Effective as of January 1, 2020
- Children’s Privacy
- Data We Collect About You
- How We Use Your Data
- How We Share Your Personal Data
- Data Retention
- Your Privacy Choices
- Account and Video Privacy Settings
- How We Secure Your Data
- Your Responsibilities
- Third Party Services
- International Data Transfers and User Rights
- Contact Us
Who we are and what we do
Acceptance and Changes
Individuals located in the European Union should be sure to read the important information provided here.
2. Children’s Privacy
Compozly, LLC does not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 16 years old or the age of majority in your jurisdiction, whichever is greater, to use our services. Individuals under the applicable age may use our services only through a parent or legal guardian’s account and with their involvement. If you are a parent or legal guardian who believes your child has provided personal information to Compozly without your consent, you may ask us to delete such information by contacting us through our Contact page
3. Data We Collect About You
Information you give us
We collect information about you when you use our services. In addition, third parties may collect information about you when you use our services. Collected information may include or reflect personal information that could identify you, as well as non-personal information. We refer to your information as “your data” for short. Personal information that you may provide through the Compozly Services or otherwise communicate with us includes:
- Contact information, such as your first name, last name, and email address
- Profile information, such as your username and password, your photograph, music tracks and preferences
- Feedback and correspondence, such as information you provide when you report a problem with the Compozly Services, receive customer support, or otherwise correspond with us
- Transaction information, such as billing information and details about purchases you make through the Sites, and information you provide when you enter into one of our contests or other promotions
- Usage information, such as information about how you use the Compozly Services and interact with us, including information associated with any content you upload to the Sites or otherwise submit to us through the Compozly Services, and information you provide when you use any interactive features of the Services
- Marketing information, such your preferences for receiving marketing communications and details about how you engage with marketing communications
- Content, Account holders may create a profile and upload content such as videos, text, photographs, artwork and music. Your profile may display information about you and your activities. This information may be accessed by others. Your videos may be viewed and otherwise accessed by others, and associated metadata (e.g., titles, descriptions, tags, etc.) are viewable by others. Your interactions with other users (e.g., comments, “likes,” private messages) may be seen by others. You may choose to limit the availability of your profile and videos.
We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our services, you agree to our use of these methods as set forth in our Terms of Service.
We collect your shipping address to send you products you have ordered.
Information Collected by Third Parties
Some third parties may collect data about you when you use our services. This may include data you submit (such as payment information) or automatically-collected information (in the case of third-party analytics providers and advertising partners).
We may obtain data from third parties about you. We may combine that data with information that we have collected. For example, some advertisers or advertising platforms may allow us to determine what other online services you might use so that we may place relevant ads on those services.
4. How We Use Your Data
If you have a Compozly account or use our Compozly Services, we use your personal information to:
- Identification and authentication: We use your data to verify you when you access your account. We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.
- Operating our services: We use your data to provide our services, process and fulfill orders, provide customer support, and to otherwise comply with our contractual obligations to you. We (and/or our third-party vendors) use your financial information to process purchases made by you and to pay you amounts you have earned.
- Communicating with you: We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).
- Improving our services: We use your data to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).
- Customizing your experience: We use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying videos that you might enjoy, based upon your viewing choices.
- Marketing and advertising: We use your data to show you ads on third-party sites. We may also use your data in delivering third-party advertisements to you. This may include “targeted ads” based upon your activities.
- Exercising our rights: Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.
- Legal compliance: We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order. We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Compozly Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
- Protecting your information: Where appropriate, we may anonymize, backup, and delete certain data.
We may use algorithms and other automated means to implement any of the above. Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:
- Performance of a contract;
- Legitimate commercial interest;
- Compliance with a legal obligation; or
5. How We Share Your Personal Data
Affiliates and Advertising
Users of the Services/Visitors to the Sites
Content you submit to the Compozly Sites or through the Services may be viewable by other users of the Services. For example, other users may be able to see your music track and/or videos available for collaboration, and your username may be associated with your projects. If you participate in a Compozly contest or promotion, we may share contestant names as disclosed in the terms of the contest or promotion, including by posting the winner’s name on our Compozly Sites.
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Compliance with Laws and Law Enforcement; Protection and Safety
Compozly, LLC may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Compozly Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Compozly, LLC handles U.S. requests in accordance with U.S. law. If the request originates from a foreign jurisdiction, we will typically disclose information where we in good faith believe that disclosure is permitted by both U.S. law and local law. In all cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
We may disclose user data where we reasonably believe that someone’s life is at risk. For example, if we become aware of a person threatening to commit suicide, we may share that person’s data with appropriate entities that may have the ability to help.
We may disclose user data to report suspected crimes. We report content suspected of exploiting minors to the National Center for Missing and Exploited Children (NCMEC) along with the data identifying the uploading user.
We may disclose user data in situations involving legal claims against us or one of our users. If you submit a Digital Millennium Copyright Act (DMCA) or other takedown notice, we may share that notice with the affected user. If you challenge such a notice, we may share your response with the complainant.
6. Data Retention
Compozly, LLC retains your data for as long as you have an account. When you close an account, we will delete its content, including its videos. We may retain logs of automatically collected information (for internal analytics and security purposes); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.
We retain deleted videos on our servers for a short period in case you wish to reverse deletion. Once we delete a video, we may not be able to recover it. If you have previously made a video public, the video or its thumbnail may be discoverable in a search engine’s cache for a time. We have no control over search engines; however, we will, upon request, send a request for deletion to major search engines.
If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.
7. Your Privacy Choices
We enable you to make numerous choices about your data:
- You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.
- You may change your account and video privacy settings.
- You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.
- You may opt out of receiving commercial emails from us.
- You may backup your videos.
