Splice - Privacy Policy

Last revised and effective as of April 1, 2023

日本語 / 한국말

This “Privacy Policy” describes the privacy practices of Distributed Creation Inc. and our Corporate Affiliates (collectively, “Splice”, “we”, “us”, or “our”). This Privacy Policy describes how we collect, use, disclose and otherwise process personal information in connection with our websites, including, without limitation, splice.com (collectively, the “Website”), Splice’s digital applications (each, an “App”), and any services and resources available or enabled via the Website or Apps and associated software made available through the Website and Apps (collectively, with the Website and each App, the “Service”). This Privacy Policy governs any Service on which the Privacy Policy is posted. Distributed Creation Inc.’s Corporate Affiliates include Distributed Creation UK, Ltd., 3rd Floor 1 Ashley Road, Altrincham, United Kingdom WA14 2DT.

If an organization with which you are associated (an “Organization”) signs up to use our Service, we may receive personal information about you in connection with our provision of the Service to your Organization. To the extent we process that personal information solely in order to provide the Service to your Organization, under the European Data Protection Laws, to the extent applicable, we will act as a processor (as defined in the European Data Protection Laws) on behalf of your Organization in respect of that personal information; this Privacy Policy will not apply to the processing of that personal information and your Organization will act as a controller (as defined in the European Data Protection Laws) in respect of that personal information and is responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable law. To the extent we process your personal information for any other lawful business purpose of ours, under the European Data Protection Laws, to the extent applicable, we will act as a controller of such personal information and this Privacy Policy will apply to the processing of such personal information.

You should be sure to read the important information provided here.

This Privacy Policy serves to notify you of the following:

• Personal Information We Collect
• Cookies and Similar Technologies
• How We Use Your Personal Information
• How We Share Your Personal Information
• Your Choices
• Security
• International Transfers
• International Transfers under the Australian Privacy Act
• Other Sites and Services
• User Generated Content and Public Areas
• Third-Party Products and Services
• Changes to this Privacy Policy
• Contact Us
• Notice to California Residents
• Additional Information Regarding European Data Protection Laws
• Additional Information Regarding Canadian Privacy Laws
• Notice to Japanese Residents
• Notice to South Korean Residents

Personal Information We Collect

Information you give us

“Personal information” is information that identifies you or can be used to identify or contact you. If the Australian Privacy Act 1988 applies, it also includes any other information or opinion about you that would not otherwise be personal information. Personal information that you may provide through the Service or otherwise communicate with us includes:

• Contact information, such as your first name, last name, address, and email address.
• Profile information, such as your username and password, unique user ID, artist name, gender, age, audio you create on the Service, your photograph, interests and preferences.
• Feedback and correspondence, such as information you provide when you report a problem with the Service, receive customer support, or otherwise correspond with us, including operating system and version as well as information about your digital audio workstation, or when you refer another person who might be interested in the Service to us.
• Transaction information, such as billing and payment information and details about purchases you make through the Service, records of Service purchased, purchase credits, date of birth (for age verification purposes), responses to our surveys, and information you provide when you enter into one of our contests or other promotions.
• Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the Service or otherwise submit to us through the Service, application crash data, and information you provide when you use any interactive features of the Service, as well as audio listening and creation preferences based on your usage.
• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with marketing communications as well as inferences as to potential advertisements to serve.

Please note that, as explained in the User Generated Content and Public Areas section of this Privacy Policy, we ask you not to include personal information in any files you upload to the Service or in the messages you exchange via the Service. If you choose to include personal information within those functionalities, we will not be able to limit the collection and use of that information by other users.

Information automatically collected

We may automatically log information about you and your computer or mobile device when you access our Service. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, device identifier, IP address, browser type, screen resolution, the website you visited before browsing to our Website, pages you viewed, search queries, browsing behavior, advertisement performance metrics (clicks, impressions), including in connection with your interaction with our advertisements on third-party websites, how long you spent on a page, access times, time zone, general location information such as city, state or geographic area, postcode, and information about your use of and actions on our Service. We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section for more details.

Sources of Information

We will collect personal information that you submit to us. We may also receive personal information about you from third parties including third parties providing credit and debit card authorization and fraud screening services as part of your use of the Service. We may also passively collect information based on your use of the Service using cookies and pixel tags, as described below.

Cookies and Similar Technologies

What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Service.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Service; and (2) third party cookies, which are served by service providers on our Service, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Service uses the following types of cookies for the purposes set out below:

In addition to Google, as described above, the Service may use third-party service platforms (including to help analyze how users use the Service).  These third-party service platforms may place cookies on your computer or mobile device.  If you would like to disable "third-party" cookies, you may be able to turn them off by going to the third party's website.

