ADA PRIVACY POLICY

ADA PRIVACY POLICY FOR B2B PERSONAL INFORMATION

Last updated: December 2021

The Alternative Distribution Alliance ("ADA") takes your privacy seriously where we deal with your personal data. This means information that identifies you personally such as your name, contact details, job title, marketing preferences or data that can be linked with such information in order to identify you directly or indirectly ("Personal Information").

This Privacy Policy describes our practices in connection with Personal Information that we collect from you when you interact with us and engage in our services such as global music distribution, digital marketing, product management, radio licensing, sync licensing and other services ("ADA Services"). We may collect your Personal Information in person or via digital interactions, such as via email or through certain of our owned or controlled websites and web properties (e.g., widgets and applications).

This Privacy Policy applies to ADA as a whole and where there are local variations or additions concerning how we use your Personal Information collected from your home country, these are set out clearly in the Country Specific Schedules  section of this Privacy Policy. Please treat these schedules as a part of this Privacy Policy. If you are a California resident, please note that we have a separate California Privacy Policy which applies to the collection and use of your Personal Information along with this Privacy Policy and also addresses your privacy rights. Please see our California Privacy Policy.

Please note that our Platforms and ADA Services are not directed to individuals under the age of sixteen (16), and we request that such individuals do not provide Personal Information through the Platforms.

QUICK GUIDE TO CONTENTS

1CONTROLLERS OF YOUR PERSONAL INFORMATION

2HOW WE USE YOUR PERSONAL INFORMATION

3HOW WE SHARE YOUR PERSONAL INFORMATION

4DO WE TRANSFER YOUR PERSONAL INFORMATION?

5HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

6SENSITIVE PERSONAL INFORMATION

7YOUR PRIVACY RIGHTS

8UPDATES TO THIS PRIVACY POLICY

9CONTACTING US

10COUNTRY SPECIFIC SCHEDULES

11CALIFORNIA PRIVACY POLICY

1. CONTROLLERS OF YOUR PERSONAL INFORMATION
1. The Alternative Distribution Alliance, a New York Corporation with its principal place of business at 1633 Broadway New York, New York 10019, USA will be responsible as Controllers of the Personal Information we collect from you when using ADA Services
2. If you have any questions about how ADA uses and safeguards your personal information, please email us at privacypolicy@wmg.com. If more convenient, you can also write to us at Warner Music UK Limited, Legal Department, The Warner Building, 27 Wrights Lane, London, W8 5SW, UK.

2. HOW WE USE YOUR PERSONAL INFORMATION

3. We use your Personal Information for various purposes (reasons) and our lawful bases (justifications) for using your Personal Information is either "where we have a legal obligation"; have entered into a contract with you to provide you or your organisation with ADA Services; where you have given us your consent"; or "where it is necessary for our legitimate interests" (this means that we have a business or commercial interest in using your Personal Information).

   The tables below set out clearly how we collect and use your Personal Information and the lawful bases (reason) we rely on for using your Personal Information. Where we have said that using or keeping your information is “necessary for our legitimate interests”, we have carried out an assessment to ensure this is not unfair to you. Please note that each heading in the “How we use your information and our lawful bases” column of the table below refers to the different lawful basis we rely on for using your Personal Information.

   Please bear in mind that if you choose not to provide information requested by us, or if you object to our use of your Personal Information where we have made it clear that this information is mandatory, we may not be able to provide you with the services you have requested or otherwise fulfil the purpose(s) for which we have asked for your Personal Information.

    

4. To Provide a Requested Service or To Carry Out a Contract with you

5. Information we collect

   How we use your information

   Account Creation and Use, and Enquiries We may collect the following Personal Information, supplied by you when you enter into a contract with us or ADA for ADA services, when you use our website and login to your account: Name Email address Job title Login details An alternate security contact in the form of a cellular telephone number or additional email address. Internet Protocol (IP) address (your IP address is a number that is automatically assigned to your device from which you are accessing our website by your internet service provider). Your IP address is identified and logged automatically in our server log files whenever you visit our website. Certain information collected by most browsers, such as your Media Access Control (MAC) address which is a unique device identifier, device type (Windows or Macintosh), screen resolution, operating system version and Internet browser type and version. A MAC address may be assigned by Warner Music Group or our service providers to the device from which you are accessing our website. We may also collect the following Personal Information from other sources which you have provided to us or authorised to be provided to us. This Personal Information includes: Information about your contract with us including the payment terms you have agreed. Details concerning your account statements, balances, and additional related financial details. Any information provided to us by email or other means outside of the use of our website (for example, customer support enquiries).

