Thank you for using Ins.Bridge services! This Privacy Policy explains what personal data Digital Musical AI Labs Co., Ltd. (“Ins.Bridge”, “we”, “us” or “our”) collect about you and how we use your personal data, as well as the choices you have about your personal data. 

This Privacy Policy applies to all Ins.Bridge’s services (such as our music learning & tuning apps:  “Tunefor Ukulele Tuner & Tabs” app), websites like insbridge.cc and related services and properties we control and which we collectively here call the “Services”. We may update this Privacy Policy from time to time by posting a new version of the Privacy Policy on insbridge.cc. If the changes we make are material, we will notify you by posting a notice in the Services or by other appropriate means. Please note that your use of the Services after the effective date is subject to the new Privacy Policy. 

The terms and conditions applicable to our Services have been set out in our Terms of Service. 

I. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

When you visit our Platform, you may provide us with the following types of personal data, and we may collect and process such personal data in accordance with his Privacy Policy, as follows:

Contact Data

This may include your name and your email address. This information will be collected by us if you communicate with us, for example if you use the links on our Platform to communicate with us via email.

Account Data

If you create an account on our Platform (including the creation of a Ins.Bridge ID) to benefit from our services, you may need to provide your name, email address, phone number and your photograph. If you use Facebook or Google to login to our Platform, Facebook [or Google] will share data with us including but not limited to your profile data,language, location and publicly available information about you and your friends.

Correspondence Data

This includes the information you provide when you request support through our Platform, contact us via the email address provided in this Privacy Policy and elsewhere on our website and your views, opinions and feedback which you choose to provide in relation to the Platform and our services, including any comment facilities and message boards.

Session Data

This includes your IP address, your device’s unique identifier details, browser details including version, device operating system, geo-location, time zone setting and time/date of access requests, the amount of data transmitted and the requesting provider. We may alsocapture other information about visits to our Platform such as pages viewed and traffic patterns.

Cookie Data

Cookies are small files which are downloaded to your device when accessing our platform. Most web browsers automatically accept cookies. Please refer to paragraph 5 below for further details about our use of cookies.

Preference data

This includes any information you choose to provide us, such as your musical preferences relating to genres and artists.

Payment data

When you purchase a subscription or any in-app content, you provide our payment processor with your payment information. We do not store such information on our servers.

II. HOW DO WE USE YOUR PERSONAL DATA?

We use your personal data in the following ways:

Data we use:

Purpose:

Lawful Basis:

Contact Data

To respond to communications that you send to us

To market products and services to you only where you have requested that we do so, or otherwise provided your explicit consent (either via our website, by emailing us or by accepting push notifications on your device) Customer relationship management (“CRM”) purposes

To enable social functionality, such as giving you the option to follow your contacts on the Platform.

Necessary for the performance of a contract where such communication relates specifically to our Services,otherwise legitimate interests so that we can respond to your query

Consent

Necessary for the performance of a contract

Consent

Account Data

To enable you to personalize your use of our services;

To enable you to save and maintain your profile and administer your account with us; and

To enable us to identify you.

Necessary for the performance of a contract

Correspondence Data

To help address issues you raise with us and to improve the Platform and our services.

Legitimate interests

User Content

To enable you to use our Platform and services

To share the User Content with other users of the Platform by making it available on the Platform.

Necessary for the performance of a contract

Legitimate interests

Session Data

To administer, maintain and improve the Platform and our services, including identifying you or your device across our Platform and apps.

To identify and respond to potential risks to the security of our Platform (for example spammers, phishing attempts, screen scraping and other actions which may violate our Terms of Use).

Legitimate interests

Preference Data

To infer your interests, including serving and suggesting content that you might like, and tailoring advertising to you based on such preferences.

Legitimate interests

III. PERSONAL DATA RETENTION

1. By using our Platform, you consent for us to store your personal data in line with legal, regulatory, financial and good-practice requirements.