Here are links to the main third-party platforms we use:

https://www.google.com/policies/privacy/

https://privacy.microsoft.com/en-us/privacystatement

https://www.facebook.com/policy/cookies/

https://help.instagram.com/1896641480634370/?helpref=uf_share

https://www.tiktok.com/legal/cookie-policy?lang=en

https://snap.com/en-US/cookie-policy

https://rakuten.co.uk/cookie-policy

https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies

https://www.braze.com/company/legal/privacy

https://instapage.com/privacy-policy

https://help.twitter.com/en/rules-and-policies/twitter-cookies

For a complete list of third parties who deploy cookies on the Service, please contact us at support@splice.com.

Online Tracking Opt-Out Guide

Like many companies online, we may use services provided by Google, Facebook and other companies that use tracking technology. These services rely on tracking technologies – such as cookies and pixel tags – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. Information collected from some cookies placed on the Service is used to deliver advertisements to Splice Service visitors when such visitors are visiting other websites, including Facebook, Twitter, and Instagram. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Note: if you do not accept our cookies, you may experience some inconvenience in your use of our Service. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Service.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third-party cookies/trackers.
• Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
• Google: https://adssettings.google.com
• Facebook: https://www.facebook.com/about/ads
• Outbrain: https://my.outbrain.com/recommendations-settings
• Advertising industry opt-out tools.You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
• Digital advertising Alliance: https://optout.aboutads.info
• Network Advertising Initiative: https://optout.networkadvertising.org/?c=1

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.

Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Service to track the actions of users on our Service. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Service, so that we can manage our content more effectively.

Do Not Track signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We do not currently respond to do not track signals. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below. To find out more about “Do Not Track,” please visit https://allaboutdnt.com/.

How We Use Your Personal Information

To provide our Service

If you have a Splice account or use our Service, we use your personal information to:

• operate, maintain, administer, promote, and improve the Service
• manage and communicate with you regarding your Splice account, if you have one, including by sending you Service announcements, technical notices, updates, security alerts, billing and account communications, and support and administrative messages. You will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service and are necessary for the performance of our contract with you
• process and manage purchases and registrations you make through the Service, including to administer contests and other promotions
• better understand your needs and interests, and personalize your experience with the Service
• provide support and maintenance for the Service
• respond to your Service-related requests, questions and feedback

To communicate with you

If you request information from us (such as signing up for our newsletter), register on the Website, have a Splice account or use our Service, or participate in our contests or promotions, then, unless you opt out (to the extent permitted by applicable law), we (and/or third parties acting on our behalf) may send you Splice-related marketing communications as permitted by state, federal and international laws. You will have the ability to opt out of such communications.

If you identify yourself to us by sending us an email with questions or comments, we may use your information (including personal information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas, search warrants, or requests from government or public authorities including to meet national security or law enforcement requirements.

With your consent

We will request your consent to use your personal information where required by law. Under certain circumstances, where required by applicable law, this may include where we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent (without affecting the lawfulness of processing based on consent prior to withdrawal) to use your personal information, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly.

For analytics

We analyze use of the Service to analyze, market, and improve the Service and to develop new products and services, including by studying user demographics and use of the Service. We may also combine information collected from cookies and/or from survey responses with information that you may provide, such as information provided in a form that you complete.

In particular, we would like you to be aware that we may employ algorithms in connection with the Service, which may use self-reported location, preferences, interests, and other data in connection with your usage data to make recommendations, tailor your search results, and determine whether to send you a survey.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service or any other contract with us; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Your Personal Information

We generally disclose information we gather through the Service to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you.

Corporate Affiliates

We may disclose your information (including your personal information) to our Corporate Affiliates for purposes consistent with this Privacy Policy. "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Distributed Creation Inc., whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

The categories of personal information disclosed to our Corporate Affiliates are those described in the Section of this Privacy Policy titled Personal Information We Collect.The individual within Splice who is responsible for controlling such personal information is our Data Protection Officer, who can be reached at support@splice.com. Our Data Protection Officer is employed by Distributed Creation Inc. with a business address at 817 Broadway, 4th Floor New York, NY 10003. Our Data Protection Officer is our representative for the purposes hereof. Distributed Creation Inc.’s Chief Executive Officer is Kakul Srivastava.

Users of the Service/Visitors to the Website

Content you submit to the Public Areas (as defined below) may be viewable by others, including other users of the Service. For example, other users may be able to see your projects available for collaboration, and your username may be associated with your projects. Please refer to the section on User Generated Content and Public Areas for additional details. If you participate in a Splice contest or promotion, we may share contestant names as disclosed in the terms of the contest or promotion, including by posting the winner’s name on our Website.

