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CALM RADIO PRIVACY POLICY

Calm Radio, part of Stingray Group Inc. (“we”, “us”, “our”) is committed to
protecting your privacy. Our Privacy Policy is designed to help you understand
how we collect, hold, use, and divulge the Personal Information (as defined
below) when you use our websites, web players, applications, widgets, products
and/or services (the “Service(s)”). In this Privacy Policy, “you” refers to the
person using the Services if this person is 13 years old or over, or to a parent
or legal guardian if the user is under the age of 13.


1. WHAT PERSONAL INFORMATION DO WE COLLECT?

For the purposes of this Privacy Policy, “Personal Information” means any
information about an individual that identifies such individual or that,
individually or in combination with other information, identifies the
individual.

Depending on your use of the Services, we may collect your Personal Information,
including but not limited to your name, contact information, e-mail address,
location, postal address, social media accounts, survey feedback, demographic
information, and information about your mobile and/or computer devices.


2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Directly from you

Generally, we will obtain the Personal Information that we need directly from
you, for example when you use our Services or when you communicate with us.

We may also gather information that is generated by your mobile and/or computer
devices (e.g., mobile advertising identifiers, location information and IP
address). See Section “How do we provide online advertising?” for more
information on this topic.

With a legal basis such as a contractual basis or your consent

The legal basis for collecting and using your Personal Information is typically
a contractual basis (i.e., to provide you with the Services) or because you have
consented to it. However, we may also rely on other legal grounds, for example,
where the processing is necessary for our legitimate interests or for compliance
with legal obligations to which we are subject.

Refusal of collection and withdrawal of your consent

You have the right, if you so choose, to refuse the collection, use and
disclosure of your Personal Information. You may also, at any time, and subject
to reasonable notice and applicable legal or contractual restrictions, withdraw
your consent (if any) to the use of your Personal Information in our possession
by contacting us. You should be aware, however, that if you choose not to
provide us with your Personal Information, this may prevent you, for example,
from using the Services, as this information is essential to the provision of
the requested services.You may contact us as set forth in the Section “How to
contact us?” to address any issue thereof.


3. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

For specific and limited Purposes

We generally collect and uses your Personal Information to:

 * Process payment for the Services that you purchase from us, when applicable;
 * Communicate with you concerning your account and provide timely customer
   service when needed;
 * Track your location for the purpose of identifying the Services that are
   currently available to you;
 * Provide you with the Services, respond to and perform your requests for the
   Services, including delivering the Services you have purchased;
 * Offer you product upgrades, and other Services;
 * Authenticate the users of the Services;
 * Provide you with advertising while using the Services or third-party services
   including social media;
 * Recommend your content based on your use of the Services; and
 * Administer the surveys that you have agreed to complete

(collectively, the “Purposes”).

To send you the Messages

If you have consented to receive such information, we may send newsletters,
electronic messages, news, updates, contests, special offers and/or other
written communications (the “Messages”) to you about the Services, and/or about
products and/or services of our partners and licensors. Separate Services and
lines of business may send separate Messages. You may opt-out of receiving the
Messages as set forth in the Section “How to contact us?”, or through the
Preference Center accessible via the Messages footer. However, we may continue
to send you Messages to inform you about available upgrades or critical
technical service issues relating to a Service that you requested or purchased,
or to provide you with important information on your account.

For secondary purposes

We may also aggregate and anonymize Personal Information that you have provided
to create aggregate statistical data which we may use to improve the Services,
train machine learning algorithms, or share with our third-party partners
including advertising partners. Such statistical data does not include any
Personal Information.


4. DO WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?

We do not rent nor sell any of your Personal Information to third parties and
will not share it with third parties without your consent, unless it is
necessary to do so by law or for the Purposes as set forth below.

With our employees

In the course of their work, our employees may need to access your Personal
Information, for example, when you contact us or request support. Their access
is limited to what is necessary to perform their duties.