   Necessary to Comply with a Legal Obligation or to provide ADA Services pursuant to your Contract with us To provide access to account statements and other materials or information to you. To respond to your inquiries and fulfil your requests related to your contract with us. To send to you information about ADA Services. To send to you administrative information, including information regarding your account and changes to our terms, conditions and policies. To provide and administer your account for your benefit and convenience. To keep your account information as secure as we are reasonably able. To manage our relationship with you which will include delivering customer services and support to you.

 

6. Direct Marketing

7. Information we collect

   How we use your information

   Direct Marketing You give us Personal Information about you when sign up/agree to receive marketing communications and related information about ADA Services directly from us. This is generally information including your name, email address, job title and organisation, telephone number and country/city, and gender where you provide us with these additional details.

   With your consent To send you marketing communications via email or SMS where you have agreed to receive these communications. We will only do this in line with your marketing preferences and you can opt-out of receiving these communications at any time by selecting the unsubscribe link in any email we send, following the instructions in any SMS we send or by emailing us at privacypolicy@wmg.com.   Please note that, if you do opt-out from receiving marketing-related messages about ADA Services from us, we will continue to send administrative and service messages to you as necessary. These messages will not contain any marketing content.

 

8. General Enquiries and Engagement

9. Information we collect	How we use your information
   General and Account Enquiries You give us Personal Information about you when you contact us or otherwise interact with us generally, including via email, SMS, social media, online contact form, telephone call, SMS post or otherwise. This is generally information including your name, contact information, and details of your communication.	To provide you with ADA Services pursuant to your contract with us To respond to your inquiries and fulfil your requests, for example, when you send us questions, suggestions, compliments or complaints about ADA Services, or when you request information about our Platforms and other services. We may also take such into account when improving our Platforms, products and services.
   Client Surveys You give us Personal Information about you when you participate in and complete any of our surveys including client satisfaction surveys. This is generally information including your name, contact information, and your survey responses.	With your consent To register you for our surveys and to analyse the responses you have provided to our survey questions.

 

10. Automatically Collected Information

11. Information we collect	How we use your information
    Email Deliverability We collect certain Personal Information by automated means when we send you marketing emails in line with your marketing preferences. This is generally information including whether you have opened the email and what you have clicked on within the email. Please see our Cookies Policy for information on what Cookies (and other similar technologies) are and how we use them. You can find it at the bottom of our website pages, next to our Terms of Use.	With your consent To monitor the performance of the marketing emails we send to you. To tailor future marketing emails, we send to you based on your interactions with our previous emails.
    Accessing our online Platform  We collect certain Personal Information by automated means when you visit or interact with any of our online Platforms, including this website. This is generally information including: Browser and Device Details: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type (Windows or Mac), screen resolution, operating system version, Internet browser type and version of our Platform that you are using. Mobile App Details: When you download and use any of our Mobile Apps, we may track and collect Mobile App usage data, such as the date and time the Mobile App on your device accesses our servers and what information and files have been downloaded to the Mobile App based on your device number. IP Address: An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing a Platform by your Internet Service Provider (ISP), and is identified and logged automatically in our server log files whenever you visit the Platform, along with the time of the visit and the activity on the Platform.	It is necessary for our legitimate interests To calculate our Platform usage levels. To help diagnose server problems. To administer our Platforms. To determine your location at a country level.
    Cookies (and Similar Technologies) When you visit any of our online Platforms. we collect Personal Information about you through cookies and similar technologies placed on your device. The information collected may include a user ID assigned to you, your IP address, the content you have interacted with on our Platforms, duration of each visit to our Platforms, error messages encountered when using our Platforms and your interactions with social plug-ins (e.g. Facebook like or share button) on our Platforms. Please see our Cookies Policy for information on what Cookies (and other similar technologies) are and how we use them. You can find it at the bottom of our website pages, next to our Terms of Use.	Necessary for our legitimate interests To ensure our Platforms work as intended on your device and as necessary to provide the content or services you request on our Platforms. Necessary to comply with a legal obligation To ensure your use of our Platforms and any activities you carry out on our Platform is secure. To comply with applicable legislation with regards to Cookies and information collected from Cookies – for example, to remember your cookies settings. With your consent To target you with customised advertising online and on social media based on your online activity and use of our Platforms. To share your information with third party partners for the purposes of them sending you customised advertising content online and on social media. To share your information with third party social media platform partners where you interact with social plug-ins (e.g. Facebook like or share button) on our Platforms. To recognise you when you return to any of our Platforms and to customise your experience based on your previous visits. To carry out web analytics on our Platforms (e.g. to monitor the number of your visits to our Platforms and the actions you take on our Platforms for analytical purposes).