Outside Contractors

We may employ third-party companies and individuals to administer and provide the Service on our behalf, to develop applications related to the Service, or otherwise to provide products or services to us related to the Service, such as customer support, hosting, email delivery, billing and payment card processing, and database management services (each, an “Outside Contractor”). In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your personal information.

Professional Advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Compliance with Laws and Law Enforcement; Protection and Safety

Splice may disclose information (including personal information) about you to government or law enforcement officials or private parties as required by law or if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law or a court or regulatory order. Additionally, and without limitation of the foregoing, we may disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas, search warrants, or requests from government or public authorities including to meet national security or law enforcement requirements; (b) enforce the terms and conditions that govern the Service or another contract with us; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Business Transfers

We reserve the right to transfer information to a third party in connection with an actual or potential business transaction, such as a sale, merger, consolidation, acquisition, reorganization, or transfer of all or substantially all of the assets of Splice or any of its Corporate Affiliates, or that portion of Splice or any of its Corporate Affiliates to which the Service relates, or in connection with a strategic investment by a third party in Splice, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding,  or in the event of bankruptcy.

Third Parties Generally

We may provide information to third parties, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. In addition to the above, when users use our Service, third parties (including without limitation third-party analytics service providers) may directly collect information (including personal information) about our users’ online activities over time and across different websites.  The third parties to which we may provide or who may independently directly collect information (including personal information) may include potential or actual advertisers, providers of advertising products or services (including vendors, analytics services providers, and website tracking services), affiliates and other actual or potential commercial partners, and other similar parties. Please note in particular that the Service uses Google Analytics, including its data reporting features.  Information collected by Google Analytics includes but is not limited to web metrics.  For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including, as described above, its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Your Choices

Access, update, correct or delete your information

Subject to applicable law, all Splice account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. You may also contact us at support@splice.com to request to access, update or correct the personal information Splice maintains about you, or if you have additional requests or questions. Generally, there is no cost for such access. However, we reserve the right to charge such costs on a case-by-case basis in accordance with applicable law. You will be notified in advance if any charges apply.

Marketing communications

You may opt out of marketing-related emails by logging in and changing your account settings, by clicking on a link at the bottom of each such email, or by contacting us at support@splice.com. You may continue to receive service-related and other non-marketing emails.

Choosing Not to Share Your Personal Information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Service. We will tell you what information you must provide to receive the Service by designating it as required in the Service or through other means.

Security

We store personal information electronically with third-party hosting providers. We strive to hold all personal information we collect consistent with technical and organizational measures designed to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of personal information processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.

The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

Children

Our Service is not directed to children under 13. We do not collect personal information from any person we actually know is under the age of 13. In fact, as currently operated, persons under the age of 18 may not use the Service.  By providing information to Splice you represent that you are 18 years of age or older. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

Sensitive Personal Information

We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on the Website, through the Service or otherwise to us.

If you send or disclose any sensitive personal information to us when you use the Service, you consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

International Transfers

Personal information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. By using the Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. Without limitation of the foregoing, you hereby expressly grant consent to Splice to: (a) process and disclose such information in accordance with this Privacy Policy; (b) transfer such information throughout the world, including to the United States or other countries that do not ensure adequate protection for personal information (as determined by the European Commission or the UK Information Commissioner’s Office, as applicable, each, an "Inadequate Jurisdiction") and/or countries that may not have laws of general applicability regulating the use and transfer of such information; and (c) disclose such information to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent required by applicable law: whenever we transfer your personal data (as defined in the European Data Protection Laws) to third parties (as described in this Privacy Policy) located in an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission or the UK Information Commissioner’s Office, as applicable, which give personal data the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction.

International Transfers under the Australian Privacy Act

In addition, if the Australian Privacy Act applies, you consent to us disclosing your personal information to recipients referred to in this Privacy Policy located throughout the world. By providing this consent, you waive any rights that you might otherwise have to require that we take reasonable steps to ensure any such recipient complies with the Australian Privacy Principles specified in the Australian Privacy Act, including any rights that you might have arising under Australian Privacy Principle 8.1.  This will mean that if there is a breach of the Australian Privacy Principles by any overseas recipient, you will not have any recourse against us and you will not be able to seek redress under the Privacy Act.

Other Sites and Services

The Website and/or Service may contain links to other websites and services. This may include providing you with the ability to automatically post updates on Facebook, Instagram, and Twitter.  These links are not an endorsement of such websites or services or any authorization or representation that we are affiliated with that third party. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We do not exercise control over any third-party websites or services and are not responsible for their actions or privacy practices. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use. This Privacy Policy applies solely to information collected by us through the Service.

