PRIVACY POLICY - Sony Music Middle East

This Policy is effective from 31 July 2024

To Read the Arabic Version Click Here

This privacy (“Privacy Policy”) explains the practices of Sony Music Entertainment
Middle East FZ LLC (“SME”) in relation to the collection, use and disclosure of
personal data on our websites, online and offline services, landing pages, apps, online
stores, podcasts, email correspondence, and any other site dedicated to the release
of Sony Music Entertainment products or services ( “Sites”), together with any entity
of Sony Music Entertainment using your data in accordance with this Privacy Policy
(collectively, “Sony Music,” “we,” “us,” “our”). Sony Music ME is a company
registered in United Arab Emirates whose registered address is P. O. Box 502812,
Office 210-212, Building 6, Dubai Media City, Dubai, United Arab Emirates.
Please read the text carefully to understand our views and practices regarding your.
By accessing this system you have consented for us processing the personal data in the manner as detailed herein.

1.APPLICATION OF THIS PRIVACY POLICY

1.1 This Privacy Policy (“Policy”) forms a part of the Terms and Conditions
(“Terms”) relating to the use of the Sony Music Sites and the Cookies Policy
found here.

1.2 Sony Music Entertainment Middle East FZ-LLC (“SME”, “we” “us” or “our”) is
committed to safeguarding the privacy of the personal information that is
provided to us or collected by us during the course of our business as well as
the personal information we receive from you (“User”, “you” or “your”) to the
Sites. This Policy, describes how and why we collect, store and use personal
information, and provides information about your rights. Please read the
following information carefully to understand our views and practices regarding
how we handle personal information.

1.3 For the purposes of applicable data protection law, SME is the “data controller”
of your personal information and data.

1.4 For purposes hereof, “services” means and includes access to and use of the
Sites.

1.5 Please read the text carefully to understand our views and practices regarding
your personal data and how we will treat it.

2.COLLECTION OF PERSONAL INFORMATION

2.1 By using the Sites, you consent to our collection, use and disclosure of your
personal information in accordance with the terms of this Policy.

2.2 Please refer to section 8, below, regarding how we use your data and the
purposes for which we process your data.

2.3 You may withdraw such consent at any time, however this will not affect the
lawfulness of the processing based on your consent prior to the withdrawal, or
where we have other legitimate interest and reasons for processing your personal data.

3.MINORS

A SPECIAL NOTE TO CHILDREN UNDER 18YEARS OF AGE
YOU MUST BE 21 YEARS OF AGE OR OLDER TO REGISTER WITH OUR SITE.
PLEASE DO NOT REGISTER IF YOU ARE UNDER 18 YEARS OF AGE.

We are committed to complying with Federal Law No.3 of 2016 on child rights
(Children’s Law). Our site and services are not directed to children under the
age of 18. We do not knowingly collect personal information from children
under the age of 18. If a user identifies him or herself as a child under the age
of 18, we will not collect, store or use any personal information. If we receive
personal information that we discover was provided by a child under the age
of 18, we will promptly destroy such information.

A SPECIAL NOTE TO PARENTS AND SCHOOLS

While we prohibit registration by children under the age of [18], parents and
schools should supervise their children’s online activities and consider using
parental and school control tools available from online services and software
manufacturers that help provide a child-friendly online environment. These
tools can also prevent children from disclosing online their name, address, and
other personal information without parental and school permission. The term
“parents” also includes legal guardians.

