Introduction

Welcome to Aroundsound’s privacy policy.

Our privacy policy will help you understand what information we collect via the Aroundsound app (“App”), how we use it, and what choices you have.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.

Important information and who we are

1. Controller

   Gritstone Studios Limited trading as Aroundsound is the controller and responsible for your personal data (referred to as “Aroundsound”, “we”, “our” or “us” in this privacy policy). When we talk about the “Services” in this privacy policy, we are referring to our sound recording and collection platform. Our Services are currently available for use via an Android application and an Apple iOS application with some web browser integration. When we talk about “you” or the “User” in this privacy policy we are talking about the user of the App on any or all of the available operating systems.

2. Contact details

   If you have any questions about this privacy policy or our privacy practices, please contact our data protection officer (“DPO”) in the following ways:

   Full name of legal entity: Gritstone Studios Limited trading as Aroundsound

   Email address: feedback@aroundsound.com

   Postal address: Denby House Business Centre, Loscoe, Derbyshire, DE75 7AB

Information we collect and receive

1. Audio Data

   Audio content or sound recordings created by the User are referred to in this privacy policy as “Audio Data”. We collect Audio Data on behalf of the User when the User is signed in to the App, by saving copies to cloud storage (specifically Google’s Firebase product Google Cloud storage). We store this data because it supports the syncing mechanism which allows you to manage and replay recordings independent of on which device they were recorded. If you are signed in to the App and additionally if you share Audio Data with another person by means of the sharing mechanism within the App, then that Audio Data may be accessible to anybody who has access to the unique web address generated by Aroundsound. Additionally, if that web address is shared outside of Aroundsound, then the Audio Data is accessible by visiting that web address. Data is shared with Google Cloud Services under their service agreement and in accordance with the Google Cloud GDPR Policy.

   You can delete Audio Data at any time from within the App after which it is immediately unavailable to you or anybody with whom you have shared the Audio Data. We will delete it within a reasonable length of time from our back-up Data. If you have deleted Audio Data in error you can contact us and we will try our best to retrieve it from a back-up.

2. Metadata

   We may store and associate Metadata with Audio Data. Metadata includes: recording title; recording description; recording duration; geographic name captured as the recording was started (only captured when location services are explicitly enabled by you); latitude and longitude captured as the recording was started (only captured when location services are explicitly enabled by you, and as provided by the device); recording date; recording start time; recording owner username; recording owner avatar (if set); collection to which recording is associated (if applicable); collection title (if applicable); comment text associated with the collection (if applicable); actions associated with the sharing and commenting of recordings (if applicable); and whether the recording has been edited / formatted. Some Metadata is visible at or accessible from the web address of the Audio Data if the Audio Data has been shared.

3. User Authentication Data

   All Aroundsound users are required to sign in to use the App. User Authentication Data includes any data associated with signing in to the Aroundsound service that is available to us.

   We currently use three third party authentication providers, which are Google, Apple and Facebook. When signing in using one of the third party providers, you are subject to their Terms of Service and Privacy Policy. These external services are not operated by us. We have access to some personal information from these third party services and we only choose to collect your email address, name and avatar. We strongly advise you to review the privacy policy of these services. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

   On our Apple iOS application you can choose to use an email authentication service supported by Google Firebase. When signing in using your email address, we only choose to store your email address and your password is not visible or available to us or Google Firebase.

   Your User Authentication Data is stored securely and in line with General Data Protection Regulation (GDPR) requirements.

   After you have signed up to Aroundsound we may use your email address to contact you directly, however you are free to opt out any time by unsubscribing or contacting us directly at feedback@aroundsound.com.

4. Email address

   If you contact us using our feedback service within the App or via our Website then we will store the content of any emails received and the email address associated with the device, from which the email was sent. This is in order that we can reply to feedback and track enquiries.

5. Log Data

   When you use the Services we automatically record information your mobile app sends when you are using it. This Log Data may include the data and time of your use of the Services, specific button taps, and language preferences. This data helps us understand and improve the usage of Aroundsound. Log Data is stored under a randomly generated User ID and is not directly connected to personal information (such as an email address) and can only be tied back to your User Authentication Data via a separate dataset with distinct access controls.

6. Device information

   We may collect information about the device you are using the Services on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers and crash data. This data helps us understand and improve the usage of Aroundsound. Whether we collect some or all of this information often depends on what type of device you are using and its settings.

7. Geolocation information

   Precise GPS location from mobile devices is collected only with your permission, which we explicitly ask for when the app is first installed. If you decline to provide permission to use GPS location information, then certain features in the Service may not work. You are free to change this permission at any time within your device settings.

8. Services integrations

   This Service may contain links to other services. For example, you may click on a link to use a service (e.g. Facebook, WhatsApp) to share Audio Data, and we will connect that service to ours. These external services are not operated by us. We do not receive or store your passwords for any of these third party services. We strongly advise you to review the privacy policy of these services. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

9. Third Party Analytics Services

   We may employ third party companies to analyse how our service is being used (for example, Google Analytics). Such third party services have access to your information including but not limited to i) your use of this Service ii) your location iii) your device information iv) log data v) metadata, however they are obligated not to disclose use this information for any other purpose than to help us analyse how our service is being used. This data is not connected to your email address. They do not have access to your Audio Data.

