Privacy Policy

Cyphr has established this privacy policy to explain to you how your information is protected, collected and used in connection with its app and website.  We may update this policy from time to time; if we make materially significant changes to this privacy policy, we will provide notice thereof by posting notice on the app and website; otherwise, you should review this privacy policy on a regular basis to keep yourself apprised of any less significant changes.

1. Data we collect and store

• Our app and web logs collect standard app and web log entries for each page served, including your domain name, IP address, type of browser/device, type of operating system, page URL, and timestamp. Web logs help us to diagnose problems with our server, to administer the app and website, and to analyze the design and effectiveness of our app and website.  These web logs and other records are stored indefinitely.
• We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services. This information is stored indefinitely.
• We will ask your permission to use location information to help enrich the Cyphr experience. This information is stored indefinitely.
• If you download the Cyphr app or register for an online account with Cyphr, we collect certain personal information from you including your full name, your email address, and your contact number.
• If you contact us directly, using the form on the app or website, or the email contact information set forth on the app or website, we may collect personal and contact information for the limited purpose of corresponding with you.

2. Protecting your privacy

• Although we make good faith efforts to store the information we store in a secure operating environment that is not available to the public, we cannot guarantee complete security. 
• We don't share your information with third parties for marketing purposes.
• We don't engage in cross-marketing or link-referral programs with other sites.
• We will send updates and promotional messages about Cyphr to the email address you provide on registration, however, you may opt out of these messages at any time.
• Cyphr may provide links to, or obtain information from, third party apps or websites, which may have different privacy practices. We are not responsible for, nor have any control over, the privacy policies of those third party apps or websites, and encourage all users to read the privacy policies of each and every app or website visited.

3. How and Why Cyphr May Use Your Information

We may process your personal information for a variety of reasons that are permitted under data protection laws and in accordance with this Privacy Policy, which may include the purposes described below. If we use your information for other purposes than those mentioned below, we will notify you of these purposes before using your information and obtain your consent where necessary. The legal bases outlined below are the legal bases upon which we will rely to process the personal data of end users located in the European Union (“EU”).

1. To fulfill our contractual obligations under an existing agreement with you or in anticipation of entering into an agreement with you, including:
• To review and process your account registration;
• To fulfill orders and provide you with products and services you have requested and/or paid for; and
• To enforce your legal rights under an agreement.

1. To meet and fulfill our legitimate business interests, including:

• To communicate with you about your account, our app and website, our services and Cyphr generally;
• To manage our business needs, such as monitoring, analyzing, modifying and improving the functionality and performance of our app, website and database;
• To prevent fraud and abuse on and unauthorized access to our app, website and database;
• To provide you with information about products and services you have purchased or indicated your interest in;
• To determine which features and functionality of the app and website users like best to help us operate, enhance and improve the Services;
• To get to know our potential and existing users; and
• To identify relevant content shared with potential and current users.

1. To comply with our regulatory and legal obligations or to enforce our legal rights, including:

• To meet reporting requirements (e.g., filing tax forms);
• To protect, enforce, or defend the legal rights, privacy, safety, or property of Cyphr and our affiliates and their respective employees, agents and contractors (including enforcement of our agreements, and our Terms of Use);
• To protect the safety, privacy and security of Users of the Services or the public;
• To comply with the law or legal process, and/or respond to requests from public and government authorities;
• To enforce your rights as a copyright holder; and
• To report data breaches or unauthorized access to our app, website or database.

