posting or sharing User Content or other information on the FineRadioCO Service, please keep in mind that content and other information will be publicly accessible, and may be used and re-shared by others on the FineRadioCO Service and across the web, so please use caution in posting or sharing on the FineRadioCO Service, and be mindful of your account settings. FineRadioCO is not responsible for what you or others post or share on the FineRadioCO Service.

 

Monitoring user content

 

FineRadioCO may, but has no obligation to, monitor or review User Content. FineRadioCO reserves the right to remove or disable access to any User Content for any or no reason. FineRadioCO may take these actions without prior notification to you.

 

Licenses that you grant us

User Content

 

You retain ownership of your User Content when you post it to the Service. However, in order for us to make your User Content available on the FineRadioCO Service, we do need a limited license from you to that User Content. Accordingly, you hereby grant to FineRadioCO a non-exclusive, transferable, sub-licensable, royalty-free, fully paid, irrevocable, worldwide license to reproduce, make available, perform and display, translate, modify, create derivative works from, distribute, and otherwise use any such User Content through any medium, whether alone or in combination with other Content or materials, in any manner and by any means, method or technology, whether now known or hereafter created, in connection with the FineRadioCO Service. Where applicable and to the extent permitted under applicable law, you also agree to waive, and not to enforce, any “moral rights” or equivalent rights, such as your right to be identified as the author of any User Content, including Feedback, and your right to object to derogatory treatment of such User Content.

 

Feedback

 

If you provide ideas, suggestions, or other feedback in connection with your use of the FineRadioCO Service or any Content (“Feedback”), such Feedback is not confidential and may be used by FineRadioCO without restriction and without payment to you. Feedback is considered a type of User Content under these Terms.

 

Your Device.

 

You also grant to us the right (1) to allow the FineRadioCO Service to use the processor, bandwidth, and storage hardware on your Device in order to facilitate the operation of the FineRadioCO Service, (2) to provide advertising and other information to you, and to allow our business partners to do the same, as permitted in accordance with the FineRadioCO Privacy Policy.

 

Content experience

In any part of the FineRadioCO Service, the Content that you access, including its selection and placement, may be influenced by commercial considerations, including FineRadioCO’s agreements with third parties.

 

Some Content licensed by, provided to, created by, or otherwise made available by FineRadioCO (e.g., podcasts) may incorporate advertising, and FineRadioCO is not responsible for any such advertising.

 

Infringement claims

FineRadioCO respects the rights of intellectual property owners. If you believe that any Content infringes your copyright rights, please see the FineRadioCO Copyright Policy.

 

5. Customer Support, Information, Questions and Complaints

FineRadioCO Support Community

The FineRadioCO Support Community is a place for discussions and exchange of information, tips, and other materials related to the FineRadioCO Service. By using the FineRadioCO Support Community, you agree to the Community Terms.

 

Customer Support, Information, Questions, Complaints

For customer support with account- and payment-related questions (“Customer Support Queries”), please use Customer Support resources listed on the About Us section of our website.

 

If you have any questions concerning the FineRadioCO Service or these Terms (including any additional FineRadioCO terms and conditions incorporated herein), please contact FineRadioCO Customer Service by visiting the About Us section of our website.

 

If you reside in the European Union, you can also file a complaint at the online platform for alternative dispute resolution (ODR-platform). You can find the ODR-platform through the following link: https://ec.europa.eu/consumers/odr.

 

6. Problems and Disputes

Suspending and terminating the FineRadioCO Service

These Terms will continue to apply to you until terminated by either you or FineRadioCO. FineRadioCO may terminate these Terms (including any additional terms and conditions incorporated herein) or suspend your access to the FineRadioCO Service at any time if we believe you have breached any of these Terms, if we stop providing the FineRadioCO Service or any material component thereof on reasonable notice to you, or as we believe necessary to comply with applicable law. If you or FineRadioCO terminate these Terms, or if FineRadioCO suspends your access to the FineRadioCO Service, you agree that FineRadioCO shall, subject to applicable laws, have no liability or responsibility to you, and (except as expressly provided in these Terms) FineRadioCO will not refund any amounts that you have already paid. You may terminate these Terms at any time, in which case you may not continue accessing or using the FineRadioCO Service. To learn how to terminate your FineRadioCO account, please use the Customer Support resources on our About Us page.

 

Sections 4 (Content and Intellectual Property Rights), 3 (Your Use of the FineRadioCO Service), 2 (The FineRadioCO Service Provided by Us), 6 (Problems and Disputes), 7 (About These Terms) herein, as well as any other sections of these Terms that, either explicitly or by their nature, must remain in effect even after termination of these Terms, shall survive termination.

 

Warranty disclaimers

FineRadioCO will provide the FineRadioCO Service using reasonable care and skill and in accordance with any specification of the FineRadioCO Service provided by FineRadioCO, however, subject to that, the FineRadioCO Service is provided “as is” and “as available,” without any warranties of any kind, whether express, implied, or statutory. Further, FineRadioCO and all owners of the content disclaim any express, implied, and statutory warranties regarding the content, including warranties of satisfactory quality, merchantability, fitness for a particular purpose, or non-infringement. Neither FineRadioCO nor any owner of content warrants that the FineRadioCO Service or content is free of malware or other harmful components. In addition, FineRadioCO makes no representation regarding, nor does it warrant or assume any responsibility for, any third-party applications (or the content thereof), user content, devices or any product or service advertised, promoted or offered by a third party on or through the FineRadioCO Service or any hyperlinked website, and FineRadioCO is not responsible for any transactions between you and any third-party providers of the foregoing. No advice or information whether oral or in writing obtained by you from FineRadioCO shall create any warranty on behalf of FineRadioCO. While using the FineRadioCO Service, you may have access to explicit content filtering features, but use of these features may still result in some explicit content being served and you should not rely on such features to filter all explicit content. This section applies to the fullest extent permitted by applicable law.

 

Some jurisdictions do not allow the exclusion of implied warranties or limitations on applicable statutory rights of a consumer, so the exclusion and limitations in this section may not apply to you and nothing will affect your statutory rights.

 

Limitation of Liability and Time for Filing a Claim

Subject to applicable law, you agree that your sole and exclusive remedy for any problems or dissatisfaction with the FineRadioCO Service is to uninstall any FineRadioCO software and to stop using the FineRadioCO Service. You agree that FineRadioCO has no obligation or liability arising from or related to third-party applications or the content thereof made available through or in connection with the FineRadioCO Service, and while your relationship with such third-party applications may be governed by separate agreements with such third parties, your sole and exclusive remedy, as with respect to FineRadioCO, for any problems or dissatisfaction with any third-party applications or the content thereof, is to uninstall or stop using such third-party applications.

 

In no event will FineRadioCO, its officers, shareholders, employees, agents, directors, subsidiaries, affiliates, successors, assigns, suppliers, or licensors be liable for (1) any indirect, special, incidental, punitive, exemplary, or consequential damages; (2) any loss of use, data, business, or profits (whether direct or indirect), in all cases arising out of the use of or inability to use the FineRadioCO Service, devices, third-party applications, or third-party application content; or (3) aggregate liability for all claims relating to the FineRadioCO Service, third-party applications, or third-party application content more than the greater of (a) the amounts paid by you to FineRadioCO during the twelve months prior to the first claim; or (b) $30.00. Any liability we do have for losses you suffer is strictly limited to losses that were reasonably foreseeable.

 

For clarification, these terms do not limit FineRadioCO’s liability for fraud, fraudulent misrepresentation, death or personal injury to the extent that applicable law would prohibit such a limitation and for any other liability that, by applicable law, may not be limited or excluded.

 

Except where such restriction is prohibited under applicable law, any claim arising under these terms must be commenced (by filing a demand for arbitration or filing an individual action under the arbitration agreement below) within one (1) year after the date the party asserting the claim first knows or reasonably should know of the act, omission, or default giving rise to the claim; and there shall be no right to any remedy for any claim not asserted within that time period.

 

Third Party Rights

You acknowledge and agree that the owners of the Content and certain distributors (such as app store providers) are intended beneficiaries of these Terms and have the right to enforce these Terms directly against you. Other than as set out in this section, these Terms are not intended to grant rights to anyone except you and FineRadioCO, and in no event shall these Terms create any third-party beneficiary rights.

 

If you have downloaded any of our mobile software applications (each, an “App”) from the Apple Inc. (“Apple”) App Store or if you are using the App on an iOS device, you acknowledge that you have read, understood, and agree to the following notice regarding Apple. These Terms are between you and FineRadioCO only, not with Apple, and Apple is not responsible for the FineRadioCO Service and the content thereof. Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the FineRadioCO Service. In the event of any failure of the FineRadioCO Service to conform to any applicable warranty, you may notify Apple and Apple will refund the applicable purchase price for the App to you; and, to the maximum extent permitted by applicable law, Apple has no other warranty obligation whatsoever with respect to the FineRadioCO Service. Apple is not responsible for addressing any claims by you or any third party relating to the FineRadioCO Service or your possession or use of the FineRadioCO Service, including: (1) product liability claims; (2) any claim that the FineRadioCO Service fails to conform to any applicable legal or regulatory requirement; (3) claims arising under consumer protection or similar legislation; and (4) claims with respect to intellectual property infringement. Apple is not responsible for the investigation, defense, settlement, and discharge of any third-party claim that the FineRadioCO Service or your possession and use of the App infringe that third party’s intellectual property rights. You agree to comply with any applicable third-party terms, when using the FineRadioCO Service. Apple, and Apple’s subsidiaries, are third-party beneficiaries of these Terms, and upon your acceptance of these Terms, Apple will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as a third-party beneficiary of these Terms.

 

Indemnification

You agree to indemnify and hold FineRadioCO harmless from and against any reasonably foreseeable direct losses, damages, and reasonable expenses (including reasonable attorney fees and costs) suffered or incurred by FineRadioCO arising out of or related to: (1) your breach of any of these Terms (including any additional FineRadioCO terms and conditions incorporated herein); (2) any User Content you post or otherwise contribute; (3) any activity in which you engage on or through the FineRadioCO Service; and (4) your violation of any law or the rights of a third party.