 

12. Internal Business Processes

13. Information we collect	How we use your information
    Aggregating Personal Information Our aggregating of Personal Information may apply to any of the above Personal Information we collect about you.	Necessary for our legitimate interests To aggregate any Personal Information we collect so that in its final aggregated form, it will no longer directly identify you or any other individual. For example, by using Personal Information collected from website visits to calculate the percentage of our users who like a particular Artist. We use the aggregated data generated for multiple purposes including: To develop new products and services. To enhance, improve, or modify our current products and services. To determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users. To operate and expand our business activities, for example, understanding which parts of our Platforms are of most interest to our users so we can focus resources and development efforts effectively.
    Audits (Internal and External) and Compliance Our audit and compliance process may apply to any of the above Personal Information we collect about you.	Necessary for our legitimate interests To verify that our internal processes function as intended. Necessary to comply with a legal obligation To verify that our internal processes are compliant with legal, regulatory or contractual requirements.
    Fraud and Security Our fraud and security monitoring process may apply to any of the above Personal Information we collect about you.	Necessary for our legitimate interests To carry out fraud and security monitoring within our business, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
    Administration Our administrative processes may apply to any of the above Personal Information we collect about you.	Necessary for our legitimate interests To operate efficiently within our business model and corporate structure, in a way that effectively services our customers, including by using a range of centralised and localised business functions.
    Legal claims Our legal claims process may apply to any of the above Personal Information we collect about you.	Necessary to comply with a legal obligation / Legitimate interests (depending on the situation) To effectively defend or bring claims to protect our legal rights and interests, and to respond to investigations from regulators or law enforcement.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

4. We share your Personal Information for the following purposes:

   • We share your Personal Information with affiliates for the purposes described in this Privacy Policy. You can consult the list and location of our affiliates here https://wminewmedia.com/affiliates/.
   • We share your Personal Information with companies who perform services on our behalf (and in some cases, our affiliates), to enable them to support the services we provide to you including those listed below. These can include consultants, providers of professional advisory services (such as lawyers and accountants), digital marketing agencies, service providers involved in hosting (cloud providers such as AWS and Microsoft Azure), marketing technology (such as for email campaign creation, email automation, managing opt-outs etc), data analysis (such as website traffic analytics), payment processing (such as PayPal), order fulfilment (such as shipping/delivery of customer orders), infrastructure provision (such as website and application development), auditing (external auditors such as KPMG and PWC), IT services, customer service, email delivery, credit card processing, and other similar services.
   • We share your Personal Information if we are under a duty to do so, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal or regulatory obligation, such as pursuant to court orders, enforcement action from regulators or law enforcement; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of the Warner Music Group, our affiliates, our artists, you, others third parties, users of our Platforms or the general public.
   • We share your Personal Information in connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
   • We share your Personal Information to enforce our terms and conditions or any other contracts we have with you and to allow us to pursue available remedies or limit the damages that we may sustain in any action, such as pursuant to court orders and engaging debt collection agencies.

4. DO WE TRANSFER YOUR PERSONAL INFORMATION?

5. ADA is a Warner Music Group company. As a result of the global nature of the Warner Music Group, your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Platforms you understand that your Personal Information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

   In particular, our consumer databases and global marketing teams are based in the United States and the United Kingdom, so the Personal Information you provide to us while interacting with us for e-commerce purposes, for marketing purposes and for purposes relating to competitions (including sweepstakes and other similar promotions) will be stored and processed in the United States and the United Kingdom for these purposes.

   Please see the “Do we transfer your personal information” section in the Country Specific Schedules of this Privacy Policy for information on how we protect your Personal Information when it is transferred from your country of residence to a location outside your country of residence.

5. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

6. We will retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law.

   The criteria we use to determine our retention periods include:

   • The length of time we have an ongoing relationship with you and provide our ADA Services to you (for example, for as long as you have an account with us or keep using the ADA Services);
   • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them);
   • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations); and
   • Any guidelines issued by relevant legal and data protection authorities.