User Generated Content and Public Areas

We may make available on our Website and/or Service features that allow you to generate your own content or share information online (e.g., on message boards, in connection with project collaboration, in chat areas, user profiles (but excluding password and unique user ID), in file uploads, etc.) (each, a “Public Area”). Please do not embed personal information in the content you generate or otherwise share personal information online in any Public Area. Whenever you voluntarily disclose personal information online (including in any Public Area), that information becomes public and can be collected and used by others. Please note in particular that all project collaborators can see the projects on which they are collaborating as well as their messages to each other. We have no control over, and take no responsibility for, the use, storage, dissemination or erasure of personal information embedded in user-generated content (including project files) or otherwise shared publicly (including in any Public Area). By posting personal information online in any Public Area, you may receive unsolicited messages from other parties.

As indicated above, user profiles are part of the Public Areas of the Service.  All information in your user profile (but excluding password and unique user ID) is part of the Public Areas of the Service and available to the public, including to all users of the Service.  A user’s username, artist name, and photograph are available to the public, including to all users, when a user shares or posts information in the Public Areas (as defined below) of the Service. When prompted to create a username and photograph, we advise users not to use personal information – i.e., select a username that is not similar to a user’s actual name and select a photograph that does not display the user’s image – because such information can be publicly available to all users.

Any information you share in a Public Area (including personal information) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to, or collected by others and may be used by others in ways we cannot regulate or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, and Bing.

Third-Party Products and Services

The Service may integrate with or enable access to third-party tools. These integrations are not an endorsement of such third-party tools or any authorization or representation that we are affiliated with that third party. Additionally, we cannot guarantee the quality or accuracy of such third-party tools or the information presented thereon. End users that register, install or access any third-party tools may be required to accept privacy notices provided by those third parties. Please review those notices carefully, as Splice does not control and cannot be responsible for these providers’ privacy or information security practices. We do not exercise control over any third-party tools and are not responsible for their actions or privacy practices. This Privacy Policy applies solely to information collected by us through the Service.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Service that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Service – or a specific announcement on this page or on our blog).

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have any complaints (including regarding a breach of any privacy law), questions or concerns at all about our Privacy Policy, please feel free to email us at support@splice.com, or write to us at:

Distributed Creation Inc.
817 Broadway, 4^th Floor
New York, New York 10003

Individuals in the United Kingdom (“UK”) can also contact our UK representative, Distributed Creation UK, Ltd., by sending an email to gdpr@splice.com.

Individuals in the European Union (“EU”) can also contact our EU representative, The DPO Centre Europe Ltd, by sending an email to gdpr@splice.com.

We take seriously any complaints regarding our privacy practices.  We strive to respond to such complaints promptly and within the timeframes required by applicable laws.  Where no timeframe is specified by an applicable law, we will contact you within a reasonable time after receipt of your complaint to outline any available options regarding how they may be resolved.

Notice to California Residents

This Section titled Notice to California Residents (this “CPRA Notice”) shall apply only to the extent that we are regulated as a business (as defined in the California Privacy Rights Act of 2020 (collectively with any regulations promulgated thereunder, the "CPRA")) under the CPRA. This CPRA Notice shall apply to you only if you are a California resident.

If an Organization with which you are associated purchases any of our services, we may receive consumer information (as defined below) about you in connection with our provision of our services to your Organization. To the extent we process or access such consumer information solely in order to provide our services to your Organization or only for a business purpose (as defined in the CPRA) pursuant to a written contract with your Organization, under the CPRA, to the extent applicable, we will act as a service provider (as defined in the CPRA) or a contractor (as defined in the CPRA), as applicable, on behalf of your Organization in respect of that consumer information; this Privacy Policy will not apply to the processing of that consumer information and your Organization will act as a business (as defined in the CPRA) in respect of that consumer information. The business is responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable law. To the extent we process your consumer information for any other lawful business or commercial purpose of ours that is outside the scope of our role as a service provider or contractor, under the CPRA, to the extent applicable, we will act as a business with respect to such consumer information and this Privacy Policy will apply to the processing of such consumer information.

As used in this CPRA Notice, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to a third party for monetary or other valuable consideration.

“Selling” does not include (i) disclosing consumer information to a third party at your direction, (ii) where you intentionally interact with one or more third parties, or (iii) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Splice, provided that information is used or shared consistent with the CPRA.

As used in this CPRA Notice, “share” (including any grammatically inflected forms thereof) means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions with a third party for cross-context behavioral advertising for our benefit in which no money is exchanged.

“Sharing” does not include (i) disclosing consumer information to a third party at your direction, (ii) where you intentionally interact with one or more third parties, or (iii) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Splice, provided that information is used or shared consistently with the CPRA.