- You may close your account (which will delete all videos)
Users in certain jurisdictions may have additional rights. See information below for more details.
All Compozly account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. You may also contact us through our contact us page to update or correct the personal information Compozly maintains about you, or if you have additional requests or questions.
8. Account and Video Privacy Settings
As part of our Compozly services we offer you the ability to limit the distribution of your content, including your videos. This section explains some of your choices.
Some of our Compozly subscription plans enable you to “hide” your profile or otherwise make it inaccessible on our website. Your profile will, however, remain accessible to persons who have access to your account or content.
We enable you to manage the privacy settings of your videos. Your options, which depend on your subscription plan, may include:
You may change these settings at any time. Changes will be applied on a go-forward basis. You should exercise caution in granting access to others. Once you have granted access to someone else, you lose a degree of control over the distribution of your video as those persons may share the password and/or link with other people. Regardless of your profile or video privacy settings, Compozly reserves the right to inspect them for compliance with its Terms of Service, to provide customer support, or to address technical issues.
If you create a Compozly account, you may receive commercial emails from us. This includes newsletters and offers. You may always opt out from receiving commercial messages in your account settings. You may opt out of marketing-related emails by logging in and changing your account settings, by clicking on a link at the bottom of each such email, or by contacting us through our Contact page.
Please note that any opt-out request may take several days to process and you will continue to receive transactional and service-related non-marketing emails from us (e.g., emails confirming transactions and/or providing information about your account).
10. How We Secure Your Data
We use physical, technical, and organizational security measures to safeguard your data from unauthorized or accidental disclosure. Despite these efforts, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users also have a role to play in keeping their data safe. We encourage you to use a unique and hard-to-guess password for your account and to not share it with others. You should only grant access rights to people who you know and trust, and, even then, you should be careful in granting all access rights. You should monitor your account regularly. If you believe that someone has gained access to your account without your permission, please contact us immediately so that we can investigate.
The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
11. Your Responsibilities
You may receive other people’s data in using our service. If you receive information from other users, you must comply with all laws, including those concerning privacy, data security, and online marketing.
Compozly may make available on our Sites, or link to, features that allow you to generate your own content or share information online (e.g., on message boards, in chat areas, in file uploads, etc.). Please do not embed personal information in the content you generate or share personal information online in public or community forums. Whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage, dissemination or erasure of personal information embedded in user-generated content (including project files) or shared publicly. By posting personal information online in public or community forums, you may receive unsolicited messages from other parties.
12. Third Party Services
13. International Data Transfers and User Rights
Compozly, LLC is based in Seattle, Washington, United States. Compozly provides services globally using computer systems, servers, and databases located in the U.S. and other countries. When you use our services from outside of the U.S., your information may be transferred to and processed in the U.S.. Please note that U.S. data and privacy laws may not be as comprehensive as those in your country. Residents of certain countries may be subject to additional protections as set forth below.
GDPR (EEA Users)
This applies only to natural persons residing in the European Economic Area (for the purpose of this section only, “you” or “your” shall be limited accordingly). It is Compozly’s policy to comply with the EEA’s General Data Protection Regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the U.S. (or other countries) based upon the following legal bases:
- Legitimate business interests: We could not provide our services or comply with our legal obligations without transferring your personal information to the U.S.
- Our certification and adherence to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, as described further below.
You have the right to: opt out of non-essential cookies, access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents. We enable exercise of these rights primarily through our services (which we reserve the right to modify). For example, we allow users to change their information, download their videos, and close their accounts. We also fulfill our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person’s rights. Compozly reserves the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.
If you have a request, complaint or inquiry, please contact our Data Protection Officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.
Under California’s “Shine the Light” law, California residents have the right to opt out of disclosing information to third parties for the purpose of allowing such third parties to directly market their products and services. At this time, we do not engage in this type of disclosure.
Under the California Consumer Privacy Act (“CCPA”), California consumers have the following rights, which can be exercised directly or in certain cases, through an authorized agent:
- Right to Know. You have the right to request information about the categories and sources of personal information we collect, our purposes for collecting the information, and the types of third parties that receive that information. Details about our data collection, use and third-party disclosures can be found in our Terms of Service. In addition, you have the right to request a copy of your personal information. You may exercise this right once per 12-month period by using the form on this Contact page.
- Right to Delete. You have the right to request that we delete some or all of the personal information that we have about you. Deleting all data will typically require the deletion of your account, along with all content, including your videos and music tracks. Notwithstanding the foregoing, we may retain information to provide services you have ordered, complete transactions, honor opt-outs, prevent fraud, spam, and other abuse, comply with our legal obligations, cooperate with law enforcement, and to exercise and defend our rights. You may exercise your right to delete using this form.
- Do Not Sell. You have the right to opt out of the sale of your personal information, and to request information about whether we have sold your personal information in the past 12 months. Compozly does not sell personal information, and we have not done so ever. If we begin to do so, we will update this notice and provide a mechanism to opt out of any such sale.
- Non-Discrimination. We won’t discriminate against you because you exercise any rights herein.
To exercise your rights to know and delete, we must be able to verify your identity as the owner of the Compozly account you are inquiring about. We may not be able to fulfill your request until we can do so. In general, we verify identity by confirming that you are the owner of the email address associated with the account. An authorized agent submitting a request on your behalf must also have access to the email address associated with the account, along with sufficient evidence that you have authorized that person to submit the request on your behalf. Although you need not have a Compozly account to submit a request, we may not be able to locate certain information to process your request if you don’t have one.
14. Contact Us
For any questions, inquiries, or complaints relating to your privacy, please contact us at:
Attention: Data Protection Officer
3907 Whitman Ave N
Seattle, WA 98103