6. SENSITIVE PERSONAL INFORMATION

7. We ask that you not send us, and you not disclose to us, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation or sex life, political opinions, religion or philosophical beliefs, health related information, criminal background or trade union membership) on or through our Platforms or otherwise unless we expressly request this information for specified purposes.

7. YOUR PRIVACY RIGHTS

8. If you would like to exercise your rights in relation to your Personal Information (such as to access, review, correct, update, suppress, restrict or delete Personal Information), you may contact us at: privacypolicy@wmg.com. We will respond to your request consistent with applicable law.

   When contacting us, please make clear what right(s) you wish to exercise, what actions you would like us to take concerning your Personal Information and any specifics on the Personal Information your request relates to. This will allow us deal with your request more efficiently.

   For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request or we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and within any legally required time limits.

   Please see the “Your Privacy Rights” section in the Country Specific Schedules of this Privacy Policy or the California Privacy Policy for information on specific data protection rights provided by your jurisdiction.

8. UPDATES TO THIS PRIVACY POLICY

9. We may change this Privacy Policy at any time. We will notify you of any significant changes where we have a relationship with you and otherwise post updated versions on our website from time to time. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through our online Platforms.

9. CONTACTING US

10. If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us by email at privacypolicy@wmg.com.

    We are located at the following address:

    Warner Music UK Limited
    Legal Department
    The Warner Building
    27 Wrights Lane
    London
    W8 5SW
    Attn: The Privacy Team

    Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your email messages to us.

10. COUNTRY SPECIFIC SCHEDULES
11. European Union and European Economic Area

12. DO WE TRANSFER YOUR PERSONAL INFORMATION?

    Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission (including the United States), we have put in place standard contractual clauses adopted by the European Commission regarding Personal Information transfers as a safeguard for the transfer of your information. You may obtain a copy of this safeguard by contacting privacypolicy@wmg.com or consult the standard terms by following this link.

     

13. YOUR PRIVACY RIGHTS?

    Privacy Rights if you are located in the EEA or your Personal Information is held by a Warner Music Company in the EEA:

    By law, you have a number of rights (subject to certain conditions and exceptions) when it comes to your information. You can exercise any of these rights by contacting us at privacypolicy@wmg.com or through our details in the contact section below.

    You have the right to object to us using your Personal Information where we rely on “legitimate interests” as a lawful basis for processing your Personal Information or where we use your Personal Information for direct marketing purposes (.e. if you no longer want to receive direct marketing newsletters, updates and other marketing communications from us).

    Rights	What does this mean?
    The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this Privacy Policy.
    The right of access	You have the right to obtain access to your Personal Information (if we are processing it), and certain other information (like the information provided in this Privacy Policy). This is so you are aware and can check that we are using your Personal Information in accordance with data protection law.
    The right to rectification	You are entitled to have your Personal Information corrected if it is inaccurate or incomplete.
    The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
    The right to restrict processing	You have rights to ‘block’ or suppress further use of your Personal Information. When processing is restricted, we can still store your Personal information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.
    The right to data portability	You have the right to receive your Personal Information in a structured, commonly used and machine-readable format and to request that this data is transmitted to another controller where this is technically feasible. This right only applies to Personal Information you have provided to us yourself (not any other information), that we process by automated means based on your consent or for the performance of a contract with you.
    The right to object	You have the right to object to the use of your Personal Information in some circumstances, such as where we don’t have to process your Personal Information to meet a contractual or other legal obligation. For example, you may object to the use of your Personal Information for direct marketing purposes. We can still store your Personal Information, but we can no longer use it in the way that you have asked us not to.
    The right not to be subject to a decision based solely on automated processing, including profiling	You have the right not to have your Personal Information used to make solely automated decisions about you that you impact you. For example, you have the right not to have your Personal Information used to create a profile of you that automated decisions are later based on without there being any human involvement in that processing.
    The right to lodge a complaint	You have the right to lodge a complaint about the way we handle or process your Personal Information with your relevant national data protection regulator. See details of the EEA data protection regulators here.
    The right to withdraw consent	If you have given your consent to anything we do with your Personal Information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Information with your consent up to that point is unlawful). This includes the right to withdraw consent to us using your Personal Information for marketing purposes.

1. United Kingdom (UK)

2. DO WE TRANSFER YOUR PERSONAL INFORMATION?

   EEA countries are recognised by the UK as providing an adequate level of data protection and as such transfers of your Personal Information from the UK to an EEA country are currently permitted under UK law. In addition, transfers of your Personal Information to some non-EEA countries are currently permitted by the UK provided these countries have been certified by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here).