Consumer Information Collected:We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents or households (“consumer information”). Consumer information does not include deidentified or aggregated information, publicly available information or lawfully obtained, truthful information that is a matter of public concern, or any other information that is excepted from the definition of “personal information” under the CPRA, or any information that is otherwise not regulated by the CPRA. For purposes hereof, “publicly available information” means information that is lawfully made available from federal, state, or local government records, or information that we have a reasonable basis to believe is lawfully made available to the general public by you or from widely distributed media, or information made available by a person to whom you have disclosed the information if you have not restricted the information to a specific audience.

For purposes hereof, "sensitive consumer information" means: (1) consumer information that reveals (A) your social security, driver's license, state identification card, or passport number; (B) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) your precise geolocation; (D) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of your mail, email, and text messages, unless we are the intended recipient of the communication; (F) your genetic data; and (2)(A) consumer information consisting of biometric information processed for the purpose of uniquely identifying you; (B) consumer information collected and analyzed concerning your health; or (C) consumer information collected and analyzed concerning your sex life or sexual orientation. We use or disclose your sensitive consumer information, provided that we only use or disclose your sensitive consumer information for the purposes specified in Section 7027(m) of the CPRA regulations, and we only collect or process sensitive consumer information without the purpose of inferring characteristics about you.

In particular, with respect to the Service, we have collected the following categories of consumer information from California residents or households within the last twelve (12) months and we may collect the following categories of consumer information from California residents or households:

Purposes for Collection of Consumer Information; Categories of Sources:We collect consumer information for the business or commercial purposes described in the table above and in the manner described in Sections of this Privacy Policy titled Personal Information We Collect, Cookies and Similar TechnologiesandHow We Use Your Personal Information  with respect to personal information. Regarding the categories of sources from which consumer information is collected, we collect consumer information from the categories of sources described in the table above.

Disclosures of Consumer Information for a Business or Commercial Purpose:Splice may disclose your consumer information described in the table above to a third party for a business or commercial purpose, as described in the table above and in Sections of this Privacy Policy tilted Cookies and Similar TechnologiesandHow We Share your Personal Information with respect to personal information. In the preceding twelve (12) months, Splice has disclosed each of the categories of consumer information described in the table above for a business or commercial purpose to the categories of third parties described in the table above.

Sharing and Sales of Consumer Information:In the preceding twelve (12) months, Splice has not shared or sold, nor does it or will it share or sell, consumer information.

California Residents’ Rights and Choices: The CPRA provides California residents with specific rights regarding their consumer information. This Section describes your CPRA rights (to the extent applicable to you) and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights:You may have the right to request that Splice disclose certain information to you about our collection and use of your consumer information over the past twelve (12) months or such other period required by the CPRA. Once we receive and confirm your verifiable consumer request (in the manner described below), to the extent required by the CPRA, we will disclose to you:

• The categories of consumer information we collected about you.
• The categories of sources for the consumer information we collected about you.
• Our business or commercial purpose for collecting that consumer information.
• The categories of third parties to whom we disclose that consumer information.
• The specific pieces of consumer information we collected about you (also called a data portability request).
• If we disclosed your consumer information for a business or commercial purpose, a list disclosing disclosures for a business or commercial purpose, identifying the categories of recipients to whom such consumer information was disclosed and the consumer information categories that each category of recipient obtained.

Deletion Request Rights:You have the right to request that Splice delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you or your authorized agent (in each case if you are a California resident) in the manner described below (“verifiable consumer request”), we will delete (and notify our service providers and/or contractors to delete, unless this proves impossible or involves disproportionate effort) your consumer information from our records, unless an exception applies or retention of your consumer information is otherwise permitted by the CPRA. We may deny your deletion request if retaining the information is reasonably necessary for us or our service provider(s) and/or contractor(s) to:

• Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Help to ensure security and integrity to the extent the use of your consumer information is reasonably necessary and proportionate for those purposes.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete the research, if you have provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
• Comply with a legal obligation.

Correction Request Rights: You have the right to request that we correct inaccurate consumer information about you that we maintain, taking into account the nature of the consumer information and the purposes of the processing of the consumer information. If we receive a verifiable consumer request from you to correct inaccurate consumer information, we will use commercially reasonable efforts to correct such inaccurate consumer information as directed by you, pursuant to Section 1798.130 of the CPRA and regulations adopted pursuant to the CPRA.

Exercising Access, Data Portability, Correction, and Deletion Rights: To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by either: (1) calling us at (888) 229-0015 ; (2) visiting support@splice.com; or (3) contacting us in accordance with Section of this Privacy Policy titled Contact Us.. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. Someone legally authorized to act on your behalf (such as an authorized agent) may make a verifiable consumer request on your behalf, provided that you have duly authorized that person or entity to make such a verifiable consumer request on your behalf and provided that that person or entity can provide verification of their authority to make such a request on your behalf where required. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a twelve (12) month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized agent; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use consumer information provided for the purposes of verification of a consumer request to verify the requestor's identity or authority to make the request. In the event you make a request under this CPRA Notice, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating telephone calls with you or reaching out to by email or otherwise to ask you questions pertaining to the information we have about you.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your consumer information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.

