Effective Date: November 12, 2024

Live Music Streaming Technology, Inc. DBA Trubify (“TRUBIFY”, “us”, or "we”) knows that you care about how your personal information is used and shared. We want to provide you with answers to your questions and concerns. You may direct any privacy-related questions to support@trubify.com.

This Privacy Policy describes TRUBIFY’s practices regarding the collection, use, and disclosure of the information we collect from and about you when you use TUBIFY’s website (http://www.trubify.com, or the “Website”), mobile application (“Trubify” or the “Application”), or associated products and services (collectively, with the Website and Trubify, the “Services”). By accessing or otherwise using the Services, you consent to the collection, use, and disclosure of information as described in this Privacy Policy.

This Privacy Policy contains the following sections:

• The Information We Collect
• Cookies and Similar Technologies
• How We Use Your Information
• Online Analytics and Advertising
• How We Share and Disclose Your Information
• Your Choices
• Third Party Website Links and Features
• Children’s Privacy
• Your Rights
• How Long We Store Your Information
• Changes to Our Privacy Policy
• How You Can Access and Update Your Information
• How We Protect Your Information
• California Privacy Rights
• Use of the Services from Outside the United States
• TRUBIFY Contact Information

The Information We Collect

Information You Provide to Us

TRUBIFY collects information from you when you do certain things, such as:

• Register for, administer, or sign in to your account
• Make a purchase
• Sign up to receive SMS (text message) notifications
• Download or use Trubify
• Use or otherwise interact with the Services directly or through social media,
• Submit requests or questions to us via forms or email
• Communicate with us or have other dealings with us, including requests for customer support or technical assistance
• Submit uploads or posts to the Services

The types of information we collect will depend upon the Services you use, how you use them, and what you choose to provide. The types of data we collect directly from you may include:

• Name, address, telephone number, email address, date of birth, SSN, and additional information collected for purposes of identity verification
• Optional information, including demographic information, or information that you elect to associate with your account (your “Profile Information”)
• Log-in details, if you create a TRUBIFY account
• Any email requests or questions you submit to us
• User content including but not limited to emails, communications, and other information for publication or distribution to third parties.
• If you choose to link a bank account or PayPal account to your user account in the Services, we will also collect information from you such as your login credentials for those accounts and other financial data and documents that we receive from the financial institution

Information We Automatically Collect

When you use the Services, we may automatically collect certain information as described in this Section.  As discussed further below, we and our service providers (which are third party companies that work on our behalf to provide and enhance the Services) use a variety of technologies, including cookies and similar tools, to assist in collecting this information.

Log Files

When you use the Services, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with the Services, metadata associated with uploaded Content, domain names, landing pages, pages viewed or moused-over, mobile carrier, date and time stamp information and other such information.

Device Identifiers

When you access the Services using a computer or mobile device, we may collect specific device information, including your MAC address and other unique device identifiers. We also collect information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your account and will use data associated with your device identifier to customize our Services to your device and to analyze any device-related issues. We may also use information gathered from your device to assist us with cross-device tracking, as described further below.

Location Information

We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturers instructions for further details. Even if you disable this, we may make certain assumptions about your location from your IP Address, or other information related to your use of the Services.

Camera, Photos, and Microphone Access

Trubify may ask you to grant access to your mobile device's camera, microphone and/or photo library. This access is only when the app is in use to allow you to live stream your performance and upload images to an image gallery. Trubify only uses the access to these functions of your mobile device when you initiate a livestream or initiate an image upload. As soon as you end your livestream, the service will stop the use of your device's camera and microphone. Trubify does not use your camera or microphone or access your image library in any background tasks or operations.

Information We Collect from Third-Party Integrations

If you choose to use third-party integrations through the Services, such providers may allow us and our service providers to have access to and store additional information about your interaction with those services and platforms as it relates to use of the Services.

Information We Collect From Affiliates And Non-Affiliated Third Parties

Trubify may receive additional information about you, such as demographic information, from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may use to supplement the information that we collect directly from you.

When you link your Bank Account to your Trubify Account, Trubify may also receive information about you and your Bank Account from the financial institution holding your Bank Account as necessary to provide the Services to you.

Collection of Information Across Devices

Sometimes, we may use the information we collect -- for instance, usernames, IP addresses and unique mobile device identifiers -- to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to provide you with a seamless experience across devices.

Cookies and Similar Technologies

To collect the information in the “Information We Automatically Collect” section above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services.

How We Use Your Information

We use your information (including any information that we collect, as described in this Privacy Policy) for various purposes depending on the types of information we have collected from and about you and the specific Trubify Services you use, including to:

• Provide the services and customer support you have requested
• Process transactions and send notices about your transactions or your network activity
• Compare information for accuracy and verification purposes
• Respond to your request for information and provide you with more effective and efficient customer service
• Provide you with product and service updates that we are offering
• Provide you with service notifications via email and within the Services based on your notification selections
• Customize the advertising and content you see
• Synthesize and derive insights from your use of the Services to help us better understand your interests and needs, and improve the services
• Protect our Services and our users
• Enforce the legal terms that govern your use of the Services

User Content. The Services may permit you to submit content, send emails and other communications, and provide other information for publication or distribution to third parties (collectively, "User Content"). Trubify may view and share your User Content for any reason, including: (i) to maintain, provide and improve the Service; (ii) to resolve a support request from you; (iii) if we have a good faith belief, or have received a complaint alleging, that such Content is in violation of our Terms of Service; (iv) as reasonably necessary to allow Trubify to comply with or avoid the violation of applicable law or regulation; or (v) to comply with a valid legal subpoena, request, or other lawful process. We may also analyze your User Content in aggregate and on an anonymized basis, in order to better understand the manner in which our Service is being used.

