Privacy Policy

Published: December 18, 2015
Last revised: September 9, 2021

Welcome to the Vertigo® application, a service provided by Vertigo Media, Inc. (“Vertigo”, “we” “our”, “us”). Thank you for your interest in and use of our mobile applications (collectively the "Application" or “Applications”); websites (vertigomusic.com) and any subdomains thereof (collectively "Website" or “Websites”); all related sites, players, widgets, tools, applications, data, software, application programmatic interfaces (APIs), and other services (collectively the "Services"); and all content (“Content”) contained therein. This Privacy Policy applies to the Website, Applications, and Services (together, the "Platform"). References to “you” or “your” mean the person accessing the Platform, including registering for a Vertigo® account.

1. YOUR PRIVACY IS IMPORTANT TO US

This Privacy Policy explains how we collect, store, use, and disclose your information, including any personal information or data, when you use the Platform. By using the Platform, and in particular by registering a Vertigo® account, you are consenting to the use of your information in the manner set out in this Privacy Policy.

This Privacy Policy applies to individuals located in the United States, the European Union (EU), and elsewhere. Specific provisions detailed herein may only be applicable to persons located in certain jurisdiction, e.g., Section 6 (California) and Section 7 (Europe).

For purposes of this Policy, the term “personal data” may be used interchangeably with “personal information” and means any information relating to an identified or identifiable natural person. An “identifiable natural person” is an individual who can be identified, directly or indirectly, by reference to an identifier such as:

• A name (e.g. first names (given names), middle names, and/or last names (surnames));

• A physical address or mailing address including street name; city or municipality; state or region; postal code; and country;

• Online contact information such as an e-mail address;

• A username or handle that functions as online contact information;

• A telephone number;

• A social security number or other identification number;

• A persistent online identifier that can be used to recognize a user over time and across different websites or online services;

• One or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person, including, for example, a person’s height, weight, or hair color;

• A photograph, video, or audio file, where such file contains a person’s image or voice;

• Geolocation information; or

• Anything else about the individual that is collected online and stored by an operator in personally identifiable form.

We are the data controller for the purpose of data protection law with respect to your personal data collected and used through your use of the Platform. This is because we dictate the purposes for which your personal data are used and how we use your personal data.

This Privacy Policy explains the following, among other things:

• Our principles with respect to your information and your privacy

• The information we collect about you

• How we use your information and our legal basis for processing

• How we share your information

• How we use cookies and similar technologies

• Your rights, including your choices, with respect to your information

• How to contact us regarding privacy issues

Please take some time to read this Privacy Policy and our Terms of Use. If you do not agree to any of the provisions of this Privacy Policy, you should not use the Platform. If you have any questions or concerns, you can contact us at [email protected].

Please note that this Privacy Policy applies only to the Platform. When using the Platform, you may find links to other third-party websites, apps, and services or tools that enable you to share information with other websites, apps, and services. We are not responsible for the privacy practices of these other websites, apps, and services, and we recommend that you review the privacy policies of each of these websites, apps, or services before connecting your Vertigo® account or sharing any personal data.

2. OUR PRINCIPLES

We have a pretty simple approach to data protection and privacy, which can be summarized as follows:

YOu should know what we do with your information.

This Privacy Policy is designed to give you transparency regarding our data protection practices. If there’s anything that’s not clear from this Privacy Policy, please feel free to e-mail us at [email protected].

YOu should have full control over your information.

We’ve designed the Platform to give you control over the information you publish and share using Vertigo and other sites and services to which you connect your Vertigo account.

Please take full advantage of these tools and make sure you share only what you want to share.

3. INFORMATION WE COLLECT ABOUT YOU

We collect information about you from various sources:

Information provided by you

You don’t need to provide us with any personal data in order to visit the Website. However, our Platform does require that you register for a Vertigo® account and, by doing so, you will provide us with certain information. Additionally, when you use the Application or interact with us, you may also provide certain information as described below. For more information on how to delete, edit, change, or amend your information, see the “Choice and control” section below.

When you register any kind of Vertigo® account, you will need to provide your full name, e-mail address, date of birth, chosen username, and chosen password. To register for an account via the Application, you must use your phone number, e-mail address (unless you use Sign in With Apple) or your Facebook or Twitter account for single sign-on (more on third-party platforms below in the “How We Share Your Information” section).

