Privacy Policy
This Privacy Policy describes how we process your personal data at Ragasphere LLP hereinafter called the 'Policy'.
It applies to your use of all the services available on www.ragasphere.com collectively called the 'Service'.
From time to time, we may develop new or offer additional services. They'll also be subject to this Policy, unless stated otherwise when we introduce them.
2. Your personal data rights and controls
Many privacy laws give rights to individuals over their personal data. These laws include the General Data Protection Regulation, or 'GDPR'.
Some rights only apply when Ragasphere uses a certain 'legal basis' to process your data.
Below is the explanation about your rights, circumstances when they apply (such as the legal basis required), how to use them.
Be informed of the personal data we process about you and how we process it.
We inform you through this Policy through information provided to you as you use the Ragasphere Service by answering your specific questions and requests when you email us on contact@ragasphere.com
Request access to the personal data we process about you.
To request a copy of your personal data from Ragasphere, please email us on contact@ragasphere.com. When you download your data you will receive the information about your data that Ragasphere has to provide under Article 15 of the GDPR. If you would like more information about how we process your personal data, you can email us on contact@ragasphere.com
Request that we amend or update your personal data where it’s inaccurate or incomplete.
You can edit your User Data under ‘Edit profile’ in your account or by emailing us on contact@ragasphere.com
Request that we erase certain of your personal data.
Login to your account and delete your account. Alternatively email us on contact@ragasphere.com requesting to erase your information.
There are situations where Ragasphere is unable to delete your data, for example when:
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it’s still necessary to process the data for the purpose we collected it for
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Ragasphere’s interest in using the data overrides your interest in having it deleted. For example, where we need the data to protect our services from fraud
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Ragasphere has a legal obligation to keep the data, or
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Ragasphere needs the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account
Request that we stop processing all or some of your personal data.
You can do this if:
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your personal data is inaccurate
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our processing is unlawful
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we do not need your information for a specific purpose, or
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you object to our processing and we are assessing your objection request. See section ‘Object’ belo
You can request that we stop this processing temporarily or permanently.
You can change your personal data from your account. Alternatively, you can exercise your right to restriction by emailing us on contact@ragasphere.com
Object to us processing your personal data.
You can do this if:
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Ragasphere is processing your personal data on the legal basis of legitimate interests, or
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Ragasphere is processing your personal data for tailored advertising
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To exercise your right to object, you can email us on contact@ragasphere.com
Data portability
Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.
You can request us to transmit your data when we are processing your personal data on the legal bases of consent or performance of contract. However Ragasphere will try to honour any request to the extent possible.
For information about how to exercise the right to portability, see ‘Access’ above.
Not be subject to automated decision making
Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
Ragasphere does not carry out this type of automated decision making in the Ragasphere Service.
Withdraw your consent to us collecting or using your personal data.
You can do this if Ragasphere is processing your personal data on the legal basis of consent.
To withdraw your consent, you can email us on contact@ragasphere.com
Right to lodge a complaint
Contact your local data protection authority about any questions or concerns.
You can also go to the website of your local data protection authority.
3. Personal data we collect about you
Collected when you sign up for the Ragasphere Service or when you update your account. Personal data that we need to create your Ragasphere account and that enables you to use the Ragasphere Service.
The type of data collected and used depends on the type of Service Option you have. It also depends on how you create your account, the country you are in, and if you use third party services to sign in. This may include your:
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profile name
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email address
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password
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phone number
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date of birth
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gender
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street address (see further details below)
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country
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Street Address Data
We may ask for and process your street address for the following reasons:
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to check eligibility for a Service Option
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to deliver notices which are required by law
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to deliver support options
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for billing and tax administration
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to deliver physical goods or gifts which you have requested
In some cases, we may use a third party application to help you verify your address, such as Google Maps.
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Collected through your use of the Ragasphere Service
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Categories
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Description
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Usage Data
Personal data collected and processed about you when you’re accessing or using the Ragasphere Service. There are a few types of information this includes, listed in the following sections.
