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Privacy Policy

Last updated date: November 12, 2018

Curb Records, Inc. (“we” or “us” or “our”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we or our third-party service providers collect through certain of our owned or controlled websites and web properties (e.g., widgets and applications) and mobile applications (“Mobile Apps”) in each case, that link to this Privacy Policy (individually and collectively referred to herein as “our Site”). By providing Personal Information (as defined below) and/or Other Information (as defined below) to us through our Site, you agree to the terms and conditions of this Privacy Policy.
This Privacy Policy does not address, and we are not responsible for, the privacy, information and/or other practices of any third party, including FutureShirts, Facebook, Inc., Apple Inc., Google LLC, Microsoft Corp., Blackberry, Google, any wireless carriers, our artists, our affiliates and any third party operating any site and/or property to which our Site contains a link. In addition, the inclusion of a link on our Site does not imply endorsement of, and/or affiliation with, the linked site and/or property by us and/or by our artists, and/or affiliates. Please note that our Site may include the ability to access and submit (including, for example, via a third-party software application or service that is available through or in connection with our Site) certain information directly to third parties such as Facebook and/or to any application platform such as Apple’s App Store and/or Google Play. Such information is submitted by you directly to such third parties; this Privacy Policy does not apply to any information submitted by you to third parties. For purposes of this Privacy Policy the term “our artist” and “our artists” shall include both our recording artists and our songwriters.
Your California Privacy Rights: If you are a California resident, you may request certain information once per year about our disclosure of certain categories of Personal Information during the preceding calendar year to third parties for such third parties’ own direct marketing purposes. Please send your request by postal mail to Curb Records, Inc., 48 Music Square East, Nashville, TN 37203, Attn.: Legal Dept. We reserve our right not to respond to requests submitted other than to the mailing addresses specified in this section.
Your use of our Site and/or your submission of any information in connection with our Site following such changes means that you accept the revised Privacy Policy.
Two types of information are collected in connection with our Site: Personal Information and Other Information. “Personal Information” is information that identifies you or makes you identifiable as an individual. “Other Information” is any information that does not reveal your specific identity. If we are required to treat Other Information as Personal Information under applicable law, then we and our partners may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. Other Information is addressed separately below, under the heading “OTHER INFORMATION”.
PERSONAL INFORMATION
Personal Information We May Collect
We and our third-party service providers may collect the following Personal Information from you:
 Name
 Postal address (including billing and shipping addresses)
 Telephone number
 Email address
 Credit and debit card number
• Shopping Cart Content

Collection of Personal Information
We and our third-party service providers collect Personal Information through our Site in a variety of ways, including:
• Through our Site
• We may collect Personal Information through our Site, for example, when you register for newsletters or other communications through our Site, make a purchase or make a request.
• Offline
o We may collect Personal Information from you offline, e.g., if you provide information to us at a concert venue.
• From Other Sources
o We may receive your Personal Information from other sources, for example:
o publicly available databases;
o our artists; or
o marketing partners when they share information with us in the context of marketing and promotional campaigns related to our business.
 If you use social media and/or other third party applications, third party websites and/or third-party web properties across the Internet to enter sweepstakes, contests and/or promotions or via an initiation to sign into such account on our Site, you will share certain Personal Information from your social media and/or other third party account with us which may include, for example, your name, email address, photo, list of social media contacts, listening history, favorite tracks and any other information that you make or which is otherwise accessible to us when you connect through such social media and/or third party account.
You are not required by statute or law to provide any Personal Information to us. For example, when you participate in various opportunities provided through our Site, we collect Personal Information from you in order to enable you (or us) to complete your experience on our Site.

How We May Use Personal Information
We, our third-party service providers and our partners may use Personal Information for the following business purposes including:
• Providing the functionality of our Site and fulfilling your requests.
o To provide our Site’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
 To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Site.
 To send to you administrative information, including information regarding our Site and changes to our terms, conditions and policies.
 To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
 To allow you to send messages (for example, music clips or artist information) to a friend through our Site. By using such functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address.
 We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Providing you with our newsletter and/or other marketing materials and/or facilitating social sharing
 To send you marketing communications, that we believe may be of interest to you (including, without limitation, by our third-party service providers that send direct mail, email, and other types of advertising)
 To send you SMS text messages using your telephone number, e.g., if you participated in a sweepstake with this number and you have indicated you would like to receive them. Please keep in mind that message and data rates may apply. You should check with your mobile service provider for applicable data rates. At any time, you may text back “HELP” for further information regarding text messages. If additional rules are provided in connection with any specific SMS text message sign-ups, such rules shall also apply and shall control in the event that they conflict with this Privacy Policy.
o To facilitate social sharing functionality that you choose to use.