Combined Information. For the purposes discussed in this Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.

Aggregate/De-Identified Data. We may aggregate and/or de-identify information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others. By using the Services, you consent to such use.

Online Analytics and Advertising

Analytics

We use third-party web and application analytics services on our Services to collect and analyze some of the information discussed above, and to engage in auditing, research or reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies and Similar Technologies” section will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive, analyzing usage trends across Trubify websites and mobile devices, assisting with fraud prevention, and providing certain features to you.

If you receive email from us, we may use certain analytics tools to capture data, such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Online Advertising

Third parties or affiliates may administer Trubify banner advertising programs and other online marketing on non-Trubify websites and services. To do so, these parties may set and access first-party cookies delivered from a Trubify domain, or they may use third-party cookies or other tracking mechanisms. For example, a third-party provider may use the fact that you visited the Trubify website to target online ads for Trubify services to you on non-Trubify websites or across mobile apps. Additionally, a third-party ad network might collect information on the Services and other websites to develop a profile of your interests and target advertisements to you based on your online behavior. These parties that use these technologies may offer you a way to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms

California Do-Not-Track Disclosure Requirements

We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide above the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, TRUSTe’s Advertising Choices page, the Google opt-out link. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.

How We Share Your Information

Affiliates and Subsidiaries. We may share all information we collect within the Company.

Service Providers. We may provide access to or share your information with select third parties who perform services on our behalf. These third parties provide a variety of services to us, including without limitation billing, sales, marketing, provision of content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing through the Automated Clearinghouse Network, and legal services.

Legal Process. We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.

Investigations. We may disclose your information when we believe in good faith that such disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service for the Services you accessed, and/or to protect the rights and property of Trubify, our employees, users and the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

Third-Party Integrations. When you initiate a connection with a third-party integration through the Services, we will share information about you that is required to enable your use of the third-party integration through the Services.

Business Transfers. If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Services can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Trubify will comply with such restrictions.

Aggregate/De-Identified Information. From time to time, Trubify may share Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. As stated above, this Policy places no limitations on our use or sharing of Aggregate/De-Identified Information.

Consent. We may also disclose your information to third parties with your prior consent.

Your Choices

We provide you with a number of choices with respect to the information we collect and use as discussed throughout this Privacy Policy.  For example, you may instruct us not to use your contact information to contact you by email, postal mail or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails.  Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational or service-related emails, such as those reflecting our relationship or transactions with you.

Third Party Links and Services

The Services contain links to third-party apps or websites or services, and also contain third-party integrations.  If you choose to use these, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function.  Because these third-party websites and services are not operated by Trubify, Trubify is not responsible for the content or practices of those websites or services.  The collection, use, and disclosure of your personal and other information will be subject to the privacy policies of the third party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third-parties.

Children's Privacy

The Services are not intended for individuals under the age of 13. We do not knowingly solicit or collect information from individuals under the age of 13. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13, we will take reasonable steps to delete it as soon as practicable. If you have concerns, or if you believe the Services are being used by someone under the age of 13, you can address these concerns to support@trubify.com.

Your Rights

If you want to learn more about the information collected through the Services, or if you would like to access or rectify your information and/or request deletion of information we collect about you, or restrict or object to the processing of your information, please contact us using the contact information below.

Where you have provided consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing your consent.

How Long We Store Your Information

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Changes to Our Privacy Policy

We reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Policy accessible through the Services, so you should review the Policy periodically. If we make a material change to the Policy, you will be provided with appropriate notice and we will seek your consent to the updated Policy in accordance with legal requirements.

How You Can Access and Update Your Information

To access, review, update and/or delete certain user profile information, you may update and/or delete certain user profile information by logging into the app and updating your account. Please remember, however, if we have already disclosed some of this user profile information to third parties, we cannot force the deletion or modification of any such user profile information by the parties to whom we have made those disclosures.

How We Protect Your Information

Although we take reasonable measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy. If you have any questions about how we protect your information, you can contact us at support@trubify.com.

California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. [However, Trubify does not share your personal information with third parties for their own direct marketing purposes.] If you are a California resident and would like to request this information, please submit your request in an email to support@trubify.com.

Additionally, California law permits residents under the age of 18 who are registered users with us to request and obtain removal of content or information they have publicly posted on our Services. To make such a request, please send an email with a detailed description of the specific content or information to support@trubify.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Use of the Services from Outside the United States

The Services are provided, supported, and hosted in the United States and are governed by United States law and the laws of the applicable states within the United States. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our databases are operated. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Privacy Policy.

Trubify Contact Info

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at support@trubify.com, or Live Music Streaming Technology, Inc., 3001 Redhill, Suite 219, Costa Mesa, CA 92626