PRIVACY POLICY

This document is a business-to-business legal document for ExpertMusic services. It is drafted for use with the ExpertMusic application, website, web player, mobile application, radio channels, video channels and related business music services.

1. Controller This Privacy Policy explains how Expert Music Sp. z o.o., with its registered office in Warsaw, Poland, at Al. Armii Ludowej 6/164, 00-571 Warsaw, Poland, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the National Court Register, under KRS number 0000502608, NIP 7010414161, REGON 147119490, share capital PLN 50,000.00 ("ExpertMusic", "we", "us" or "our") processes personal data in connection with the ExpertMusic website, application, web player, mobile application, customer account, music portal, payment flows, support services, radio channels, video channels and related business services (the "Service"). For privacy questions, rights requests and data protection matters, contact us at: support@expertmusic.net. If a data protection contact or Data Protection Officer is appointed by ExpertMusic, that person may be contacted at: aod@expertmusic.net.

2. Who this Policy applies to This Policy applies to business customers, representatives of business customers, account users, prospective customers, website visitors, support contacts, billing contacts, partners and other persons who interact with the Service. The Service is intended for business use and is not directed to children.

3. Personal data we process Depending on how you use the Service, we may process the following categories of personal data: a) identification data: first name, last name, business role and customer representative details; b) contact data: email address, postal address, phone number and support contact details; c) company and billing data: company name, tax number, registration number, billing address, invoice data, payment status, selected Plan, order history and subscription information; d) Venue data: business location name, address, type of venue, country, floor area or other information relevant to the license and Plan; e) Account data: login data, password hash, account settings, selected products, permissions and customer profile; f) usage data: Service activity, selected playlists, channels, player status, application interactions, device connections, technical logs and support history; g) technical data: IP address, device identifiers, browser type, operating system, app version, language settings, access times, pages visited, referrer URL and approximate location derived from technical data; h) communication data: emails, support messages, forms, requests, feedback and other correspondence; i) marketing data: consent status, marketing preferences, campaign interactions and website analytics; j) payment data: payment confirmation, transaction identifiers and payment status. Full payment card data is normally processed by payment service providers and not stored by ExpertMusic unless expressly stated otherwise.

4. How we collect data We collect personal data when you: a) visit our website or application; b) create or use an Account; c) place an Order or pay for a subscription; d) use the Application, web player, mobile app, radio channels, video channels or other Products; e) contact support; f) complete forms or request a proposal; g) subscribe to marketing communications; h) communicate with us as a partner, supplier or representative of a customer. We may also receive data from payment processors, hosting providers, analytics providers, communication tools, partners or public registers where lawful and relevant.

5. Purposes and legal bases We process personal data for the following purposes: a) to create and manage Accounts, provide the Service, activate Products and deliver the selected Plan - performance of a contract or steps before entering into a contract; b) to issue invoices, process payments, manage subscriptions, debt, tax records and accounting - performance of a contract and legal obligation; c) to identify the licensed Venue, generate license documents and verify the scope of use - performance of a contract and legitimate interest; d) to provide customer support and respond to requests - performance of a contract and legitimate interest; e) to maintain security, prevent fraud, protect the Service and enforce legal terms - legitimate interest and legal obligation where applicable; f) to maintain logs, diagnose errors, improve the Service and develop products - legitimate interest; g) to send service messages, subscription notices, invoices, technical notices and legal updates - performance of a contract, legal obligation and legitimate interest; h) to send marketing communications where permitted by law - consent or legitimate interest, depending on the communication and applicable law; i) to comply with legal obligations, respond to authorities and establish, exercise or defend legal claims - legal obligation and legitimate interest.

6. Requirement to provide data Providing data is voluntary, but some data is necessary to create an Account, conclude and perform a contract, issue an invoice, verify a licensed Venue, process payment, provide support or comply with law. If you do not provide required data, we may be unable to provide the Service.