Analysis of Personal Information for business purposes and providing personalized services.
 To personalize your experience on our Site using your IP address, by presenting content, products, and offers tailored to you.
 To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Site.

 To allow you to participate in sweepstakes, contests and other promotions using your email address or other Personal Information, and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully; in the event of a conflict between such rules and this Privacy Policy, such rules will govern.
 We use this information to manage our contractual relationship with you.

Aggregating and/or anonymizing Personal Information.
o We and our partners may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we and our partners may use and disclose for any purpose.
We will engage in this activity because we have a legitimate interest.

Accomplishing our business purposes.
o Data analysis, for example, to improve the efficiency of our Site;
o Audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
o For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
o For developing new products and services;
o For enhancing, improving, or modifying our current products and services;
o For identifying usage trends, for example, understanding which parts of our Site are of most interest to users; For determining the effectiveness of promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
o For operating and expanding our business activities, for example, understanding which parts of our Site are of most interest to our users so we can focus our energies on meeting our users’ interests.
o We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

Disclosure of Personal Information
We and our partners may disclose Personal Information:
• To our affiliates (including, without limitation Word Entertainment LLC) for the purposes described in this Privacy Policy.
• To our third-party service providers (and in some cases, our affiliates and our artists), to facilitate the services they provide to us.
 These can include third-party service providers of services such as hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery, credit card processing, auditing and other similar services to enable them to provide such services.
 To third parties to permit them to send, or cause to be sent, marketing communications to you in online and offline media.
 To our artists (including any of the artists’ band members, if applicable) and their representatives, so that our artists and their representatives may use this information to send to you communications (including marketing communications) that they believe may be of interest to you, including, for example, if you (a) sign up to join the applicable artist’s mailing list and/or to receive such artist’s newsletters, (b) register with the applicable artist’s website, or (c) have otherwise indicated that you would like to receive information and/or marketing communications from the applicable artist. We do not control, and are not responsible for, our artists’ and their representatives’ use of Personal Information.
o To a relevant artist who is not currently affiliated with us, if you indicated to us an interest in such artist.
• To third parties that sponsor contests, sweepstakes and/or promotions so that they can facilitate and administer such contests, sweepstakes and/or promotions.
 By using our Site, you may elect to disclose Personal Information.
 On or through message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. Please note that any information and materials that you post or disclose on or through our Site will become public information, and may be available to visitors to our Site and to the general public, and may be redistributed through the Internet and other media channels where they will reach an even broader audience. Additionally, please note that, per our Terms of Use located at http://www.curb.com/terms-use, we retain certain rights in the information and materials that you post on or through our Site, and we and our partners may use and disclose such information and materials (including any Personal Information included therein) in accordance with our Terms of Use. We urge you to be very careful when deciding to disclose your Personal Information, or any Other Information, on or through our Site. WE ARE NOT RESPONSIBLE FOR THE USE AND/OR DISCLOSURE OF ANY INFORMATION YOU DISCLOSE THROUGH OUR SITES.

Other Uses and Disclosures
We and our partners may also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
• To comply with applicable law.
o This can include laws outside your country of residence.
• To respond to requests from public and government authorities.
o These can include authorities outside your country of residence.
• To cooperate with law enforcement.
o For example, when we respond to law enforcement requests and orders.
• For other legal reasons.
o To enforce our terms and conditions
o To protect our operations or those of any of our affiliates or our artists;
To protect our rights, privacy, safety and/or property, and/or that of our affiliates, our artists, you and/or others; or to allow us to pursue available remedies or limit the damages that we and/or our partners may sustain.
• In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our (and our affiliates’) business, assets and/or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
 To relevant artists who is not currently affiliated with us, if you indicated an interest in such artist(s).
 As we believe to be necessary or appropriate: (a) to comply with all applicable laws, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations and/or those of any of our affiliates and/or our artists; (f) to protect our rights, privacy, safety and/or property, and/or that of our affiliates, our artists, you and/ or others; and/or (g) to allow us to pursue available remedies and/or limit the damages that we and/or our partners may sustain.

Retention Period
• We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria we use to determine our retention periods include:
• The length of time we have an ongoing relationship with you and provide our Site to you (for example, for as long as you have an account with us or keep using our Site);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Sensitive Information
We ask that you not send us, and you not disclose to us, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through our Site and/or otherwise.