You may choose to provide your phone number or gender.

You may choose, at your discretion, to provide additional information for your public profile on the Vertigo® Platform, for example:

* the city and country in which you reside

* a profile picture or avatar

* information about how you categorize yourself with respect to your content (for example, whether you are a musician, a label, or some other category of artist)

* details of your other websites and social media profiles, including links to those websites and profilesCopyright is a legal right that seeks to protect original works of authorship fixed in a tangible medium of expression. Protected works may be visual (paintings, photographs, videos, movies), audio (songs, recordings) or written (books, plays, articles). Copyright protects words or images, not facts or ideas (although it may protect the original words or images used to describe an idea). Copyright doesn’t protect things like names, titles and slogans.

We keep track of your interactions with the Platform, which may include the features you use, the advertising in which you show interest, and the content you encounter.For example, we maintain analytics data such as the number and titles of media tracks you listen to, the content you share with others, the users you follow, and the users that follow you.As this data is essential to the function of the Platform, you may not opt out of our collection and use of such data or information. By accessing or otherwise using any portion of the Platform, you hereby consent to the foregoing collection and use of your activity and behavior for the purposes outlined in this Privacy Policy.

You will provide certain personal data if you contact us by e-mail, the Websites (such as when you complete the forms on the Websites), mail, phone, fax, or other offline means.

If you participate in any survey, you will provide certain personal data as part of your response.

You may provide personal information when you post comments, photos, and video, or contribute to community discussions.

If you participate in any of our marketing promotions, you may provide certain personal data (such as your contact information, date of birth, and other information) that may be required to verify your eligibility or award a prize.

Information we collect automatically

There is certain information that we (or our service providers on our behalf) collect automatically as the result of your use of the Platform or through the use of web analytics services as described in the section on “Cookies” below. This information includes but is not limited to:

• the Internet Protocol (IP) address of the device from which you access the Platform (this can sometimes be used to derive the country or city from which you are accessing the Platform)

• the sites that you visited or services you accessed immediately prior to visiting the Platform

• the specific actions that you take on the Platform, for example visiting pages or screens, streaming or downloading media, sharing media with other users, following or unfollowing other users, posting comments, or performing searches

• any search terms that you may enter

• the time, frequency, and duration of usage

• your browser types and operating systems

• the nature of the device from which you are accessing the Platform, for example, whether you are accessing the Platform from a personal computer or from a mobile device

• information collected through cookies and similar technologies

• information regarding your interaction with e-mail messages, for example, whether you opened, clicked on, or forwarded e-mail messages

• location data: we or our service providers may receive or infer information about your location from a variety of sources. For example, we may use your Internet Protocol (IP) address to identify your general location or we may receive more precise location data from your mobile device (such as via global positioning systems (GPS), cellular towers, or wireless network access points). We may use location data to analyze certain information and to improve our Platform and relevance of the information we provide to you via the Platform.

4. HOW WE USE YOUR INFORMATION

We may use the information that we collect about you for the following purposes:

* To operate and maintain your Vertigo® account, and to provide you with access to the Website and use of the Apps and any Services that you may request from time to time. Your e-mail address and password are used to identify you when you log into the Platform.

* To identify you as the author of comments that you post and/or the other contributions that you make to the Platform.

* To seek your participation in surveys, and to conduct and analyze the results of those surveys, if you choose to participate.

* To administer promotions, and your involvement in them, if you choose to participate.

* To gain an understanding of the types of music, content, or features you and/or other listeners tend to like or dislike.

* To provide information to rightsholders or their service providers for the purpose of compensating artists and other rightsholders for use of content.

* To provide you with technical support.

* To respond to you about any comment or inquiry you have submitted.

* To provide other users with information regarding listening behavior and activity.

* To prevent or take action against activities that are, or may be, in breach of our Terms of Use, Intellectual Property Policy, Community Guidelines, Contest Rules, or any applicable laws or regulations.

* To enable age restrictions.

* To send you service updates and notifications regarding your account and other notifications from time to time. We will exercise due diligence and use commercially reasonable efforts to contact you according to the preferences you communicate to us; however, please note that we must continue to notify you when there are material changes to your account or to policies governing our relationship with you. Please keep your e-mail address updated in your account settings so that you receive notifications from us.

