Hodi.tv

Privacy

Hodi TV Privacy Policy

Effective as of 5 December 2023

1. About this Policy

2. Your personal data rights and controls

3. Personal data we collect about you

4. Our purpose for using your personal data

5. Sharing your personal data

6. Data retention

7. Transfer to other countries

8. Keeping your personal data safe

9. Children

10. Changes to this Policy

11. How to contact us

1. About this Policy

This Privacy Policy describes how we process your personal data at Hodi.tv.

From now on, we'll call it the 'Policy'.

It applies to your use of:

all Hodi.tv streaming services as a user. For example this includes:
your use of Hodi.tv on any device
the personalisation of your user experience. Watch our personalisation explainer video to learn more about this
the infrastructure required to provide our services
connection of your Hodi.tv account with another application
both our free or paid streaming options (each a 'Service Option')
other Hodi.tv services which include a link to this Policy. These include Hodi.tv websites, Customer Service and the Community Site

From now on, we'll collectively call these the 'Hodi.tv Service'.

From time to time, we may develop new or offer additional services. They'll also be subject to this Policy, unless stated otherwise when we introduce them.

This Policy is not...

· the Hodi.tv Terms of Use, which is a separate document. The Terms of Use outline the legal contract between you and Hodi.tv for using the Hodi.tv Service. It also describes the rules of Hodi.tv and your user rights

· about your use of other Hodi.tv services which have their own privacy policy. Other Hodi.tv services include Anchor, Soundtrap, Megaphone and the Hodi.tv Live app

Other resources and settings

Key information about your personal data is right here in this Policy. However, you might want to take a look at our other privacy resources and controls:

· Privacy Center: A user-friendly hub with summaries of key topics and helpful videos. It includes the 'Your Privacy Controls' video which shows you how to exercise your user rights and make choices about the way we process your data. See Section 2 'Your personal data rights and controls' for more on user rights.

· Privacy Settings: Control the processing of certain personal data, including tailored advertising.

· Notification Settings: Set which marketing communications you get from Hodi.tv.

· Settings (found in the Desktop and Mobile versions of Hodi.tv): Control certain aspects of the Hodi.tv Service such as 'Social' or 'Explicit Content'. On the 'Social' setting, you can:

· start a Private session

· choose whether to share what you listen to on Hodi.tv with your followers

· choose whether to show your recently played artists on your public profile

On the 'Explicit Content' setting you can control whether explicit-rated content can be played on your Hodi.tv account.

· Cookies Policy: Information on how we use cookies and how to manage your cookie preferences. Cookies are files saved on your phone, tablet or computer when you visit a website.

2. Your personal data rights and controls

Many privacy laws give rights to individuals over their personal data. These laws include the General Data Protection Regulation, or 'GDPR'.

Some rights only apply when Hodi.tv uses a certain 'legal basis' to process your data. We explain each legal basis, and when Hodi.tv uses each one, in Section 4 'Our purpose for using your personal data'.

The table below explains:

· your rights

· circumstances when they apply (such as the legal basis required)

· how to use them

It’s your right to...

1. 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 Hodi.tv Service

· by answering your specific questions and requests when you contact us

2. Access

Request access to the personal data we process about you. To request a copy of your personal data from Hodi TV:

· contact us

3. Rectification

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.

4. Erasure

Request that we erase certain of your personal data.

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

· it’s still necessary to process the data for the purpose we collected it for

· Hodi.tv’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

· Hodi.tv has a legal obligation to keep the data, or

· Hodi.tv 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 erase personal data from Hodi TV:

· to request erasure of your other personal data from Hodi TV, contact us to request erasure

5. 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.

To exercise your right to restriction, contact us

6. Object

Object to us processing your personal data.

You can do this if:

· Hodi.tv is processing your personal data on the legal basis of legitimate interests, or

· Hodi.tv is processing your personal data for tailored advertising

To exercise your right to object, contact us

7. 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 Hodi.tv will try to honour any request to the extent possible.

For information about how to exercise the right to portability, see ‘Access’ above.

8. 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.

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

9. Withdrawal of consent

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

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

To withdraw your consent, you can contact us

10. Right to lodge a complaint

Contact the ICO for Privacy Protection or your local data protection authority about any questions or concerns.

Tailored advertising controls

What is tailored advertising?

This is when we use information about you to tailor ads to be more relevant to you. This is also known as interest based advertising.

An example of tailored advertising is when an advertising partner has information suggesting you like cars. This could enable us to show you ads about cars.

How to control tailored advertising:

· You can control tailored advertising in your account Privacy Settings under 'Tailored Ads'.