OTHER INFORMATION
We and our third-party service providers may collect Other Information (defined above) such as:
 Browser and device information
 Mobile App usage data
 Server log files
• Information collected through cookies, pixel tags and other technologies. Please read our cookie policy set forth below for further details on our use of cookies.
• Geographic location information
• Demographic information and other non-personally identifiable information provided by you
• Information about how you use our Site
 Aggregated information

How We May Collect Other Information
We, our partners and our third-party service providers may collect Other Information in a variety of ways, including:
 Through your browser or your device: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type (Windows or Macintosh), screen resolution, operating system version, Internet browser type and version and the type and version of the Site that you are accessing. We and our third-party service providers may also collect a unique device identifier assigned by us or our third-party service providers to the device from which you are accessing our Site and other transactional information for the device that we, our partners and our third-party service providers may use to serve content and advertisements to the device.
 Through your use of Mobile Apps: When you download and use a Mobile App, we and our service providers may track and collect Mobile App usage data, such as the date and time the Mobile App on your device accesses our servers and what information and files have been downloaded to the Mobile App based on your device number.
 Through server log files: An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing our Site by your Internet Service Provider (ISP), and is identified and logged automatically in our server log files whenever you visit the Site, along with the time of the visit and the activity on the Site. We and our third-party service providers use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, administering our Site and determining your approximate geographic location.
• Using cookies: We, our partners and our third-party service providers may use cookies, pixel tags, web beacons, Adobe Flash technology (including Flash Local Stored Objects (“Flash LSOs”)) and other similar technologies to, among other things, better serve you with more tailored information for our and third parties’ products and services and to facilitate your ongoing access to and use of our Site, and collect and store information about your use of our Site. For example, pixel tags and/or web beacons may be used in connection with our Site to, among other things, track the actions of our Site’s users, measure the success of marketing campaigns and compile statistics about our Site’s usage and response rates.
o If you do not want information collected through the use of cookies, there is a simple procedure on most devices through which our Site are accessed that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org. If you choose to decline cookies, then some or all of the features, functionality and promotions available through the Site may not be available to you.
 If your device stores Flash LSOs, and if you do not want Flash LSOs stored on your device through which you access our Site, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained using the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your device without you being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Site or our content. We expect our third-party service providers and our third party IT managers to honor any decision by you to restrict or limit Flash LSOs, but we cannot guarantee that they will do so.
 The use of these technologies allows us, our partners and other third parties to deliver advertisements about our products and/or services and/or the products and/or services of others, when you use our Site, third party applications, third party websites and/or third party web properties across the Internet on any of your devices. These parties may place so-called “pixel tags,” “web beacons,” “clear GIFs” and/or similar technologies on the devices through which you access our Site, third party applications, third party websites and/or third party web properties across the Internet, and also place and/or recognize third-party cookies when you use our Site third party applications, third party websites and/or third party web properties across the Internet. They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile device and a laptop. We, our partners and other third parties may use information about your visits, on the different devices you use, to access our Site, third party applications, third party websites and/or third party web properties across the Internet (excluding your name, address, and telephone number), as well as information received from third parties, to provide advertisements for us and others about goods and services that may be of interest to you. If you would like more information about this practice, please visit the Network Advertising Initiative at www.networkadvertising.org or the Digital Advertising Alliance at www.aboutads.info.
o Our Site do not respond to browser-based do-not-track signals.
 Geographic location information:
If you use any location-enabled products or services, you may be sending us location information. When you use a location-enabled service, we may collect and process information about your precise geographical location, such as GPS signals sent by a mobile device. We and our third-party service providers and partners may use your device’s physical location to provide you with personalized location-based services, content and advertisements. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you choose to deny such uses, we may not be able to provide you with the applicable personalized services and content.
• Demographic Information
From you: We may collect demographic information, such as your zip code or gender, as well as other information, such as your preferred means of communication, when you voluntarily provide this information to us. This information does not necessarily personally identify you and/or any other user of our Site, unless further information is added to it that would allow identification to take place. In such case, the information will be treated as Personal Information.
 Information about how you interact on our Site: We may collect information about how you interact on our Site. For example, our Site may utilize analytic tools to help us better serve you through improved products, services and/or revisions to our Site. This collected information may let us know which services and features you are using the most within our Site, as well as device type and hardware features, country and language of download, etc.
 By aggregating information: We may aggregate Personal Information so that the end-product does not personally identify you or any other user of our Site, for example, by using Personal Information to calculate the percentage of our users who like a particular artist.

How We May Use and Disclose Other Information
Please note that we and our partners may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we and our partners may use it as described in “How We May Collect Other Information” section above, as well as for all the purposes for which we use and disclose Personal Information. In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.
SECURITY
We will use commercially reasonable physical, technical and administrative measures to protect Personal Information under our control. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately in accordance with the “Contacting Us” section below. If any provision of this policy is found to be invalid, illegal or unenforceable, that provision will not affect the validity and enforceability of any other provision.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you many choices regarding our use and disclosure of Personal Information about you for marketing purposes.