* Any additional information that you provide as part of your public profile may be published on the Platform. This information may be publicly accessible and may be viewed by anyone accessing the Platform. Please bear this in mind when considering whether to provide any additional information about yourself.

* To analyze the use of the Platform in order to improve the Vertigo® Platform and customize it to the needs and interests of existing and potential users.

* To show you ads on behalf of advertisers. (Currently, we do not partner with any advertisers.)

We use information that you make available to us when you interact with the Platform directly or through third-party services. This allows us to show you ads that are more relevant and interesting to you.

Instead, advertisers pre-define specific audiences by certain criteria (e.g. age range, interests, locations, or the number of followers of users) for specific ad campaigns. If information about you matches these criteria, we may choose to display a suitable ad to you.

We may also display ads based on the content that you have recently viewed or searched.

We may share personal information with our service providers in order to deliver advertising to you. These will then be shared with us or a respective service provider.

5. HOW WE SHARE YOUR INFORMATION

We will not share your information with any third party except as described in this Privacy Policy. We do not sell your information to anyone for advertising or other purposes. There are circumstances in which we may need to share some of the information we collect about you or the information you provide to us. These circumstances are as follows:

Any information in your public profile will be accessible by other users of the Platform, who may view your profile information, listen to your shared playlists, add themselves to your list of followers, send you messages, or utilize other features that may allow them to communicate with you or view information about you. If you comment on any content on the Platform, your comments may be available to all users of the Platform.

If you choose to connect your Vertigo® account to other apps, such as Apple Music or Spotify, or social networks, such as Facebook or Twitter, you will share certain information with those apps or networks. Any new content that you publish to the Platform may be shared to connected networks and may be visible to your followers and friends on those networks, in accordance with the permissions that you grant when connecting a third-party account. In the case of connected apps that utilize the Platform, we are not responsible for the content or use of personal data on other apps or networks. Please make sure you connect your Vertigo® account only with apps or services that you trust.

Additionally, we use certain third parties, some of whom may be located outside of the United States, to provide us with certain specialized services related to the Platform. For example, we may engage third-party service providers to host our Platform or to provide analytics, advertising, communication, customer support, or maintenance. These third parties may have access to certain information about you but only where this is necessary in order for those third parties to provide their services to us. Where we transfer personal data to these third parties, we require these third parties to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us. The third-party service providers we use include:

* Apple Inc.: https://www.apple.com/legal/privacy/en-ww/

* Google LLC: https://policies.google.com/privacy

* Intercom: https://www.intercom.com/terms-and-policies#privacy

* Mailrecipe LLC. (Formfacade): https://formfacade.com/website/privacy.html

* The Rocket Science Group, LLC (Mailchimp): https://mailchimp.com/legal/privacy/ 

* Shopify: https://www.shopify.com/legal/privacy

* Squarespace, Inc.: https://www.squarespace.com/privacy

* Twilio, Inc.: https://www.twilio.com/legal/privacy

* Zapier, Inc.: https://zapier.com/privacy

We may grant permission to third parties to use programmatic interfaces to enable application developers to integrate elements of the Platform into various applications. Some of these developers may be located outside of the United States. Any information that you publish to the Platform may be accessible to these developers. Please bear this in mind when deciding what information to add to the Platform.

We may aggregate your personal data with similar data relating to other users of the Platform in order to create statistical information regarding the Platform and its use, which we may then share with third parties or make publicly available. In this use case, aggregate information generally would not include personally identifiable information (PII); or any PII would be anonymized so as to no longer be considered PII.

We may share your information with our music industry partners, including artists that host listening parties, contests, or other promotions on our platform. Such disclosure of your information shall only be provided for data analysis, and will not be shared for marketing, advertising, or commercial purposes. For example, certain information of our users (such as public usernames and geographic locations) may be shared, sometimes in pseudonymized form, with our music industry partners to help them understand how songs that they promote on the Vertigo® Platform are performing.

We will disclose your information if we believe in good faith that we are permitted or required to do so by law, including in response to a court order, subpoena, or other legal demand or request.

We may disclose your information if we feel this is necessary in order to protect or defend our legitimate rights and interests or those of our users, employees, directors, or shareholders, or to ensure the safety and security of the Platform or the Vertigo® community.

We may transfer your information in the event of a corporate divestiture, acquisition, merger, dissolution, or insolvency. If there is a transfer of assets, your information may be reviewed, transferred to, and acquired by a third party. The new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use your information for the purposes and in the scope that it was supplied to us.