4.HOW WE COLLECT YOUR DATA

We may collect and process the following personal information:

4.1 Information you give us

We may collect and process personal data relating to you by you providing
such personal data by filling in forms on our site or by you contacting us or by
corresponding with us by phone, e-mail or other electronic means (including
accepting online “remember me” functions). This includes, but is not limited
to, information provided at the time of registering to use (or become a member
of) our Sites, subscribing to any services (e.g. newsletters, podcasts or voice
activated content, alerts, special invitations), promotions, purchasing
downloads or other products, posting material, participating in contest or
opportunity or requesting further services
When you participate in a promotional offer, then we may request and process
with your consent for your personal information including your name, home or
work address, telephone number and e-mail address bank details / financial
information or identification details so we can administer the promotion. We
may share this information with business partners of ours participating in or
supporting the promotion.
If you contact us by email, you’ll be sharing with us your email address, name,
and any other personal data you might include in your message.
If you enter a Sony Music contest on social media by commenting on a post,
or posting to your profile using the contest hashtag, we will collect your
username, and sometimes your name, in order to randomly select the winners
and contact you via direct message if you are a winner
Further we may collect the following categories of personal data from you:

Contact information, including name, email address, street or mailing address,
and telephone or mobile phone number;
Billing information, including billing address, order details and other
commercial information;
Demographic information, including age, date of birth, gender, interests,
country, and post code;
Unique online identifiers, including username and password, and your device’s
Internet Protocol (“IP”) address;
Preferences and other information, including product wish lists, order history
and marketing & listening preferences;
Geolocation information, including your actual or approximate location (for
example, from the IP address of your device or computer);
Photos, videos, and other content that you submit on our Sites, which may
include metadata which can reveal further information about the content,
including but not limited to where and when images were taken;
Audio, video or audio-visual recordings or photos (in as far as they may feature
you) taken at events hosted by or on behalf of Sony Music, or on set at one of
our podcast recordings or content shoots;
Internet and other electronic network activity; and
Other information you provide to us in connection with a request (including
without limitation information about your health relating to access or special
requirements at events or productions hosted by or on behalf of Sony Music).

– 4.1.1 Arists and Labels
If you are an independent artist or label client (for example, a label distributing
their music through a Sony Music-owned distribution platform) engaging with
Sony Music’s client-facing Site(s), services, or tools, in certain cases we may
collect the following additional categories of personal data:
Your trading or company name, and company number (if applicable);
Contact information of authorized representatives and employees, including
name, email address, street or mailing address and telephone or mobile phone
number;
Accounts payable information, which may include bank account details and
applicable tax forms;
Limited identification documents, such as passport or driving licence, and proof
of address such as utility bills or credit card statements;
Information provided on identification documents, such as nationality, gender,
date of birth, place of birth.
We may collect personal data from the following sources:
From the user
We may collect and process personal data that you provide to us by filling in
forms on our Sites, or by you contacting us. This includes, but is not limited
to, information provided at the time of registering to use (or become a member
of) any of our or our artists’ Sites, subscribing to any of our services (such as
newsletters, podcasts or voice activated content), purchasing downloads or
other products, posting material, participating in a contest or opportunity, or
requesting further services.
If you contact us by email, you’ll be sharing with us your email address, name,
and any other personal data you might include in your message.
If you enter a Sony Music contest on social media by commenting on a post,
or posting to your profile using the contest hashtag, we will collect your
username, and sometimes your name, in order to randomly select the winners
and contact you via direct message if you are a winner.

– 4.1.2 From third parties with the user’s consent
We may collect your personal data when you access our services, participate
in a Sony Music campaign or contest, or otherwise contact Sony Music, by
using your account credentials from your social media accounts (such as
Facebook, Google, or X) or content streaming services (such as Spotify or
YouTube), or by clicking ‘like’ or ‘share’ on such third-party platforms. For
example, you might use your Spotify credentials to participate in an artist’s
pre-save contest or a campaign that generates a personalised playlist, or you
might submit a form using your Facebook credentials to sign up to receive an
artist’s newsletter.
Depending on the platform, Sony Music may receive general information and
contact information (such as, name, username, profile picture, email address,
age, date of birth, gender, country), technical or financial information (such as
type of computer, or type of service or chosen subscription model), and/or
information about your actions and behaviours on the applicable platform
(which may include frequency of use, activity, followers, date of registration,
artists and songs most listened to and artists or pages followed or liked).
This information will only be collected by Sony Music should you subscribe or
engage with Sony Music or its artists or content by using the log-in credentials
of your social media or streaming platform account, and only after you have
been informed about the sharing of such information by way of this Privacy
Policy and the privacy notice served to you by the applicable platform setting
out the permissions to be granted to Sony Music and how your data shall be
processed in these cases.
In addition to fulfilling the purpose(s) of your registration (such as pre-saving
an artist’s release, signing up to an artist newsletter, or entering a contest),
Sony Music may file, organise, consult, store, use for profiling, and cross-
compare such personal and behavioural information with the personal data
provided by you as described above so that we may enhance your online
experience, measure our audience, and provide you with tailored marketing
and advertising content, which might include sending you information about
other artists, events, content, products or services based on your listening
preferences or use that may be of interest you,.
At any time, you can remove Sony Music’s access permissions on your account,
and stop the applicable platform from sharing with us further personal data
relating to your account, either by emailing
[email protected] and/or changing the data privacy
settings on your account page on the applicable platform.
You don’t need to share such platform account information to enjoy Sony Music
content, sign up to an artist’s newsletter, enter a contest, or join in with most
Sony Music campaigns. For example, you could fill in the form yourself, or
pre-save the album next time you’re on your streaming account. However,
without account information and permissions from such platforms, we won’t
be able to generate certain personalised content (for example, a playlist based
on your favourite songs, but you’ll still be able to enjoy the artist’s official
playlist on your streaming service).
We have set out below the information and access each platform may share
with us, subject to your agreement and/or depending on the configuration of
your settings when using the platform:

– 4.1.3 Spotify
By clicking the ‘Spotify Connect’ button on a Sony Music Site, and then clicking
‘Agree’ on the permissions pop-up, you agree to Spotify sharing the following
personal and account information with Sony Music and letting us take certain
actions on your account (until you remove those permissions and stop Spotify
sharing your information with us):
Sony Music will be able to view your Spotify account data, as follows:
your email address;
the type of Spotify subscription you have;
your account country;
your settings for explicit content filtering;
your name and username;
your profile picture, if applicable; and
how many followers you have on Spotify, and your public playlists.
Sony Music will be able to view your activity on Spotify (limited to the 50 most
recent records, unless otherwise stated), as follows:
content you’ve recently played;
what you’ve saved in your library;
the artists and content you listen to most (limited to the 10 most recently
played artists and tracks each week);
who you follow on Spotify;
playlists you’ve made and your collaborative playlists (limited to the 10 most
recent playlists);
collections you’ve made;
playlists you follow; and
your podcast subscriptions.
Sony Music will be able to take the following actions on Spotify on your behalf
(solely for the purpose of following the relevant artist and saving or pre-saving
the relevant playlist or release, or generating your personalised playlist, as
applicable depending on the purpose of your interaction):
upload images to personalise your profile or playlist cover;
add and remove items in your library;
create, edit, and follow private playlists;
create, edit, and follow playlists; and
manage who you follow on Spotify.