You may opt-out from the following as set forth below:
 Receiving marketing-related emails from us and our affiliates: If you do not want to receive marketing-related emails from us and our affiliates on a going-forward basis, you may opt-out from receiving such emails either by using the unsubscribe mechanism provided in the email or by emailing us at privacypolicy@curb.com.
 Receiving marketing-related SMS text messages from us and our affiliates: If you do not want to receive marketing-related SMS text messages from us and our affiliates on a going-forward basis, you may opt-out from receiving such messages by texting back “STOP” or by emailing us at privacypolicy@curb.com.
 Our sharing of your Personal Information with our artists and third parties for their marketing purposes: If you prefer that we not share your Personal Information on a going-forward basis with our artists or third parties for their marketing purposes, you may opt-out from such sharing by emailing us at privacypolicy@curb.com.
 In each case, please make clear in your email what you are opting-out from. We will comply with your request(s) as soon as reasonably practicable. Please note that, if you do opt-out from receiving marketing-related messages from us, we may still send administrative messages to you.
How you can access, change or delete your Personal Information
 If you would like to access, review, correct, update, suppress, restrict or delete Personal Information that you previously provided to us, if you would like to object to our use of your Personal Information, or if you would like to request 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 at: privacypolicy@curb.com. We will respond to your request consistent with applicable law.
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 otherwise let us know 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. We will try to comply with your request 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 (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
Where our collection and use of Personal Information is based on your consent, you may withdraw such consent at any time by emailing us at privacypolicy@curb.com, and such withdrawal will not affect the lawfulness of processing based on consent before your withdrawal.

CROSS-BORDER TRANSFER
Our Site are controlled and operated from the United States; accordingly, this Privacy Policy, and our collection, use and disclosure of your Personal Information, is governed by the laws of the United States, and our Site are not intended to subject us and/or any of its affiliates to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Site you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

If you are located in the European Economic Area (“EEA”)
Our Site operates in the United States. If you are located in the EEA, Canada or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our Site, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Our Site are not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide Personal Information through our Site.

UPDATES TO THIS PRIVACY POLICY
We may change this Privacy Policy at any time. Please take a look at the “Last updated date” at the beginning of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through our Site.

CONTACTING US
Curb Records, Inc. is located at 48 Music Square East, Nashville, TN 37203 is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.
If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us by email at privacypolicy@curb.com. Alternatively, if you are located within the EU/EEA, you may also lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here. For the avoidance of doubt, (i) the use of the word “or” shall be interpreted for our benefit (e.g. “or” may also mean “and/or” if we elect) and (ii) the use of the word “and/or” and ”and” shall be interpreted for our benefit.

We are located at privacypolicy@curb.com, or please write to the following address:

Curb Records, Inc.
48 Music Square East
Nashville, TN 37203
Attn: Legal Dept.

COOKIES POLICY
Our Site uses cookies and other similar technologies (as described below) to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site, allows us to improve our Site and provide you with tailored content and advertising.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
You can find more information about some of the types of cookies we use and (as of the last updated date at the beginning of this Privacy Policy) the main purposes for which we use them below:

Strictly Necessary
These cookies are essential in order to enable you to browse our Site and use its features. The information collected by these cookies relate to the operation of our Site, for example website scripting language and security tokens to maintain secure areas of our Site

Performance / Analytics
These cookies collect anonymous information about how you use our Site, for example which pages you visit most often, whether you receive any error messages, and how you arrived at our Site. Information collected by these cookies is used to improve your use of our Site and never to identify your name. These cookies are sometimes placed by third-party providers of web traffic analysis services, such as Google Analytics.

Functionality
These cookies remember choices you make, for example the country you visit our Site from, your language and any changes you have made to text size or other parts of web pages that you can customize, in order to improve your experience of our Site and to make your visits more tailored and enjoyable. The information these cookies collect may be anonymized and cannot be used to track your browsing activity on other websites.

Targeting or Advertising
These cookies collect information about your browsing habits and inferred interests in order to make advertising more relevant to you. They are also used to limit the number of times you see an advertisement, as well as to measure the effectiveness of an advertising campaign. These cookies are usually placed by third-party advertising networks. They remember the other websites that you visit and this information is shared with third-party organizations, for example advertisers.

Social Media
These cookies allow you to share what you’ve been doing on our Site with social media organizations such as Facebook and Twitter. These cookies are not within our control. Please refer to the privacy policies of these organizations for how their cookies work.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
Most internet browsers are automatically set up to accept cookies. However, if you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. Please note you may not be able to take advantage of all the features of our Site, including certain personalized features, if you delete or disable cookies.

For more information on managing cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.eu which has further information about behavioral advertising and online privacy.

All materials © 2018 Curb Records, Inc. unless otherwise noted. All rights reserved.