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 TheFreshFinds Service
• by answering your specific questions and requests when you contact us

Know/

Access

Request to know and access the personal data we process about you.

To request a copy of your personal data from TheFreshFinds, either:

• use the “Download your data” tool in your account Privacy Settings, or
• contact us

When you download your data you will receive the information about your data that TheFreshFinds has to provide under applicable laws. If you would like more information about how we process your personal data, you can contact us.

Correction

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.

Deletion

Request that we delete certain of your personal data.

For example, you can ask us to delete your 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 TheFreshFinds is unable to delete your data, for example when:

• it’s still necessary to process the data for the purpose we collected it for
• TheFreshFinds’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
• TheFreshFinds has a legal obligation to keep the data, or
• TheFreshFinds 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 delete personal data from TheFreshFinds:

• 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 deletion of your other personal data from TheFreshFinds (and thus close your account), 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 or reach out to customer support via our chat bot

Right to Limit

Under California law, request that we limit the processing of sensitive personal data if we are using or disclosing it for purposes other than those specified in Section 7027(m) of the CCPA Regulations.

Currently, we are not using or disclosing any sensitive personal data for purposes other than those specified in Section 7027(m) of the CCPA Regulations.

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:

• TheFreshFinds is processing your personal data on the legal basis of legitimate interests, or
• TheFreshFinds is processing your personal data for tailored advertising.

To exercise your right to object, you can:

• use controls on the TheFreshFinds 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 TheFreshFinds will try to honor 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.

TheFreshFinds does not carry out this type of automated decision making in the TheFreshFinds Service.

Withdrawal of consent

Withdraw your consent to us collecting or using your personal data.

You can do this if TheFreshFinds is processing your personal data on the legal basis of consent.

To withdraw your consent, you can:

• adjust the relevant control on TheFreshFinds
• contact us

Right to Know / Access

457,465

457,465

0

4 days

Request to Delete

2,298,607

2,298,607

0

15.5 days

Categories

Categories under CCPA

Description

User Data

Identifiers

Personal data that we need to create your TheFreshFinds account and that enables you to use the TheFreshFinds 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 TheFreshFinds 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

Identifiers

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.

Categories

Categories under CCPA

Description

Usage Data

Internet or other electronic network activity information; and

Inferences

Personal data collected and processed about you when you’re accessing or using the TheFreshFinds Service.

There are a few types of information this includes, listed in the following sections.

Information about how you use TheFreshFinds

Examples include:

• information about your TheFreshFinds Service Option
• your actions with the TheFreshFinds Service (including date and time), such as:
  • search queries
  • streaming history
  • playlists you create
  • your library
  • browsing history
  • account settings
  • interactions with other TheFreshFinds users
  • your use of third party services, devices and applications in connection with the TheFreshFinds Service
• inferences (i.e., our understanding) of your interests and preferences based on your usage of the TheFreshFinds Service
• content you provide when participating in TheFreshFinds promotions, such as contests or sweepstakes
• content you post to any part of the TheFreshFinds 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
  • TheFreshFinds 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 TheFreshFinds Service
  • devices your operating system makes available when connecting via Bluetooth, plugin, and installation
  • TheFreshFinds 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 TheFreshFinds 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 TheFreshFinds Service that require this data. This is data which your device collects about the way you move or hold your device.

Categories

Categories under CCPA

Description

Voice Data

Internet or other electronic network activity information

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

Commercial information

If you make any purchases from TheFreshFinds 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

Identifiers; and

other information you share

When you respond to a survey or take part in user research, we collect and use the personal data you provide.

Categories of third parties

Description

Data categories

Authentication partners

If you register for or log into the TheFreshFinds 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 TheFreshFinds account

If you connect your TheFreshFinds 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 TheFreshFinds to provide the TheFreshFinds 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
• analyze 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

To provide the TheFreshFinds Service in accordance with our contract with you. See Section 1 ‘About this Policy’ for what we mean by the TheFreshFinds Service.

