ISINA is committed to making your experience online satisfying and safe. Your privacy on the Internet is of the utmost importance to us. Please read this Privacy Policy carefully before using our Platform (e.g., isina.com, ISINA’s Site (s), applications and any other sites controlled by ISINA). Your use of the ISINA Platform serves as your acceptance of this Privacy Policy and consent to ISINA’s collection and use of the information you provide as set forth in the Privacy Policy. Please note the Privacy Policy applies only to the Site (s) operated by ISINA, and not to other websites operated by other third parties to which they may hyperlink to. When you hyperlink to any other website from the ISINA Platform, this Privacy Policy no longer applies and ISINA has no control of the activities of those third party websites. Also, this Privacy Policy does not apply to any information that ISINA may collect from you in any manner other than online. ISINA may revise the Privacy Policy at any time. You should therefore, review it periodically. The updated version of the Privacy Policy will be updated on the Site (s) and will reflect the most recent changes, effective when published. If you do not want to submit personal information when requested, you will not be able to access certain areas of our Platform. You acknowledge and agree that the terms and obligations in this Privacy Policy affect your legal rights, remedies and obligations. Your acceptance of the ISINA Terms of Use and access and/or use of the Platform constitute you entering into a legal contract with ISINA. In the event that any terms in this Privacy Policy are in conflict with the terms in the Terms of Use, the Terms of Use shall control.
When you use our Platform, ISINA may ask you to provide us you’re your Personally Identifiable Information. As used in the Privacy Policy, “Personally Identifiable Information” means any information that can be used to contact or identify you such as your name, your age, gender, home address, zip code, email address, telephone number or payment card number, or government issued identification information. ISINA only generally collects Personally Identifiable Information from you when you voluntarily submit it to us when you register with us; participate in contests, various promotional campaigns, events, or promotions; and/or send us questions, feedback or comments via email or other communication channels offered to you by us (e.g., feedback and other customer service posts on dedicated online pages, communications via third party service providers engaged by us for better customer service experience, etc.). ISINA never collects more information than what is reasonably necessary to fulfill your requests and ISINA’s business objectives. We will take appropriate steps to ensure the security and integrity of any information you provide to us. We use the information you provide for such purposes as responding to your requests, improving our Platform, improving the enduser experience of all our registered users and visitors on the Platform, and communicating with you.
YOU ACKNOWLEDGE AND AGREE THAT YOU ARE YOU ARE AT LEAST SIXTEEN (16) YEARS OF AGE OR MORE IF YOU RESIDE IN THE EUROPEAN UNION AND AT LEAST THIRTEEN (13) YEARS OF AGE OR MORE IF YOU RESIDE IN THE UNITED STATES OR ANOTHER TERRITORY OF THE WORLD (EXCEPT EU). WRITTEN SIGNED CONSENT OF YOUR PARENT OR LEGAL GUARDIAN MAY BE REQUIRED TO BE SUBMITTED TO US AT [email protected] IF YOU ARE UNDER THE LEGAL AGE IN YOUR TERRITORY BEFORE YOU CAN PROVIDE ANY PERSONAL INFORMATION TO US FOR PURPOSES OF REGISTRATION, ACCESS OR USE OF THE ISINA PLATFORM. PLEASE REACH OUT TO [email protected] IF YOU HAVE ANY QUESTIONS REGARDING THIS REQUIREMENT AND PROVIDE US WITH THE INFORMATION ABOUT YOUR TERRITORY IN ORDER TO ASSIST YOU. YOU EXPRESSLY ACKNOWLEDGE AND AGREE THAT YOU MAY NOT REGISTER YOUR ACCOUNT WITHOUT MEETING LEGAL AGE REQUIREMENTS OF YOUR TERRITORY
Like other websites, ISINA uses “COOKIES” on the Platform. Cookies are small pieces of information that we place on your computer to help us accurately understand how many times you visit our Platform and what content you are most interested in. For example, a cookie will allow us to remember certain things based on your Internet Protocol (i.e., “IP address”), such as the time and duration of your visits, how you navigated through our content and where you exited a particular site. If you do not want us to use cookies, you can easily disable them by going to the toolbar of your web browser, and clicking on the “help” button. Follow the instructions that will prevent the browser from accepting cookies, or set the browser to inform you when you receive a new cookie.