With strategic partners

We may share your Personal Information with our partners and licensors to the
extent that such disclosure is required for the Purposes. We may use third
parties to facilitate our business, such as payment processors, hosting services
providers, contractors for sending out e-mail updates about us and the Services
or for providing customer support services. In connection with these business
operations, our service providers may have access to your Personal Information
for use for a limited time in connection with these business activities. Where
we utilize third parties for the processing of any Personal Information, we
implement reasonable contractual and technical protections in order for such
third parties to keep all Personal Information they process strictly
confidential. Please note that these third parties may be located in other
countries than your location in which case appropriate measures are taken by us
as set forth below in the Section “Where is your Personal Information stored and
transferred?”.

When required by applicable laws

We may also share your Personal Information if required to do so by law or in
the good faith belief that such action is necessary to: (a) conform with the
law; (b) comply with the order of a competent judicial authority in any
jurisdiction; (c) comply with legal process served on us; (d) protect and defend
our rights or property; (e) enforce or verify your compliance with any part of
the agreements that you have entered into with us, if any; (f) prevent fraud or
other illegal activity perpetrated through the Services; or (g) act in urgent
circumstances to protect the personal safety of users of the Services or the
public at large.

During business transfers

We may share your Personal Information without your permission when our
operations require it (in the event of a merger, acquisition, bankruptcy or sale
of assets, for example). As part of this kind of event, we may also share some
or all of your Personal Information to the relevant third-party (or its
advisors) as part of a due diligence process.

For other purposes with your consent

Where you have expressly consented, your Personal Information may be shared with
other third parties. For example, there may be specific instances where
additional terms apply and, through these, we make clear that specific third
parties process your Personal Information.


5. THIRD-PARTY SERVICES AND PLATFORMS

Links to third-party platforms

The Services may contain links to other websites, applications, or platforms.
Please read the privacy policies of these third-party websites, applications or
platforms that collect personally identifiable information in order to
understand their privacy policies and data collection practices. This Privacy
Policy applies solely to Personal Information collected and processed by us or
on our behalf.

Use of reCAPTCHA

We may use the reCAPTCHA service from Google Inc. (“Google”) to check whether
the data entered on the Services has been entered by a human or by an automated
program. The reCAPTCHA service may collect information about you, including your
Personal Information for security purposes. The information gathered by
reCAPTCHA is held in accordance with Google’s privacy policy. By using the
reCAPTCHA service, you consent to the processing of your Personal Information by
Google in the manner and for the purposes set out in its privacy policy.


6. HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

We will retain your Personal Information only for as long as necessary to
fulfill the Purposes for which it was collected, or as required for our
legitimate interests, or to comply with applicable legal, tax or regulatory
requirements. After such time, any Personal Information held by us will be
destroyed, deleted, or made anonymous. If you would like more information on
this subject, we invite you to contact us as set forth in the Section “How to
contact us?”.


7. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

With necessary and appropriate security measures

We strive to apply appropriate precautions to protect your Personal Information.
We use physical, electronic, and procedural safeguards that comply with
applicable regulations to protect your Personal Information.

Increase your level of privacy

Our software may include the opportunity to disable certain software features to
increase your level of privacy. However, certain technical information (e.g.,
zip code) may be automatically transmitted between networked servers to
authenticate access to the Services, enable their delivery, or optimize your
media delivery experience.

Children’s privacy

Except as otherwise provided for a specific Service, the Services are only
available for individuals aged 13 years or older. We do not knowingly collect,
hold, use or divulge any Personal Information from children under the age of 13,
unless a parent or legal guardian has consented to it. If you believe that
Personal Information has been collected from children under the age of 13
without your prior consent, you may contact us as set forth in the Section “How
to contact us?”.


8. HOW DO WE USE COOKIES?

A cookie is a small text file that is stored in a dedicated location on your
computer, mobile device, tablet or other device when you use your browser to
visit an online service. Other tracking technologies, such as web beacons and
tracking pixels may be used for similar purposes. In this Privacy Policy, all of
these tracking technologies are collectively referred to as “Cookies”. Any
Personal Information collected with Cookies by us or on our behalf are treated
with the same level of confidentiality as any other Personal Information held by
us.

Strictly necessary Cookies

These Cookies are necessary for the Services to function and cannot be switched
off in our systems. Strictly necessary cookies must be present for the Services
to provide basic functions and could include signing in, adding items to a cart,
or e-billing. They allow for a user to navigate back and forth between pages
without losing their previous actions from the same session.

Non-essential Cookies

If you have consented to their use, we and/or our third-party partners may also
use non-essential Cookies in connection with the Services and the Messages,
including the following:

 * Functional Cookies. These Cookies enable the Services to provide enhanced
   functionality and personalisation. If you have consented to their use,
   functional Cookies allow the Services to remember the preferences and choices
   that you make including your username, region, and language.
 * Social media Cookies. If you have consented to them, we use social media
   Cookies such as the Facebook pixel to provide you with personalised offers,
   to measure, optimize and build audiences for advertising campaigns served on
   social media platforms. The Services may also use Cookies for sharing content
   with social media (such as Facebook, LinkedIn, Twitter and Instagram). Using
   the share buttons will set a Cookie to link the content viewed on our website
   to your user account with such networks, if any.
 * Advertising Cookies. If you have consented to their use, we use advertising
   Cookies to gather information from you on your devices to display
   advertisements to you based on relevant topics that may be of interest to
   you. Also, our partners may use these Cookies to determine whether our
   advertisements were displayed to you and whether you interacted with them. In
   such cases, our partners share data with us, including statistics about the
   performance of our ads. If you want more information about how to manage
   and/or disable Advertising Cookies, visit http://www.youronlinechoices.com/
   and http://www.youronlinechoices.com/. You can also refuse the use of such
   Cookies by following the instructions listed below.
 * Analytic Cookies. We use analytic Cookies to understand traffic patterns on
   the Services, to help measure and improve the effectiveness of the Messages
   and to determine whether such messages have been opened and links clicked on.
   These Cookies are used for statistical purposes only. All information these
   Cookies collect is aggregated and anonymous. To opt out of being tracked by
   Google Analytics, visit http://tools.google.com/dlpage/gaoptout. You can also
   refuse the use of analytic Cookies by following the instructions listed
   below.

How to manage Cookies

Except for strictly necessary Cookies, we will only place Cookies on your
devices if you consent to it, and such Cookies will be kept for a maximum period
of thirteen (13) months from when they are placed on your devices. At the end of
this period, your consent will be required again.

Cookies can be managed and/or disabled through your browser’s Cookie settings,
mobile device’s advertising settings and, in the case of the Messages, through
the Preference Center. Social media Cookies (“plugins”) can also be managed by
consulting the following networks’ policies:

 * Facebook: https://www.facebook.com/policies/cookies/
 * LinkedIn: https://fr.linkedin.com/legal/cookie-policy
 * Twitter: https://support.twitter.com/articles/20171379
 * Instagram: https://www.facebook.com/policies/cookies/

However, if you refuse Cookies, you may not be able to use all the features of
the Services and the Messages, and you will still be served with advertising,
but such advertising will no longer be as tailored to you.

If you want more information about how to manage and/or disable non-essential
Cookies, please visit http://www.allaboutcookies.org/manage-cookies/, and
http://optout.aboutads.info/?c=2&lang=EN.


9. HOW DO WE PROVIDE ONLINE ADVERTISING?

With the use of Cookies, questionnaires or with mobile advertising identifiers

We may, together with our third-party partners, collect your Personal
Information to provide advertisements about goods and services likely to be of
interest to you, including advertisements about specific Services. Such Personal
Information is collected: (i) with social media Cookies and/or advertising
Cookies as set forth above in the Section “How do we use Cookies?”; (ii)
directly from you when completing a survey, filling in a questionnaire or
consenting to receiving the Messages.