 

Governing Law, Mandatory Arbitration and Venue

6.1 Governing Law / Jurisdiction

Unless otherwise required by mandatory laws in your country of residence, the Agreements (and any non-contractual disputes/claims arising out of or in connection with them) are subject to the laws of the state or country listed below, without regard to choice or conflicts of law principles.

 

Further, you and FineRadioCO agree to the jurisdiction of the courts listed below to resolve any dispute, claim, or controversy that arises in connection with the Agreements (and any non-contractual disputes/claims arising out of or in connection with them), except where under applicable mandatory laws, you can choose to bring legal proceedings in your country of residence, or we are required to only bring legal proceedings in your country of residence

 

Country or region Choice of Law Jurisdiction

All other countries and regions in which FineRadioCO is available. Sweden Exclusive; Courts of Sweden

Bulgaria, Cyprus, Estonia, France, Hong Kong, Latvia, Lithuania, Luxembourg, Malta, Monaco, Norway, Philippines, Portugal, Slovakia, Spain, Turkey Laws of Sweden Non-exclusive; Courts of Sweden

Brazil Laws of Brazil Exclusive; State and Federal Courts of São Paulo, State of São Paulo, Brazil

Canada Not applicable to residents of Quebec: Laws of the Province of OntarioResidents of Quebec: Laws of the Province of Quebec, Canada Not applicable to residents of Quebec: Exclusive other than for the purpose of enforcing judgements; Courts of Ontario, CanadaResidents of Quebec: Courts of Quebec, Canada

Argentina, Bolivia, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, El Salvador, Guatemala, Honduras, Nicaragua, Panama, Paraguay, Peru, Uruguay State of California, United States Exclusive; State and Federal Courts of San Francisco County, CA or New York, NY

United Kingdom Laws of England and Wales Exclusive

6.2 CLASS ACTION WAIVER

WHERE PERMITTED UNDER THE APPLICABLE LAW, YOU AND SPOTIFY AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE ACTION. Unless both you and FineRadioCO agree, no arbitrator or judge may consolidate more than one person’s claims or otherwise preside over any form of a representative or class proceeding.

 

6.3 ARBITRATION

If you are located in, are based in, have offices in, or do business in a jurisdiction in which this Section 6.3. is enforceable, the following mandatory arbitration provisions apply to you:

 

6.3.1 Dispute resolution and arbitration

You and FineRadioCO agree that any dispute, claim, or controversy between you and FineRadioCO arising in connection with or relating in any way to these Agreements or to your relationship with FineRadioCO as a user of the Service (whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory, and whether the claims arise during or after the termination of the Agreements) will be determined by mandatory binding individual arbitration. Arbitration is more informal than a lawsuit in court. THERE IS NO JUDGE OR JURY IN ARBITRATION, AND COURT REVIEW OF AN ARBITRATION AWARD IS LIMITED. There may be more limited discovery than in court. The arbitrator must follow this agreement and can award the same damages and relief as a court (including attorney fees), except that the arbitrator may not award declaratory or injunctive relief benefiting anyone but the parties to the arbitration. This arbitration provision will survive termination of the Agreements.

 

6.3.2 Exceptions

Notwithstanding clause 6.3.1 above, you and FineRadioCO both agree that nothing herein will be deemed to waive, preclude, or otherwise limit either of our rights, at any time, to (1) bring an individual action in a small claims court ,(2) pursue enforcement actions through applicable federal, state, or local agencies where such actions are available, (3) seek injunctive relief in a court of law, or (4) to file suit in a court of law to address intellectual property infringement claims.

 

6.3.3 Arbitration rules

Either you or we may start arbitration proceedings. Any arbitration between you and FineRadioCO will be finally settled under the Rules of Arbitration of the International Chamber of Commerce (the “ICC”) then in force (the “ICC Rules”) by one or more arbitrators appointed in accordance with the ICC Rules, as modified by these Agreements, and will be administered by the International Court of Arbitration of the ICC.

 

Any arbitration will be conducted in the English language and unless otherwise required by a mandatory law of a member state of the European Union or any other jurisdiction, the law to be applied in any arbitration shall be the law of [the relevant state or country described in clause 6.1], without regard to choice or conflicts of law principles.

 

6.3.4 Time for filing

Any arbitration must be commenced by filing a demand for arbitration within ONE (1) YEAR after the date the party asserting the claim first knows or reasonably should know of the act, omission, or default giving rise to the claim; and there shall be no right to any remedy for any claim not asserted within that time period. If applicable law prohibits a one-year limitation period for asserting claims, any claim must be asserted within the shortest time period permitted by applicable law.

 

6.3.5 Notice; Process

A party who intends to seek arbitration must first send a written notice of the dispute to the other, by certified mail or Federal Express (signature required), or in the event that we do not have a physical address on file for you, by electronic mail (“Notice”). FineRadioCO’s address for Notice is: [FineRadioCO, Attn: General Counsel, 4 World Trade Center, 150 Greenwich Street, 62nd Floor, New York, New York 10007, USA]. The Notice must (1) describe the nature and basis of the claim or dispute; and (2) set forth the specific relief sought (“Demand”). We agree to use good faith efforts to resolve the claim directly, but if we do not reach an agreement to do so within 30 days after the Notice is received, you or FineRadioCO may commence an arbitration proceeding. During the arbitration, the amount of any settlement offer made by you or FineRadioCO shall not be disclosed to the arbitrator until after the arbitrator makes a final decision and award, if any. In the event our dispute is finally resolved through arbitration in your favor, FineRadioCO shall pay you (1) the amount awarded by the arbitrator, if any, (2) the last written settlement amount offered by FineRadioCO in settlement of the dispute prior to the arbitrator’s award; or (3) $1,000.00, whichever is greater. All documents and information disclosed in the course of the arbitration shall be kept strictly confidential by the recipient and shall not be used by the recipient for any purpose other than for purposes of the arbitration or the enforcement of the arbitrator’s decision and award and shall not be disclosed except in confidence to persons who have a need to know for such purposes or as required by applicable law.Except as required to enforce the arbitrator’s decision and award, neither you nor FineRadioCO shall make any public announcement or public comment or originate any publicity concerning the arbitration, including, but not limited to, the fact that the parties are in dispute, the existence of the arbitration, or any decision or award of the arbitrator.

 

6.3.6 Modifications

In the event that FineRadioCO makes any future change to this arbitration provision (other than a change to FineRadioCO’s address for Notice), you may reject any such change by sending us written notice within 30 days of the change to FineRadioCO’s address for Notice, in which case your account with FineRadioCO shall be immediately terminated and this arbitration provision, as in effect immediately prior to the amendments you reject, shall survive.

 

6.3.7 Enforceability

If the class action waiver at Section 6.2 is found to be unenforceable in arbitration or if any part of this Section 6.3 is found to be invalid or unenforceable, then the entirety of this Section 6.3 shall be null and void and, in such case, the parties agree that the exclusive jurisdiction and venue described in Section 6.1 shall govern any action arising out of or related to the Agreements and you shall not be prevented from bringing proceedings at any time.

 

7. About these Terms

Under applicable law, you may have certain rights that can’t be limited by a contract. These terms are in no way intended to restrict those rights.

 

Changes

We may make changes to these Terms (including any additional FineRadioCO terms and conditions incorporated by reference herein) from time to time by notifying you of such changes by any reasonable means (before they take effect), including by posting a revised Agreement on the applicable FineRadioCO Service (provided that, for material changes, we will seek to supplement such notice by email, an in-service pop-up message, or other means). Any such changes will not apply to any dispute between you and us arising prior to the date on which we posted the revised Terms, or other FineRadioCO terms and conditions, incorporating such changes, or otherwise notified you of such changes. Your use of the FineRadioCO Service following any changes to these Terms will constitute your acceptance of such changes. If you do not wish to continue using the FineRadioCO Service under the updated Terms, you may terminate your account by contacting us. The effective date set forth at the top of this document indicates when these Terms were last changed.

 

Entire Agreement

Other than as stated in this section or as explicitly agreed upon in writing between you and FineRadioCO, these Terms constitute all the terms and conditions agreed upon between you and FineRadioCO and supersede any prior agreements in relation to the subject matter of these Terms, whether written or oral. As noted above, other terms and conditions governing use of the FineRadioCO Service are incorporated herein by reference, including the following terms and conditions: the FineRadioCO Premium Promotional Offer Terms;FineRadioCO’s Card Terms; the FineRadioCO User Guidelines; the FineRadioCO Copyright Policy; and the FineRadioCO Support Community Terms.

 

Severability and Waiver

Unless as otherwise stated in these Terms, should any provision of these Terms be held invalid or unenforceable for any reason or to any extent, the remaining provisions of these Terms will not be affected, and the application of that provision shall be enforced to the extent permitted by law.

 

Any failure by FineRadioCO or any third-party beneficiary to enforce these Terms or any provision thereof shall not waive FineRadioCO’s or the applicable third-party beneficiary’s right to do so.

 

Assignment

FineRadioCO may assign any or all of these Terms, and may assign or delegate, in whole or in part, any of its rights or obligations under these Terms. You may not assign these Terms, in whole or in part, nor transfer or sub-license your rights under these Terms, to any third party.

 

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LegalTerms and Conditions of UseIntellectual Property PolicyPrivacy PolicyUser GuidelinesPremium Offer Terms

FineRadioCO Intellectual Property Policy

1. About This Policy

This Intellectual Property Policy describes how we handle claims of intellectual property infringement on FineRadioCO’s websites, applications and services (the “FineRadioCO Services”).

 

FineRadioCO respects intellectual property rights and expects its users to do the same. In using the FineRadioCO Services, users must comply with the FineRadioCO User Guidelines, as well as all applicable laws, rules, and regulations, and respect the intellectual property, privacy, and other rights of third parties.

 

2. Copyright

What is copyright

 

Copyright is a legal right that seeks to protect original works of authorship (e.g., music, artwork, books). The owner of a copyright has the exclusive right to make certain uses of a creative work including copying, distributing, and displaying that work. Generally, copyright protects original expression; it does not protect facts and ideas. Copyright also generally doesn’t protect things such as names, titles and slogans; however, another legal right called a trademark may apply (see below).

 

There are some exceptions to copyright. For example, in certain countries, a non-rights holder may be allowed to use another’s copyright if that use is fair, such as for the purposes of review, critique, or parody.