Except as otherwise set forth in this Privacy Policy, we will disclose your information if you have explicitly agreed that we may do so. We will make this clear to you at the point at which we collect or agree to disclose your information.

How we use cookies and other measurement technologies

This section describes use of cookies and other measurement technologies used in device, user, and network identification.

For further information about how information may be shared by us, please see the section “How We Share Your Information.”

What are cookies and other measurement technologies?

A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognize your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an e-mail, which indicate that a page or e-mail has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.

There are also technologies such as mobile device identifiers and software development kit (SDK) integrations to help systems recognize your device when you return to an Application or otherwise use the Platform.

We use various technologies, including but not limited to session cookies (which expire once you close your Web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them). We may use mobile device identifiers and the other measurement technologies for the purposes articulated in this Privacy Policy, for example to recognize your devices when you return to the Platform.

The information collected through such means are used for the following purposes:

This information allows us to operate the Platform. For example, they allow us to recognize what type of user you are and then provide you with Platform resources accordingly.

This information allows us to analyze how the Platform is accessed, used, and performing. We use this information to maintain, operate, and improve the Platform and to deliver information to you that you may find relevant or interesting.

This information allows us to operate certain functions of the Platform. For example, when you continue to use or come back to the Platform, we can provide you with features and information  such as maintaining your logged-in session and remembering how you have customized various settings.

This information allows us to convey advertisements, from time to time, that may be relevant to you and your interests. We may work with web publishers, advertising networks, and service providers to deliver and display advertisements and messaging for other applications, services, and websites. The information may also be used for frequency capping purposes (i.e. to ensure we do not display the same advertisement to you repeatedly) and to help us regulate the advertisements you receive and measure their effectiveness.

We may allow our business partners to use cookies and other measurement technologies on or outside the Platform for the same purposes identified above, including collecting information about your online activities over time and across different applications, services, and websites. We may also use service providers acting on our behalf to use cookies for the purposes identified above.

Managing your preferences for cookies and other measurement technologies

Many Web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other measurement technologies in the same way that you manage cookies using your browser’s preferences.

Please note that if you choose to block cookies, doing so may impair the Platform or prevent certain elements of the Platform from functioning.

The Platform does not observe Do Not Track signals from Web browsers.

An available tool is the Network Advertising Initiative’s (NAI) Opt-Out Tool at https://www.networkadvertising.org/choices. This allows you to opt out from the use of information about your online activities for online behavioral advertising by NAI member companies.

On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices, go to “Settings” > “Privacy” > “Advertising” and turn on “Limit Ad Tracking”) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.

Please note that even if you opt out of some advertising using the mechanisms above, you may still receive advertisements when using the Platform, but they will no longer be targeted ads.

We work with advertising partners to serve advertisements on the Platform. One of the services we use to track activity is Google Analytics by Google (Google, Inc., a company headquartered at 1600 Amphitheatre Parkway, Mountain View, California, 94043, United States of America). We may use vendors, including Google, who use first-party mechanisms (such as the Google Analytics) and third-party mechanisms (such as the DoubleClick) together to inform, optimize, and serve ads based on your past visits to our Platform. Google provides tools to manage the collection and use of certain information by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network by updating Ads Settings for Google at https://www.google.com/settings/ads.

By using this Platform, you hereby consent to the use of the cookies and other measurement technologies described above. If you do not agree with any of the terms of this Privacy Policy, including our use of cookies and other measurement technologies, you should not use the Platform.

For more information about the use of cookies and how to block them, visit https://www.allaboutcookies.org, https://www.youronlinechoices.eu/ (Europe), or https://www.aboutads.info/choices/ (United States). If you have any questions or comments about our use of cookies, please contact us at [email protected].

Third parties, other than our service providers, do not have authorization from us to track which websites, apps, or other online services you visit prior to and after visiting the Platform. Please note, however, that we cannot control third-party tracking and there may be some third-party tracking that occurs without our consent or knowledge.

6. YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to Section 1798.83 of the California Civil Code, California residents have the right to request from a business with whom the California resident has an established business relationship: (1) What types of personal information, if any, of the California resident the business shares with third parties for direct marketing purposes of those third parties; and (2) the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year.

