Privacy and Cookies Policy

 Last updated: January 1, 2022

1. About Us

This privacy and cookie policy (hereinafter, the “Policy”) explains the data protection practices of Sony Music Entertainment España S.L. Sony Music Entertainment España S.L. is an entity registered in the Commercial Registry of Madrid on October 24, 2005, under Volume 20150, Book 9, Folio 224, Section 8, Sheet M-60370, Entry No. 110, and its current name is recorded in a public deed authorized by the Illustrious Notary of Madrid, Mr. Ignacio Maldonado Ramos, dated February 9, 2009, protocol number 310, which is duly registered in the Commercial Registry of Madrid on February 26, 2009, under Volume 21224, Book 0, Folio 189, Section 8, Sheet M-60370, Entry No. 122. When we refer to "Sony Music", "Sony Music Entertainment" or "we", we mean Sony Music Entertainment España S.L.

You can contact the Data Protection Officer of Sony Music Entertainment España S.L. at dpo@sonymusic.com.

We are committed to protecting and respecting your privacy, and these are the bases on which we will process any personal data we collect from you, or that you provide to us. Please read the text carefully to understand our perspective and practices regarding your personal data and how we will treat it.

2. Key Points

• We use your personal data to enable you to use the content features, process your registration and orders, and provide you with the requested content and product related to our offers and content.

• Our Sony Music Store website offers interactive features that connect with social networks, such as Facebook, Instagram, and Twitter, as well as music streaming services, such as Spotify. If you use these features or subscribe to a contest or the Sony Music newsletter and/or other artists who sell products through the Sony Music Store using your Spotify account or, where applicable, any of the aforementioned platforms, these platforms will send us personal information about you and your use of the content on those platforms.

• Although some products are aimed at minors, in general, we try not to collect information from children under 14 and may ask for your age before you register to order a product, receive newsletters, or use our content.

• If you authorize us, we will send you news and promotional material about merchandise products, news, and updates about Sony Music artists and/or other artists who have agreed to sell their products through the Sony Music Store. You can change your mind on this at any time and ask us to stop processing your personal data for direct marketing purposes. For sending news and promotional material, Sony Music may also create a profile with the information it has about you and track your behavior while browsing Sony Music's various websites and communications sent by Sony Music, as well as on the social networks mentioned above (if you request registration with your account on these platforms). This Policy also explains when we process personal data to comply with our legitimate interests. You can ask us to stop processing this information at any time, in which case we will assess, in accordance with the law and this policy, whether there are compelling legitimate grounds for processing that override, or if it is necessary for the establishment, exercise or defense of legal claims.

• We disclose your personal data publicly when you post content through the Sony Music Store. We disclose your personal data, when you accept or when we have legitimate interests, to other companies in the Sony Music group. We may also share information with third parties we contract for data processing on our behalf or when required by law or a competent authority.

• We may transfer certain personal data to the US and other countries outside the EEA (European Economic Area).

• We use cookies and other tracking technologies to personalize content and advertising and to make our content work better.

3. Special Notice to Children Under 14

YOU MUST BE AT LEAST 14 YEARS OLD TO REGISTER ON OUR WEBSITE. PLEASE DO NOT REGISTER IF YOU ARE UNDER 14.

4. Special Notice to Parents

While we do not intentionally allow registration by children under 14, parents should supervise their children's online activities and consider using parental control tools available from online services and software manufacturers that help provide a child-friendly online environment. These tools can also prevent children from disclosing their names, addresses, and other personal information online without parental authorization.

5. How We Collect Your Personal Data and What Data We Collect

Through the user

You provide us with your personal data, which we collect and process, by purchasing a product or filling out a form in the Sony Music Store, requesting your subscription, or by contacting us. This includes information provided at the time of purchasing a product, registering to use (or become a member of) the Sony Music Store website, or subscribing to receive commercial information.

Through third parties

Likewise, we may collect personal data about you when the entry or contact with Sony Music is made through your registration (e.g., for product acquisition or sending commercial information, or your participation in a contest) through your social media account (such as Facebook) or streaming music services (such as Spotify), or when you use the "like" or "share" button on these platforms.

Through these platforms, Sony Music may collect general and contact information (full name and username, profile picture, email, age and date of birth, gender, country), technical or economic information (type of computer used, or type of service or subscription contracted), or information about the use of your account on these platforms, frequency, activity, most listened to songs and artists, followers, or start date on the platform.

Sony Music may record, organize, consult, store, use for profiling, and cross-reference this information with the information it has about you in its own databases as a result of information provided by you in accordance with the previous section.

This information will only be collected if you subscribe or interact with Sony Music through your account on these platforms and after being informed about the processing of your personal data in these cases through this Policy and appropriate notices.

Through the use of cookies and other tracking technologies

Likewise, on our websites, we use technology to collect information that helps us improve navigation and how you view Sony Music web pages, measure our audience, and offer personalized advertising based on your behavior on the different Sony Music web pages or through your account on the platforms mentioned in this Policy. We refer to this technology as “cookies” throughout this Policy, but it also covers similar technologies known as web beacons (“tracking pixels”), log files, pixel tags, gifs (also described below). We use both our own cookies and third-party cookies to collect the information we need. For more information, see “cookies and other tracking technologies” below.

Minors

If at any time we provide online services to a minor under 14, and we need parental consent for it, we may ask for a parent's email address to request such consent.

6. How We Use Your Data

We use the personal data collected in accordance with this Policy for the following purposes:

(1) To execute or enforce a contract, or take actions related to a contract;

a) To process your registration in the Sony Music Store or in any of the contests we organize.

b) To process the acquisition or purchase of merchandise products on the Sony Music Store website.

c) To send you information about changes to our terms and policies.