7. Data recipients We may share personal data with recipients that support the Service, including: a) hosting and cloud infrastructure providers; b) payment processors and banks; c) accounting, invoicing and tax service providers; d) email, communication and support tools; e) analytics and security providers; f) IT contractors, developers and maintenance providers; g) legal, debt collection, audit and compliance advisers; h) public authorities, courts or regulators where required by law; i) business partners where necessary to provide a jointly requested service or where you have consented. Processors may process personal data only under appropriate data processing arrangements.

8. International transfers Some service providers may process personal data outside the European Economic Area. Where this happens, ExpertMusic uses safeguards required by applicable data protection law, such as an adequacy decision, standard contractual clauses or other lawful transfer mechanisms.

9. Retention periods We retain personal data only for as long as necessary for the purposes for which it was collected, including: a) Account and contract data for the duration of the customer relationship and afterwards for the limitation period for legal claims; b) invoice, accounting and tax data for the period required by accounting and tax law; c) support correspondence - for the period necessary to handle the request and protect legal interests; d) technical logs - for the period necessary for security, troubleshooting and service operation; e) marketing data until consent is withdrawn, objection is made or the data is no longer needed for marketing purposes; f) data processed on the basis of consent - until consent is withdrawn, unless another legal basis applies.

10. Your rights Subject to conditions and limitations under applicable law, you may have the right to: a) access your personal data; b) receive a copy of your data; c) correct inaccurate or incomplete data; d) request erasure of data; e) request restriction of processing; f) object to processing based on legitimate interests, including direct marketing; g) withdraw consent at any time, without affecting processing carried out before withdrawal; h) request data portability where applicable; i) lodge a complaint with the competent supervisory authority, in particular the President of the Personal Data Protection Office in Poland (Prezes Urzędu Ochrony Danych Osobowych). To exercise your rights, contact support@expertmusic.net or, where applicable, aod@expertmusic.net.

11. Cookies and similar technologies We use cookies and similar technologies to operate the website and application, keep users logged in, remember preferences, secure the Service, analyse traffic, improve usability and support marketing where permitted. Cookies may be: a) necessary cookies required for the Service to function; b) preference cookies that remember settings; c) analytics cookies that help us understand how the Service is used; d) marketing cookies used to measure and improve campaigns, where permitted. Where required by applicable EU and Polish laws (including GDPR and ePrivacy regulations), preference, analytics, and marketing cookies or tracking tools are used strictly on the basis of your prior voluntary consent. You are provided with a transparent consent management interface (cookie banner/preferences) that enables you to accept or reject non-essential cookies at any time, ensuring that rejecting non-essential tracking is as easy as accepting it. You can also manage cookies in your browser settings. Blocking some cookies may affect Service functionality.

12. Analytics, advertising and similar tools We may use analytics and advertising tools to understand website usage, improve the Service and measure marketing. Where required by law, such tools are deployed only after obtaining your explicit prior consent through our consent management platform, allowing you to opt out or withdraw consent at any time without negative consequences.

13. Security We use technical and organisational measures intended to protect personal data, including access controls, encryption where appropriate, secure communication, backups, logging and internal access restrictions. No internet service can guarantee absolute security. You must protect your Account credentials and notify us promptly if you suspect unauthorised access.

14. Automated decision-making We do not make decisions producing legal or similarly significant effects based solely on automated processing, unless we inform you separately and such processing is permitted by law.

15. Business customers and representatives If you provide personal data of employees, contractors or other representatives of your business, you must ensure that you are allowed to provide such data to ExpertMusic and that those persons receive appropriate privacy information.

16. Marketing communications We may send marketing communications where permitted by law. You can opt out of marketing at any time by using the unsubscribe mechanism in the message or contacting support@expertmusic.net. Service, billing, technical and legal notices are not marketing communications and may still be sent where necessary for the customer relationship.

17. Changes to this Privacy Policy We may update this Privacy Policy from time to time because of legal, technical, business or Service changes. The updated version applies from the date of publication unless stated otherwise.

18. Contact Privacy and support contact: support@expertmusic.net. Data protection contact, if applicable: aod@expertmusic.net. Postal contact: Expert Music Sp. z o.o., Al. Armii Ludowej 6/164, 00-571 Warsaw, Poland.

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