We do not currently share personal information with third parties for their direct marketing purposes.

If you are a minor under the age of 18 in California, you also have the right to request and obtain removal of any content that you post on our Platform. Content includes images, videos, recordings, and text. To request removal, please send an e-mail to [email protected] with information to identify the content that you want removed, including the date the content was posted, a brief description of the content, and a hyperlink to the content if available. You may be required to provide additional information to verify your identity as the author of the content. We will remove the content, if doing so is technologically and practically feasible, within a reasonable amount of time.

If you have any questions, comments, or requests related to this section of the Privacy Policy, please contact us by e-mail at [email protected].

A number of states are currently considering enacting laws similar to the California law mentioned above. If you are a resident of a state that enacts such a law, please use the contact information provided above to contact us with any questions, comments, or requests.

7. YOUR GDPR PRIVACY RIGHTS

Legal basis for processing

With respect to personal data that we collect or receive that is subject to the General Data Protection Regulation (“GDPR”) of the European Union (EU) and the European Economic Area (EEA), our legal basis for processing such personal data depends on the type of personal data and the purpose for which we collect it. For the purposes stated in the “How we use your information” section above, the relevant legal bases under the GDPR are as follows:

• We process your personal data for our legitimate business interests. These interests include but are not limited to: the commercial interests of Vertigo or a third party in providing the Platform; compliance with applicable legal and regulatory obligations and any codes of conduct; improvement and development of our business operations and service offerings or those of a third party; or protection of our business, employees, users, or third parties.

• In certain instances, we may process your personal data pursuant to a contract between you and us (e.g. if you enter into an agreement with us relating to your use of the Platform).

• Where appropriate, we may ask for your consent. If we rely on your consent to process personal data, you have a right to withdraw such consent.

If your personal data is protected by the GDPR, you have certain data protection rights described below with respect to the personal data collected and used by us. These rights may apply only in certain circumstances and are subject to certain exemptions. You can exercise these rights using the contact details contained within this Privacy Policy.

Your rights

The rights under the GDPR are as follows:

• To receive a copy of your personal data that we hold about you.

• To ask us to correct or delete your personal data.

• To restrict our use of your personal data.

• To object to our use of your personal data, including our use of personal data for direct marketing.

• To ask us to transfer your personal data to another organization where it is technically feasible.

• To withdraw your consent at any time where we rely on consent to use your personal data.

• To notify the relevant data protection authority that you believe we have not used your personal data in accordance with data protection law.

For more information about your choices and how to exercise your rights, please also refer to the “Choice and Control” section below.

Parental rights with regard to minors in the GDPR

As further set forth in Section 10 herein (Children), the Vertigo® Platform is not intended for use by anyone under 16 years of age in the EU and EEA absent written parental consent. We do not knowingly gather any personal data from anyone under the age of 16 on the Platform. For more information on how parental rights under the GDPR and how parents can provide consent for EU/EEA teens aged 13 to 15, click here.

8. CHOICE AND CONTROL

We seek to provide you choices about the information you provide to us and the control you have over that information.

It is not necessary for you to provide us with any personal data in order to visit the Websites, although certain information will be collected automatically by virtue of your visit (as described above). If you decide to register a Vertigo® account, you can control your information in the following ways.

Notification Preferences

If you have opted in to receive any promotional e-mail communication from us, you will also be given the option to “unsubscribe” from receiving further e-mail communications from us. Your option not to receive promotional and marketing material from us will not preclude us from corresponding with you, by e-mail or otherwise, regarding existing or past business relationships with us and will not preclude us from accessing and viewing your personal information in the course of maintaining and improving the Platform.

Sharing with other apps and networks

THE PLATFORM ENABLES YOU TO SHARE INFORMATION WITH OTHER NETWORKS AND APPLICATIONS.

Please note that this Privacy Policy does not apply to any third-party sites or applications, and we cannot control the activities of those sites or applications. You are advised to read the privacy policies of those sites or applications before sharing your information with, or connecting your Vertigo® account to, any of these third-party sites or applications.

Application preferences

You can use the settings within your iOS or Android device to opt out of some analytics tracking and bug reporting.

You can choose whether to allow the Applications to collect and use data about your device’s location from your device’s operating system. If you block the use of location information, some or all parts of the Platform may be inaccessible or may not function properly.