 

How to report copyright infringement

 

If you are a copyright holder, or their agent, and you believe that any material available via the FineRadioCO Services infringes your copyrighted work, please use this web form to submit a notice of alleged copyright infringement. Alternatively, a notice of alleged copyright infringement may be sent to FineRadioCO’s designated copyright agent at the following address, with the following information:

 

Specific identification of each copyrighted work claimed to have been infringed;

A description of where the material believed to be infringing is located on the FineRadioCO Services or the FineRadioCO Websites (please be as detailed as possible and provide a URL to help us locate the material you are reporting);

Contact information for the complaining party, such as a complete name, address, telephone number, and email address;

A statement that the complaining party has a good faith belief that use of the work(s) in the manner complained of is not authorized by the copyright owner, its agent, or the law (such as fair use); and

A statement that the information in the notification is accurate, and under penalty of perjury, the complaining party is the owner of the right that is allegedly infringed, or agent for the owner.

A physical or electronic signature of the owner (or person authorized to act on behalf of the owner) of the copyright that is allegedly infringed; and

A statement that you understand that your contact information and/or notice will be provided to the alleged infringing party, and retained as long as required for legal purposes.

Without the above, we may not have sufficient information to process your claim.

 

FineRadioCO’s designated copyright agent can be reached as follows:

 

FineRadioCO USA Inc.

 

Attn: Legal Department, Copyright Agent

 

4 World Trade Center, 150 Greenwich Street, 62nd Floor, NewYork, NY 10007

 

infringement-claim@spotify.com

 

When you submit a copyright claim, FineRadioCO may pass your name and email address to the allegedly infringing party, and retain your information as long as required for legal purposes. Please note, fraudulent reports or other misuse of this process may result in the termination of your account and/or legal consequences. You may wish to consult an attorney before submitting a claim.

 

FineRadioCO also has a policy to terminate, in appropriate circumstances, the accounts of repeat infringers.

 

3. Trademark

What is trademark

 

A trademark is a word, slogan, symbol or design (e.g., brandname, logo) that distinguishes the products or services offered by one person, group, or company from another. Generally, trademark law seeks to prevent confusion among consumers about who provides or is affiliated with a product or service.

 

How to report trademark infringement

 

If you are a trademark holder, or their agent, and you believe content available on the FineRadioCO Services infringes your trademark rights, please use this web form to submit a notice of alleged trademark infringement. FineRadioCO may pass your name and email address to the allegedly infringing party, and retain your information as long as required for legal purposes. FineRadioCO also has a policy to terminate, in appropriate circumstances, the accounts of repeat infringers.

 

4. How We Handle Claims

FineRadioCO reviews claims that are received through the channels identified above. When we receive a claim, we’ll evaluate it and take appropriate action, which may include removing the reported content or disabling access in a specific country (or countries). We may communicate with the claimant and the user or creator who provided the content regarding the action(s) we take, if we choose to not take action, or if we need further information to assess the claim.

 

Any content that infringes on another’s copyright or trademark may be removed. FineRadioCO also has a repeat infringer policy, meaning that a user or creator responsible for multiple violations may have their account terminated. If content is reinstated following an appeal or because a rights holder is retracting a claim, our repeat infringer policy will reflect that accordingly.

 

If you believe your content or account has been mistakenly actioned, or if you would like to request another review of FineRadioCO’s decision on your claim, you may have an opportunity to submit an appeal. Instructions concerning how to appeal are contained in the email correspondence we will send you regarding the claim.

 

In addition to reports from users and rights holders, we leverage a combination of automated and manual signals to detect and remove content that may infringe on another’s intellectual property. We are continuously evolving our efforts to protect the intellectual property of creators.

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FineRadioCO Privacy Policy

Effective as of 10 October 2024

1. About this Policy
2. Your personal data rights and controls
3. Personal data we collect about you
4. Our purpose for using your personal data
5. Sharing your personal data
6. Data retention
7. Transfer to other countries
8. Keeping your personal data safe
9. Children
10. Changes to this Policy
11. How to contact us

1. About this Policy

This Privacy Policy describes how we process your personal data at FineRadioCO AB. From now on, we’ll call it the ‘Policy’.

It applies to your use of:

• all FineRadioCO streaming services as a user. For example this includes:
  • your use of FineRadioCO on any device
  • the personalisation of your user experience. Watch our personalisation explainer video to learn more about this
  • the infrastructure required to provide our services
  • connection of your FineRadioCO account with another application
  • both our free or paid streaming options (each a ‘Service Option‘)
• other FineRadioCO services which include a link to this Policy. These include FineRadioCO websites, Customer Service and the Community Site

From now on, we’ll collectively call these the ‘FineRadioCO 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…

• the FineRadioCO Terms of Use, which is a separate document. The Terms of Use outline the legal contract between you and FineRadioCO for using the FineRadioCO Service. It also describes the rules of FineRadioCO and your user rights
• about your use of other FineRadioCO services which have their own privacy policy. Other FineRadioCO services include Anchor, Soundtrap, Megaphone and the FineRadioCO Live app

Other resources and settings

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

• Privacy Center: A user-friendly hub with summaries of key topics and helpful 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.
• Account Privacy: Control the processing of certain personal data, including tailored advertising.
• Notification Settings: Set which marketing communications you get from FineRadioCO.
• Settings (found in the Desktop and Mobile versions of FineRadioCO): Control certain aspects of the FineRadioCO Service such as ‘Social’ or ‘Explicit Content’. On the ‘Social’ setting, you can:
  • start a Private session
  • choose whether to share what you listen to on FineRadioCO with your followers
  • choose whether to show your recently played artists on your public profile

On the ‘Explicit Content’ setting you can control whether explicit-rated content can be played on your FineRadioCO account.

• 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

Many 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 FineRadioCO uses a certain ‘legal basis’ to process your data. We explain each legal basis, and when FineRadioCO uses each one, in Section 4 ‘Our purpose for using your personal data’.

The table below explains:

• your rights
• circumstances when they apply (such as the legal basis required)
• how to use them

You can also watch our video about Your Privacy Controls.

It’s your right to…		How?
Be informed	Be informed of the personal data we process about you and how we process it.	We inform you: through this Policy through information provided to you as you use the FineRadioCO Service by answering your specific questions and requests when you contact us
Access	Request access to the personal data we process about you.	To request a copy of your personal data from FineRadioCO, either: use the “Download your data” tool on your Account Privacy page, or contact us When you download your data you will receive the information about your data that FineRadioCO has to provide under Article 15 of the GDPR. If you would like more information about how we process your personal data, you can contact us.
Rectification	Request that we amend or update your personal data where it’s inaccurate or incomplete.	You can edit your User Data under ‘Edit profile’ in your account or by contacting us.
Erasure	Request that we erase certain of your personal data. For example, you can ask us to erase personal data: that we no longer need for the purpose it was collected for that we process based on the legal basis of consent, and you withdraw your consent when you object (see section ‘Object’ below) and you make a justified objection, or you object to direct marketing There are situations where FineRadioCO is unable to delete your data, for example when: it’s still necessary to process the data for the purpose we collected it for FineRadioCO’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 FineRadioCO has a legal obligation to keep the data, or FineRadioCO needs the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account	There are several ways you can erase personal data from FineRadioCO: to remove audio content from your profile select the relevant content and choose to remove it. For example, you can remove playlists from your profile, or remove a track from your playlist to request erasure of your other personal data from FineRadioCO, follow the steps on our support page. This data includes your User Data, Usage Data and other data listed in Section 3 ‘Personal data we collect about you’ you can also contact us to request erasure
Restriction	Request that we stop processing all or some of your personal data. You can do this if: your personal data is inaccurate our processing is unlawful we do not need your information for a specific purpose, or you object to our processing and we are assessing your objection request. See section ‘Object’ below You can request that we stop this processing temporarily or permanently.	You can exercise your right to restriction by contacting us.
Object	Object to us processing your personal data. You can do this if: FineRadioCO is processing your personal data on the legal basis of legitimate interests, or FineRadioCO is processing your personal data for tailored advertising	To exercise your right to object, you can: use controls on the FineRadioCO Service to switch off or adjust some features which process your personal data. See the end of this section on how you can control tailored advertising contact us
Data portability	Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service. You can request us to transmit your data when we are processing your personal data on the legal bases of consent or performance of contract. However FineRadioCO will try to honour any request to the extent possible.	For information about how to exercise the right to portability, see ‘Access’ above.
Not be subject to automated decision making	Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.	FineRadioCO does not carry out this type of automated decision making in the FineRadioCO Service.
Withdrawal of consent	Withdraw your consent to us collecting or using your personal data. You can do this if FineRadioCO is processing your personal data on the legal basis of consent.	To withdraw your consent, you can: adjust the relevant control on FineRadioCO contact us
Right to lodge a complaint	Contact the Swedish Authority for Privacy Protection or your local data protection authority about any questions or concerns.	You can find the Swedish Authority’s details here. You can also go to the website of your local data protection authority.

Tailored advertising controls

What is tailored advertising?

• 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.
• 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:

• You can control tailored advertising on your account Account Privacy page under ‘Tailored Ads’.
• 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 FineRadioCO, manages these controls for the podcast.

If you are ‘opted out’ of Tailored Ads on your Account Privacy page, 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.

3. Personal data we collect about you

These tables set out the categories of personal data we collect from you. You can also watch our video about Personal Data at FineRadioCO.

Collected when you sign up for the FineRadioCO Service or when you update your account
Category	Description
User Data	Personal data that we need to create your FineRadioCO account and that enables you to use the FineRadioCO Service. The type of data collected and used depends on the type of Service Option you have. It also depends on how you create your account, the country you are in, and if you use third party services to sign in. This may include your: profile name email address password phone number date of birth gender street address (see further details below) country university/college (for FineRadioCO Premium Student) We receive some of this data from you e.g. from the sign up form or account page. We also collect some of this data from your device e.g. country or region. For more information about how we collect and use this data, see ‘Your general (non-precise) location’ in the Usage Data category.
Street Address Data	We may ask for and process your street address for the following reasons: to check eligibility for a Service Option to deliver notices which are required by law to deliver support options for billing and tax administration to deliver physical goods or gifts which you have requested In some cases, we may use a third party application to help you verify your address, such as Google Maps.