Non-Discrimination: We will not discriminate against you for exercising any of your CPRA rights, including, unless permitted by the CPRA, by:

• Denying you goods or services;
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Providing you a different level or quality of goods or services;
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or
• Retaliating against an employee, applicant for employment, or independent contractor, as defined in subparagraph (A) of paragraph (2) of subdivision (m) of Section 1798.145 of the CPRA for exercising their rights under the CPRA.

Consumer Information Retention. We will only retain your consumer information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law. To determine the appropriate retention period for consumer information, we consider the amount, nature, and sensitivity of that consumer information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your consumer information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Contact. If you have any questions or concerns relating to this Privacy Policy our consumer information practices, please contact us in accordance with Section of this Privacy Policy titled Contact Us.

Additional Information Regarding European Data Protection Laws

As used in this Privacy Policy (a) “GDPR” means the General Data Protection Regulation (EU) 2016/679; (b) “UK Data Protection Laws” means data protection laws enacted under the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (“UK GDPR”) and the UK Data Protection Act 2018 (“UK DPA 2018”); and (c) “European Data Protection Laws” means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable.

To the extent that the Service is available to individuals located in the European Economic Area or the United Kingdom, or to the extent we process your personal information in the context of the activities of an establishment in the European Economic Area or United Kingdom, this Privacy Policy sets out our practices and obligations under the European Data Protection Laws, to the extent applicable.

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European Data Protection Laws.

Controller

Splice is the controller of your personal information for purposes of European Data Protection Laws. See the Contact Us section above for contact details.

Our UK representative is Distributed Creation UK, Ltd., and can be reached by sending an email to gdpr@splice.com.

Our EU representative is The DPO Centre Europe Ltd, and can be reached by sending an email to gdpr@splice.com.

Our Data Protection Officer can be reached by sending an email to support@splice.com.

Legal bases for processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at support@splice.com.

In particular, we would like you to be aware that we may employ algorithms in connection with the Service, which may use self-reported location, preferences, interests, and other data in connection with your usage data to make recommendations, tailor your search results, and determine whether to send you a survey. Under the European Data Protection Laws (to the extent applicable), this usage may be considered profiling. The European Data Protection Laws define "profiling" as "any form of automated processing of personal information consisting of the use of personal information to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements". To the extent Splice's processing constitutes profiling under the European Data Protection Laws (to the extent applicable), you have the right to specifically object to the processing of your personal information for the purpose of profiling. To learn more, please reach out to support@splice.com.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may retain indefinitely certain information associated with content you upload to the Service, such as the title and authorship of your projects. We encourage you not to embed any personal information in such content. When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information where there is no good reason for us to continue processing it.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict and suspend the processing of your personal information.
• Object.Object to our reliance on our legitimate interests as the basis of our processing of your personal information.

You can submit these requests by email to support@splice.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Additional Information Regarding Canadian Privacy Laws

As used in this Privacy Policy (a) “PIPEDA” means thePersonal Information Protection and Electronic Documents Act, SC 2000, c 5; (b) “Substantially Similar Legislation” means provincial privacy legislation deemed to be substantially similar to PIPEDA, which, to date, includes the Personal Information Protection Act,RSA 2003, c P-6.5 (Alberta), the Personal Information Protection Act,RSBC 2003, c 63 (British Columbia) and An Act respecting the protection of personal information in the private sector,CQLR c P-39.1 (Quebec) ; and (c) “Canadian Privacy Laws” means PIPEDA and/or Substantially Similar Legislation, in each case to the extent applicable.

To the extent that the Service is available to individuals located in Canada this Privacy Policy sets out our practices and obligations under Canadian Privacy Laws, to the extent applicable.

We do not rent, sell or trade your personal information.

Accuracy and Completeness

We make every reasonable effort to ensure that personal information is accurate and complete. This may involve requesting further information or updates from you. We rely on you to notify us if there is a change to your personal information that may affect your relationship with us.

Retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may retain indefinitely certain information associated with content you upload to the Service, such as the title and authorship of your projects. We encourage you not to embed any personal information in such content. When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Security Incident

The protection of personal information is of paramount concern to us, and we are prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with Canadian Privacy Laws.

Privacy Officer

For further information about our privacy practices, to make a request for access to personal information or to exercise any other rights outlined in this Privacy Policy, please contact our Data Protection Officer at the following address: 817 Broadway, 4th Floor New York, NY 10003.