ISINA engages other companies and individuals to perform functions on our behalf, such as, but not limited to, sending postal mail and email, processing credit card payments, posting and responding user feedback and inquiries, enabling additional feature functions on the Platform, and more. These companies and individuals have access to personal information needed to perform their business functions, but may not use your information for other purposes. In addition, from time to time, we may send you special offers, advertisements, or promotional materials, unless you choose to “opt out” from receiving such offers either by clicking on the “opt out” or “unsubscribe” buttons, links or hyperlinks provided by us in our communications with you or by sending us a request in the dedicated customer service areas on our Site (s) intended for such customer communications or via sending us a specific request via email to [email protected]. We may offer promotions in conjunction with a sponsor, and may share your information with these sponsors. In the event that you want to “opt out” of the use of your information in such sponsor promotions, you may send us a request to do so via the process described directly above or by choosing to “opt out” by the method we provide in connection with such sponsor promotions after identifying the sponsor to you. We may also use your personal information for internal and/or marketing studies, so we can improve the products and services we provide you. We may sell, transfer or otherwise share some or all of ISINA’s assets, including your Personally Identifiable Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. If we receive a lawful court order to release account or other personal information then we will comply with the applicable law (e.g., subpoenas).
Since our goal is to help you make meaningful experience, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, with other ISINA affiliated and related companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.
• With other users:
You share information with other users when you voluntarily disclose information on the Platform (including your Platform profile). Please be careful with your information and make sure that you are comfortable with the public view of the information and content that you share . You acknowledge that neither you nor we can control what others do with your information and content once you share it. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your Profile settings. ISINA is committed to continuously improving the functionality aspect of the Platform and new settings features will be available with the latest Platform system versions and updates allowing you to customize your permissions in Profile settings, including the limitations for certain content and information about you. Other users of the Platform may access and view your profile information (except your email address), listen to audio and video works submitted to ISINA by you, comment in designated areas of the Site(s), view your information and interact with you on the active post feed. ISINA Platform provides statistics for the registered profile owners and users and visitors on the Platform will be able to see the ratings and rankings in connection with the uploaded audio and video works. This allows the creators to track the popularity of the musical work. In any areas on the Platform where you are allowed to comment, your information will be viewable and accessible to other registered users of the ISINA platform.
• With our service providers and partners:
We use third parties to help us operate and improve ISINA services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, security operations and more. We may also share information with partners who distribute and assist us in advertising our services and assist us with various promotional campaigns for our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising and promotional campaign partners or third party servicers. We follow a strict vetting process prior to engaging any service provider or working with any partner or entity. All of our service providers, partners or engaged third party entities must agree to strict confidentiality obligations before working with ISINA or having access to our Services or collected information.
• With other ISINA affiliated businesses:
We share your information with other ISINA affiliated companies to benefit you in two respects: for other companies to assist us in processing your information, as service providers, upon our instructions and on our behalf. Assistance provided by other companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users’ behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
We may also share information with other companies for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. We may share user information with other companies to remove users who violate our Terms of Use, or have been reported for criminal activity and/or inappropriate behavior. In some instances, we may remove that user from our Platform, terminate account and forbid further access to our Site (s).
• For rightsholders:
You can listen to a variety of musical works on the Platform submitted by us and other registered users. We may share personal data directly with the rightsholders or the associations or entities representing the rights of such interest holders when our contracts with such entities or rightsholders state that they will be granted these insights. We may share personal data with the associations processing royalties’ payments for the rightsholders. The interest of the rightsholders prevails over your legitimate interest in the safekeeping of your public profile information and basic usage data.
• For corporate transaction
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
• When required by law:
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements according to applicable law; (ii) to assist in the prevention or detection of crime or other wrongdoing (subject in each case to applicable law); (iii) to protect the safety of any person; (iv) and in other circumstances when such disclosure is reasonably necessary.
