Effective as of November 3, 2018

Reoent Assets, ("Reoent Assets", "we", "us", or "our") is committed to maintaining your confidence and trust as it relates to the privacy of your information. This Privacy Policy describes how we collect, protect, share and use your information as part of our technology platforms, including, our websites, interactive features and mobile Apps ("Platforms") and how you may access and control its use in connection with our marketing communications and business activities.

For GDPR purposes, we are a data controller.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS. BY ACCESSING OR USING THE APP, YOU AGREE TO PROCESSING OF YOUR PERSONAL DATA WHICH IS PROVIDED TO US IN LINE WITH THE TERMS OF THIS PRIVACY POLICY.

QUICK GUIDE TO CONTENTS

  1. INTRODUCTION
  2. INFORMATION WE COLLECT ABOUT YOU
  3. HOW WE USE YOUR INFORMATION
  4. HOW WE SHARE YOUR INFORMATION
  5. INTERNATIONAL DATA TRANSFERS
  6. EXERCISING YOUR RIGHTS
  7. OTHER SITES
  8. CHILDREN’S PRIVACY
  9. CHANGES TO OUR PRIVACY POLICY
  10. CONTACT US

1. INTRODUCTION

Our Privacy Policy will provide you with a detailed explanation of how we collect and use your data on the Platform. Before we delve into the details, however, we’d like to provide you with a brief overview of our philosophy as it pertains to user privacy and to highlight some key basic ideas.

By using the Platform, you consent to the collection of certain types of data (outlined below). You should fully understand what we do (and don’t do) with your personal information and data.

We’d also like to offer a brief overview of what you’re consenting to by using the Platform. All of these points will be explained in more detail below.

By using the Platform, you consent to;

Our use of cookies and other related technologies;

The transfer of your information to a 3rd party outside of the country you reside in;

The collection, processing, use, and sharing of your information;

The public availability of certain kinds of personal information you elect to share by registering for an account, and your controls for sharing such information.

2. INFORMATION WE COLLECT ABOUT YOU

1.1 Information that you submit

We ask for and collect the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App all perform the requested services.

Authorization and/or Account Information. When you sign up for an account, we require certain information such as your email address or Google ID or Dropbox ID or OneDrive ID - depending on the App settings.

Content Information, audio files and other data that you upload using the App.

Personal Information, which you may fill in by yourself when the App is designed for tracking your info, storing your records and/or managing them for your convenience and upon your explicit request.

1.2 Information That Is Processed Automatically

When you use the App, some information about your device and your user behaviour may be processed automatically. This information is generally non-personal, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. Otherwise we may not be able to provide you with all the requested services and features of the App.

We use third-party automatic data processing technologies (such as AdMob, Firebase Analytics, Youtube, One Drive, Google Drive, DropBox, Mega, Box Drive, Yandex) to analyze certain information sent by your device or our App. Automatic data processing technologies (advertising or analytics tools) provide us with the data described below. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties. 

Device identifiers. When you use a mobile device (a tablet or a phone) to access our App, we may access or monitor one or more “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. Device identifier provides reports or personalized content and ads.

What data can be processed:

  1. type of your mobile device and operational system version which is installed on your mobile device;
  2. region information of your mobile device;
  3. region associated with your SIM card;
  4. Internet Protocol (“IP”) address;
  5. Identity For Advertisers / Advertising ID which is a string of numbers and letters that identifies your individual smartphone or tablet.

Processing information through automatic data processing technologies starts automatically when you start using the App.

The App may use automated processing of your personal data, including profiling which means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements.

3. HOW WE USE YOUR INFORMATION

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a)  To make our service available. We use information that you submit and information that is processed automatically to provide you with all requested services.

(b)  To improve, test and monitor the effectiveness of our App. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

(c)  To provide you with interest-based (behavioral) advertising or other targeted content. We may use information information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.

(d)  To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

(e)  To prevent fraud and spam, to enforce of law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

4. HOW WE SHARE YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy.

We will not rent or sell your personal data to third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

We may use one or more of the following third-party advertising services and analytics tools: Adjust; AdMob; Amplitude; AnnAnnie; AppFigures; Apple SearchAds; Appmetrica; Appodeal; AppsFlyer; Facebook; Firebase; Flurry; Google AdWords; ironSource; Mopub; SensorTower; Vungle. In case you want to learn more about the services and privacy options please consult their websites and privacy policies.

Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices or the content of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it needed for objective reasons, due to public interest or in other unforeseen circumstances:

- as required by law;

- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

- if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

5. INTERNATIONAL DATA TRANSFERS

We work in the international space and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

6. EXERCISING YOUR RIGHTS

For the data we store and access you are entitled to address us regarding the following issues:

Please bear in mind that we ensure the above mentioned rights only with respect to the information that you submit.

When your personal information that is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

Please note that you can opt-out of marketing tracking by moving the "Limit Ad Tracking" in the settings on your mobile phone to “on”.

US regional patterns:

Residents of the State of California (USA) have the right to request a list of all third parties to whom our App disclosed certain personal information (in accordance with the laws of the State of California) in the previous year for the purposes of direct marketing of such third parties. If you are a resident of the State of California and want to receive such a list, please contact us through the email displayed below. When submitting such a request, please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California", as well as your name, address, city, state, and zip code. In the text of your request, please provide us with sufficient information so that we can determine if the above requirements of the law apply to your situation. You must confirm that you are a resident of the State of California (USA) and provide the current address in the state of California for our response. Please note that we do not accept calls by phone, mail or facsimile, nor are we responsible for calls that are flagged or misdelivered or that do not contain exhaustive information.

7. OTHER SITES

The Platform contains links to third-party content, advertisements, and sites that are not owned by nor affiliated with Reoent Assets. We cannot be held accountable for the content or privacy policy of third- party sites. Be sure to read their privacy policies to determine if you are comfortable with how they handle your information.

8. CHILDREN’S PRIVACY

The Platform is not intended for use by those under the age of 13. We never knowingly or purposefully collect information from anyone under the age of 13, or under the legal age limit in their respective territory (“Age Limit”), under any circumstances. If you are under the Age Limit, you should not use the Platform and are expressly prohibited from registering for a user account, or transmitting any data or personal information on the Platform. If you are the parent/guardian of a child under the Age Limit and believe we have collected such information, please contact us immediately at reoentassetslp@gmail.com and it will be promptly removed.

9. CHANGES TO OUR PRIVACY POLICY

We may, at our sole discretion, change the terms of this Privacy Policy at any time and for any reason. In the event that we do change this Privacy Policy, we will post notification of updates both within the Policy itself and via notifications throughout the Platform and specifically on the mobile app. Please be sure to read all updates to the Privacy Policy thoroughly before continuing to use the “Music Cloud - offline music” platform. Your continued use of the Platform constitutes acceptance of any new or changed terms in this Privacy Policy.

Please contact reoentassetslp@gmail.com with any questions or concerns about the Privacy Policy.

10. CONTACTS US

If you have any questions or concerns about this Privacy Statement, the practices of the Platforms, or your experiences with the Platforms, please contact us at:

E-Mail: reoentassetslp@gmail.com