Notice to Japanese Residents

We disclose the matters relating to retained personal data, pursuant to the Article 32 of the Act on Protection of Personal Information (“APPI”), as follows:

The Name, Address, and the Name of Representative of the Personal Information Handling Business Operator

Distributed Creation Inc.
817 Broadway, 4^th Floor
New York, New York 10003

Chief Executive Officer: Kakul Srivastava

The Utilization Purpose of All Retained Personal Data

Please see the section of this Privacy Policy above titled “How We Use Your Personal Information”.

How to Request and/or Demand

Please see the claim procedure below if you would like to (1) request to be informed of a utilization purpose of retained personal data that can identify you, (2) request that we disclose to you retained personal data that can identify you, (3) request that we make a correction, addition or deletion in regard to the contents of retained personal data that can identify you, (4) request that we cease utilization of, or delete, retained personal data that can identify you, (5) request that we cease a third-party provision of retained personal data that can identify you, and/or (6) request that we disclose our record on a third-party provision:

• Claim Procedure;You can submit these requests by email to support@splice.com or our postal address provided above. Please note that whether by email or letter, we cannot correspond in Japanese.

Security Control Action for Retained Personal Data

Please see the section of this Privacy Policy above titled “Security”.

Contact for Complaints

If you have any complaints about our handling of retained personal data, please feel free to email us at support@splice.com, or write to us at:

Distributed Creation Inc.
817 Broadway, 4^th Floor
New York, New York 10003

Please note that whether by email or letter, we cannot correspond in Japanese.

We also disclose the following necessary matters pursuant to the APPI.

Third-Party Provision and International Transfer

As described above in the section of this Privacy Policy titled “How We Use Your Personal Information”, we provide your personal information to certain third parties to administer and provide the Service.

Such processing is based on your consent. In particular and in addition, we need to obtain your advance consent to the International Transfer of your personal information. Please review this Privacy Policy carefully before you start to use the Service or submit your personal information on it.

As agreed upon when you create a Splice account, you voluntarily consent to the provision of your personal information third parties and to the International Transfer of your personal information.

Kojin-Kanren-Jouhou

We use cookies and similar technologies (see the section of this Privacy Policy above titled “Cookies and Similar Technologies”), and provide some or all of the personal information collected through such technologies to third parties (see also the section of this Privacy Policy above titled “Third Party Generally”). Some of those third parties may identify you by collecting your information by using cookies and similar technologies (see the section of this Privacy Policy above titled “Cookies and Similar Technologies”). Those third parties may seek your consent to such usage. Or we may seek your consent to it.

Change to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, except (1) when we modify, amend, revise, change the utilization purpose beyond the scope recognized to be reasonably relevant to the present utilization purpose or when we add new matters to the utilization purpose of personal data (“How We Use Your Personal Information”) or (2) when we add a new type of third party with whom we share your personal information. Except for the foregoing exceptions, any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting).

In connection with the exceptions described in (1) and (2) above, we will notify you, seek your consent, and then (1) we will modify, amend, revise, change or add new matters to the utilization purpose of personal data or (2) we will add the new type of t third parties with which we share your personal information.

Whenever we modify this Privacy Policy, we may try to obtain your acceptance of the terms of the modified Privacy Policy.

We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Service that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Service – or a specific announcement on this page or on our blog).

Notice to South Korean Residents

Process/Retention Period and Destruction of Personal Information

Mandatory information (and optional information, if agreed) set forth above will be retained and used for as long as necessary to fulfill the purposes we collected it for to achieve the abovementioned purposes of use, unless a longer retention period is otherwise required or permitted by law.

Personal information which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be processed, will be destroyed in an irreversible way pursuant to our internal policies, unless we are required to retain it for a longer period under applicable laws.  Personal information stored in electronic files will be deleted in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating.

Documents which are statutorily required to be retained for a certain period are as follows:

• Register of workers: three (3) years from the date of dismissal, retirement, or death (The Labor Standards Act)
• Employment agreement: three (3) years from the date on which the employment is terminated (The Labor Standards Act)
• Documents related to employment, dismissal, and retirement: three (3) years from the date of dismissal or retirement (The Labor Standards Act)
• Wage ledger: three (3) years from the date on which any matter was recorded therein for the last time (The Labor Standards Act)
• Documents related to recruitment, employment, wage, money and goods other than wages, education assignment, promotion, age limit, retirement and dismissal: three (3) years (Equal Employment Opportunity and Work-Family Balance Assistance Act)
• Documents related to application for, and permits of, childcare leave: three (3) years (Equal Employment Opportunity and Work-Family Balance Assistance Act)
• Documents related to health insurance including management of the eligibility requirements and calculation of insurance premium: three (3) years (National Health Insurance Act)

Rights and Obligations of Data Subject and Legal Representative and Method of Exercise thereof

If we must obtain consent from a child under 14 years of age to process his or her personal information, we will obtain consent from his or her legal representative.  In such cases, we may request that the child furnish the minimum information necessary for us to obtain consent from the legal representative.  The legal representative may exercise the rights of the child under the Privacy Policy.