• To enforce legal rights:
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit, alleged or threatened claim; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
• With your consent or at your request:
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other companies and third parties (notably advertisers and sponsorship entities) to develop and deliver targeted advertising for our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional nonpersonal information or personal information in hashed, non-human readable form collected from other sources.
We may use cookies and similar technologies (e.g., technologies identifying device(s)) to recognize you and your device(s) on and off the Platform, and across devices. We may allow third parties to use cookies in order to track user behavior on the Platform and to show you ads based on your interests. You can control cookies through your browser’s settings. You consent to the use of the cookies which are necessary for us to provide you with the Services. ISINA is striving to develop its Platform and functionalities by constantly developing and upgrading the tools available to you. Please review the Privacy Policy for the updates regularly. We will notify you when and if your user profile account settings are upgraded to more functionality and tools in managing your experience and permissions, including cookies permissions.
Sharing of information sometimes involves cross-border data transfers, for instance to and from the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as where you live. If you are located outside the United States and choose to provide information to us, we may transfer your Personally Identifiable Information to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. In certain instances and territories, your Personal Identifiable Information may be processed outside of the territory you are in (for example, outside of EU) and such processing may involve data protection risks.
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We utilize and maintain technical safeguards designed to prevent unauthorized access, use or disclosure of Personally Identifiable Information we collect or store. ISINA continually works to improve its level of security and monitors its systems for this purposes. You understand, acknowledge and agree that there are assumed risks that may be involved with our processing operations and you provide us with your personal data at your own discretion and risk.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately via the communication channels provided by us to you or by sending an email to our Legal Department at: [email protected].
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three (3) months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after three years of continuous inactivity, unless:
1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one (1) year to comply with statutory data retention obligations);
2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five (5) years);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
“Opt-out” option exists when you do not want ISINA to send you emails or special offers from us. You may “opt-out” from receiving information from us at any time. You may “opt out” of email communications from ISINA at any time by clicking on the “unsubscribe” link found at the bottom of every email. Requests are processed as they are received; however, some email communications are planned in advance and may continue to be sent for a few days following your unsubscribe request. You may also contact us directly at [email protected] with the request to opt out by specifying the ISINA communications you wish to opt out of. We will be updating settings for “opt-out” in the future updated versions of the Platform. Please review and refer to the latest version of this Privacy Policy document on the Site (s) of ISINA for additional updates with regards to “opt-out” functionality.
Consistent with the Children’s Online Privacy Protection Act (“COPPA”), ISINA does not knowingly collect or solicit personal information from children. ISINA Platform is not directed to children under 13 years of age. If a parent or guardian becomes aware that his or her child has provided us with Personally Identifiable Information without their consent, he or she should contact us at [email protected]. If we become aware that a child under 13 years of age has provided us with Personally Identifiable Information without verifiable parental or guardian consent submitted to us for verification purposes and our express approval, we will delete such information from our files.
We will occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the "EFFECTIVE DATE" date at the bottom of this Privacy Policy and will include the links to prior dated version(s) of the Privacy Policy. We recommend that you check our Service from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.
In case of making significant changes, we will notify you before any material changes take effect, through our applications or by other means of communication, for example, by email, and to the extent permitted by applicable law we will provide you with sufficient time to review the changes. Your use of the ISINA Services after receiving such notifications means your acceptance of the amended Policy.
We recommend that you check our Service from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.
To update or correct your information and privacy preference, you may write to ISINA at:
ISINA Academy, Inc.
637 S. Fairfax Ave, Suite 102
Los Angeles, CA 90036, USA
YOU CAN USE THE SAME CONTACT INFORMATION ABOVE TO REQUEST INFORMATION UNDER CALIFORNIA CIVIL CODE SECTION 1798.83.
If you are a registered user residing in the EU/EAA, you may contact us at [email protected] with any questions regarding this Privacy Policy or if you need to exercise any of the rights described in this Privacy Policy. ISINA will respond within a reasonable time frame. Please note that verification of your identity will be necessary before taking any further action on your request and we may ask you to provide all necessary forms of identification in compliance with applicable law.
The effective date of this Privacy Policy is July 30, 2024.