4. Circumstances in which Cyphr may release information

• We may disclose information about our registered users if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process.
• We may also disclose information about our registered users to law enforcement officers or others, in the good faith belief that such disclosure is reasonably necessary to: enforce our terms and conditions for use of the app and website; respond to claims that any posting or other content violates the rights of third-parties; or protect the rights, property, or personal safety of Cyphr, its affiliates, users or the general public.
• We may share information with other carefully selected third party operators, developers, merchants, website hosts, service providers and participants to your transactions and the licensing of your musical compositions for the purpose of (a) assisting with facilitating transactions and licenses on or through the Services, (b) sending you information about our products, offerings and services, (c) providing information technology and member service assistance, and (d) providing, offering, supporting, administering, maintaining and enabling the app, website and our database (including providing a full range of content, activities, services, widgets, payment processors, features and functions offered on or in connection with or to enable the app, website and/or database). They will only be given limited access to your personal data as is reasonably necessary to deliver the services they are engaged to provide. These third party service providers are required to collect and use any personal information collected from you on our behalf in a manner that is consistent with this Privacy Policy and/or applicable law. We request that service providers maintain commercially reasonable standards of security and confidentiality and must agree to keep such information secure and confidential in line with this Privacy Policy. In addition to the foregoing, please note that the third parties mentioned above will in many cases have their own statement regarding the processing of your personal information. We strongly advise you to carefully review these statements. We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties. Some information that we provide to third party service providers may be in an aggregated and anonymized form and will not personally identify you.
• We may disclose your personal information in connection with a merger, sale of substantially all of our assets, transfer, corporate reorganization or other disposition of our business.
• If you elect to use certain features or functions of our app and website including sharing, messaging, posting, and responding to surveys, we may use your personal information to fulfill your request to participate in such activities and/or to share content on Third Party Social Media Services.
• If we do not process your personal information in accordance with our legitimate interest or based on a contractual obligation we have with you, we may share or disclose your personal information if you provide us with your affirmative consent.

5. Provisions for EU Citizens and Residents

If you are an EU citizen or reside in the EU, you may have certain rights with respect to the personal information you provided to us. To the extent permitted by applicable data protection laws, you may:

• Access or modify your personal information;
• Object, on grounds relating to your particular situation, at any time to the processing of your personal information if the legal ground we are relying on is our legitimate interest or in the public interest;
• Request that your personal information (i) be corrected if such personal information proves inaccurate or incomplete, or (ii) be erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn consent to, or object to, the processing of such personal information and we meet no other legitimate basis for such processing or it has been unlawfully processed;
• Restrict the processing of your personal information if you contest its accuracy or the lawfulness of our processing, we no longer need it but you need it for a legal claim or you have objected to its processing and await verification of our legitimate grounds for processing it;
• Ask to stop receiving our marketing communications. If you opt out of marketing emails, you will continue to receive messages from us about your relationship with us where permitted by law;
• Under certain circumstances, have your personal information transferred to another company;
• Withdraw any consents that you have previously provided to allow us to process your personal information; or
• Lodge a complaint to the relevant data protection authority.

If you wish to exercise any of these rights please submit a data subject request message via email to contact@cyphr.co. Please note that some requests may require you to verify your identity.

6. Data Collection from Children

Our Sites and Services are not directed to children under the age of 13 (if you are located in the United States) and under the age of 16 (if you are located outside the United States). We do not knowingly collect information, including personal information from children or other individuals who are not legally able to join Cyphr or use our app or website. If we obtain actual knowledge that we have collected personal information from someone under the applicable age listed above, we will promptly delete it, unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from someone under the applicable age listed above, please submit a request via email to contact@cyphr.co.

7. Changes to our Privacy Policy

From time to time, we may modify this Privacy Policy to reflect industry initiatives, third party requirements or changes in the law, technology, our information collection and use practices or the features and functionality of the Services, and such modifications shall be effective upon posting. When we change this Privacy Policy in a material way, a notice will be posted on our app and website along with the updated Privacy Policy. Your continued use of the app, website and/or database after we post a revised Privacy Policy (and, where appropriate, notify you of same) signifies your acceptance of the revised Privacy Policy. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. We may continue to process your information based on our legitimate interests or in order to fulfill our obligations under a contract and/or may also seek your affirmative consent to the terms of the updated Privacy Policy.  For example, we may ask for your consent before implementing new uses of the personal information that we’ve already collected from you based on such consent, if such new use was not addressed by the privacy policy under which such information was collected or if our legal basis for processing such information changes.