   For transfers from the UK to countries not considered adequate by the European Commission (including the United States), the standard contractual clauses adopted by the European Commission regarding Personal Information transfers are currently certified by the UK as a valid safeguard for the transfer of your information and we have put these standard contractual clauses in place where we transfer your Personal Information to countries not considered by the UK as providing an adequate level of data protection. You may obtain a copy of this safeguard by contacting privacypolicy@wmg.com or consult the standard terms by following this link.

    

    

   YOUR PRIVACY RIGHTS?

   Privacy Rights if you are located in the UK or your Personal Information is held by a Warner Music Company in the UK:

   By law, you have a number of rights (subject to certain conditions and exceptions) when it comes to your Personal Information. You can exercise any of these rights by contacting us at privacypolicy@wmg.com or through our details in the contact section below.

   You have the right to object to us using your Personal Information where we rely on “legitimate interests” as a lawful basis for processing your Personal Information or where we use your Personal Information for direct marketing purposes (.e. if you no longer want to receive direct marketing newsletters, updates and other marketing communications from us).

   Rights	What does this mean?
   The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this Privacy Policy.
   The right of access	You have the right to obtain access to your Personal Information (if we are processing it), and certain other information (like the information provided in this Privacy Policy). This is so you are aware and can check that we are using your Personal information in accordance with data protection law.
   The right to rectification	You are entitled to have your Personal Information corrected if it is inaccurate or incomplete.
   The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
   The right to restrict processing	You have rights to ‘block’ or suppress further use of your Personal Information. When processing is restricted, we can still store your Personal Information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.
   The right to data portability	You have the right to receive your Personal Information in a structured, commonly used and machine-readable format and to request that this data is transmitted to another controller where this is technically feasible. This right only applies to Personal information you have provided to us yourself (not any other information), that we process by automated means based on your consent or for the performance of a contract with you.
   The right to object	You have the right to object to the use of your Personal Information in some circumstances, such as where we don’t have to process your Personal Information to meet a contractual or other legal obligation. For example, you may object to the use of your Personal Information for direct marketing purposes. We can still store your Personal Information, but we can no longer use it in the way that you have asked us not to.
   The right not to be subject to a decision based solely on automated processing, including profiling	You have the right not to have your Personal Information used to make solely automated decisions about you that you impact you. For example, you have the right not to have your Personal Information used to create a profile of you that automated decisions are later based on without there being any human involvement in that processing.
   The right to lodge a complaint	You have the right to lodge a complaint about the way we handle or process your Personal Information with the UK data protection regulator (ICO). Please see contact details for the ICO below:   Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Phone number: 0303 123 1113. Website: https://ico.org.uk/make-a-complaint/
   The right to withdraw consent	If you have given your consent to anything we do with your Personal Information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Information with your consent up to that point is unlawful). This includes the right to withdraw consent to us using your Personal information for marketing purposes.

11. CALIFORNIA PRIVACY POLICY

12. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), this California Privacy Policy provides California residents with a description of our practices regarding the collection, use, sale, and disclosure of their Personal Information. Under the CCPA, “Personal Information” is information that identifies, relates to, describes, or could reasonably be associated or linked with a particular California resident or household. This California Privacy Policy also addresses other provisions of California law. We are providing this California Privacy Policy in addition to the information contained in our general Privacy Policy, above. As noted above, this California Privacy Policy describes our practices in connection with Personal Information that we collect from you in person and through certain of our owned or controlled Platforms. This California Privacy Policy does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.

13. Collection of Personal Information

14. We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information, as listed in the CCPA:

    1. Identifiers. Identifiers, such as name, contact information (address, email address, telephone number), an IP address that can reasonably be linked or associated with a particular consumer or household, Social Security number, social media username or handle, and online identifiers;
    2. Customer Records Information. Personal information as defined in the California customer records law, such as name, contact information, and financial account information;
    3. Protected Class Information. Characteristics of protected classifications under California or federal law, such as gender and age;
    4. Transaction Information. Commercial information about the ADA Services we provide to you;
    5. Online Use Information. Internet or network activity information, such as browsing history, search history, and interactions with our online properties or ads;
    6. Geolocation Information. Geolocation information, such as device location and approximate location derived from IP address;
    7. Audio/Video Information. Audio, electronic, visual, and similar information, such as call and video recordings;
    8. Inferences. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, a Client’s preferences for ADA Services.
15. Sources of Personal Information

16. We collect Personal Information directly from you and from other sources, such as third parties with which we have relationships, publicly available databases, social media platforms (LinkedIn), and our third-party service providers.