Information about how you use Ragasphere. Examples include:
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information about your Ragasphere Service Option
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your actions with the Ragasphere Service (including date and time), such as:
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search queries
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streaming history
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playlists you create
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your library
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browsing history
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account settings
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interactions with other Ragasphere users
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your use of third party services, devices and applications in connection with the Ragasphere Service
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inferences (i.e., our understanding) of your interests and preferences based on your usage of the Ragasphere Service
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content you provide when participating in Ragasphere promotions, such as contests or sweepstakes
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content you post to any part of the Ragasphere Service. For example: images, audio, text, titles, descriptions, communications, and other types of content
Your technical data. Examples include:
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URL information
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online identifiers such as cookie data and IP addresses
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information about the devices you use such as:
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device IDs
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network connection type (e.g. wifi, 4G, LTE, Bluetooth)
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provider
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network and device performance
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browser type
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language
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information enabling digital rights management
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operating system
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information which enables us to discover and connect with third party devices and applications. Examples of this information are the device name, device identifiers, brand and version. Examples of third party devices and applications are:
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devices on your wifi network (such as speakers) which can connect to the Ragasphere Service
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devices your operating system makes available when connecting via Bluetooth, plugin, and installation
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Ragasphere partner applications to determine whether the application is installed on your device
Your general (non-precise) location
Your general location includes country, region or state. We may learn this from technical data (e.g. your IP address, language setting of your device) or payment currency. We need this to meet geographic requirements in our agreements with the owners of content on the Ragasphere Service deliver content and advertising that’s relevant to you.
Your device sensor data
Motion-generated or orientation-generated device sensor data if needed to provide features of the Ragasphere Service that require this data. This is data which your device collects about the way you move or hold your device.
Additional data you may choose to give us
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Categories
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Description
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Voice Data
If voice features are available in your market and where you’ve chosen to use a voice feature, we collect and process voice data. Voice data means audio recordings of your voice and transcripts of those recordings.
Payment and Purchase Data
If you make any purchases from Ragasphere or sign up for a paid Service Option or a trial, we will need to process your payment data.
The exact personal data collected and used will vary depending on the payment method. It will include information such as:
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name
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date of birth
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payment method type (e.g. credit or debit card)
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if using a debit or credit card, the card type, expiration date, and certain digits of your card number Note: For security, we never store your full card number
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ZIP/postal code
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mobile phone number
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details of your purchase and payment history
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Survey and Research Data
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When you respond to a survey or take part in user research, we collect and use the personal data you provide.
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We receive some of the data mentioned above from third parties. The below table describes the categories of those third parties.
Third party sources that we receive your data from
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Categories of third parties
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Description
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Data categories
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Authentication partners
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If you register for or log into the Ragasphere Service using another service, that service will send your information to us. This information helps create your account with us.
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User Data
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Third party applications, services and devices you connect to your Ragasphere account
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If you connect your Ragasphere account to a third party application, service or device, we may collect and use information from them. This collection is to make the integration possible.
These third party apps, services or devices may include:
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social media
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devices including:
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audio (e.g. speakers and headphones)
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smart watches
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televisions
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mobile phones and tablets
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automotive (e.g. cars)
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games consoles
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services or platforms such as voice assistants or content platforms
We’ll ask your permission before we collect your information from certain third parties.
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User Data
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Usage Data
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Technical service partners
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We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g., country or region, city, state).
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This makes it possible for Ragasphere to provide the Ragasphere Service, content, and features.
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We also work with security service providers who help us protect user accounts.
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User Data
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Usage Data
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Payment partners and Merchants
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If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners.
This allows us to:
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send you invoices
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process your payment
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give you what you’ve purchased
If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to an artist’s merchandise store on a third party platform or to a third party ticketing website.
Receiving this data allows us to:
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calculate any commissions owed to us
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analyse the effectiveness of our partnership with these merchant partners
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understand your interests
Advertising and marketing partners
We receive inferences from certain advertising or marketing partners. These inferences are the partners’ understanding of your interests and preferences.
This allows us to deliver more relevant ads and marketing.
Usage Data
Acquired companies
We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.
User Data
Usage Data
If you try Ragasphere using a logged out user experience, we will collect limited information about your usage of the Ragasphere Service, including Usage Data. We do this to understand how you are accessing and using the Service. We also do this to ensure we provide the right experience for you, for example based on your country or region. If you decide to create a Ragasphere account to experience our service in full, then we will combine this data with your Ragasphere account data.