You may exercise the following privacy rights against us at any time:

• Right to demand access to his or her personal information
• Right to demand correction in case of error
• Right to demand deletion of his or her personal information; and
• Right to demand suspension of personal information processing.

You may exercise the above rights in writing or via email, fax, etc. and we will take appropriate measures without delay. In the event that you request correction or deletion of all or a certain portion of personal information, the relevant information will not be used or provided until the correction or deletion is completed. You may exercise such rights through your legitimate representative or agent authorized by you, in which case, the appropriate power of attorney must be submitted to us.

Provision of Personal Information to Third Parties

We do not provide your personal information to third parties for such third parties’ own independent purposes.

Delegation of Processing of Personal Information

We delegate the processing of your personal information as described below, and the delegatees may process your personal information according to the purpose of the delegation:

For a complete list of delegatees, please contact us at support@splice.com.

Measures to Ensure the Security of Personal Information

A. Managerial measures for the protection of personal information

1. 1) We will designate a Chief Privacy Officer (“CPO”) to ensure that your personal information is processed according to the law and will establish and implement an internal management plan for doing so.
2. 2) We will establish and implement plans for personal information protection training for our employees, delegatees and others who are directly in charge of processing personal information.
3. 3) We will periodically conduct an internal audit to verify personal information protection, in accordance with the internal management plan.

B. Technical measures for the protection of personal information

1. 1) We will control access to personal information and will restrict and manage the access right.
2. 2) We will record the details of the management of access right to personal information and will retain such records for a certain period of time.
3. 3) We will install and operate an intrusion blocking/prevention system to prevent any unauthorized access to personal information. In addition, a safe access measures, including a virtual private network, will be applied to control the access from the outside.
4. 4) We will establish and apply password generation rules to enable employees to set up and use a secure password. Upon designating a password to access a certain area of this website, employees are obligated to keep the password confidential and must not disclose it to a third party.
5. 5) At the time of transmitting, receiving and saving personal information, including sensitive information and unique ID information, we will take encryption measures required under applicable laws and regulations.
6. 6) We will install and periodically update programs to fix security defects in software, including operating systems.
7. 7) We will keep the records of access to the personal information processing system in a safe manner for a certain period of time.

C. Physical measures for the protection of personal information

1. We will take physical access prevention measures, including restrictions on access and placing locks, to store personal information kept by way of hard copy in a safe manner

Matters Concerning the Collection, Use, Provision and Refusal of Behavioral Data

A. We collect and use behavioral data in order to provide customized services and benefits, as well as customized online advertisements, etc. that are optimized for you in the course of using the Service.

B. We collect behavioral data as follows:

C. We permit online customized advertising business operators to collect and process behavioral data as follows:

1. 1) Advertising business operators that intend to collect and process behavioral data:
   1. Google  LLC
   2. Microsoft
   3. Facebook
   4. Instagram
   5. TikTok
   6. Snap
   7. Twitter
2. 2) How to collect behavioral data: cookies; direct from user.
3. 3) Items of behavioral data collected and processed: Site visits and conversion actions (such as whether a user registered or starts a trial).
4. 4) Period of retention and use: as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

D. We (i) collect only the minimum behavioral data necessary for customized online advertisements, etc., and (ii) do not collect any sensitive behavioral data, such as ideology, beliefs, family relationships, educational background, medical history, and history of other social activities that is likely to seriously infringe upon an individual's rights, interests, or privacy.

E. We do not collect behavioral data for customized advertising purposes from children who we know to be under the age of 14 or online services mainly intended for children under the age of 14, and do not provide customized advertising to children who we know to be under the age of 14.

F. We collect and use advertisement identifiers for customized online advertisements on the mobile app. You can block and allow customized ads on your apps by changing the settings on your mobile devices.

G. You may block and allow all customized online advertisements by changing the cookie settings of your web browsers, etc. However, changes to cookie settings may affect the use of certain services, such as automated login to the website.

H. You may ask questions such as exercising your right of refusal, or receiving reports of damage, etc. in relation to behavioral data by using the contact information listed below.

Contact

If you have any questions or comments about the Privacy Policy, if you need to report a problem, or if you would like us to update, amend, or request deletion of the information we have about you, please contact our Data Protection Officer (or department in charge of personal data protection) at support@splice.com

Changes in our Privacy Policy

Please find the previous versions of our privacy policy below:

• November 11, 2020
• September 22, 2022
• October 20, 2022