You can choose whether to allow the Applications to collect data from your device’s camera and photos through your device’s settings. If you block the use of cameras or photos, some or all parts of the Platform may be inaccessible or may not function properly.

You can choose whether to allow the Applications to collect data from your device’s microphone through your device’s settings. If you block the use of the microphone, some or all parts of the Platform may be inaccessible or may not function properly.

If you do not want to receive push notifications from us, you may opt out of receiving these when prompted for permission or at any time by using the operating system settings on your mobile device.

Access to your data

If you wish to review, amend, or delete personal data we hold about you, or if you have any objection to the processing of any personal data that we hold about you, please contact us at [email protected] or the address provided below. We will process and respond to your requests in accordance with applicable laws and regulations and our policies, including our Privacy Policy, Terms of Use, Intellectual Property Policy, Community Guidelines, and Official Rules. We reserve the right to deny requests to amend or delete certain information where the request is not legally mandated or not technologically or practically feasible or where the request would require an unreasonable use or expenditure of additional resources.

Deleting your account

You can request that your account be deleted by sending a message to us at [email protected]. Please bear in mind that, if you request deletion of your account, content and information associated with your account will be inaccessible to you and may not be recoverable after your request is processed.

If you ask us to delete your account, we will do so within a reasonable period of time, but we may need to retain some of your personal data in order to satisfy our legal obligations, or where we have a legitimate reason for doing so.

9. INTERNATIONAL DATA TRANSFERS

Vertigo Media, Inc. is based in the United States, and your personal information is collected, stored, used, and shared in accordance with United States law. However, from time to time, it may be necessary for us, our affiliates, or our service providers to use, transfer, or store your personal data elsewhere around the world. If you are located outside the United States, be advised that any information you provide to us will be transferred to and stored in the United States and that, by using the Platform and submitting information to us, you explicitly authorize its transfer and storage within the United States. We will treat personal information subject to this Privacy Policy in accordance with this Privacy Policy regardless of where it is processed or stored. You should be aware that privacy laws in the United States may not be equivalent to the laws in other countries.

The United States has not received an “adequacy decision” from the European Commission, which means that the data protection laws of the United States may not offer the same protections as the country in which you reside when you provide information to us. If we transfer personal information outside the European Union (EU) or European Economic Area (EEA), we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law. For further information as to the safeguards we implement, please contact [email protected].

10. CHILDREN

Anyone under the age of 13 is not permitted to use the Platform and must not attempt to register an account or submit any personal information to us.

Anyone under the age of 16 in the EU (and the European Economic Area) is not permitted to use the Platform and must not attempt to register an account or submit any personal information to us, absent written parental consent. For more information on how parental rights under the GDPR and how parents can provide consent for EU/EEA teens aged 13 to 15, click here.

The Vertigo® APP is not intended for use by children.

We do not knowingly collect personal information from any person who is under the age of 16 in the EU or EEA, or under the age 13 in the United States or any other jurisdiction. If it comes to our attention that we have collected personal data from a person under the age of 16 in the EU or EEA or under 13 in any other jurisdiction, we will delete any such information as quickly as possible. If you have reason to believe that we may have collected any such personal data, please notify us immediately at [email protected].

11. SECURITY AND DATA RETENTION

We take reasonable security precautions to protect the personal information that you choose to provide. Although guaranteed security does not exist on the Internet or offline, we make commercially reasonable efforts to handle such information consistent with this Privacy Policy and applicable laws. Due to the design of the Internet and other factors outside our control, we cannot guarantee communications between you and our servers will be free from unauthorized access by third parties. We will retain your personal data for as long as necessary for the purposes for which it was collected. The precise period will depend on the reason why it was collected. Those periods are also based on the requirements of applicable data protection laws, applicable legal and regulatory requirements, and periods relating to the commencement of legal actions.

12. CHANGES AND UPDATES TO THIS POLICY

If you have questions about this Privacy Policy, want to suggest changes to this Privacy Policy, or want to know what information we store about you, please contact us by e-mail at [email protected], or write to us at Vertigo Media, Inc., 14835 Ballantyne Village Way, Suite 200, Charlotte, North Carolina, 28277, United States of America, Attention: Privacy.

13. DON’T WANT TO GIVE US YOUR INFORMATION?

If you decide that you do not want us to use your information in the manner described in the Privacy Policy, do not use the Platform.