· You can also control tailored advertising for some podcasts using the link in the episode's show description. This applies where the content provider inserts advertising into the podcast to fund it. The hosting provider, which might not be Hodi.tv, manages these controls for the podcast.

If you are 'opted out' of Tailored Ads in your Privacy Settings, you may still get advertising. This can include on our free Service Option, as well as our paid Service Option, as applicable (for example, advertising in podcasts). This type of advertising is based on your registration information and what you are currently listening to on our services. For example, if you are listening to a cooking podcast, you may hear an ad for a food processor.

Appropriate age for tailored advertising:

· The appropriate age for tailored advertising is determined by the country you are in and what rules apply to tailored advertising in that country. You will not receive Tailored Ads unless you have reached the appropriate age.

· You will not be able to 'opt-in' to Tailored Ads if you are under the appropriate age.

· You will start to receive Tailored Ads once you reach the appropriate age for your country. When this happens, you will receive a message within the Hodi.tv Service to let you know. This message will contain a link to the Privacy Settings where you can change your preferences or 'opt-out' of Tailored Ads at any time.

3. Personal data we collect about you

User Data

Personal data that we need to create your Hodi.tv account and that enables you to use the Hodi.tv 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 Hodi.tv 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.

Address Data

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.

Usage Data:

Personal data collected and processed about you when you’re accessing or using the Hodi.tv Service.
There are a few types of information this includes, listed in the following sections.

Information about how you use Hodi.tv
Examples include:

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

Authentication partners:

If you register for or log into the Hodi.tv Service using another service, that service will send your information to us. This information helps create your account with us.

Third party applications, services and devices you connect to your Hodi.tv account:

If you connect your Hodi.tv 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.

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 Hodi.tv to provide the Hodi.tv Service, content, and features.
We also work with security service providers who help us protect user accounts.

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
analyse the effectiveness of our partnership with these merchant partners
understand your interests

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.

Acquired companies:

We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.

If you download the Hodi.tv mobile app and try Hodi.tv using a logged out user experience, we will collect limited information about your usage of the Hodi.tv Service, including Usage Data. We do this to understand how you are accessing and using the Service. We also do this to ensure we provide the right experience for you, for example based on your country or region. If you decide to create a Hodi.tv account to experience our service in full, then we will combine this data with your Hodi.tv account data.

4. Our purpose for using your personal data

Here is a general explanation of each 'legal basis' :

Performance of a Contract: When it's necessary for Hodi.tv (or a third party) to process your personal data to:
- comply with obligations under a contract with you. This includes Hodi.tv's obligations under the Terms of Use to provide the Hodi.tv Service to you, or
- verify information before a new contract with you begins.
Legitimate Interest: When Hodi.tv or a third party has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Hodi.tv users. For example, using your Usage Data to improve the Hodi.tv Service for all users. Contact us if you want to understand a specific justification.
Consent: When Hodi.tv asks you to actively indicate your agreement to Hodi.tv's use of your personal data for a certain purpose.
Compliance with Legal Obligations: When Hodi.tv must process your personal data to comply with a law.

5. Sharing your personal data

This section sets out who receives personal data which is collected or generated through your use of the Hodi.tv Service.

Publicly available information

The following personal data will always be publicly available on the Hodi.tv Service (except to any user you have blocked):

your profile name
your profile photo
other content you post on the Hodi.tv Service, and any associated titles, descriptions and images
who you follow on the Hodi.tv Service
who follows you on the Hodi.tv Service

You or another user can share certain information on third party services, like social media or messaging platforms. This includes:

your profile
any content you post on Hodi.tv and details about that content
your playlists and any associated titles, descriptions and images

When this sharing occurs, the third party service may store a copy of it to support their features.

Personal data you may choose to share

We will only share the following personal data with those outlined in the table below:

where you have chosen to use a Hodi.tv Service feature, or a third party application, service or device, and we need to share personal data to enable this, or
if you otherwise grant us your permission to share the personal data. For example, you can do it by selecting the appropriate setting in the Hodi.tv Service or by giving your consent

6. Data retention

We keep your personal data only as long as necessary to provide you with the Spotify Service and for Spotify's legitimate and essential business purposes, such as:

maintaining the performance of the Spotify Service
making data-driven business decisions about new features and offerings
complying with our legal obligations
resolving disputes

Here are some of the categories of our retention periods, and the criteria we use to determine them:

Data retained until you remove it
It's your right to request that we delete certain of your personal data. See the section on 'Erasure' in Section 2 'Your personal data rights and controls' for more information, and the circumstances in which we can act on your request.
You can also delete certain personal data directly from the Spotify Service: for example, you can edit or delete your profile picture. Where users are able to see and update the personal data themselves, we keep the information for as long as the user chooses unless one of the limited purposes described below applies.
Data that expires after a specific period of time
We have set certain retention periods so that some data expires after a specific period of time. For example, personal data you may input as part of search queries is generally deleted after 90 days.
Data retained until your Spotify account is deleted
We keep some data until your Spotify account is deleted. Examples of this include your Spotify username and profile information. We also typically keep streaming history for the life of an account, for example, to provide retrospective playlists that users enjoy and personalised recommendations that take listening habits into account (for example, Your Time Capsule or Your Summer Rewind). When your Spotify account is deleted, this category of data is deleted or de-identified.
Data retained for extended time periods for limited purposes
After your account is deleted, we keep some data for a longer time period but for very limited purposes. For example, we may be subject to legal or contractual obligations that require this. These may include mandatory data retention laws, government orders to preserve data relevant to an investigation, or data kept for the purposes of litigation. We may also keep data that has been removed from the Spotify Service for a limited period of time. This could be:
- to help ensure user safety, or
- to protect against harmful content on our platform.

This helps us investigate potential breaches of our User Guidelines and Platform Rules. On the other hand, we will remove unlawful content if the law requires us to do so.

7. Transfer to other countries

Because of the global nature of our business, Hodi.tv shares personal data internationally with Hodi.tv group companies, subcontractors and partners when carrying out the activities described in this Policy. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.

Whenever we transfer personal data internationally, we use tools to:

· make sure the data transfer complies with applicable law

· help to give your data the same level of protection as it has in the EU

To ensure each data transfer complies with applicable EU legislation, we use the following legal mechanisms:

· Standard Contractual Clauses ('SCCs'). These clauses require the other party to protect your data and to provide you with EU-level rights and protections. For example, we use SCCs to transfer the personal data described in Section 3 'Personal data we collect about you' to our hosting provider which uses servers in the US. You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.

· Adequacy Decisions. This means that we transfer personal data to countries outside of the European Economic Area which have adequate laws to protect personal data, as determined by the European Commission. For example, we transfer the personal data described in Section 3 'Personal data we collect about you' to vendors based in the United Kingdom, Canada, Japan, Republic of Korea and Switzerland.

We also identify and use additional protections as appropriate for each data transfer. For example, we use:

· technical protections, such as encryption and pseudonymisation

· policies and processes to challenge disproportionate or unlawful government authority requests

8. Keeping your personal data safe

We're committed to protecting our users' personal data. We put in place appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

We have put various safeguards in place to guard against unauthorised access and unnecessary retention of personal data in our systems. These include pseudonymisation, encryption, access, and retention policies.

To protect your user account, we encourage you to:

· use a strong password which you only use for your Hodi.tv account

· never share your password with anyone

· limit access to your computer and browser

· log out once you have finished using the Hodi.tv Service on a shared device

· read more detail on protecting your account

· You can log out of Hodi.tv in multiple places at once by using the 'Sign out everywhere' function on your account page.

If other individuals have access to your Hodi.tv account, then they can access personal data, controls and the Hodi.tv Service available in your account. For example, you might have allowed someone to use your account on a shared device.

It's your responsibility to only allow individuals to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your Hodi.tv account may impact your personalised recommendations and be included in your data download.

9. Children

Note: This Policy doesn't apply to Hodi.tv Kids unless the Hodi.tv Kids Privacy Policy says so. Hodi.tv Kids is a separate Hodi.tv application.

The Hodi.tv Service has a minimum 'Age Limit' in each country or region. The Hodi.tv Service is not directed to children whose age:

· is under the age of 13 years

· makes it illegal to process their personal data, or

· requires parental consent to process their personal data

· We do not knowingly collect or use personal data from children under the applicable Age Limit. If you're under the Age Limit, do not use the Hodi.tv Service, and do not provide any personal data to us. Instead, we recommend using a Hodi.tv Kids account.

If you're a parent of a child under the Age Limit and become aware that your child has provided personal data to Hodi.tv, contact us.

If we learn that we've collected the personal data of a child under the applicable Age Limit, we'll take reasonable steps to delete the personal data. This may require us to delete the Hodi.tv account for that child.

When using a shared device on the main Hodi.tv Service, be cautious about playing or recommending any inappropriate content to individuals under 18 years old.

10. Changes to this Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Hodi.tv Service or send you an email or device notification.

11. How to contact us

For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:

email contact@Hodi.tv.com

write to us at: Hodi.tv, 83 Ducie Street, Manchester, M1 2JQ

Hodi TV Limited is the data controller of personal data processed under this Policy.