For example, when we use your personal data to:

• set up an account for you
• personalize your account, or
• provide the TheFreshFinds 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 TheFreshFinds Service.

For example, when we use your personal data to enable you to share a link to TheFreshFinds content with someone else.

Legitimate Interest

Our legitimate interests here include:

• keeping the TheFreshFinds Service running and functional
• allowing users to access and use the TheFreshFinds Service

• User Data
• Street Address Data
• Usage Data
• Voice Data
• Payment and Purchase Data

To provide certain additional voluntary features of the TheFreshFinds 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 understand, diagnose, troubleshoot, and fix issues with the TheFreshFinds Service.

For example, we use your personal data to:

• respond to your messages when you contact customer services
• spot unusual data or behavior in our logs which might indicate a bug or other issue, or
• check and verify accounts to find and prevent unauthorized users

Performance of a Contract

• User Data
• Usage Data

To evaluate and develop new features, technologies, and improvements to the TheFreshFinds Service.

For example:

• we use personal data to develop and improve our personalized recommendation algorithms
• we analyze 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 TheFreshFinds 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 fulfill contractual obligations with third parties.

For example, when we provide pseudonymized data about our users’ listening because we have an agreement with a TheFreshFinds rightsholder to do so.

Pseudonymized 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 TheFreshFinds 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 TheFreshFinds subscription.

Performance of a Contract, and consent

• User Data
• Payment and Purchase Data
• Street Address Data

To detect and prevent fraud.

For example, when we analyze Usage Data to check for fraudulent use of the TheFreshFinds Service.

Legitimate Interest

Our legitimate interests here include protecting the TheFreshFinds 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 TheFreshFinds Service.

• User Data
• Usage Data
• Voice Data
• Survey and Research Data

Third party applications, services and devices you connect to your TheFreshFinds account

• User Data
• Usage Data

To connect your TheFreshFinds account, or so that you can use the TheFreshFinds 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 TheFreshFinds Support Community service.

When you register for an account on the TheFreshFinds Support Community, we’ll ask you to create a profile name. This will be publicly displayed to anyone who uses the TheFreshFinds Support Community. We’ll also display any questions or comments you post.

Other TheFreshFinds users

• User Data
• Usage Data
• Voice Data

To share information about your use of the TheFreshFinds Service with other TheFreshFinds users. These could include your followers on TheFreshFinds.

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.

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 TheFreshFinds.

These service providers include those we hire to:

• give customer support
• operate the technical infrastructure we need to provide the TheFreshFinds Service
• assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)
• help market TheFreshFinds’s (and our partners’) products, services, events and promotions
• verify your eligibility for certain types of Service Options (e.g., TheFreshFinds Premium Student)

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 TheFreshFinds Service, and help measure the effectiveness of ads.

For example, our ad partners help us facilitate tailored advertising.

With respect to TheFreshFinds Service users under the age of 16, we do not share personal data to advertising partners by default.

Marketing Partners

• User Data
• Usage Data

To promote TheFreshFinds with our partners. We share certain User Data and Usage Data with these partners where necessary to:

• enable you to participate in TheFreshFinds promotions, including trials or other bundled offers
• to promote TheFreshFinds in media and advertising published on other online services
• help us and our partners to measure the effectiveness of TheFreshFinds 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 TheFreshFinds 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.

With respect to TheFreshFinds Service users under the age of 16, we do not share personal data to marketing partners by default.

Ticketing and event partners

• User Data

For every event for which we sell tickets, we will need to share your name, email or other order details to our event partners such as ticketing agent or venue box office where the event is taking place so that you can check-in as a verifiable guest who purchased tickets through TheFreshFinds’s ticketing platform.

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 TheFreshFinds.

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 pseudonymized format.

Other TheFreshFinds group companies, including companies that TheFreshFinds 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 TheFreshFinds 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 TheFreshFinds Service
• sharing data with our measurement companies to measure the effectiveness of ad campaigns that run on the TheFreshFinds 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.