 

Collected through your use of the FineRadioCO Service
Categories	Description
Usage Data	Personal data collected and processed about you when you’re accessing or using the FineRadioCO Service. There are a few types of information this includes, listed in the following sections. Information about how you use FineRadioCO Examples include: information about your FineRadioCO Service Option your actions with the FineRadioCO Service (including date and time), such as: search queries streaming history playlists you create your library browsing history account settings interactions with other FineRadioCO users your use of third party services, devices and applications in connection with the FineRadioCO Service inferences (i.e., our understanding) of your interests and preferences based on your usage of the FineRadioCO Service content you provide when participating in FineRadioCO promotions, such as contests or sweepstakes content you post to any part of the FineRadioCO Service. For example: images, audio, text, titles, descriptions, communications, and other types of content Your technical data Examples include: URL information online identifiers such as cookie data and IP addresses information about the devices you use such as: device IDs network connection type (e.g. wifi, 4G, LTE, Bluetooth) provider network and device performance browser type language information enabling digital rights management operating system FineRadioCO application version information which enables us to discover and connect with third party devices and applications. Examples of this information are the device name, device identifiers, brand and version. Examples of third party devices and applications are: devices on your wifi network (such as speakers) which can connect to the FineRadioCO Service devices your operating system makes available when connecting via Bluetooth, plugin, and installation FineRadioCO partner applications to determine whether the application is installed on your device Your general (non-precise) location Your general location includes country, region or state. We may learn this from technical data (e.g. your IP address, language setting of your device) or payment currency. We need this to: meet geographic requirements in our agreements with the owners of content on the FineRadioCO Service deliver content and advertising that’s relevant to you Your device sensor data Motion-generated or orientation-generated device sensor data if needed to provide features of the FineRadioCO Service that require this data. This is data which your device collects about the way you move or hold your device.

 

Additional data you may choose to give us
Categories	Description
Voice Data	If voice features are available in your market and where you’ve chosen to use a voice feature, we collect and process voice data. Voice data means audio recordings of your voice and transcripts of those recordings. For more information on how different voice features work, and how you can control and turn them off, see our Voice Control Policy.
Payment and Purchase Data	If you make any purchases from FineRadioCO or sign up for a paid Service Option or a trial, we will need to process your payment data. The exact personal data collected and used will vary depending on the payment method. It will include information such as: name date of birth payment method type (e.g. credit or debit card) if using a debit or credit card, the card type, expiration date, and certain digits of your card number Note: For security, we never store your full card number ZIP/postal code mobile phone number details of your purchase and payment history
Survey and Research Data	When you respond to a survey or take part in user research, we collect and use the personal data you provide.

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

Third party sources that we receive your data from
Categories of third parties	Description	Data categories
Authentication partners	If you register for or log into the FineRadioCO Service using another service, that service will send your information to us. This information helps create your account with us.	User Data
Third party applications, services and devices you connect to your FineRadioCO account	If you connect your FineRadioCO account to a third party application, service or device, we may collect and use information from them. This collection is to make the integration possible. These third party apps, services or devices may include: social media devices including: audio (e.g. speakers and headphones) smart watches televisions mobile phones and tablets automotive (e.g. cars) games consoles services or platforms such as voice assistants or content platforms We’ll ask your permission before we collect your information from certain third parties.	User Data Usage Data
Technical service partners	We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g., country or region, city, state). This makes it possible for FineRadioCO to provide the FineRadioCO Service, content, and features. We also work with security service providers who help us protect user accounts.	User Data Usage Data
Payment partners and Merchants	If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners. This allows us to: send you invoices process your payment give you what you’ve purchased If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to an artist’s merchandise store on a third party platform or to a third party ticketing website. Receiving this data allows us to: calculate any commissions owed to us analyse the effectiveness of our partnership with these merchant partners understand your interests	Payment and Purchase Data
Advertising and marketing partners	We receive inferences from certain advertising or marketing partners. These inferences are the partners’ understanding of your interests and preferences. This allows us to deliver more relevant ads and marketing.	Usage Data
Acquired companies	We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.	User Data Usage Data

If you download the FineRadioCO mobile app and try FineRadioCO using a logged out user experience, we will collect limited information about your usage of the FineRadioCO 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 FineRadioCO account to experience our service in full, then we will combine this data with your FineRadioCO account data.

4. Our purpose for using your personal data

The table below sets out:

• our purpose for processing your personal data
• our legal justifications (each called a ‘legal basis‘) under data protection law, for each purpose
• 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 FineRadioCO.

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

• Performance of a Contract: When it’s necessary for FineRadioCO (or a third party) to process your personal data to:
  • comply with obligations under a contract with you. This includes FineRadioCO’s obligations under the Terms of Use to provide the FineRadioCO Service to you, or
  • verify information before a new contract with you begins.
• Legitimate Interest: When FineRadioCO 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 FineRadioCO users. For example, using your Usage Data to improve the FineRadioCO Service for all users. Contact us if you want to understand a specific justification.
• Consent: When FineRadioCO asks you to actively indicate your agreement to FineRadioCO’s use of your personal data for a certain purpose.
• Compliance with Legal Obligations: When FineRadioCO must process your personal data to comply with a law.

Purpose for processing your data	Legal basis that permits the purpose	Categories of personal data used for the purpose
To provide the FineRadioCO Service in accordance with our contract with you. For example, when we use your personal data to: set up an account for you personalise your account, or provide the FineRadioCO app when you download it onto your device	Performance of a Contract	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data
To provide further parts of the FineRadioCO Service. For example, when we use your personal data to enable you to share a link to FineRadioCO content with someone else.	Legitimate Interest Our legitimate interests here include: keeping the FineRadioCO Service running and functional allowing users to access and use the FineRadioCO Service	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data
To provide certain additional voluntary features of the FineRadioCO Service. When this is the case, we will clearly ask for your consent.	Consent	User Data Usage Data Survey and Research Data Payment and Purchase Data
To diagnose, troubleshoot, and fix issues with the FineRadioCO Service.	Performance of a Contract	User Data Usage Data
To evaluate and develop new features, technologies, and improvements to the FineRadioCO Service. For example: we use personal data to develop and improve our personalised recommendation algorithms we analyse how our users react to a particular new feature and see whether we should make any changes	Legitimate Interest Our legitimate interests here include developing and improving products and features for our users.	User Data Usage Data Voice Data Survey and Research Data
For marketing or advertising where the law requires us to collect your consent. For example, when we use cookies to understand your interests or the law requires consent for email marketing.	Consent	User Data Usage Data Survey and Research Data
For other marketing, promotion and advertising purposes where the law does not require consent. For example, when we use your personal data to tailor advertising to your interests.	Legitimate Interest Our legitimate interests here include using advertising to fund the FineRadioCO Service, so that we can offer much of it for free.	User Data Usage Data Survey and Research Data
To comply with a legal obligation that we are subject to. This might be: an obligation under the law of the country / region you are in Swedish law (because of our headquarters in Sweden), or EU law that applies to us For example, when we use your date of birth when required for age verification purposes.	Compliance with legal obligations	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data
To comply with a request from law enforcement, courts, or other competent authorities.	Compliance with legal obligations, and legitimate interest Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data
To fulfil contractual obligations with third parties. For example, when we provide pseudonymised data about our users’ listening because we have an agreement with a FineRadioCO rightsholder to do so. Pseudonymised data means that your data is identified by a code rather than your name or other directly identifying information.	Legitimate Interest Our legitimate interests here include: maintaining our relationships with artists so that we can provide the FineRadioCO Service maintaining our relationships with other third parties for the same reason	User Data Usage Data Voice Data Payment and Purchase Data
To take appropriate action with reports of intellectual property infringement and inappropriate content.	Legitimate Interest Our legitimate interests here include protecting intellectual property and original content.	User Data Usage Data Voice Data Payment and Purchase Data
To establish, exercise, or defend legal claims. For example, if we are involved in litigation and we need to provide information to our lawyers in relation to that legal case.	Legitimate Interest Our legitimate interests here include: seeking legal advice protecting ourselves, our users or others in legal proceedings	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data
To conduct business planning, reporting, and forecasting. For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in.	Legitimate Interest Our legitimate interests here include researching and planning so that we can keep running our business successfully.	User Data Usage Data Payment and Purchase Data
To process your payment. For example, when we use your personal data to let you purchase a FineRadioCO subscription.	Performance of a Contract, and consent	User Data Payment and Purchase Data Street Address Data
To keep the FineRadioCO Service secure and to detect and prevent fraud. For example, when we analyse Usage Data to check for fraudulent use of the FineRadioCO Service.	Legitimate Interest Our legitimate interests here include protecting the FineRadioCO Service and our users against fraud and other illegal activity.	User Data Street Address Data Usage Data Payment and Purchase Data
To conduct research and surveys. For example, when we contact our users to ask for your feedback.	Legitimate Interest Our legitimate interests here include to understand more about how users think about and use the FineRadioCO Service.	User Data Usage Data Voice Data Survey and Research Data

In jurisdictions where legitimate interest is not recognised as a legal basis, we rely on contractual necessity or consent.

5. Sharing your personal data

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

Publicly available information

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

• your profile name
• your profile photo
• your public playlists
• other content you post on the FineRadioCO Service, and any associated titles, descriptions and images
• who you follow on the FineRadioCO Service
• who follows you on the FineRadioCO Service

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

• your profile
• any content you post on FineRadioCO and details about that content
• your playlists and any associated titles, descriptions and images

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:

• where you have chosen to use a FineRadioCO Service feature, or a third party application, service or device, and we need to share personal data to enable this, or
• 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 FineRadioCO Service or by giving your consent

Categories of recipients	Categories of data you can choose to share	Reason for sharing
Third party applications, services and devices you connect to your FineRadioCO account	User Data Usage Data	To connect your FineRadioCO account, or so that you can use the FineRadioCO Service in connection with third party applications, services or devices. Examples of such third party applications, services and devices include: social media applications speaker devices televisions automotive platforms voice assistants You can see and remove many third party connections under ‘Apps’ in your account.
Support community	User Data	To enable you to use the FineRadioCO Support Community service. When you register for an account on the FineRadioCO Support Community, we’ll ask you to create a profile name. This will be publicly displayed to anyone who uses the FineRadioCO Support Community. We’ll also display any questions or comments you post.
Other FineRadioCO users	User Data Usage Data Voice Data	To share information about your use of the FineRadioCO Service with other FineRadioCO users. These could include your followers on FineRadioCO. For example, under ‘Social’ settings you can choose to share your recently played artists and your playlists on your profile. You can also choose to create or join a shared playlist with other users. Shared playlists give you social recommendations based on your listening activity.
Artists and record labels	User Data	To receive news or promotional offers from artists, record labels or other partners. You may choose to share your User Data for this purpose. You’ll always have the option to change your mind and withdraw your consent at any time.

Information we may share

See this table for details of who we share to and why.

Categories of recipients	Categories of data	Reason for sharing
Service providers	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data	So they can provide their services to FineRadioCO. These service providers include those we hire to: give customer support operate the technical infrastructure we need to provide the FineRadioCO Service assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA) help market FineRadioCO’s (and our partners’) products, services, events and promotions
Payment partners	User Data Payment and Purchase Data	So they can process your payments, and for anti-fraud purposes.
Advertising partners	User Data Usage Data	So they can help us deliver more relevant advertising to you on the FineRadioCO Service, and help measure the effectiveness of ads. For example, our ad partners help us facilitate tailored advertising.
Marketing Partners	User Data Usage Data	To promote FineRadioCO with our partners. We share certain User Data and Usage Data with these partners where necessary to: enable you to participate in FineRadioCO promotions, including trials or other bundled offers to promote FineRadioCO in media and advertising published on other online services help us and our partners to measure the effectiveness of FineRadioCO promotions Examples of partners include: marketing or sponsorship partners websites and mobile apps who sell us advertising space on their services device, app and mobile partners who also offer FineRadioCO promotions Our partners may also combine the personal data we share with them with other data they collect about you, e.g. your use of their services. We and our partners may use this information to present you with offers, promotions, or other marketing that we think you’ll find relevant.
Hosting Platforms	Usage Data	Hosting platforms host podcasts so that they can deliver them to you. We share certain data, such as your IP address, with the hosting platforms when you play a podcast. We also allow you to stream podcasts available from other hosting platforms not owned by FineRadioCO. Podcast providers should explain in the show or episode description which platform is hosting the podcast. See the hosting platform’s own privacy policy for how they use data shared with them.
Academic researchers	User Data Usage Data	For activities such as statistical analysis and academic study, but only in a pseudonymised format.
Other FineRadioCO group companies, including companies that FineRadioCO acquires	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data	To carry out our daily business operations and so we can maintain, improve and provide the FineRadioCO Service and acquired companies’ services to you. For example: enabling our employees who work for different group companies to develop and improve features for the FineRadioCO Service sharing data with our measurement companies to measure the effectiveness of ad campaigns that run on the FineRadioCO Service sharing data with our podcast companies to better understand user listening trends
Law enforcement and other authorities, or other parties to litigation	User Data Usage Data	When we believe in good faith it’s necessary for us to do so, for example: to comply with a legal obligation to respond to a valid legal process (such as a search warrant, court order, or subpoena) for our own or a third party’s justifiable interest, relating to: national security law enforcement litigation (a court case) criminal investigation protecting someone’s safety preventing death or imminent bodily harm
Purchasers of our business	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data	If we were to sell or negotiate to sell our business to a buyer or possible buyer. In this case, we may transfer your personal data to a successor or affiliate as part of that transaction.

6. Data retention

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

• maintaining the performance of the FineRadioCO Service
• making data-driven business decisions about new features and offerings
• complying with our legal obligations
• resolving disputes

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

• 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 FineRadioCO 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.
• 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.
• Data retained until your FineRadioCO account is deleted
  We keep some data until your FineRadioCO account is deleted. Examples of this include your FineRadioCO 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 FineRadioCO account is deleted, this category of data is deleted or de-identified.
• 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 FineRadioCO Service for a limited period of time. This could be:
  • to help ensure user safety, or
  • 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, FineRadioCO shares personal data internationally with FineRadioCO group companies, subcontractors and partners in order to provide the FineRadioCO Service to you. 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 use tools to:

• make sure the data transfer complies with applicable law
• 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:

• 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.
• 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:

• technical protections, such as encryption and pseudonymisation
• 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:

• use a strong password which you only use for your FineRadioCO account
• never share your password with anyone
• limit access to your computer and browser
• log out once you have finished using the FineRadioCO Service on a shared device
• read more detail on protecting your account

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

If other individuals have access to your FineRadioCO account, then they can access personal data, controls and the FineRadioCO 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 FineRadioCO account may impact your personalised recommendations and be included in your data download.

9. Children

Note: This Policy doesn’t apply to FineRadioCO Kids unless the FineRadioCO Kids Privacy Policy says so. FineRadioCO Kids is a separate FineRadioCO application.

The FineRadioCO Service has a minimum ‘Age Limit’ in each country or region. The FineRadioCO Service is not directed to children whose age:

• is under the age of 13 years
• makes it illegal to process their personal data, or
• requires parental consent to process their personal data

We do not knowingly collect or use personal data from children under the applicable Age Limit. If you’re under the Age Limit, do not use the FineRadioCO Service, and do not provide any personal data to us. Instead, we recommend using a FineRadioCO Kids account.

If you’re a parent of a child under the Age Limit and become aware that your child has provided personal data to FineRadioCO, contact us.

If we learn that we’ve collected the personal data of a child under the applicable Age Limit, we’ll take reasonable steps to delete the personal data. This may require us to delete the FineRadioCO account for that child.

When using a shared device on the main FineRadioCO Service, be cautious about playing or recommending any inappropriate content to individuals under 18 years old.

10. 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 FineRadioCO Service 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:

• email privacy@spotify.com
• write to us at: FineRadioCO AB, Regeringsgatan 19, 111 53 Stockholm, Sweden

FineRadioCO AB is the data controller of personal data processed under this Policy.

© FineRadioCO AB

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FineRadioCO User Guidelines

Hello! Welcome to the FineRadioCO User Guidelines (“User Guidelines“) which apply when using FineRadioCO’s websites, applications and services that reference these User Guidelines (the “Services“) including accessing any type of material or content made available through those Services (“Content“). These User Guidelines are designed to ensure the Services stay enjoyable for everyone. In addition to these User Guidelines, content must adhere to the FineRadioCO Platform Rules (“Platform Rules“).

We may update these User Guidelines and the Platform Rules from time to time – you can find the latest version on our website.

Violating the User Guidelines or Platform Rules may result in removal of any content or material you’ve contributed to the Services and/or termination or suspension of your account. We try to make the Services broadly available to everyone, but you cannot use our Services if we’ve previously terminated your account on any of our Services. We also prohibit attempts to circumvent prior enforcement actions, including through the creation of new accounts.

The following is not permitted for any reason whatsoever in relation to the Services and the material or content made available through the Services, or any part thereof:

1. reverse-engineering, decompiling, disassembling, modifying, or creating derivative works, except where such restriction is expressly prohibited by applicable law. If applicable law allows you to decompile any part of the Services or Content where required in order to obtain the information necessary to create an independent program that can be operated with the Services or with another program, the information you obtain from such activities (a) may only be used for the foregoing objective, (b) may not be disclosed or communicated without FineRadioCO’s prior written consent to any third party to whom it is not necessary to disclose or communicate in order to achieve that objective, and (c) may not be used to create any software or service that is substantially similar in its expression to any part of the Services or the Content;
2. copying, reproducing, redistributing, “ripping,” recording, transferring, performing, framing, linking to or displaying to the public, broadcasting, or making available to the public, or any other use which is not expressly permitted under the Agreements or applicable law, or which otherwise infringes intellectual property rights;
3. importing or copying any local files that you do not have the legal right to import or copy in this way;
4. transferring copies of cached Content from an authorized Device to any other Device via any means;
5. “crawling” or “scraping”, whether manually or by automated means, or otherwise using any automated means (including bots, scrapers, and spiders), to view, access or collect information, or using any part of the Services or Content to train a machine learning or AI model or otherwise ingesting FineRadioCO Content into a machine learning or AI model;
6. selling, renting, sublicensing, leasing or other monetization except as expressly permitted under the Agreements;
7. selling a user account or playlist, or otherwise accepting or offering to accept any compensation, financial or otherwise, to influence the name of an account or playlist or the content included on an account or playlist; or
8. artificially increasing play counts or follow counts, artificially promoting Content, or other manipulation including by (i) using any bot, script or other automated process, (ii) providing or accepting any form of compensation (financial or otherwise), or (iii) any other means;
9. circumventing any technology used by FineRadioCO, its licensors, or any third party, including any territorial or other content access restrictions applied by FineRadioCO or its licensors;
10. circumventing or blocking advertisements or creating or distributing tools designed to block advertisements;
11. removing or altering any copyright, trademark, or other intellectual property notices (including for the purpose of disguising or changing any indications of ownership or source);
12. deleting or altering any part of the Services or Content except as expressly permitted under the Agreements or, in the case of Content made available by another user, with such user’s express consent; or
13. providing your password to any other person or using any other person’s username and password.

Please respect FineRadioCO, the owners of the material and content on the Services, and other users of the Services. Don’t engage in any activity, post any User Content, or register or use a username, which is or includes material that:

1. is illegal, or intended to promote or commit an illegal act of any kind, including violations of intellectual property rights, privacy rights, publicity rights, or proprietary rights of FineRadioCO or a third party, or would violate any agreement to which you are a party, such as, by way of example and not limitation, an exclusive recording agreement or publishing agreement;
2. includes your password or purposely includes any other user’s password or purposely includes personal data of third parties or is intended to solicit such personal data;
3. exposes confidential or proprietary information of a third party or personal information about yourself that is not intended to be broadcast to people around the world;
4. includes malicious content such as malware, Trojan horses, or viruses, or otherwise interferes with any user’s access to the FineRadioCO Service;
5. impersonates or misrepresents your affiliation with FineRadioCO (including, for instance, by using FineRadioCO’s copyrighted content, using the FineRadioCO logo without permission, or otherwise using FineRadioCO trademarks in a confusing manner), another user, person, or entity, or is otherwise fraudulent, false, deceptive, or misleading;
6. involves the transmission of unsolicited mass mailings or other forms of spam, junk mail, chain letters, or similar;
7. unauthorized commercial or sales activities, such as advertising, promotions, contests, sweepstakes, gambling, bookmaking, or pyramid schemes;
8. unauthorized linking to, referencing, or otherwise promoting commercial products or services, except as expressly authorized by FineRadioCO;
9. interferes with or in any way disrupts the FineRadioCO Service, tampers with, breaches, or attempts to probe, scan, or test for vulnerabilities in the FineRadioCO Service or FineRadioCO’s computer systems, network, usage rules, or any of FineRadioCO’s security components, authentication measures or any other protection measures applicable to the FineRadioCO Service, the Content or any part thereof;
10. conflicts with the FineRadioCO Terms and Conditions of Use or any other terms or policies applicable to your use of any of the Services; or
11. has been removed from any of our services for a breach of our terms or policies, such as a prohibited track, episode or show. This includes content being created or repurposed to reconstitute or serve the same objective as previously removed Content.