4. Our purpose for using your personal data
The table below sets out:
our purpose for processing your personal data
our legal justifications (each called a 'legal basis') under data protection law, for each purpose
categories of personal data which we use for each purpose. See more about these categories in Section 3 'Personal data we collect about you'
Here is a general explanation of each 'legal basis' to help you understand the table:
Performance of a Contract: When it's necessary for Ragasphere (or a third party) to process your personal data to:
comply with obligations under a contract with you. This includes Ragasphere's obligations under the Terms of Use to provide the Ragasphere Service to you, or
verify information before a new contract with you begins.
Legitimate Interest: When Ragasphere or a third party has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Ragasphere users. For example, using your Usage Data to improve the Ragasphere Service for all users. Contact us if you want to understand a specific justification.
Consent: When Ragasphere asks you to actively indicate your agreement to Ragasphere's use of your personal data for a certain purpose.
Compliance with Legal Obligations: When Ragasphere must process your personal data to comply with a law.
Purpose for processing your data
Legal basis that permits the purpose
Categories of personal data used for the purpose
To provide the Ragasphere Service in accordance with our contract with you. See Section 1 ‘About this Policy’ for what we mean by the Ragasphere Service.
For example, when we use your personal data to:
set up an account for you
personalise your account, or
provide the Ragasphere app when you download it onto your device
Performance of a Contract
User Data
Street Address Data
Usage Data
Voice Data
Payment and Purchase Data
To provide further parts of the Ragasphere Service.
For example, when we use your personal data to enable you to share a link to Ragasphere content with someone else.
Legitimate Interest
Our legitimate interests here include:
keeping the Ragasphere Service running and functional
allowing users to access and use the Ragasphere Service
User Data
Street Address Data
Usage Data
Voice Data
Payment and Purchase Data
To provide certain additional voluntary features of the Ragasphere Service. When this is the case, we will clearly ask for your consent.
Consent
User Data
Usage Data
Survey and Research Data
Payment and Purchase Data
To understand, diagnose, troubleshoot, and fix issues with the Ragasphere Service.
For example, we use your personal data to:
respond to your messages when you contact customer services
spot unusual data or behaviour in our logs which might indicate a bug or other issue, or
check and verify accounts to find and prevent unauthorised users
Performance of a Contract
User Data
Usage Data
To evaluate and develop new features, technologies, and improvements to the Ragasphere Service.
For example:
we use personal data to develop and improve our personalised recommendation algorithms
we analyse how our users react to a particular new feature and see whether we should make any changes
Legitimate Interest
Our legitimate interests here include developing and improving products and features for our users.
User Data
Usage Data
Voice Data
Survey and Research Data
For marketing or advertising where the law requires us to collect your consent.
For example, when we use cookies to understand your interests or the law requires consent for email marketing.
Consent
User Data
Usage Data
Survey and Research Data
For other marketing, promotion and advertising purposes where the law does not require consent.
For example, when we use your personal data to tailor advertising to your interests.
Legitimate Interest
Our legitimate interests here include using advertising to fund the Ragasphere Service, so that we can offer much of it for free.
User Data
Usage Data
Survey and Research Data
To comply with a legal obligation that we are subject to.
This might be:
an obligation under the law of the country / region you are in
Swedish law (because of our headquarters in Sweden), or
EU law that applies to us
For example, when we use your date of birth when required for age verification purposes.
Compliance with legal obligations
User Data
Street Address Data
Usage Data
Voice Data
Payment and Purchase Data
Survey and Research Data
To comply with a request from law enforcement, courts, or other competent authorities.
Compliance with legal obligations, and legitimate interest Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.
User Data
Street Address Data
Usage Data
Voice Data
Payment and Purchase Data
Survey and Research Data
To fulfil contractual obligations with third parties.
For example, when we provide pseudonymised data about our users’ listening because we have an agreement with a Ragasphere rightsholder to do so.
Pseudonymised data means that your data is identified by a code rather than your name or other directly identifying information.
Legitimate Interest
Our legitimate interests here include:
maintaining our relationships with artists so that we can provide the Ragasphere Service
maintaining our relationships with other third parties for the same reason
User Data
Usage Data
Voice Data
Payment and Purchase Data
To take appropriate action with reports of intellectual property infringement and inappropriate content.
