v3.3 Effective Date: April 1, 2024

Here at Universal Music Group, we take your privacy seriously and we’re dedicated to providing you with the best possible music experience. To do that, we collect and use information about you to personalize our sites, stores, and marketing communications. However, only you know what your best experience is, so we provide fans with choices about how we collect, use and share your data.

This page describes specific rights you may have based on where you live, but if you live somewhere else you can still contact us and we will try to address any questions or concerns.

To exercise any of the rights described on this page, or to ask us a question about our data collection practices, please contact us:

Online using our Privacy Request Form; or
By emailing us at privacy@universalmusic.com.

You can exercise your right to opt out of targeted advertising and/or the sale of personal information by clicking the “Cookie Choices” link at the bottom of the website you are interacting with and disabling Online Advertising. You must do this on each browser and each device you use in order to fully opt out.

US STATE RIGHTS

Residents of Colorado, Connecticut, Utah, or Virginia have certain rights with respect to their personal information, including the right to:

· Confirm whether we process the consumer’s personal information and to access such information;

· Correct inaccuracies in personal information;

· Delete personal information;

· Data portability;

· Opt out from targeted advertising; and/or

· Opt out from the sale of personal information.

Residents of Virginia, Colorado, and Connecticut have the right to opt out from profiling in furtherance of decisions that produce legal or similarly significant effects and to appeal decisions regarding a request to exercise their rights.

California residents may opt out of having their personally identifiable information shared with third parties for those third parties' direct marketing purposes by contacting us as described above.

Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. While there is no comprehensive industry standard for such signals, certain websites UMG operates attempt to recognize this signal and, if detected, limit our use of cookies and similar tracking technologies. Unfortunately, due to the variation in browsers and detection capabilities and the lack of accepted standards we cannot guarantee that transmitting a “do-not-track” signal will result in our disabling cookies and tracking technologies. We recommend using the cookie choices tools on our sites to control UMG’s use of cookies and tracking technologies.

Personal Data We Collect and Disclose

In the preceding 12 months, UMG collected and disclosed the following categories of personal data. UMG shares personal data for targeted advertising but does not otherwise engage in “sales” of personal data as defined by state laws.

Categories of personal data	Disclosed to the following categories of third parties for business purposes:	Shared for targeted advertising purposes with the following categories of third parties:	Sold to the following categories of third parties:
Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	UMG affiliates; Business partners; Service providers; and Advertising companies.	Our business partners; Our service providers; and Advertising companies.	Data enrichment providers;
Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	UMG affiliates; Business partners; Service providers; and Advertising companies.	N/A	N/A
Gender, a protected classification under California and federal law.	UMG affiliates; Business partners; and Service providers.	Advertising companies.	N/A
Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.	UMG affiliates; Business partners; and Service providers.	Advertising companies.	N/A
Geolocation data, generally derived from IP address location services, but could also include presence in a geo-fenced area.	UMG affiliates; Business partners; and Service providers.	Advertising companies.	N/A
Audio, electronic, visual, or similar information.	Service providers.	N/A	N/A
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	UMG affiliates; Business partners; Service providers; and Advertising companies.	Advertising companies.	N/A
Other information about you that is linked to the personal information above	UMG affiliates; Business partners; Service providers; and Advertising companies.	Advertising companies.	N/A

Categories of Sources:

We collect personal data from:

· Individuals who provide information directly;

· Affiliates and business partners, which may include third parties;

· Third-party data providers and data brokers;

· Service providers; and

· Advertising companies.

Business or Commercial Purposes for Processing Personal Data:

We use and disclose the personal data as described above in the “How Your Information May Be Used” section of our privacy policy.

Your Rights:

Residents of certain states have rights with respect to the personal data collected by UMG. You may be able exercise the following rights regarding your personal data:

The right to confirm whether we process personal data about you;
The right to correct inaccurate personal data;
The right to know the categories and specific pieces of personal data we collect, use, disclose, and sell about you; the categories of sources from which we collected personal data about you; our purposes for collecting or selling personal data about you; the categories of personal data about you that we have sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal data;
The right to request the deletion of personal data we have collected about you;
The right to opt out of processing and sharing of personal data for targeted advertising;
Depending on your state, the right to limit our processing of certain “sensitive” personal data, including the withdrawal of prior consent; and/or
The right to be free of discriminatory treatment for the exercise of the above privacy rights.

UMG does not knowingly sell or share personal data of individuals younger than 16.

Depending on your state, if you have submitted a request that we have not reasonably fulfilled, you may contact us to appeal our decision by sending an email with the subject line “Appeal” to privacy@universalmusic.com.

Verification

We may take steps to verify your identity before completing your request. Our verification measures vary based on the risk to the individual and may involve confirming access to the relevant email account, providing a government-issued ID or other identification documents, or providing other account details or information that indicates a valid request.

Authorized Agent

You may also designate an authorized agent to requests on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

EUROPEAN AND UK RIGHTS

This section of this Privacy Policy applies only if you use the App or UMG websites from a country that is a Member State of the European Economic Area and supplements the information in this Privacy Policy.

You may be entitled, subject to validation of your identity and in accordance with applicable law, to:

· Confirm whether we process the consumer’s personal information and to access such information;

· Correct inaccuracies in personal information;

· Delete personal information;

· Data portability;

· Withdraw consent you have previously given; and/or

· Object to or request the restriction of processing of your personal data.

You may also be entitled, in accordance with applicable law, to lodge a complaint with a supervisory authority if you consider that our processing of your personal data infringes applicable law.

Legal Basis for Data Processing: We process personal data for the purposes set out in the relevant privacy policy. Our legal bases to process personal data includes processing that is: necessary for the performance of the contract between you and us (for example, to provide you with the services you request and to identify and authenticate you so you may use the App); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve the App); and based on the consent of our customers (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time (by using preference settings found in our emails/Apps or by contacting UMG as described above) without affecting the lawfulness of processing based on consent before its withdrawal.

We may use automated decision-making technologies, including profiling, to support our data processing activities. Our automated decision-making capabilities include logic that attempts to identify artists, music, communications, products, or offers that we believe may interest you. By using this logic, it helps us personalize your interactions with UMG and UMG artists. For you, this means that you may see online advertisements, direct marketing communications (if you have subscribed), or other advertising or marketing messages or special offers based on your activity on our Apps or interactions with UMG Companies or our third-party partners.

In some instances, you may be required to provide us with personal data for processing as described above, for us to be able to provide you to use all the features of the App.

International transfers

Our sharing your personal data in accordance with this Privacy Policy, may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by certifying, where required by law, at least one of the following safeguards is implemented:

· transferring personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;

· consent of the individual;

· adherence to the EU-US Data Privacy Framework, the Swiss-US Data Privacy Framework, and UK Extension to the EU-US Data Privacy Framework (see details below); or

· using specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

You may be entitled, in accordance with applicable law, to request a copy of relevant safeguards by contacting UMG as described above.