Gumbot Privacy Policy

Effective as of 1^st November 2017

You are strongly encouraged to read this Privacy Policy (Policy) carefully before using the Gumbot mobile app (App), as it explains what data (including personal data) we collect from your use of the App and how we use that data.

You should read this Policy together with our Terms & Conditions, which apply to your use of the App.

Who we are

The App is provided by Audiogum UK Limited. We are a private company registered in England and Wales under company number 10151657. Our registered office is at Freshford House, Redcliffe Way, Bristol BS1 6NL.

Our commitment to protecting your privacy

When we say we are committed to maintaining the privacy of your personal data, we truly mean it. Privacy issues are considered by our team as part of the development process and as a business, we will never sell or commercially exploit data which identifies you personally. If any data that we have collected from the use of the App by you and other users would be of interest to another organization, we will only share it with them once it has been anonymized in accordance with regulatory guidance and best industry practice, so that it cannot identify you personally.

Use of the App by children

Please see our Terms & Conditions regarding age restrictions. We do not knowingly collect personal data from any individual who does not meet our age restrictions and you should not use the App if you do not meet them. If you are a parent or guardian and are concerned that the App may have inadvertently collected personal information from your child, please notify us by sending an email to gumbot-support@audiogum.com.

The data that we collect from you and how we use it

This section of the Policy is important, as it explains the data that we collect from and about you and your device and how we will use it. This forms the basis of your consent to the processing of your personal data by us and by our technical partners. Our objective is to ensure that you are never surprised by how we use your personal data, through being transparent with you about the purposes for which we may process it.

Account credentials: You do not need to create an account with us in order to use the App. However we will need to verify your credentials with third party music streaming services to enable you to play audio content through the App. We will keep your account credentials separate from the data about your use of the App and only associate the two if we need to for any of the reasons set out in the rest of this Policy, for example, if you wish to exercise any of your rights in relation to your personal data.

Device data: We will collect technical data about the device that you use to access the App. This includes data about the type of your device, operating system/firmware version, IP address of your device and network, other device identifiers, time zone, regional and language settings. We will use this data to understand the types of devices used to access the App and to improve and optimize the App.

Usage data: We will collect data about how you use and interact with the App to help us improve the App. We will also collect data about the audio content that you listen to however, as noted above; we will keep this data separate from your account credentials and not associate the two except in limited circumstances.

Voice data: The App is controlled using voice commands. The App will only listen for your voice when you push the button on the screen. Voice data is streamed from the App to the Google Cloud Speech tool which then converts it into text, and the text command is then passed back to our service which figures out what you want to do before playing the appropriate track or personalised playlist from the third party music streaming service you have linked with the App.

Who we may share your data with

We aim to keep the amount of personal data that we collect about you to a minimum so that we can keep the amount of personal data that we need to share about you to a minimum. We will only share your personal data for the sole purpose of enabling your use of the App and for no other purpose. In this context, “share” does not necessarily mean that we hand your data over to any third party, but that they may have access to it, for example, because they host the App.

Prospective buyers or sellers: If we sell or buy any business or assets, or enter into negotiations for any merger or acquisition, we may need to disclose your data to the prospective buyer or seller of such business or assets. We will only do so if we are satisfied that sufficient safeguards and agreements are in place in respect of such disclosure.

Rights holders and law enforcement: We may be required to disclose or share your data with individuals or organisations enforcing their legal rights, or in order to comply with any legal or regulatory obligation or request. We may also share your data with our legal advisers and law enforcement in order to protect third party rights and to enforce our Terms & Conditions. We will not do so without fully considering the implications of such disclosure and your privacy rights and will, where lawfully possible, seek to resist such disclosure.

Technical service providers: We use third party service providers to host our App (Amazon Web Services), convert voice commands to text (Google Cloud Speech API, where we share audio recordings) and to recommend music based on the commands you give to the App (Moodagent, where we share text translations of voice commands).

Other information about how we keep your data

Where we store your data: Your data is hosted on the Amazon Web Services (AWS) platform in accordance with AWS’s policies and standards for privacy and security. AWS will not disclose, move, access or use your personal data except as necessary to fulfil their contractual obligations to us and our technical service providers, or to comply with the law or any binding order of a governmental body.

Transfer of personal data: As our technical partners are based outside of the European Economic Area, we will need to transfer, store and/or process your personal data outside of the European Economic Area. If we transfer your personal data to a country or territory which has not been determined by the European Commission to have an adequate level of data protection, we will use a variety of legal mechanisms, including contracts, to help ensure that your rights are protected.

How long we keep your data for: As explained above, we keep the account credentials for the third party music streaming services linked to the App separate from the other data that we collect from your use of the App. When you delete the App, we will continue to retain your account credentials until such time as you have revoked the App’s access to them (these settings are usually within the privacy section of the account settings for the third party music streaming services linked to the App). We will retain any data collected from your use of the App, but which does not identify you, indefinitely.

How we keep your data secure: The security of your personal data is important to us. We use, and require our technical service providers and any other parties with whom we may share your personal data to use, a variety of technical and non-technical measures to protect your personal data. Despite this, unfortunately the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data.

Your rights

You have the following rights in relation to your personal data:

Right of access: You have the right to access and receive a copy of any personal data that we process about you and certain additional information about how such data are processed.

Right to withdraw consent: You have the right to withdraw your consent at any time for future processing.

Right to request rectification or erasure: You have the right to request that we rectify any inaccurate personal data that we may hold about you, including the right to have incomplete personal data completed. You also have the right to request that we erase any personal data concerning you where you have withdrawn your consent, and in certain other circumstances.

Right to restriction of processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.

Right to object to processing: You have the right to object to the processing of your personal data for direct marketing purposes.

Right to complain: You have the right to lodge a complaint with a data protection authority.

Changes to this Policy

We may need to update this Policy in order to reflect changes to the App; the purposes for which we intend to process your personal data; customer feedback; or changes to any law or regulation relating to the processing of personal data. You are strongly encouraged to review this Policy regularly to take notice of any changes. However if we make any material changes to this Policy, we will try to give you as much notice as possible by displaying a prominent notice within the App.

How to contact us

You can contact us with any questions or concerns you may have by writing to our registered office at the address set out above or by email to gumbot-support@audiogum.com.