– 4.1.4 Apple Music
By clicking the ‘Apple Music’ button on a Sony Music Site, and providing your
email address (the email you use for your Apple Music account) on the pop-up
form, you agree to Apple Music sharing the following personal and account
information with Sony Music and letting us take certain actions on your account
(for 60 days or until you remove those permissions and stop Apple Music
sharing your information with us, if sooner):
Sony Music will collect your email address (and first name if applicable) as
provided by you on the Apple Music permissions form.
Sony Music will be able to view your activity on Apple Music (limited to the 50
most recent records), as follows:
the artists to which you’ve recently listened;
the albums or tracks you’ve recently added to your library; and
the artists you listen to most.
Sony Music will be able to take the following actions on Apple Music on your
behalf (solely for the purpose of saving or pre-saving the relevant release to
your Apple Music library, or generating your personalised playlist, as applicable
depending on the purpose of your interaction):
upload images to personalise your profile or playlist cover;
add and remove items in your library;
create, edit, and follow private playlists;
create, edit, and follow playlists; and
manage who you follow on Apple Music.
Facebook
By clicking the ‘Facebook’ button on a Sony Music Site, and clicking ‘Continue
as… [your Facebook username]’ on the permissions pop-up, you agree to
Facebook sharing the following personal and account information with Sony
Music (for 60 days or until you remove those permissions and stop Facebook
sharing your information with us, if sooner):
Sony Music will collect and/or be able to view your Facebook account data, as
follows:
your email address;
your name;
your profile picture, if applicable;
your username if available;
your website, if applicable;
your birthday;
your gender; and
your city.
Sony Music will be able to view your activity on Facebook (limited to your 25
most recent statuses unless otherwise stated), as follows:
the pages you ‘like’ (limited to your 25 most recently liked pages);
if you ‘like’ a Sony Music artist’s page;
if you’ve mentioned a Sony Music artist in a post or on your profile;
if you’ve posted on a Sony Music artist’s page;
if you’ve shared on your profile a photo from a Sony Music artist’s page;
if you’ve shared on your profile a status from a Sony Music artist’s page; and
if you’ve tagged a post or photo with a Sony Music campaign hashtag.
Google
By submitting your details on a Sony Music form by clicking the ‘Google’ button,
and clicking ‘Next’ on the permissions pop-up, you agree to Google sharing the
following personal data and user preferences with Sony Music:
Sony Music will collect and be able to view your Google account data, as
follows:
your email address;
your name;
your language preferences;
your profile picture, if applicable;
your username;
your bio, if applicable;
your gender;
your city; and
your country.

– 4.1.5 X (formerly Twitter)
By clicking the ‘X’ or ‘Twitter’ button on a Sony Music Site, and clicking
‘Authorize app’ on the permissions pop-up, you agree to X sharing the following
personal and account information with Sony Music (until you remove those
permissions and stop X sharing your information with us):
Sony Music will collect and/or be able to view your X account data, as follows:
your email address;
your name;
your profile picture, if applicable;
your username;
your website, if applicable;
your bio; and
your city or country.
Sony Music will be able to view your activity on X (limited to your 60 most
recent posts unless otherwise stated), as follows:
the accounts you follow, mute, and block (limited to 5,000);
your posts;
if you’ve mentioned a Sony Music artist in a post on your account;
if you’ve retweeted a Sony Music artist’s post;
if you’ve shared on your X account a Sony Music artist’s TikTok video;
if you’ve shared on your X account a Sony Music artist’s Discord server; and
if you’ve posted on X using a Sony Music campaign hashtag.
YouTube
By clicking the ‘YouTube’ button on a Sony Music Site, and clicking ‘Next’ on
the permissions pop-up, you agree to YouTube sharing the following personal
and account information with Sony Music and letting us take certain actions on
your account (until you remove those permissions and stop YouTube sharing
your information with us):
Sony Music will be able to view your YouTube account data, as follows:
your email address;
your name and username;
your gender; and
your profile picture, if applicable.
Sony Music will be able to view your activity on YouTube (limited to the 50
most recent records), as follows:
videos you’ve liked;
videos you’ve marked as a favourite; and
your channel subscriptions.
Sony Music will be able to take the following actions on YouTube on your behalf
(solely for the purpose of subscribing to the applicable artist’s or label’s channel
if that is the purpose of your interaction):
manage your channel subscriptions.

– 4.1.6 Deezer
By clicking the ‘Deezer’ button on a Sony Music Site, and clicking ‘Accept’ on
the permissions pop-up, you agree to Deezer sharing the following personal
and account information with Sony Music and letting us take certain actions on
your account (until you remove those permissions and stop Deezer sharing
your information with us):
Sony Music will be able to view your Deezer account data, as follows:
your email address;
your name and username;
your birthday;
your gender;
your country; and
your profile picture, if applicable.
Sony Music will be able to view your activity on Deezer (limited to the 25 most
recent records unless otherwise stated), as follows:
content you’ve recently played;
artists you’ve added as a favourite;
tracks you’ve added as a favourite (limited to the most recent 50);
albums you’ve added to your library or a collection;
playlists you follow; and
your top content (limited to your 25 most played tracks since opening your
account).
Sony Music will be able to take the following actions on Deezer on your behalf
(solely for the purpose of following the applicable artist on Deezer and saving
or pre-saving the applicable playlist or release, or generating your personalised
playlist, as applicable depending on the purpose of your interaction):
upload images to personalise your profile or playlist cover;
add and remove items in your library;
create, edit, and follow private playlists;
create, edit, and follow playlists; and
manage who you follow on Deezer.

– 4.1.7 Other sources of information
We may receive information about you from other sources, including:
Artists and their representatives: such as marketing data from a new or
partnering artist, which is integrated with information we already have about
you to create a more tailored fan experience;
Business partners: such as contest providers and other promotional partners,
sub-contractors in technical, payment and delivery services, advertising
networks, analytics providers and others who enable sign-on functionality and
social network integration;
Publicly available databases;
Other applications: such as streaming sites and social media platforms not
specifically referenced above, which may share similar account information and
permissions;
Information you disclose publicly: our Sites and our artist, label, podcast and
product pages on third-party platforms may offer message boards, chat rooms,
games, and other public areas (collectively, “Community Forums”) where you
can engage in social networking, interact with others, as well as have the
opportunity to submit photographs, writings, music, video, audio recordings,
computer graphics, pictures, data, questions, comments, suggestions or other
content (collectively, “User Submissions”);

– 4.1.8 Your contacts
As part of a Sony Music campaign, one of your contacts may provide us with
personal data relating to you. Participants in such campaigns are encouraged
to seek the person’s consent before referencing or nominating someone else
in a contest entry or content submission. We will only use this information for
the specific purpose for which it is provided. If you believe that one of your
contacts has provided us with your personal data without your consent, and
you would like to request that it be removed from our systems, please contact
At your direction, your authorised representative(s) (for example, a manager,
lawyer, or accountant) may share your personal data with us.

– 4.1.9 Collection societies
If you are an independent artist or label client registered with the collection
societies around the world may share your personal data with us if you have
directed them to do so.
The above information may be combined with personal data we already have
about you, which helps us to update, expand and analyse our records, identify
new customers, and provide content and services that may be of interest to
you.

4.2 Information we collect about you
With regard to each of your visits to our Sites, we may automatically collect
the following information:
i. technical information, including the Internet protocol (IP) address used to
connect your computer to the Internet, browser type and version, time zone
setting, browser plug-in types and versions, operating system and platform;
ii. by using cookies and tracking technologies: we may use ‘cookies’ to collect
data relating to your general internet usage, information about your visit;
services you viewed or searched for; page response times, download errors,
length of visits, page interaction information (such as scrolling, clicks, and
mouse-overs). In addition, we use technology on our Sites, services, and
content to collect information that helps us to enhance your online experience,
measure our audience and provide you with tailored advertising based on your
behaviour on our Sites, and interactions with our content, and, if applicable,
your behaviour on the aforementioned social media platforms and streaming
services
A ‘cookie’ is a small text file that is placed on your computer’s hard drive.
Cookies help us to improve our site and to deliver a better and more
personalised service, for instance by storing information about your
preferences and allowing us to recognise you when you return to our site.
We refer to this technology as “cookies” throughout this Privacy Policy, but this
is intended to cover all similar technologies including web beacons, log files,
pixel tags, gifs. We use our own and third-party cookies to collect the
information we require. For more information see “Cookies and other tracking
technologies” below.
Sometimes we receive information about you from third parties in other
circumstances. For example, if you use a ‘like’ or a ‘share’ button for a feature
on our Sites then the third-party platform will share information with us. If you
participate in activities on other third-party sites or apps, such as participating
in a Facebook application, you may allow us to have access to personal data
held by Facebook, or other site or app owners as applicable.
If, at some point, we provide online services to a child under 18 years old,
where we need parental consent for this, we may ask for a parent’s or legal
guardian’s email address in order to ask for consent.
You may refuse to accept cookies by activating settings on your internet
browser. However, please note that if you select such settings you may be
unable to access certain parts of our site.

5.HOW WE SHARE YOUR DATA

We may share your personal data with the following categories of recipients
(which may be located outside your territory of domicile and/or residence):

Other Sony Music entities and Sony Group companies. We may share your
personal data with other affiliated Sony Music entities, as well as with Sony
Group companies worldwide, for the purposes listed in this Privacy Policy

Artists & artists’ representatives. We may share your personal data with
artists (and their management companies) about whom you have requested
to receive updates, who may then use your personal data to keep you updated
with information about them.

Suppliers and vendors. We share personal data with suppliers and vendors
who perform functions on our behalf, such as hosting or operating our Sites,
sending e-mails, and carrying out data analysis.

Other third parties. We may transfer or assign personal data to third parties
in connection with the sale, merger, consolidation, change in control, transfer
of substantial assets, reorganisation or liquidation of Sony Music, or any part
of it.

We may share with other third parties, at our discretion, certain aggregate
statistical data about purchases and the use of our content, which data may
include demographic data such as the age range and/or geographic location of
groups of users. No personal data (such as names or email addresses) will be
directly identifiable from such statistics.

To enforce legal rights and comply with applicable laws. We may
disclose personal data in special cases when we have reason to believe that
disclosing this data is necessary to identify, contact or bring legal action against
someone who may be causing injury to or interference (either intentionally or
unintentionally) with the rights or property of Sony Group companies or artists,
or to otherwise comply with applicable law. Personal data may be shared with
government authorities and/or law enforcement officials if required for the
purposes above, if mandated by law or court order, or if required for the legal
protection of our legitimate interests in compliance with applicable laws.

At your instruction or direction. We may disclose personal data when
instructed or directed by you to do so, including when you decide to participate
in certain types of activities that necessitate your personal data being shared.
For example, your personal data may be shared with:

Podcasts. If you consent to receive direct marketing about a particular
podcast, or submit content for consideration in a podcast, or participate in a
podcast call-to-action, we may share your personal data with the podcast
operator, who may then use your personal data to keep you updated about the
podcast, or contact you about your participation or User Submission, as
applicable.

Independent artist or label clients. Some of our marketing and pre-save
campaign tools are used by independent artist and label clients to promote
their content directly to their audience. When you request to join their mailing
list via our Sites or services, we may share your personal data with the
applicable independent label or artist (or their management company), who
may use your personal data to keep you updated with information about them,
subject to their own privacy policy.

Event promoters. Where you have asked to receive updates from an event
promoter, by ticking their newsletter opt-in on a Sony Music form, we will share
your name and email address as requested by you. The promoter will have
their own privacy policy, which we encourage you to read before you choose
to receive marketing from them.

Co-promoters and prize providers. Where a Sony Music related contest is
managed or co-promoted by a third party, or the prize is provided and/or
fulfilled (in part or in full) by a third party, we will share each winner’s basic
contact information for the purpose of managing the contest and fulfilling the
prizes. Where a prize includes attending an event, each winner’s full name will
also be shared with the venue or event promoter, and they may request to see
the winner’s ID before allowing entry to the event. Each winner’s surname and
city may also be included on a winners’ list if another contest entrant asks who
won.

Collection Societies. If you are an independent artist or label client registered
with copyright societies, we will share your personal data with applicable
collection societies if you direct us to do so.

If you post content directly to a Sony Music Site, or to an artist’s social media
account, anyone may be able to see it. Particularly if you are under 18, we
encourage you to set your social media accounts to ‘private’ so that only people
you know can see your posts and personal data.
When you upload your content via a Sony Music form as part of a “user-
generated-content” opportunity, if we include your content in the final product
then anyone will be able to see it. For example, we may publish an online
gallery, or make a video for social media featuring contest winner’s videos,
along with first name and city. Users aged under 18 will need parental
permission before sharing such content with us.

6.SECURITY

6.1 We use up to date information storage and security to hold your personal
information securely in electronic and physical form to protect your personal
information from unauthorized access, improper use or disclosure,
unauthorized modification or unlawful destruction or accidental loss. Whilst we
have put in place physical, electronic and managerial procedures to secure and
safeguard your personal information, we will not be held responsible for any
unauthorised access by third parties and we cannot guarantee that the
personal information provided by you or that is transmitted via your
transmission of information visa the internet, the Sites or by e-mail is totally
secure and safe and you provide it at your own risk. By accessing this system
you have consented for us processing the personal data in the context of the
relevant service as detailed herein.
6.2 Where we have given you (or where you have chosen) a password which
enables you to access certain parts of our site, you are responsible for keeping
this password confidential. We ask you not to share the password with anyone.
6.3 We are committed to ensuring that your information is secure. In order to
prevent unauthorised access or disclosure, we have put in place appropriate
physical, electronic and managerial procedures to safeguard and secure the
information we collect.

7.CROSS BORDER TRANSFER

7.1 The data that we collect may be transferred to, and stored at, a destination
outside the Territory, for instance if any of our servers from time to time are
located outside the Territory or if one of our service providers or suppliers is
located in a country outside the Territory or if we share your data (in
accordance with the ‘With whom we share your data’ section below).

7.2 Where any of those destinations are countries that do not have data protection
laws as stringent as those to which we are subject, we will take all steps
necessary to ensure that your data is only transferred lawfully out of the
Territory, and used in accordance with this privacy policy.

7.3 You expressly consent to the transfer of your personal information to, and the
collection and processing of such personal information in a destination outside
the Territory where we or our vendors operate. In giving this consent, you
acknowledge that you understand that the laws on holding, processing, using
and transferring personal information in those territories may vary and be less
protective of your privacy than laws of your state or country.

8.HOW WE USE YOUR DATA

8.1 We use your personal information and data for the following purposes where
permitted by applicable law as follows:
To fulfil a contract, or take steps linked to a contract