10. Cookies

    “Cookies” are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your device’s internal memory. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

    See our cookie policy for further details.

International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see the European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How we use your information:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

Please see our Glossary below to find out more about the types of lawful basis that we rely on to process your personal data.

You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a summary of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To install the App and register you as a new App user	Identity Data Contact Data Device	Performance of a contract with you
To process and deliver our Services	Identity Data Contact Data Transaction Data Device Data Marketing and Communications Data Location Data (opt in only)	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to the App, the Services and/or our privacy policy (b) Asking you to leave a review or take a survey	Identity Data Contact Data Profile Data Marketing and Communications Data	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products / services)
To enable you to partake in a prize draw, competition or complete a survey	Identity Data Contact Data Profile Data Device Data Marketing and Communications Data	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products / services, to develop them and grow our business)
To administer and protect our business and this App (including troubleshooting, data analysis and system testing	Identity Data Contact Data Device Data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App	Identity Data Contact Data Profile Data Usage Data Marketing and Communications Data Device Data Content Data Location Data (opt in only)	Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)

We use your information to provide and improve the Services. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel our Services but we will notify you if this is the case at the time.

1. User Data

   Aroundsound may access and use Information we collect and receive as reasonably necessary and in accordance with this Privacy Policy to a) provide, maintain and improve the Services, b) to prevent or address service, security, technical issues or in connection with user support matters, or c) as required by law (for example, to enforce our rights, prevent fraud and for safety).

   We may use Audio Data to determine whether it is offensive in nature (see Terms of Service) and then to take appropriate action, such as to pass your Data to any law enforcing organisations.

   Data is synced automatically and securely between the App and server side applications and cloud storage using Hyper Text Transfer Protocol Secure (HTTPS).

   Disclosures of your personal data

   We may share your personal data with the parties set out below for the purposes set out in the table above:

   • Internal Third Parties (as set out in the Glossary).

   • External Third Parties (as set out in the Glossary).

   • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

   • To comply with legal processes, to establish or exercise our legal rights, to defend against legal claims or otherwise required by law.

   We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with or instructions.

   Your personal data may be shared with Good Cloud Services (“GCP”) in accordance with their service agreement https://cloud.google.com/terms/ and the Google Cloud privacy policy https://cloud.google.com/terms/data-processing-terms and https://policies.google.com/privacy in order to securely back up and share data using cloud services. We use the following GCP managed services:

   • Google App Engine
     • Personal data in transit is encrypted over HTTPS
     • Managed service environment
     • Secrets configuration access protected by IAM
   • Big Query
     • Server-side encryption of data at rest
     • Authorisation controlled via IAM
     • Access to data is over HTTPS
   • Cloud Firestore
     • Server-side encryption of personal data at rest
     • Authorisation controlled via IAM
     • Daily backups stored in Google Cloud Storage:
     • Service-side encryption of personal data at rest for backups
     • Backups stored in different multi-region
     • Client-side data in transit is over HTTPS
     • Data access rules are checked-in to and deployed from source control and deployed changes are auditable
     • Data access rules are reviewed and tested by developers
   • Cloud Functions
     • Managed environment for code execution
     • Any public-facing endpoints use HTTPS
   • Cloud Pub/Sub
     • Server-side encryption of personal data at rest
     • Data retention set to 7 days
     • Authorisation to read/write messages controlled via IAM and service accounts
   • Cloud Storage
     • Server-side encryption of data at rest
     • Access controlled via IAM
     • Daily backups to Cloud Storage
     • Stored in different buckets for different multi-regions

2. Other types of disclosure

   We may disclose or use aggregate de-identified information for any purpose. For example, telling a potential investor the average number of audio recordings taken in a day using Aroundsound.

Children’s information

Our services are not directed at children under 13. If you learn that a child under 13 has provided us with information without consent, or you have any related concerns, please contact us (see below).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

1. Promotional offers from us

   We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

   You will receive marketing communications from us if you have requested information from us or received Services from us and you have not opted out of receiving that marketing.

2. Third-party marketing

   We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

3. Opting out

   You can ask us or third parties to stop sending you marketing messages at any time by opening the App checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.

   Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of us providing our Services, service experience or other transactions.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an authorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).

Certain of the Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data (see Your legal rights below).

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us (see below).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Privacy Policy

We keep our privacy policy under regular review. This version was last updated on 27th November 2019.

We may change this policy from time to time and if we do we will post any changes on this page. Thus, you are advised to review this page periodically for any changes. These changes are effective immediately, after they are posted on this page. If you continue to use the Services after those changes are in effect, you agree to the revised privacy policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Contacting us

Please also feel free to contact us if you have any questions about our Privacy Policy or practices. You may contact us at feedback@aroundsound.com or at our mailing address below:

Gritstone Studios Limited,
Denby House Business Centre,
Loscoe,
Derbyshire,
DE75 7AB,
UK

Glossary

DATA

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Device Data includes that type of mobile device you use, mobile network information, your mobile operating system, the type of mobile browser you use.
• Content Date includes information stored on your device, including friends’ lists, login information, photos, videos or other digital content.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use the App, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Date includes your current location disclosed by GPS technology.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors based in Hungary who provide App development services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances