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PRIVACY NOTICE

Last modified: January 6, 2020

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Privacy NoticeTerms & ConditionsAccessibilityCalifornia Privacy NoticeProcessing
ActivitiesContract TermsCookie PolicyAnti-Slavery Statement

Last modified: January 6, 2020

Acoustic, L.P., (“Acoustic,” “we,” “our,” or “us”) is committed to protecting
your privacy.  This Acoustic Privacy Notice (this “Notice”) applies to our
websites and online services that link to this Notice (collectively, our
“Sites”), and describes how we collect, use and disclose your personal
information when you visit our Sites or otherwise engage with us (collectively,
our “Service”).

For the purposes of data protection laws in the European Economic Area (“EEA“),
including the General Data Protection Regulation (the “Data Protection Law“),
Acoustic L.P., with offices at 100 Summit Drive, Suites 911 & 912, Burlington,
MA 01803, is a data controller (i.e., Acoustic is responsible for, and controls
the processing of, your personal information). 

By accessing or using our Service, you signify that you have read, understood,
and agree to our collection, storage, use, and disclosure of your personal
information as described in this Notice and our Terms & Conditions.

Click on the links below to jump to each section:

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We collect personal information you provide to us in a variety of ways. For
example, you may provide us your personal information when you visit our Sites,
access our cloud-based services, place an order, request information, order a
product or service, send us messages, subscribe to our mailing lists,
newsletters or other forms of marketing communications, or use some other
feature of our Service.

We may link or combine your activities and information collected from you on our
websites and authorized mobile apps with information we receive from third
parties, as well as information we collect automatically through tracking
technologies (defined below). This allows us to provide you with a personalized
experience regardless of how you interact with us.

The categories of information we collect may include:

Information you provide:

 * Contact and profile information. We may collect personal information, such as
   your name, phone number, address, business information, gender, age, zip
   code, address, and e-mail address, when you register for our Service, order a
   product or service, sign up for our mailing list, or otherwise communicate or
   interact with us. We use this information to create, verify and personalize
   your account, to fulfill your request or transaction, to communicate with you
   directly, and to send you marketing communications in accordance with your
   preferences.
 * Payment and transaction information. We may collect information such as
   payment information including your credit/debit card number. We use this
   information to complete your transaction, detect and prevent fraud, and to
   inform our advertising and marketing.
 * Comments, chat and opinions. When you contact us directly (e.g., by email,
   phone, mail or by completing an online form or participating in online chat),
   we may record your comments and opinions. We use this information to respond
   to your question or comment, to evaluate and improve our products and
   services and to inform our marketing and advertising.

Information we collect when you use our Sites and our Service:

 * Location information. We may collect information about your location if you
   provide your address or zip code or we may approximate your location based on
   your IP address. If you provide our mobile applications access to location
   services on your device, we and our third-party providers may collect
   location data through GPS, Wi-Fi, wireless network triangulation or other
   similar methods. We may use your location information to provide personalized
   content and advertising, to allow you to view deals and products available to
   you based on your location, to assist us with analytics such as foot traffic
   measurement, and to improve the effectiveness of our websites, mobile
   applications, merchandise, advertising, and customer service. We may also use
   your location information to provide you with more information regarding
   events, personalized offers regarding products, services, or other
   opportunities, and notifications via social media which may interest you.
 * Information you may post or submit to our Sites. We may collect information
   about how you use and interact with our Sites and our Service, including any
   content you post to the Service.

Information provided by others:

 * Information provided by social networks. When you interact with our Service
   through various social media networks, such as when you “Like” us on Facebook
   or when you follow us or share our content on Facebook, Twitter, Snapchat,
   LinkedIn, Instagram or other social networks, we may receive some information
   about you that you permit the social network to share with third parties. We
   use this information to complete your profile, to better understand the
   demographics of our customers and to inform our advertising and marketing
   activities. The data we receive is dependent upon your privacy settings with
   the social network. You should always review and, if necessary, adjust your
   privacy settings on third party websites and social media networks and
   services before linking or connecting them to our Sites or Service.
 * Information we receive from authentication services you connect to our
   Service. Some parts of our Service may allow you to login through a third
   party social network or authentication service such as Facebook. These
   services will authenticate your identity and provide you the option to share
   certain personal information with us, which could include your name, email
   address, address book and contacts, or other information. The data we receive
   is dependent on that third party’s policies and your privacy settings on that
   third-party site.
 * Information provided by others. From time to time, we may receive information
   about you from third parties and other users. For example we may obtain
   information from our marketing partners or from third parties to enhance or
   supplement our existing user information. We may also collect information
   about you that is publicly available. We may combine this information with
   the information we collect from you directly.
 * Information provided by Acoustic entities. We may receive information about
   you from other Acoustic companies and affiliates so that information you
   provide to one company may be used by another company to provide you
   services, communicate with you or provide you advertisements or other
   personalized content.

Inference-based information:

 * We may derive inferences about you based on the categories of information
   described above.

If you provide us with personal information of another person (for instance, a
potential employee/referral), you are responsible for ensuring that such person
is made aware of the information contained in this Notice and that the person
has given you his/her consent for sharing the information with Acoustic.

Except where certain information is required by law or by Acoustic policies
(including management of an employment relationship with Acoustic), your
decision to provide any personal information to us is voluntary. Please note
that if you do not provide certain information, we may not be able to accomplish
some or all of the purposes outlined in this Notice, and you may not be able to
use certain tools and systems which require the use of such personal
information.

HOW DO WE USE PERSONAL INFORMATION?

The table available in the Processing Activities Chart (available here sets out
in detail the categories of personal information we collect about you, the
source of the personal information and how we use that information when you use
the Service, as well as details of the recipients of that personal information.
In addition, as required by Data Protection Laws, it also sets out the purpose
of legal basis that we rely on to process the personal information, which we
have also summarized below:

Legal basis for processing in the EEA (see the ‘PURPOSE OF LEGAL BASIS’ section
of the Processing Activities Chart available here. In the EEA, the purposes for
which we process your personal information are:

 1. the provision of personal information by you may be necessary for the
    performance of any contractual relationship we have with you;
 2. where it is necessary for compliance with our legal obligations laid down by
    EU law;
 3. where in our legitimate interests (provided these are not overridden by your
    interests and fundamental rights and freedoms – this includes our own
    legitimate interests and those of other entities and branches in our group
    of companies) such as:

 * to contact you and respond to your requests and enquiries;
 * for business administration, including statistical analysis;
 * to provide the Sites to you; and
 * for fraud prevention and detection; and
 * to comply with applicable laws, regulations or codes of practices.

We may also process your personal information on the basis of your freely given,
specific, informed and unambiguous consent. You should be aware that you are
entitled under Data Protection Law to withdraw your consent where that has been
given, at any time. If you do this and we have no alternative lawful reason to
process your personal information, this may affect our ability to provide you
with rights to use the Service. You have the right to withdraw your consent at
any time by contacting our Data Protection Officer (as set out in the ‘How to
Contact Us‘ section below). If you withdraw your consent, this will not affect
the lawfulness of our use of your personal information before your withdrawal.

WHAT INFORMATION DO WE COLLECT AUTOMATICALLY (Cookies and Tracking
Technologies)?

When you visit our Sites and Service, read our emails, or otherwise engage with
us through a computer or mobile device, we and our third-party partners
automatically collect information about how you access and use the Service and
information about the device you use to access the Service.

This information allows us to improve your customer experience. For example, we
may use this information to enhance and personalize your user experience, to
monitor and improve our Sites and Services, and for other internal purposes. We
typically collect this information through a variety of tracking technologies,
including cookies, Flash objects, web beacons, embedded scripts,
location-identifying technologies, and similar technology (collectively,
“tracking technologies”). Information we collect automatically about you may be
combined with other personal information we collect directly.

Specifically, we and our third-party partners may use tracking technologies to
automatically collect usage and device information, such as: information about
how you access and use the Service, information about the computer, tablet,
smartphone or other device you use as well as analytics information.

We, or our third-party partners, may use the data collected through tracking
technologies to: (a) remember information so that you will not have to re-enter
it during your visit or the next time you visit the Sites; (b) provide custom,
personalized content and information, including targeted content and
advertising; (c) identify and contact you across multiple devices; (d) provide
and monitor the effectiveness of our Service; (e) perform analytics and detect
usage patterns on our Service; (f) diagnose or fix technology problems; (g)
detect or prevent fraud or other harmful activities, and (h) otherwise to plan
for and enhance our Service.

Your choices to control tracking technologies. If you would prefer not to accept
cookies, most browsers will allow you to: (i) change your browser settings to
notify you when you receive a cookie, which lets you choose whether or not to
accept it; (ii) disable existing cookies; or (iii) set your browser to
automatically reject cookies. For more information on how to block, delete
and/or disable tracking technologies, see “Your Choices and Control Over Your
Information” below.