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FineRadioCO Platform Rules

FineRadioCO’s mission is to unlock the potential of human creativity – by giving a million creative artists the opportunity to live off their art and billions of fans the opportunity to enjoy and be inspired by it. We believe achieving this mission on our platform is made possible by welcoming different forms of artistic expression, ideas, perspectives, and voices. This may mean that some content on our platform may not be to each individual’s liking or is content that FineRadioCO endorses.

However, that doesn’t mean that anything goes on our platform. In addition to the terms that you agreed to governing your use of our services, these rules help ensure that everyone has a safe and enjoyable experience.

What are the rules?

Whether you are a musician, podcaster, or other contributor, it is important to be aware of what is not allowed on our platform. The examples in the below sections are for illustrative purposes and are not exhaustive.

Dangerous Content

FineRadioCO is home to communities where people can create, express themselves, listen, share, learn, and be inspired. Don’t promote violence, incite hatred, harass, bully, or engage in any other behavior that may place people at risk of serious physical harm or death. What to avoid:

Content that advocates or glorifies serious physical harm towards an individual or group includes, but may not be limited to:

• encouraging, promoting, or glorifying suicide and self-harm (if you or someone you know is struggling or thinking about self-harm, please see here for ways to get help)
• inciting or threatening serious physical harm or acts of violence against a specific target or specific group

Content that promotes or supports terrorism or violent extremism includes, but may not be limited to:

• glorifying or praising violent extremist groups or their members
• coordinating, promoting, threatening, or praising an act of violence by or on behalf of violent extremist groups or their members
• providing instructions or instructional materials to commit an act of violent extremism
• soliciting an individual or group to finance, undertake an act of violent extremism, or become involved in the activities of a violent extremist group

Content that targets an individual or identifiable group for harassment or related abuse includes, but may not be limited to:

• repeatedly targeting specific individuals with sexual advances
• repeatedly targeting a minor to shame or intimidate
• sharing or re-sharing non-consensual intimate content, as well as threats to distribute or expose such content
• sharing, threatening to share, or encouraging others to share someone’s private information, including credit card or banking information, National Identity numbers, etc.

Content that incites violence or hatred towards a person or group of people based on race, religion, gender identity or expression, sex, ethnicity, nationality, sexual orientation, veteran status, age, disability or other characteristics associated with systemic discrimination or marginalization includes, but may not be limited to:

• praising, supporting, or calling for violence against a person or group of people based on the characteristics listed above
• dehumanizing statements about a person or group based on the protected characteristics listed above
• promoting or glorifying hate groups and their associated images, and/or symbols

Content that promotes dangerous false or dangerous deceptive medical information that may cause offline harm or poses a direct threat to public health includes, but may not be limited to:

• asserting that AIDS, COVID-19, cancer or other serious life threatening diseases are a hoax or not real
• encouraging the consumption of bleach products to cure various illnesses and diseases
• promoting or suggesting that vaccines approved by local health authorities are designed to cause death
• encouraging people to purposely get infected with COVID-19 in order to build immunity to it (e.g. promoting or hosting “coronavirus parties”)

Content that illicitly promotes the sale of regulated or illegal goods includes, but may not be limited to:

• selling illegal firearms or firearm parts
• selling illegal drugs
• selling endangered species or products derived from endangered species

Content that promotes, solicits, or facilitates child sexual abuse or exploitation includes, but may not be limited to:

• visual depictions of a minor engaged in a sexual act or lascivious depictions of a nude minor
• promoting acts of sexual abuse against a child in exchange for money
• encouraging or promoting sexual attraction by adults towards minors
• promoting, normalizing, or glorifying child grooming behaviors

Deceptive Content

Creating great experiences on FineRadioCO requires trust that people are who they say they are, that they won’t be scammed, and that no one is trying to manipulate our platform. Don’t use malicious practices to deceive others. What to avoid:

Content that impersonates others in order to deceive includes, but may not be limited to:

• replicating the same name, image, and/or description as another existing creator
• posing as another person, brand, or organization in a misleading manner

Content that promotes manipulated and synthetic media as authentic in ways that pose the risk of harm includes, but may not be limited to:

• audio or video recording that comes from a real and valid source that has been altered in a way that changes the meaning or context of the original media and is purported to be true, thus posing a risk of harm to the speaker or other individuals
• audio or visual media artificially created through the use of technology that’s purported to be true, such as digitally manufactured sexual audio and video content or content falsely suggesting that someone committed a crime

Content that attempts to manipulate or interfere with election-related processes includes, but may not be limited to:

• misrepresentation of procedures in a civic process that could discourage or prevent participation
• misleading content promoted to intimidate or suppress voters from participating in an election

Content that attempts to take advantage of the FineRadioCO community includes, but may not be limited to:

• posting, sharing, or providing instructions on implementing malware or related malicious practices that seek to harm or gain unauthorized access to computers, networks, systems, or other technologies
• phishing or related attempts to deceptively solicit or collect sensitive information
• promoting investment and financial scams like get rich quick and pyramid schemes, or otherwise encouraging others to part with money under false pretenses

Sensitive Content

We have tons of amazing content on FineRadioCO, but there are certain things that we don’t allow on our platform. Don’t post excessively violent or graphic content, and don’t post sexually explicit content. What to avoid:

Content that promotes graphic or gratuitous depictions of violence, gore, or other shocking imagery includes, but may not be limited to:

• severely mutilated or dismembered bodies
• promoting animal cruelty or torture

Content that contains sexually explicit material includes, but may not be limited to:

• pornography or visual depictions of genitalia or nudity presented for the purpose of sexual gratification
• advocating or glorifying sexual themes related to rape, incest, or beastiality

Illegal Content

The law is the law. No matter who you are, it is your responsibility to comply with applicable laws and regulations. What to avoid:

Content that violates applicable laws and regulations includes, but may not be limited to:

• content that does not comply with applicable sanctions and export regulations
• content that is intended to promote or commit an illegal act of any kind

Content that infringes the intellectual property rights of others includes, but may not be limited to:

• content provided to FineRadioCO without obtaining necessary permissions
• content that infringes third-party copyrights or trademarks

How does FineRadioCO enforce these rules?

FineRadioCO seeks to enforce these rules consistently and at scale across the world using a combination of technology and human review. In addition to user reports, we leverage automated tools that rely on a combination of signals to detect content that may violate our Platform Rules.

We have global teams of experts who develop, maintain and enforce our Platform Rules. When potentially violating content is reported or detected, our teams will work to take the appropriate enforcement action.

What happens when the rules are broken?

We take these decisions seriously and keep context in mind when assessing possible Platform Rules violations. Breaking the rules may result in the violative content being removed from FineRadioCO. Repeated or egregious violations may result in accounts being suspended and/or terminated. Learn more about other actions we may take on content or accounts here.

What else do I need to know?

These Platform Rules will help ensure that FineRadioCO remains an open and safe platform for all. We will continue to evaluate and update this information as needed, so please check back frequently. Depending on which FineRadioCO products or features you use, you may be subject to additional requirements.

How can I report an issue?

Have you found an issue with a piece of content on FineRadioCO? If so please let us know by reporting it here.

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FineRadioCO Privacy Policy

Effective as of 10 October 2024

1. About this Policy
2. Your personal data rights and controls
3. Personal data we collect about you
4. Our purpose for using your personal data
5. Sharing your personal data
6. Data retention
7. Transfer to other countries
8. Keeping your personal data safe
9. Children
10. Changes to this Policy
11. How to contact us

1. About this Policy

This Privacy Policy describes how we process your personal data at FineRadioCO AB. From now on, we’ll call it the ‘Policy’.

It applies to your use of:

• all FineRadioCO streaming services as a user. For example this includes:
  • your use of FineRadioCO on any device
  • the personalisation of your user experience. Watch our personalisation explainer video to learn more about this
  • the infrastructure required to provide our services
  • connection of your FineRadioCO account with another application
  • both our free or paid streaming options (each a ‘Service Option‘)
• other FineRadioCO services which include a link to this Policy. These include FineRadioCO websites, Customer Service and the Community Site

From now on, we’ll collectively call these the ‘FineRadioCO 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…

• the FineRadioCO Terms of Use, which is a separate document. The Terms of Use outline the legal contract between you and FineRadioCO for using the FineRadioCO Service. It also describes the rules of FineRadioCO and your user rights
• about your use of other FineRadioCO services which have their own privacy policy. Other FineRadioCO services include Anchor, Soundtrap, Megaphone and the FineRadioCO Live app

Other resources and settings

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

• Privacy Center: A user-friendly hub with summaries of key topics and helpful 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.
• Account Privacy: Control the processing of certain personal data, including tailored advertising.
• Notification Settings: Set which marketing communications you get from FineRadioCO.
• Settings (found in the Desktop and Mobile versions of FineRadioCO): Control certain aspects of the FineRadioCO Service such as ‘Social’ or ‘Explicit Content’. On the ‘Social’ setting, you can:
  • start a Private session
  • choose whether to share what you listen to on FineRadioCO with your followers
  • choose whether to show your recently played artists on your public profile

On the ‘Explicit Content’ setting you can control whether explicit-rated content can be played on your FineRadioCO account.

• 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

Many 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 FineRadioCO uses a certain ‘legal basis’ to process your data. We explain each legal basis, and when FineRadioCO uses each one, in Section 4 ‘Our purpose for using your personal data’.

The table below explains:

• your rights
• circumstances when they apply (such as the legal basis required)
• how to use them

You can also watch our video about Your Privacy Controls.

It’s your right to…		How?
Be informed	Be informed of the personal data we process about you and how we process it.	We inform you: through this Policy through information provided to you as you use the FineRadioCO Service by answering your specific questions and requests when you contact us
Access	Request access to the personal data we process about you.	To request a copy of your personal data from FineRadioCO, either: use the “Download your data” tool on your Account Privacy page, or contact us When you download your data you will receive the information about your data that FineRadioCO has to provide under Article 15 of the GDPR. If you would like more information about how we process your personal data, you can contact us.
Rectification	Request that we amend or update your personal data where it’s inaccurate or incomplete.	You can edit your User Data under ‘Edit profile’ in your account or by contacting us.
Erasure	Request that we erase certain of your personal data. For example, you can ask us to erase personal data: that we no longer need for the purpose it was collected for that we process based on the legal basis of consent, and you withdraw your consent when you object (see section ‘Object’ below) and you make a justified objection, or you object to direct marketing There are situations where FineRadioCO is unable to delete your data, for example when: it’s still necessary to process the data for the purpose we collected it for FineRadioCO’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 FineRadioCO has a legal obligation to keep the data, or FineRadioCO needs the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account	There are several ways you can erase personal data from FineRadioCO: to remove audio content from your profile select the relevant content and choose to remove it. For example, you can remove playlists from your profile, or remove a track from your playlist to request erasure of your other personal data from FineRadioCO, follow the steps on our support page. This data includes your User Data, Usage Data and other data listed in Section 3 ‘Personal data we collect about you’ you can also contact us to request erasure
Restriction	Request that we stop processing all or some of your personal data. You can do this if: your personal data is inaccurate our processing is unlawful we do not need your information for a specific purpose, or you object to our processing and we are assessing your objection request. See section ‘Object’ below You can request that we stop this processing temporarily or permanently.	You can exercise your right to restriction by contacting us.
Object	Object to us processing your personal data. You can do this if: FineRadioCO is processing your personal data on the legal basis of legitimate interests, or FineRadioCO is processing your personal data for tailored advertising	To exercise your right to object, you can: use controls on the FineRadioCO Service to switch off or adjust some features which process your personal data. See the end of this section on how you can control tailored advertising contact us
Data portability	Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service. You can request us to transmit your data when we are processing your personal data on the legal bases of consent or performance of contract. However FineRadioCO will try to honour any request to the extent possible.	For information about how to exercise the right to portability, see ‘Access’ above.
Not be subject to automated decision making	Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.	FineRadioCO does not carry out this type of automated decision making in the FineRadioCO Service.
Withdrawal of consent	Withdraw your consent to us collecting or using your personal data. You can do this if FineRadioCO is processing your personal data on the legal basis of consent.	To withdraw your consent, you can: adjust the relevant control on FineRadioCO contact us
Right to lodge a complaint	Contact the Swedish Authority for Privacy Protection or your local data protection authority about any questions or concerns.	You can find the Swedish Authority’s details here. You can also go to the website of your local data protection authority.

Tailored advertising controls

What is tailored advertising?

• 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.
• 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:

• You can control tailored advertising on your account Account Privacy page under ‘Tailored Ads’.
• 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 FineRadioCO, manages these controls for the podcast.

If you are ‘opted out’ of Tailored Ads on your Account Privacy page, 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.

3. Personal data we collect about you

These tables set out the categories of personal data we collect from you. You can also watch our video about Personal Data at FineRadioCO.

Collected when you sign up for the FineRadioCO Service or when you update your account
Category	Description
User Data	Personal data that we need to create your FineRadioCO account and that enables you to use the FineRadioCO Service. The type of data collected and used depends on the type of Service Option you have. It also depends on how you create your account, the country you are in, and if you use third party services to sign in. This may include your: profile name email address password phone number date of birth gender street address (see further details below) country university/college (for FineRadioCO Premium Student) We receive some of this data from you e.g. from the sign up form or account page. We also collect some of this data from your device e.g. country or region. For more information about how we collect and use this data, see ‘Your general (non-precise) location’ in the Usage Data category.
Street Address Data	We may ask for and process your street address for the following reasons: to check eligibility for a Service Option to deliver notices which are required by law to deliver support options for billing and tax administration to deliver physical goods or gifts which you have requested In some cases, we may use a third party application to help you verify your address, such as Google Maps.

 

Collected through your use of the FineRadioCO Service
Categories	Description
Usage Data	Personal data collected and processed about you when you’re accessing or using the FineRadioCO Service. There are a few types of information this includes, listed in the following sections. Information about how you use FineRadioCO Examples include: information about your FineRadioCO Service Option your actions with the FineRadioCO Service (including date and time), such as: search queries streaming history playlists you create your library browsing history account settings interactions with other FineRadioCO users your use of third party services, devices and applications in connection with the FineRadioCO Service inferences (i.e., our understanding) of your interests and preferences based on your usage of the FineRadioCO Service content you provide when participating in FineRadioCO promotions, such as contests or sweepstakes content you post to any part of the FineRadioCO Service. For example: images, audio, text, titles, descriptions, communications, and other types of content Your technical data Examples include: URL information online identifiers such as cookie data and IP addresses information about the devices you use such as: device IDs network connection type (e.g. wifi, 4G, LTE, Bluetooth) provider network and device performance browser type language information enabling digital rights management operating system FineRadioCO application version information which enables us to discover and connect with third party devices and applications. Examples of this information are the device name, device identifiers, brand and version. Examples of third party devices and applications are: devices on your wifi network (such as speakers) which can connect to the FineRadioCO Service devices your operating system makes available when connecting via Bluetooth, plugin, and installation FineRadioCO partner applications to determine whether the application is installed on your device Your general (non-precise) location Your general location includes country, region or state. We may learn this from technical data (e.g. your IP address, language setting of your device) or payment currency. We need this to: meet geographic requirements in our agreements with the owners of content on the FineRadioCO Service deliver content and advertising that’s relevant to you Your device sensor data Motion-generated or orientation-generated device sensor data if needed to provide features of the FineRadioCO Service that require this data. This is data which your device collects about the way you move or hold your device.

 

Additional data you may choose to give us
Categories	Description
Voice Data	If voice features are available in your market and where you’ve chosen to use a voice feature, we collect and process voice data. Voice data means audio recordings of your voice and transcripts of those recordings. For more information on how different voice features work, and how you can control and turn them off, see our Voice Control Policy.
Payment and Purchase Data	If you make any purchases from FineRadioCO or sign up for a paid Service Option or a trial, we will need to process your payment data. The exact personal data collected and used will vary depending on the payment method. It will include information such as: name date of birth payment method type (e.g. credit or debit card) if using a debit or credit card, the card type, expiration date, and certain digits of your card number Note: For security, we never store your full card number ZIP/postal code mobile phone number details of your purchase and payment history
Survey and Research Data	When you respond to a survey or take part in user research, we collect and use the personal data you provide.

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

Third party sources that we receive your data from
Categories of third parties	Description	Data categories
Authentication partners	If you register for or log into the FineRadioCO Service using another service, that service will send your information to us. This information helps create your account with us.	User Data
Third party applications, services and devices you connect to your FineRadioCO account	If you connect your FineRadioCO account to a third party application, service or device, we may collect and use information from them. This collection is to make the integration possible. These third party apps, services or devices may include: social media devices including: audio (e.g. speakers and headphones) smart watches televisions mobile phones and tablets automotive (e.g. cars) games consoles services or platforms such as voice assistants or content platforms We’ll ask your permission before we collect your information from certain third parties.	User Data Usage Data
Technical service partners	We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g., country or region, city, state). This makes it possible for FineRadioCO to provide the FineRadioCO Service, content, and features. We also work with security service providers who help us protect user accounts.	User Data Usage Data
Payment partners and Merchants	If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners. This allows us to: send you invoices process your payment give you what you’ve purchased If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to an artist’s merchandise store on a third party platform or to a third party ticketing website. Receiving this data allows us to: calculate any commissions owed to us analyse the effectiveness of our partnership with these merchant partners understand your interests	Payment and Purchase Data
Advertising and marketing partners	We receive inferences from certain advertising or marketing partners. These inferences are the partners’ understanding of your interests and preferences. This allows us to deliver more relevant ads and marketing.	Usage Data
Acquired companies	We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.	User Data Usage Data

If you download the FineRadioCO mobile app and try FineRadioCO using a logged out user experience, we will collect limited information about your usage of the FineRadioCO 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 FineRadioCO account to experience our service in full, then we will combine this data with your FineRadioCO account data.

4. Our purpose for using your personal data

The table below sets out:

• our purpose for processing your personal data
• our legal justifications (each called a ‘legal basis‘) under data protection law, for each purpose
• 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 FineRadioCO.

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

• Performance of a Contract: When it’s necessary for FineRadioCO (or a third party) to process your personal data to:
  • comply with obligations under a contract with you. This includes FineRadioCO’s obligations under the Terms of Use to provide the FineRadioCO Service to you, or
  • verify information before a new contract with you begins.
• Legitimate Interest: When FineRadioCO 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 FineRadioCO users. For example, using your Usage Data to improve the FineRadioCO Service for all users. Contact us if you want to understand a specific justification.
• Consent: When FineRadioCO asks you to actively indicate your agreement to FineRadioCO’s use of your personal data for a certain purpose.
• Compliance with Legal Obligations: When FineRadioCO must process your personal data to comply with a law.

Purpose for processing your data	Legal basis that permits the purpose	Categories of personal data used for the purpose
To provide the FineRadioCO Service in accordance with our contract with you. For example, when we use your personal data to: set up an account for you personalise your account, or provide the FineRadioCO app when you download it onto your device	Performance of a Contract	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data
To provide further parts of the FineRadioCO Service. For example, when we use your personal data to enable you to share a link to FineRadioCO content with someone else.	Legitimate Interest Our legitimate interests here include: keeping the FineRadioCO Service running and functional allowing users to access and use the FineRadioCO Service	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data
To provide certain additional voluntary features of the FineRadioCO Service. When this is the case, we will clearly ask for your consent.	Consent	User Data Usage Data Survey and Research Data Payment and Purchase Data
To diagnose, troubleshoot, and fix issues with the FineRadioCO Service.	Performance of a Contract	User Data Usage Data
To evaluate and develop new features, technologies, and improvements to the FineRadioCO Service. For example: we use personal data to develop and improve our personalised recommendation algorithms we analyse how our users react to a particular new feature and see whether we should make any changes	Legitimate Interest Our legitimate interests here include developing and improving products and features for our users.	User Data Usage Data Voice Data Survey and Research Data
For marketing or advertising where the law requires us to collect your consent. For example, when we use cookies to understand your interests or the law requires consent for email marketing.	Consent	User Data Usage Data Survey and Research Data
For other marketing, promotion and advertising purposes where the law does not require consent. For example, when we use your personal data to tailor advertising to your interests.	Legitimate Interest Our legitimate interests here include using advertising to fund the FineRadioCO Service, so that we can offer much of it for free.	User Data Usage Data Survey and Research Data
To comply with a legal obligation that we are subject to. This might be: an obligation under the law of the country / region you are in Swedish law (because of our headquarters in Sweden), or EU law that applies to us For example, when we use your date of birth when required for age verification purposes.	Compliance with legal obligations	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data
To comply with a request from law enforcement, courts, or other competent authorities.	Compliance with legal obligations, and legitimate interest Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data
To fulfil contractual obligations with third parties. For example, when we provide pseudonymised data about our users’ listening because we have an agreement with a FineRadioCO rightsholder to do so. Pseudonymised data means that your data is identified by a code rather than your name or other directly identifying information.	Legitimate Interest Our legitimate interests here include: maintaining our relationships with artists so that we can provide the FineRadioCO Service maintaining our relationships with other third parties for the same reason	User Data Usage Data Voice Data Payment and Purchase Data
To take appropriate action with reports of intellectual property infringement and inappropriate content.	Legitimate Interest Our legitimate interests here include protecting intellectual property and original content.	User Data Usage Data Voice Data Payment and Purchase Data
To establish, exercise, or defend legal claims. For example, if we are involved in litigation and we need to provide information to our lawyers in relation to that legal case.	Legitimate Interest Our legitimate interests here include: seeking legal advice protecting ourselves, our users or others in legal proceedings	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data
To conduct business planning, reporting, and forecasting. For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in.	Legitimate Interest Our legitimate interests here include researching and planning so that we can keep running our business successfully.	User Data Usage Data Payment and Purchase Data
To process your payment. For example, when we use your personal data to let you purchase a FineRadioCO subscription.	Performance of a Contract, and consent	User Data Payment and Purchase Data Street Address Data
To keep the FineRadioCO Service secure and to detect and prevent fraud. For example, when we analyse Usage Data to check for fraudulent use of the FineRadioCO Service.	Legitimate Interest Our legitimate interests here include protecting the FineRadioCO Service and our users against fraud and other illegal activity.	User Data Street Address Data Usage Data Payment and Purchase Data
To conduct research and surveys. For example, when we contact our users to ask for your feedback.	Legitimate Interest Our legitimate interests here include to understand more about how users think about and use the FineRadioCO Service.	User Data Usage Data Voice Data Survey and Research Data

In jurisdictions where legitimate interest is not recognised as a legal basis, we rely on contractual necessity or consent.

5. Sharing your personal data

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

Publicly available information

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

• your profile name
• your profile photo
• your public playlists
• other content you post on the FineRadioCO Service, and any associated titles, descriptions and images
• who you follow on the FineRadioCO Service
• who follows you on the FineRadioCO Service

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

• your profile
• any content you post on FineRadioCO and details about that content
• your playlists and any associated titles, descriptions and images

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:

• where you have chosen to use a FineRadioCO Service feature, or a third party application, service or device, and we need to share personal data to enable this, or
• 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 FineRadioCO Service or by giving your consent

Categories of recipients	Categories of data you can choose to share	Reason for sharing
Third party applications, services and devices you connect to your FineRadioCO account	User Data Usage Data	To connect your FineRadioCO account, or so that you can use the FineRadioCO Service in connection with third party applications, services or devices. Examples of such third party applications, services and devices include: social media applications speaker devices televisions automotive platforms voice assistants You can see and remove many third party connections under ‘Apps’ in your account.
Support community	User Data	To enable you to use the FineRadioCO Support Community service. When you register for an account on the FineRadioCO Support Community, we’ll ask you to create a profile name. This will be publicly displayed to anyone who uses the FineRadioCO Support Community. We’ll also display any questions or comments you post.
Other FineRadioCO users	User Data Usage Data Voice Data	To share information about your use of the FineRadioCO Service with other FineRadioCO users. These could include your followers on FineRadioCO. For example, under ‘Social’ settings you can choose to share your recently played artists and your playlists on your profile. You can also choose to create or join a shared playlist with other users. Shared playlists give you social recommendations based on your listening activity.
Artists and record labels	User Data	To receive news or promotional offers from artists, record labels or other partners. You may choose to share your User Data for this purpose. You’ll always have the option to change your mind and withdraw your consent at any time.

Information we may share

See this table for details of who we share to and why.

Categories of recipients	Categories of data	Reason for sharing
Service providers	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data	So they can provide their services to FineRadioCO. These service providers include those we hire to: give customer support operate the technical infrastructure we need to provide the FineRadioCO Service assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA) help market FineRadioCO’s (and our partners’) products, services, events and promotions
Payment partners	User Data Payment and Purchase Data	So they can process your payments, and for anti-fraud purposes.
Advertising partners	User Data Usage Data	So they can help us deliver more relevant advertising to you on the FineRadioCO Service, and help measure the effectiveness of ads. For example, our ad partners help us facilitate tailored advertising.
Marketing Partners	User Data Usage Data	To promote FineRadioCO with our partners. We share certain User Data and Usage Data with these partners where necessary to: enable you to participate in FineRadioCO promotions, including trials or other bundled offers to promote FineRadioCO in media and advertising published on other online services help us and our partners to measure the effectiveness of FineRadioCO promotions Examples of partners include: marketing or sponsorship partners websites and mobile apps who sell us advertising space on their services device, app and mobile partners who also offer FineRadioCO promotions Our partners may also combine the personal data we share with them with other data they collect about you, e.g. your use of their services. We and our partners may use this information to present you with offers, promotions, or other marketing that we think you’ll find relevant.
Hosting Platforms	Usage Data	Hosting platforms host podcasts so that they can deliver them to you. We share certain data, such as your IP address, with the hosting platforms when you play a podcast. We also allow you to stream podcasts available from other hosting platforms not owned by FineRadioCO. Podcast providers should explain in the show or episode description which platform is hosting the podcast. See the hosting platform’s own privacy policy for how they use data shared with them.
Academic researchers	User Data Usage Data	For activities such as statistical analysis and academic study, but only in a pseudonymised format.
Other FineRadioCO group companies, including companies that FineRadioCO acquires	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data	To carry out our daily business operations and so we can maintain, improve and provide the FineRadioCO Service and acquired companies’ services to you. For example: enabling our employees who work for different group companies to develop and improve features for the FineRadioCO Service sharing data with our measurement companies to measure the effectiveness of ad campaigns that run on the FineRadioCO Service sharing data with our podcast companies to better understand user listening trends
Law enforcement and other authorities, or other parties to litigation	User Data Usage Data	When we believe in good faith it’s necessary for us to do so, for example: to comply with a legal obligation to respond to a valid legal process (such as a search warrant, court order, or subpoena) for our own or a third party’s justifiable interest, relating to: national security law enforcement litigation (a court case) criminal investigation protecting someone’s safety preventing death or imminent bodily harm
Purchasers of our business	User Data Street Address Data Usage Data Voice Data Payment and Purchase Data Survey and Research Data	If we were to sell or negotiate to sell our business to a buyer or possible buyer. In this case, we may transfer your personal data to a successor or affiliate as part of that transaction.

6. Data retention

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

• maintaining the performance of the FineRadioCO Service
• making data-driven business decisions about new features and offerings
• complying with our legal obligations
• resolving disputes

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

• 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 FineRadioCO 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.
• 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.
• Data retained until your FineRadioCO account is deleted
  We keep some data until your FineRadioCO account is deleted. Examples of this include your FineRadioCO 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 FineRadioCO account is deleted, this category of data is deleted or de-identified.
• 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 FineRadioCO Service for a limited period of time. This could be:
  • to help ensure user safety, or
  • 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, FineRadioCO shares personal data internationally with FineRadioCO group companies, subcontractors and partners in order to provide the FineRadioCO Service to you. 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 use tools to:

• make sure the data transfer complies with applicable law
• 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:

• 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.
• 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:

• technical protections, such as encryption and pseudonymisation
• 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:

• use a strong password which you only use for your FineRadioCO account
• never share your password with anyone
• limit access to your computer and browser
• log out once you have finished using the FineRadioCO Service on a shared device
• read more detail on protecting your account

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

If other individuals have access to your FineRadioCO account, then they can access personal data, controls and the FineRadioCO 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 FineRadioCO account may impact your personalised recommendations and be included in your data download.

9. Children

Note: This Policy doesn’t apply to FineRadioCO Kids unless the FineRadioCO Kids Privacy Policy says so. FineRadioCO Kids is a separate FineRadioCO application.

The FineRadioCO Service has a minimum ‘Age Limit’ in each country or region. The FineRadioCO Service is not directed to children whose age:

• is under the age of 13 years
• makes it illegal to process their personal data, or
• requires parental consent to process their personal data

We do not knowingly collect or use personal data from children under the applicable Age Limit. If you’re under the Age Limit, do not use the FineRadioCO Service, and do not provide any personal data to us. Instead, we recommend using a FineRadioCO Kids account.

If you’re a parent of a child under the Age Limit and become aware that your child has provided personal data to FineRadioCO, contact us.

If we learn that we’ve collected the personal data of a child under the applicable Age Limit, we’ll take reasonable steps to delete the personal data. This may require us to delete the FineRadioCO account for that child.

When using a shared device on the main FineRadioCO Service, be cautious about playing or recommending any inappropriate content to individuals under 18 years old.

10. 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 FineRadioCO Service 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:

• email privacy@spotify.com
• write to us at: FineRadioCO AB, Regeringsgatan 19, 111 53 Stockholm, Sweden

FineRadioCO AB is the data controller of personal data processed under this Policy.

© FineRadioCO AB