We’re glad you are a part of the Solfeg.io (“SIA Solfegio” or ”we”, ”us”,“our”) community. We at Solfeg.io are concerned about privacy issues and invite you to familiarise yourself with how we collect, use and disclose information.
Last updated: December 9, 2020
Solfeg.io provides a music education software that can be used through most web browsers (at http://web.solfeg.io) and through our Apps. A Solfeg.io web software (referred to as a “Solfeg.io”) consists of interactive classes and songs that users can learn to play individually, or in groups during music lessons.
We may collect the personal information that you provide to us. “Personal information” is information that identifies an individual or relates to an identifiable person, it can include the following:
We may need to collect and process personal information marked as ‘required’ in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services.
We do not collect any Personal Information from a person who merely visits the Solfeg.io website. However, in order to be able to see and play songs, a user (“accountholder”) must create an account at http://web.solfeg.io/ or through our App. We may collect and use Personal Information from adult accountholders. An “adult accountholder” is a US user who is age 13 or older or a user from outside the US who is age 16 or older.
As an educational platform we respect and highly value the privacy of our younger users, so our information practices are different with respect to them. More specifically, when a US user under the age of 13 or a user from outside the US who is under the age of 16 creates an account (a “child accountholder”), we collect their email address only for the purpose of providing password reminders to them. We collect no other personal information from child accountholders, and we immediately and permanently alter the email address such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the child accountholder.
We and our service providers may collect personal information from adult accountholders in a variety of ways, including:
We and our service providers may use personal information for our legitimate business interests, including the following:
The personal information of adult accountholders may be disclosed:
As noted above, we do not collect any personal information from a person who merely visits the Solfeg.io website.
When a user who is under the age of 13 (for US users) or 16 (for non-US users) creates an account (a “child accountholder”), we collect their email address only for the purpose of providing password reminders to them. We immediately and permanently alter the email address such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the child accountholder. We also collect a username and password from child accountholders, which are used for login purposes only, to permit the child accountholder to use the Services.
We and our service providers also collect the information described below, under “Other Information,” from child accountholders. This includes Google’s use of certain persistent identifiers to collect information about the use of our Services for analytics purposes only.
If you would like to review the information we have collected from your child (i.e., their username and password), or if you would like to ask us to make no further use of, or delete, the information we have collected from your child, contact us using the live chat provided in the website. In your request, please include your name and your child’s Solfeg.io username, and specify the action you would like us to take. For your child’s protection, we may need to verify your identity before implementing your request.
“Other information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
If we are required to treat other information as personal information under applicable law, then we may use it for the same purposes for which we use and disclose personal information as detailed in this Policy.
We and our third party service providers may collect other information in a variety of ways, including:
We may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine other information with personal information. If we do, we will treat the combined information as personal information as long as it is combined.
We ask that you don’t send and don’t disclose any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health information, biometrics or genetic characteristics, criminal background or trade union membership) to us by any means.
We give adult accountholders choices regarding our use and disclosure of their personal information for marketing purposes. You may opt-out from receiving marketing-related emails from us on a going-forward basis by clicking the unsubscribe link in any such email. In addition, in your user settings, you may opt-out of receiving emails letting you know that a challenge has been shared.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
If you are an adult accountholder and you would like to (i) review, correct, update, suppress or delete personal information that you have previously provided to us; (ii) restrict the processing of your personal information, object to the processing of your personal information; (iii) if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us through the live chat service in our website or at info (at) solfeg.io.
In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or what limitations you would like to put on our use of your personal information.
For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. You may also delete your account by sending us a request in the live chat widget when logged into the Services. You may also delete, when logged into the Services, any content or information that you have posted to the Services in the form of challenges that you have created. Please note that your actions cannot ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted or repurposed by another accountholder. We will try to comply with your requests as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
We keep your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you and provide our Services to you; (ii) as required by a legal obligation to which we are subject to; (iii) or as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).
You have certain rights regarding your information if you are based in the EEZ, Switzerland, or are a legal resident of California, US (under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199, also “CCPA”) and its implementing regulations, as amended or superseded from time to time) or Brazil (under the Lei Geral de Proteção de Dados (Lei nº 13.709, de 14 de agosto de 2018, also “LGPD”) and its implementing regulations, as amended or superseded from time to time). To exercise your rights contact us through the chat available on our Services or at info (at) solfeg.io.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations. We encourage you to acquaint yourself with the privacy and cookie policies of any third parties.
We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country.
If you are located in the European Economic Area (“EEA”):
Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at https://ec.europa.eu/). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your personal information. You may obtain a copy of these measures by contacting us (see below under Contacting Us).
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As email communications are not always secure, we ask you to not include sensitive information in your emails to us.