17. Our Use of Personal Information

18. We use Personal Information as set forth in our Privacy Policy, above, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: develop, improve, and maintain our products and services; personalize, advertise, and market our products and services; conduct research and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit,investigations, and other internal functions; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

19. Our Disclosure and Sale of Personal Information

20. As set forth in our general Privacy Policy, above, we share Personal Information with the following categories of third parties:

    • Affiliates. We share with our affiliates for the purposes described in this Privacy Policy.
    • Service Providers. We share with our service providers, to facilitate the services they provide to us, such as website hosting, marketing services, data analysis, payment processing, order fulfilment, infrastructure provision, auditing, IT services, customer service, and email delivery.
    • Business Partners. We share with third parties when you have requested us to do so and where you wish to utilise one of their services.
    • Legal Authorities. We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.
    • Other Parties in Legal Proceedings. We share Personal Information in the context of litigation discovery and in response to subpoenas and court orders.

    Under the CCPA, a "sale" is broadly defined as the disclosure of Personal Information for monetary or other valuable consideration and may include certain of our business practices, including those related to certain types of online advertising. In the preceding 12 months, we disclosed Personal Information for our operational business purposes to the following categories of recipients:

    Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes	Sold to Which Categories of Third Parties
    Identifiers	Affiliates; Service Providers; Business Partners.	None
    Client Records Information	Affiliates; Service Providers; Business Partners.	None
    Protected Class Information	Affiliates; Service Providers.	None
    Transaction Information	Affiliates; Service Providers; Business Partners.	None
    Online Use Information	Affiliates; Service Providers.	None
    Geolocation Information	Affiliates; Service Providers.	None
    Audio/Video Information	Affiliates; Service Providers	None
    Inferences	Affiliates; Service Providers	None

1. We do not knowingly collect or sell the Personal Information of minors under 16 years of age.

2. Your CCPA Rights

3. Requests to Know and Delete

   You may request that we disclose to you the following information covering the 12 months preceding your request:

   • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   • The specific pieces of Personal Information we collected about you;
   • The business or commercial purpose for collecting or selling Personal Information about you;
   • The categories of Personal Information about you that we sold and, for each, the categories of third parties to whom we sold such Personal Information; and
   • The categories of Personal Information about you that we otherwise shared and, for each, the categories of third parties with whom we shared such Personal Information.

   You may request that we delete Personal Information we collected from you.

   To make a Request to Know or a Request to Delete, please contact us at 833-596-2637 . We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as your email address, phone number, recent communications with us, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

   If you are the authorized agent of a consumer, making a Request to Know or a Request to Delete on behalf of the consumer, we will ask you for:

   • Proof of your registration with the California Secretary of State to conduct business in California; and
   • Proof that the consumer has authorized you to make a Request to Know or a Request to Delete on the consumer’s behalf. This must be a permission signed by the consumer. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.

   If an authorized agent has not provided us with a power of attorney from the consumer pursuant to Probate Code sections 4000-4465, we may also:

   • Require the consumer to provide you with a written permission signed by the consumer to make the request on the consumer’s behalf;
   • Verify the identity of the consumer as we would if the consumer were making the request personal; and
   • Obtain verification from the consumer that they provided you permission to make the request.

   Request to Opt Out of a Sale

   You may request to opt out of any future sale of Personal Information about you by contacting us at 833-596-2637.

   If you are the authorized agent of a consumer, making a Request to Opt Out on behalf of the consumer, we will ask you for:

   • Proof of your registration with the California Secretary of State to conduct business in California; and
   • Proof that the consumer has authorized you to make a Request to Know or a Request to Delete on the consumer’s behalf. This must be a permission signed by the consumer. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.

   Right to Non-Discrimination

   You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.

1. Do Not Track Signals

2. We do not currently respond to browser do-not-track signals.

1. Your California Privacy Rights

2. If you are a California resident, you may request certain information once per year about our disclosure of certain categories of Personal Information during the preceding calendar year to third parties for such third parties’ own direct marketing purposes. Please send your request by email to privacypolicy@wmg.com, or by postal mail to Warner Music Group, Attn: Privacy Coordinator, 1633 Broadway, New York, NY 10019. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.