Do Not Track.  Some web browsers may be configured to send “Do Not Track”
signals to the online services that you visit. There is no consensus among
industry participants as to what “Do Not Track” means in this context. Although
we do our best to honor the privacy preferences of our visitors, like many
websites and online services our website does not alter its practices when a “Do
Not Track” signal is received from a visitor’s browser. To find out more about
“Do Not Track,” please visit http://www.allaboutdnt.com.

We and our third-party partners may collect information through tracking
technologies for personalized advertising purposes.

For more information, please visit our Cookie Policy.

HOW WE SHARE YOUR INFORMATION

We may share, sell or disclose your information in the instances described below
and as detailed in the ‘Recipients’ column of the Processing Activities
Chart available here.  In addition, for further information on your choices
regarding your information, see “Your Choices and Control Over Your Information”
below.

 * Other Acoustic affiliates:  We may share personal information with our
   affiliates within the Acoustic corporate group and companies that we acquire
   in the future when they are made part of the Acoustic corporate group, to the
   extent such sharing of data is necessary to fulfill a request you have
   submitted via our Sites or for customer support, marketing, technical
   operations and account management purposes. Further, due to the nature of our
   relationship with our social enterprise organization, Acoustic.org, we may
   share personal information between Acoustic and Acoustic.org for the business
   and/or organizational purposes of both or either; and if we are involved in a
   merger, reorganization, dissolution or other fundamental corporate change, or
   sell a website or business unit, or if all or a portion of our business,
   assets or stock are acquired by third party, with such third party. In
   accordance with applicable laws, we will use reasonable efforts to notify you
   of any transfer of personal information to an unaffiliated third party.
 * Third parties at your request:  You may choose to share your activities on
   the Service with your friends through email, text or on various social media
   networks.
 * Select marketing and strategic business partners:  We may share limited data
   with our preferred marketing and strategic business partners so that they can
   provide you with information and marketing messages about products or
   services that may interest you. These parties may use your information in
   accordance with their own privacy policies.
 * Online advertising partners: We may share information with third party online
   advertising partners or permit these partners to collect information from you
   directly on our Sites to facilitate online advertising.
 * The public:  When you provide feedback or post user content on our Service
   (e.g., if you post a product review on our Sites or comment on our social
   media sites), your information (e.g., your first name, last initial, state of
   residence, and your comments) may be displayed on our Sites or on our social
   media pages. When you engage with us on social media, we may tag your social
   media account or the social media account of others (e.g., to give photo
   credit to another user).
 * With your consent or at your direction:  In addition to the sharing described
   in this Notice, we may share information about you with third parties
   whenever you consent to or direct such sharing.

Other instances in which we may share your personal information:

 * Service providers and advisors:  Personal information may be shared with
   third party vendors and other service providers who perform services for us
   or on our behalf. This may include vendors and providers who engage in
   marketing or advertising activities or provide mailing or email services, tax
   and accounting services, product fulfillment, delivery services, payments
   processing, data enhancement services, fraud prevention, web hosting, or
   analytic services. For Acoustic commercial support, we provide a list of the
   suppliers used to provide support. In individual instances, with professional
   advisers acting as processors or joint controllers including lawyers,
   bankers, auditors and insurers based in countries in which we operate who
   provide consultancy, banking, legal, insurance and accounting services, and
   to the extent we are legally obliged to share or have a legitimate interest
   in sharing your personal information.
 * Purchasers and third parties in connection with a business
   transaction:  Personal information may be disclosed to third parties in
   connection with a corporate transaction, such as a merger, sale of any or all
   of our company assets or shares, reorganization, financing, change of control
   or acquisition of all or a portion of our business by an affiliate or third
   party, or in the event of a bankruptcy or related or similar proceedings.
 * Law enforcement, regulators and other parties for legal reasons:  Personal
   information may be disclosed to third parties, as required by law or
   subpoena, or if we reasonably believe that such action is necessary to (a)
   comply with the law and the reasonable requests of law enforcement; (b) to
   enforce our Terms & Conditions or to protect the security or integrity of our
   Service; and/or (c) to exercise or protect the rights, property, or personal
   safety of our organization, our visitors, or others.

In connection with the above, we may share information with others in an
aggregated or otherwise anonymized form that does not reasonably identify you.
For example, we may share usage data on an aggregated basis with Acoustic’s
service providers for the purposes of helping Acoustic to carry out analysis and
improvements to its products and services. Additionally, we may share the same
in the normal course of operating our business; for example, we may share
information publicly to show trends about the general use of our services.