Depending on the preferences that you have expressed in your mobile devices, we
may, together with our advertising partners, also use your mobile advertising
identifier to target and measure the effectiveness of their advertising
campaigns. In iOS, this identifier is called “IDFA” (ID for Advertising); in
Android (Google Play), this identifier is called “AAID” (Android Advertising
ID). You can access and reset your mobile advertising identifier or limit its
use through the settings on your mobile devices’ operating system.

In no event will we permit advertising directed at children where it has actual
knowledge that the user is under the age of 13. To learn more about our
advertising practices, please contact us as set forth in the Section “How to
contact us?”.

Do Not Track

Web browsers can transmit Do Not Track (“DNT”) signals that indicate that a user
does not wish to have his/her activity tracked over time and across websites.
Currently, no universally accepted standard exists for how to interpret such
signals, although work to create consensus is ongoing. Accordingly, and because
we do not track its users over time and across third-party websites, we do not
respond to such DNT signals.


10. WHERE IS YOUR PERSONAL INFORMATION STORED AND TRANSFERRED?

Your Personal Information may be held by us in locations other than your
province, territory, state, or country of residence, including in Canada
(including in the provinces of Quebec and Ontario), the United States and/or the
United Kingdom. We may also subcontract processing to or share your Personal
Information with third parties located elsewhere, including locations other than
your province, territory, state, or country of residence. In such case, we will
ensure that your Personal Information is transferred to countries that have
received an adequacy decision from the competent authority, or that your
Personal Information is adequately protected by appropriate technical,
organizational, contractual, or other lawful means. If you would like to obtain
more information on these security measures, please contact us as set forth in
the Section “How to contact us?”.


11. WHAT ARE YOUR RIGHTS?

Depending on applicable laws, you might have the right to have your Personal
Information deleted, the right to obtain access to, or rectification of your
Personal Information, the right to withdraw your consent (if any), the right not
to be discriminated against, the right to object to the use of your Personal
Information by us, or the right to receive a copy of all Personal Information
that we have about you in a structured, commonly used and machine-readable
format. To exercise any of these rights (to the extent available), please
contact us as set forth in the Section “How to contact us?”.


12. HOW TO CONTACT US?

If you have questions about the privacy aspects of the Services or the Messages,
would like to know more about our legitimate interests, make a complaint or
exercise any of the rights made available to you according to applicable laws,
please do so through the “Contact Us” section or link on the Services, when such
link is available, or please contact our Data Protection Officer as follows:

 * If you are located in America: Customer Support re Privacy, Calm Radio, part
   of Stingray Group Inc., 730 Wellington Street, Montreal, Quebec, Canada H3C
   1T4, tel: 1-514-664-1244, fax: 1-514-664-1143, e-mail: privacy@stingray.com.
 * If you are located in Europe or in the rest of the world: Customer Support re
   Privacy, Stingray Digital International Limited, 65 Aspenlea Road, London W6
   8LH, United Kingdom, tel: +44 (0) 208 237 1197, email: privacy@stingray.com.

Your request may be accepted or denied by us based on the applicable laws. We
will take prompt corrective action when it learns of any failure to comply with
this Privacy Policy. We shall not be liable for any incidental, consequential or
punitive damages relating to this Privacy Policy.

You may file a complaint with a competent authority at any time if you believe
that we are not processing your Personal Information in a manner that is
compliant with this Privacy Policy or with the applicable laws.


13. CHANGES TO THIS PRIVACY POLICY

We frequently revise this Privacy Policy to keep it up to date with applicable
legislation and our operations. If material changes are made to the Privacy
Policy, then update notices (such as online notices or emails) may be used to
alert you of such changes. Otherwise, the posting of the revised Privacy Policy
on the Services shall be considered sufficient notice to you, and by continuing
to use the Services or the Messages, or by submitting Personal Information to
us, you are consenting to any changes to our Privacy Policy.

Unless stated otherwise, the current Privacy Policy applies to all Personal
Information that we have about you, and Stingray Group Inc. is the data
controller for the purposes of the Personal Information processed under this
Privacy Policy by or on behalf of us.

Last update: July 23, 2021.


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