Legitimate Interest
Our legitimate interests here include protecting intellectual property and original content.
User Data
Usage Data
Voice Data
Payment and Purchase Data
To establish, exercise, or defend legal claims.
For example, if we are involved in litigation and we need to provide information to our lawyers in relation to that legal case.
Legitimate Interest
Our legitimate interests here include:
seeking legal advice
protecting ourselves, our users or others in legal proceedings
User Data
Street Address Data
Usage Data
Voice Data
Payment and Purchase Data
Survey and Research Data
To conduct business planning, reporting, and forecasting.
For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in.
Legitimate Interest
Our legitimate interests here include researching and planning so that we can keep running our business successfully.
User Data
Usage Data
Payment and Purchase Data
To process your payment.
For example, when we use your personal data to let you purchase a Ragasphere subscription.
Performance of a Contract, and consent
User Data
Payment and Purchase Data
Street Address Data
To detect and prevent fraud.
For example, when we analyse Usage Data to check for fraudulent use of the Ragasphere Service.
Legitimate Interest
Our legitimate interests here include protecting the Ragasphere Service and our users against fraud and other illegal activity.
User Data
Street Address Data
Usage Data
Payment and Purchase Data
To conduct research and surveys.
For example, when we contact our users to ask for your feedback.
Legitimate Interest
Our legitimate interests here include to understand more about how users think about and use the Ragasphere Service.
User Data
Usage Data
Voice Data
Survey and Research Data
This section sets out who receives personal data which is collected or generated through your use of the Ragasphere Service.
Publicly available information
The following personal data will always be publicly available on the Ragasphere Service (except to any user you have blocked):
your profile name
your profile photo
your public playlists
other content you post on the Ragasphere Service, and any associated titles, descriptions and images
who you follow on the Ragasphere Service
who follows you on the Ragasphere Service
You or another user can share certain information on third party services, like social media or messaging platforms. This includes:
your profile
any content you post on Ragasphere and details about that content
your public playlists
When this sharing occurs, the third party service may store a copy of it to support their features.
Personal data you may choose to share
We will only share the following personal data with those outlined in the table below:
where you have chosen to use a Ragasphere Service feature, or a third party application, service or device, and we need to share personal data to enable this, or
if you otherwise grant us your permission to share the personal data. For example, you can do it by selecting the appropriate setting in the Ragasphere Service or by giving your consent
Categories of recipients
Categories of data you can choose to share
Reason for sharing
Third party applications, services and devices you connect to your Ragasphere account
User Data
Usage Data
To connect your Ragasphere account, or so that you can use the Ragasphere Service in connection with third party applications, services or devices.
Examples of such third party applications, services and devices include:
social media applications
speaker devices
televisions
automotive platforms
voice assistants
You can see and remove many third party connections under ‘Apps’ in your account.
Support community
User Data
To enable you to use the Ragasphere Support Community service.
When you register for an account on the Ragasphere Support Community, we’ll ask you to create a profile name. This will be publicly displayed to anyone who uses the Ragasphere Support Community. We’ll also display any questions or comments you post.
Other Ragasphere users
User Data
Usage Data
Voice Data
Artists and record labels
User Data
Information we may share
See this table for details of who we share to and why.
We keep your personal data only as long as necessary to provide you with the Ragasphere Service and for Ragasphere's legitimate and essential business purposes, such as:
maintaining the performance of the Ragasphere Service
making data-driven business decisions about new features and offerings
complying with our legal obligations
resolving disputes
Here are some of the categories of our retention periods:
Data retained until you remove it
It's your right to request that we delete certain of your personal data. See the section on 'Erasure' in Section 2 'Your personal data rights and controls' for more information.
Data that expires after a specific period of time
We have set certain retention periods so that some data expires after a specific period of time.
Data retained until your Ragasphere account is deleted
We keep some data until your Ragasphere account is deleted. When your Ragasphere account is deleted, your data is deleted or anonymised.
Data retained for extended time periods for limited purposes
After your account is deleted, we keep some data for a longer time period but for very limited purposes.
Criteria used to determine the retention periods include:
What is the appropriate retention period to carry out our purpose? Our systems are designed to automatically 'age out' data based on a defined retention period. We choose the retention period based on its legitimate business purpose.
Do we need to keep data to ensure the service that users expect? We keep personal data for an appropriate period to deliver a personalised service to our users over time. We typically keep streaming history for the life of an account, for example, to provide retrospective playlists that users enjoy and personalised recommendations that take listening habits into account. For example, Your Summer Rewind and the end-of-year Wrapped campaign.
Are users able to update or delete the data themselves? Where users are able to see and update the personal data themselves, we keep the information for as long as the user chooses.
Do we need to keep the data to uphold our rules and keep our service safe? We may keep data that has been removed from the Ragasphere Service for a limited period of time. This is:
to help ensure user safety
to protect against harmful content on our platform
to take action with reports of intellectual property infringement
Is Ragasphere subject to a legal or contractual obligation to keep or delete the data? Examples include mandatory data retention laws, government orders to preserve data relevant to an investigation or data kept for the purposes of litigation. Conversely, we will remove unlawful content if the law requires us to do so.
7. Transfer to other countries
Because of the global nature of our business, your personal data will be shared internationally among Ragasphere group companies, subcontractors and partners when carrying out the activities described in this Policy. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.
Whenever we transfer personal data internationally, we use tools to:
make sure the data transfer complies with applicable law
help to give your data the same level of protection as it has in the EU
To ensure each data transfer complies with applicable EU legislation, we use the following legal mechanisms:
Standard Contractual Clauses ('SCCs'). These clauses require the other party to protect your data and to provide you with EU-level rights and protections. For example, we use SCCs to transfer the personal data described in Section 3 'Personal data we collect about you' to our hosting provider which uses servers in the US. You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.
Adequacy Decisions. This means that we transfer personal data to countries outside of the European Economic Area which have adequate laws to protect personal data, as determined by the European Commission. For example, we transfer the personal data described in Section 3 'Personal data we collect about you' to vendors based in the United Kingdom, Canada, Japan, Republic of Korea and Switzerland.
We also identify and use additional protections as appropriate for each data transfer. For example, we use:
technical protections, such as encryption and pseudonymisation
policies and processes to challenge disproportionate or unlawful government authority requests
8. Keeping your personal data safe
We're committed to protecting our users' personal data. We put in place appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.
We have put various safeguards in place including pseudonymisation, encryption such as Transport Layer Security (TLS) and AES, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems. In addition, personal data stored in our computer systems are secured by physical security measures.
To protect your user account, we encourage you to:
use a strong password which you only use for your Ragasphere account
never share your password with anyone
limit access to your computer and browser
log out once you have finished using the Ragasphere Service on a shared device
read more detail on protecting your account
You can log out of Ragasphere in multiple places at once by using the 'Sign out everywhere' function on your account page.
If other individuals have access to your Ragasphere account, then they can access personal data, controls and the Ragasphere Service available in your account. For example, you might have allowed someone to use your account on a shared device.
It's your responsibility to only allow individuals to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your Ragasphere account may impact your personalised recommendations and be included in your data download.
Note: This Policy doesn't apply to Ragasphere Kids unless the Ragasphere Kids Privacy Policy says so. Ragasphere Kids is a separate Ragasphere application.
The Ragasphere Service has a minimum 'Age Limit' in each country or region. The Ragasphere Service is not directed to children whose age:
is under the age of 13 years
makes it illegal to process their personal data, or
requires parental consent to process their personal data
We do not knowingly collect or use personal data from children under the applicable Age Limit. If you're under the Age Limit, do not use the Ragasphere Service, and do not provide any personal data to us. Instead, we recommend using a Ragasphere Kids account.
If you're a parent of a child under the Age Limit and become aware that your child has provided personal data to Ragasphere, contact us.
If we learn that we've collected the personal data of a child under the applicable Age Limit, we'll take reasonable steps to delete the personal data. This may require us to delete the Ragasphere account for that child.
When using a shared device on the main Ragasphere Service, be cautious about playing or recommending any inappropriate content to individuals under 18 years old.
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Ragasphere Service or send you an email or device notification.
For any questions or concerns about this Policy, contact our Grievance Officer/Data Protection Officer any one of these ways:
Email contact@ragasphere.com
For the purposes of the GDPR, Ragasphere LLP is the data controller of personal data processed under this Policy.
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