YOUR CHOICES AND CONTROL OVER YOUR INFORMATION

Profile and settings:  You may update your account information and adjust your
account settings by logging into your account. Please note that changes to your
settings may require some time to take effect.

How to control your email preferences: You can stop receiving promotional email
communications from us by clicking on the “unsubscribe link” provided in such
communications. We make every effort to promptly process all unsubscribe
requests. You may not opt out of service-related communications (e.g., account
verification, transactional communications, changes/updates to features of the
Service, technical and security notices). You may also be able to adjust certain
communications preferences by logging into your account.

Geolocation and device Information:  You may control the Service’s access to
your device information through your “Settings” app on your device.  For
instance, you can withdraw permission for the Service to access your address
book, location, photo stream, and camera.  You may also control precise location
tracking by adjusting your location services settings on your mobile device. We
may continue to approximate your location based on your IP address or through
other means when you access the Service through a computer or device.

HOW WE STORE AND PROTECT YOUR INFORMATION

Data storage and transfer:  Your information collected through our Service may
be stored and processed in the United States or any other country in which
Acoustic, its affiliates or service providers maintain facilities.  If you are
located in regions with laws governing data collection and use that may differ
from U.S. law, please note that we may transfer information, including personal
information, to a country and jurisdiction that has data protection laws that
may be more or less restrictive than those required under U.S. law. 

In addition, the personal information we collect may be transferred to and
stored in countries outside of the jurisdiction you are in where we and our
third-party service providers have operations. If you are accessing our Service
from the EEA, your personal information will be processed outside of the EEA. In
the event of such a transfer, we ensure that:

 1. the personal information is transferred to countries recognised as offering
    an equivalent level of protection; or
 2. the personal information is transferred to entities certified under the
    EU-U.S. Privacy Shield; or
 3. the transfer is made pursuant to appropriate safeguards, such as standard
    data protection clauses adopted by the European Commission.

If you wish to enquire further about these safeguards used, please contact us by
using the information in the “How to Contact Us” section.

Data retention:  We will retain your personal information as long as reasonably
necessary to maintain the Service, to meet legal and accounting obligations, and
for the other purposes described in this Notice. We may anonymize and/or
aggregate personal information and store it in order to analyze aggregate
metrics and trends. We may retain your personal information for a period of time
consistent with the original purpose of collection (see the “PURPOSE” column of
the Processing Activities Chart available here. We may, however, need to retain
your personal information for longer if we are required to do so by law. We
determine the appropriate retention period for personal information on the basis
of the amount, nature and sensitivity of the personal information processed, the
potential risk of harm from unauthorized use or disclosure of your personal
information and whether we can achieve the purposes of the processing through
other means, as well as on the basis of applicable legal requirements (such as
applicable statutes of limitation). After expiry of the applicable retention
periods, your personal information will be deleted. If there is any data that we
are unable, for technical reasons, to delete entirely from our systems, we will
put in place appropriate measures to prevent any further use of such data. For
further information on applicable data retention periods, please contact us by
using the information in the “How to Contact Us” section, below.

Keeping your information safe:  Security of your information is very important
to us, and we have put in place safeguards to preserve the integrity and
security of information we collect and share with our service providers.
However, no security system is impenetrable and we cannot guarantee the security
of our systems at all times. In the event that any information under our control
is compromised as a result of a breach of data security, we will take reasonable
steps to investigate the situation and, where appropriate, notify those
individuals whose information may have been compromised and take additional
steps, in accordance with any applicable laws and regulations.

JURISDICTIONAL DISCLOSURES

We may choose or be required by law to provide different or additional
disclosures about our data privacy practices depending on your state or country
of residence.  Please review this section to understand how our practices or
policies may differ in your jurisdiction:

UNITED STATES

 * California. If you are a California resident, please click here for
   additional California-specific privacy disclosures.

EUROPE

If you are located in the EEA, you have the following rights in respect of your
personal information that we hold:

Right to object. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR
LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR
SITUATION. YOU CAN OBJECT TO MARKETING ACTIVITIES FOR ANY REASON WHATSOEVER.