to process your registration on one of our Sites in accordance with the
applicable terms of service or terms of use;
to fulfil our obligations and enforce our rights and remedies under a contract;
to process your entry to any contest or user-generated-content opportunity we
run, and to record your agreement to the corresponding contest rules and, if
applicable, the accompanying disclaimer / release form; or
to send you information about changes to our terms or policies or other
relevant updates.
Where this is necessary for purposes which are in our or third parties’
legitimate interests. These interests are (without limitation):
to provide you with access to content and features on our Sites and artists’
sites;
to send you information you have requested from us or our artists;
to ensure the security of our Sites and apps by trying to prevent unauthorised
or malicious activities; identify fraudulent activities and transactions; prevent
abuse of and investigate and/or seek prosecution for any potential threats to
or misuse of our Sites or services; ensure compliance with the applicable terms
of service and this Privacy Policy; investigate violations of or enforce these
agreements; and otherwise to protect the rights and property of Sony Music,
its partners and customers.;
to investigate violations of or enforce compliance with our terms of use, this
Privacy Policy and other applicable policies; and to help other organisations
(such as copyright owners) to enforce their rights;
to personalise content, advertising, marketing and offers for you, which may
include providing information about artists, podcasts, live events, products, or
services based on your listening preferences or use that may be of interest
you;
to invite you to submit your content for potential inclusion in an artist’s
campaign or podcast episode; and
for internal analysis to measure our audience, improve our product range and
enhance the Sony Music user experience.
When you submit your details to receive marketing from Sony Music, we may
undertake limited profiling activities to personalise such marketing, whereby
we combine the personal data and any other information provided by you with
additional information lawfully collected by Sony Music, such as your
navigation of Sony Music’s Sites, and how you interact with Sony Music
communications you may have received by any means authorised by you.
When you access our services, participate in a campaign, or otherwise interact
with Sony Music by using your social media or content streaming service
account credentials, Sony Music may also take into account your behavior on
the applicable platform based on the data shared with Sony Music by such
platform with your consent. Such information may be used for internal analysis
so as to measure our audience and enhance the Sony Music user experience,
and to identify and create audiences for the Sony Music artists, products or
services, and where possible to send you more personalised information about
the artist, label, podcast or live event for which you have requested to receive
updates, or about other artists, content, live events, products or services that
may be of interest to you based on your listening preferences or use.
Where you give us consent
Where you ask us to send marketing information to you via a medium where
we ask for your consent (for example, email or SMS marketing or accessing
our Site and accepting the terms via the Click Wrap Agreement), and you tick
the box on the sign-up form giving us your permission to collect and process
your data to send you updates about an artist, label, podcast, live event or
product, and information about special offers and other artists, podcasts, live
events, products or services based on your listening preferences or use.
Where you allow us to share your data with parties from whom you have
agreed to receive marketing, such as artists and their management, or event
promoters.
Where you agree to participate in market research studies (such as a survey
or focus group) conducted by Sony Music or third-party companies on Sony
Music’s behalf, about Sony’s artists, content and products or the entertainment
sector generally.
Where you give us consent to place cookies and to use similar tracking
technologies.
On other occasions where we ask you for consent, for a purpose which we
explain at that time.
For purposes which are required by law.
In response to requests by government or law enforcement authorities
conducting an investigation.

9.HOW LONG WE KEEP YOUR PERSONAL DATA

Your personal data which we collect will be retained for a period necessary to
attain the specified purposes.

10.YOUR RIGHTS

10.1 You can opt out of receiving any further messages from SME or anyone with
whom we share your data (as described above) at any time by following the
unsubscribe instructions in any message sent to you. If you wish to
unsubscribe from messages we send you, you can also send an email to
[email protected]

10.2 You have a right to access or correct the personal data we hold about you. To
obtain a copy of the personal information we hold about you, please write to
us at our registered address provided at the beginning of this privacy policy.

11.LINKS TO THIRD PARTY SITES

11.1 Whilst we endeavour to adhere to our strictest guidelines and select only
reputable partners in providing the service, our privacy protection does not
cover any personal data that you provide directly to third parties (including but
not limited to online merchants sites and other hyperlinked websites). We
advise you to consult with the relevant parties before providing any such data.

11.2 Our website may contain links to other websites which are outside our control
and are not covered by this privacy policy. If you access other sites using the
links provided, the operators of these sites may collect and process information
from you in a way which is different to how we do so.

11.3 These third-party sites may send their own cookies to users to collect data or
solicit personal information. These other sites are not subject to our Privacy
Policy and we are not responsible for the privacy policies of these third-party
sites, or for the use of any information that these sites may collect.

12.CHANGES TO OUR PRIVACY POLICY

By using this Site, you consent to the collection and use of your personal
information as described above. We are sensitive to users’ privacy issues and
recognize the need to update this policy as new features and business services
are offered by us. Accordingly, we may modify, alter or otherwise update this
privacy policy at any time. We will indicate any changes by updating the date
at the top of the policy. We encourage you to review this policy from time to
time. Any information collected under our old Privacy Policy will be subject to
the terms of our new Privacy Policy.

13.CONTACT DETAILS

Sony Music Entertainment Middle East FZ-LLC is a company registered in
United Arab Emirates whose registered address is P. O. Box 502812, Office
210-212, Building 6, Dubai Media City, Dubai, United Arab Emirates.
If you have any questions about this Policy, or our processing of your personal
data, please contact us on [email protected]