2. The period for which we may retain your personal data will depend on the type of personal data collected, the purposes for which it was collected, applicable limitation periods for the exercise of legal rights and whether any legal or regulatory obligations require the retention of the personal data.

IV. COOKIES AND TRACKERS

1. We use cookies and other software development kits (“SDKs”) and third-party libraries. Our Platform uses the following categories of cookies:

Strictly necessary cookies

These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to load webpages.

Analytical/performance cookies

These cookies allow us to recognize and count the number of visitors to our Platform and to see how visitors move around our Platform. This helps us to improve the way our Platform works, for example, by ensuring that visitors are finding what they are looking for easily.

Functionality cookies

These are used to recognize you when you return to our Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Tracking ID

Every iOS and Google Android device has a unique Tracking ID, for iOS devices, called an Identifier for Advertising (IDFA) and for Android devices, called a Google Advertising ID (AAID). These Tracking IDs enable app providers and advertisers to track user activity and target ads at those users.

2. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

3. You may block cookies by updating the relevant settings on your device or browser to allow you to refuse the setting of some or all types of cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site.

V. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may need to share your personal data with selected third parties in the following circumstances:

Third party service providers

This may include providers of certain systems and services that we use to host, administer and maintain our Platform, including for example the servers used to host our Platform.

Third party service providers for marketing purposes

If you explicitly consent to any marketing from us, certain personal data may be shared with third party service providers we use to help us carry out marketing including, for example, third party marketing automation platforms.

To comply with legal or regulatory requests

If we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency.

Prospective buyers or sellers

If Ins.Bridge, or its owners, buys or sells any business or assets, we may disclose your personal data to the prospective buyer or seller of such business or assets. If Ins.Bridge (or substantially all of its assets) is acquired by a third party, your personal data held by Ins.Bridge, or within such assets, may be transferred to such third party.

VI. THIRD PARTY WEBSITES

Our Platform may contain links to third party websites. If you follow a link to a third-party website, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

VII. SECURITY

1. We take data security seriously. We implement and maintain appropriate technical and organisational measures including resilient security systems and protocols to protect the personal data we store.

2. We have put procedures in place to deal with any suspected data security breach and will notify you and applicable regulator of a suspected breach where the breach may cause a risk to you.

3. Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal data to you.

VIII. ACCESSING YOUR PERSONAL DATA AND YOUR RIGHTS

As a result of us collecting and processing your personal data, you have the following legal rights:

a.To access personal data we hold on you;

b.To request us to make any changes to your personal data if it is inaccurate or incomplete;

c.To request your personal data is erased where we do not have a compelling reason to continue to process such personal data in certain circumstances;

d.To receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the personal data is based on:

(i) your consent;

(ii) our necessity for performance of a contract to which you are a party to; or

(iii) steps taken at your request prior to entering into a contract with us and the processing is carried out byautomated means;

e.To object to, or restrict, our processing of your personal data in certain circumstances;

f.If we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;

g.If we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;

h.To object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you;

i.If we are processing your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent. You may do so by contacting us;

IX. OUR POLICIES CONCERNING CHILDREN

Our Platform is not intended for children (under the age of 13 or such higher age as required by applicable law). We do not knowingly collect or solicit any personal data or target interest based advertising to children and we do not knowingly allow children to register for or use the Platform. Children should not use our Platform or send us any personal data about themselves at any time. In the event that we learn that we have inadvertently gathered personal data from children, we will take reasonable measures to promptly erase such information from our records. If youbelieve that we might have information from or about a child, please contact us contact@ukustudy.com.

X. CONTACTING US AND CHANGES TO YOUR PERSONAL DATA

If you have any questions or comments about this Privacy Policy or your personal data, or if you want to exercise any of your rights, including as set out in paragraph 9 above, or you wish to withdraw your consent where we have stated we are processing your personal data based on your consent, then please contact our Data Protection Officer via e-mail at: contact@ukustudy.com;

XI. CHANGES TO THIS PRIVACY POLICY

1. Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.