 * Right of access. The right to obtain access to your personal data.
 * Right to rectification. The right to obtain rectification of your personal
   data without undue delay where that personal data is inaccurate or
   incomplete.
 * Right to erasure. The right to obtain the erasure of your personal data
   without undue delay in certain circumstances, such as where the personal data
   is no longer necessary in relation to the purposes for which it was collected
   or processed.
 * Right to restriction. The right to obtain the restriction of the processing
   undertaken by us on your personal data in certain circumstances, such as
   where the accuracy of the personal data is contested by you, for a period
   enabling us to verify the accuracy of that personal data.
 * Right to portability. The right to portability allows you to move, copy or
   transfer personal data easily from one organization to another.
 * Right not to be subject to a decision based solely on automated processing,
   including profiling, which produces legal effects or significantly similar
   effects. You have a right not to be subject to processing being carried out
   by solely automated means and it either produces a “legal effect” or has an
   effect that is “equivalent or similarly significant in its impact”.

If you wish to exercise one of these rights, please contact us by using the
information in the “How to Contact Us” section using the contact details at the
end of this Notice.

CHILDREN'S PRIVACY

Our websites and online services are not directed to, and we do not intend to,
or knowingly, collect or solicit personal information from children under the
age of 16. If you are under the age of 16, please do not use our websites or
online services or otherwise provide us with any personal information either
directly or by other means. If a child under the age of 16 has provided personal
information to us, we encourage the child’s parent or guardian to contact us to
request that we remove the personal information from our systems.

YOUR RIGHTS RELATING TO CUSTOMER DATA

As described above, we may also process personal information submitted by or for
a customer to our cloud products and services. To this end, if not stated
otherwise in this Notice or in a separate disclosure, we process such personal
information in the role of a mere processor on behalf of a customer (and/or its
affiliates) who is the responsible controller of the personal information
concerned. We are not responsible for and have no control over the privacy and
data security practices of our customers, which may differ from those set forth
in this Notice. If your data has been submitted to us by or on behalf an
Acoustic customer and you wish to exercise any rights you may have under
applicable data protection laws, please inquire with the applicable customer
directly. Because we may only access a customer’s data upon instruction from
that customer, if you wish to make your request directly to us, please provide
to us the name of the Acoustic customer who submitted your data to us. We will
refer your request to that customer, and will support them as needed in
responding to your request within a reasonable timeframe.

YOUR PREFERENCES FOR EMAIL AND SMS MARKETING COMMUNICATIONS

From time to time we may contact you with information about our products and
services, including sending you marketing messages and asking for your feedback
on our products and services. We will only send you marketing messages if you
have given us your consent to do so. You may manage your receipt of marketing
and non-transactional communications from Acoustic by clicking on the
“unsubscribe” link located on the bottom of Acoustic marketing emails, by
replying or texting ‘STOP’ if you receive Acoustic SMS communications, or by
contacting privacy@acoustic.com.

Please note that opting out of marketing communications does not opt you out of
receiving important business communications related to your current relationship
with us, such as communications about your subscriptions or event registrations,
service announcements or security information.

YOUR PREFERENCES FOR TELEMARKETING COMMUNICATIONS

If you want your phone number to be added to our internal Do-Not-Call
telemarketing register, please contact us by using the information in the “How
to Contact Us” section, below. Please include your first name, last name,
company and the phone number you wish to add to our Do-Not-Call register.
Alternatively, you can always let us know during a telemarketing call that you
do not want to be called again for marketing purposes.

LINKS TO OTHER WEB SITES AND SERVICES

The Service may contain links to and from third party websites of our business
partners, advertisers, and social media sites and our users may post links to
third party websites.  If you follow a link to any of these websites, please
note that these websites have their own privacy policies and that we do not
accept any responsibility or liability resulting from you following a link these
websites.  Additionally, other privacy policies may apply when you engage with
us through a co-branded or co-sponsored promotional or marketing activity. We
strongly recommend that you read the privacy policies and terms and conditions
of use of any third party website or service to understand how your information
will be collected, used and shared. We are not responsible for the privacy
practices or the content on the websites of third-party sites.

HOW TO CONTACT US

Please contact privacy@acoustic.com if you have any questions, comments and
requests regarding this Notice.

If we are unable to deal with any issues you raise with us, you also have the
right to lodge a complaint with your national data protection authority. Further
information about how to contact your local data protection authority is
available
at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

CHANGES TO OUR PRIVACY NOTICE

We may modify or update this Notice from time to time to reflect the changes in
our business and practices, so you should review this Notice periodically.  When
we change this Notice in a material manner, we will so by indicating and
updating the “last modified” date in the heading of this Notice.  If you object
to any changes in this Notice, you may close your account associated with the
Service.

What do you want to achieve?

Contact us and we’ll help you get there.

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