(2) In cases where it is necessary to comply with our legitimate interests related to Sony Music's relationship with you or the continuity of business or improvement of services provided.

These interests are:

a) To provide you with access to content and features on the Sony Music Store website.

b) To send you the information you have requested.

c) To ensure the security of the Sony Music Store website, trying to prevent unauthorized or malicious activities.

d) To enforce our terms of use and other policies and to help other organizations (such as copyright holders) assert their rights.

The processing of your personal data for the purpose of fulfilling these legitimate interests overrides other interests or rights and freedoms. You may request more information about the prior balancing test by requesting it at the addresses indicated in this Policy.

(3) When you give us your express consent:

a) When you ask us to send you commercial information, news, contests, surveys, and promotional material about merchandise products, news, and updates about Sony Music artists and/or other artists who have agreed to sell their products through the Sony Music Store, through any means and, in particular, by electronic means (e.g., email marketing).

The sending of commercial information may be based on the creation of a profile by Sony Music, taking into account your behavior while browsing the Sony Music Store website and other Sony Music websites, as well as regarding communications received by you through any authorized means.

Likewise, it may take into account your behavior on other platforms (Facebook, Spotify) when you use your user account on these other platforms to participate, subscribe, or interact with Sony Music and its activities. This information, explained in section 5 of this Policy, is only used for creating audiences for each artist, to whom specific impactful advertising campaigns are sent, and you are not sent individual commercial communications. In no case will automated decisions be made that may produce legal effects on the interested party or significantly affect them.

b) When you allow us to contact you to participate in market research about artists or the music industry in general, conducted by Sony Music (or through authorized third-party companies that provide services to Sony Music).

c) When you give us your consent to set cookies and use similar technologies.

d) On other occasions when we ask for your consent, for purposes that will be explained to you at that time.

(4) For purposes stipulated by law:

a) When we need parental consent to offer online services to children under 14, or the corresponding minimum age required at any given time. However, our websites and apps are generally not designed for children under 14.

b) In response to requirements or requests from law enforcement authorities who are conducting an investigation.

7. How We Share Your Data

Subject to the other terms of this Policy, we may share your personal data with:

(a) Group companies

We may share your personal data with our affiliated or group companies, whose relationship you can find at the following link https://www.sonymusic.com/contacts/, worldwide, based on our legitimate interest, for administrative purposes and for the purposes described above.

(b) Other third parties

We may transfer and/or assign personal data to third parties in connection with the sale, merger, consolidation, change of control, transfer of substantial assets, reorganization, or liquidation of Sony Music, or any part thereof.

We may share with third parties, at our discretion, certain aggregated statistical data about purchases and the use of our content; such data may include demographic data such as the age range and/or geographical location of user groups. No personal data (such as names or email addresses) will be identifiable in these statistics.

(c) In special circumstances

We may disclose personal data in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or take legal action against someone who may be causing injury to or interfering with (either intentionally or unintentionally) the rights of Sony Music. Personal data may be shared with government, administrative, and/or law enforcement bodies and forces, if this is necessary for the purposes mentioned above, if required by law, or if it is necessary for the legal protection of our legitimate interests for law enforcement purposes.

If you post content on a website or app, it will be publicly visible.

(d) Providers or collaborators

We share data with third parties who perform actions on our behalf, such as physical hosting (ICP warehouses) and web hosting, and management of our websites and apps, development agency for technical improvements, sending emails, and data analysis.

Additionally, if you register for a promotion, such as a sweepstake or contest administered by a third party, your personal data will be disclosed to the organizer for them to manage the promotion. This may also mean that your personal data is included in a winner's list.

8. International Transfer

The data we collect may be transferred to, and stored at, a destination within the United States or another country outside the EEA (European Economic Area), for example if any of our servers, or any of our service providers based in the EEA, are located outside the EEA from time to time; or if one of our service providers is established in a country outside the EEA; or if we share your data (in accordance with the “How We Share Your Data” section above).

In cases where information is transferred outside the EEA to a partner or provider in a country that is not subject to an adequacy decision by the European Union Commission, the data will be adequately protected by the standard contractual clauses approved by the European Union Commission, or the signing of Binding Corporate Rules with the third party concerned.

9. Cookies and Other Tracking Technologies

What is a cookie?

Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device.

Cookies help us improve our website and offer a personalized and better service, for example, by storing information about your preferences and allowing us to recognize you when you return to our website. You can refuse to accept cookies by activating the necessary settings in your internet browser. However, please note that if you activate such settings, certain parts of our website may not function correctly.

The information we collect may include IP addresses, browser version, number of visits, which pages you access, and your display preferences. For information on the duration of the cookies we use, as well as whether they are our own or third-party, their purpose, and the possibility of opposing their installation, please click here:

http://tools.sonymusiccreative.com/privacy/SME_UK_CookieGrid.pdf

We use the following categories of cookies on our websites:

Category 1: Strictly Necessary Cookies

These cookies are essential to move around the page and use the functions it offers, such as access to secure areas of the website. Without these cookies, the services you have requested, such as an item you have added to a shopping cart, cannot be provided. We do not use these cookies to collect information about you that could be used to identify your profile, for advertising, or to remember which websites you have visited on the internet.

Category 2: Performance Cookies

These cookies collect information about how visitors use our website. For example, which pages the user visits most often, and if they receive error messages from web pages. These cookies do not collect information that identifies you as a visitor. All information collected by these cookies is aggregated and, therefore, anonymous. It is only used to improve the performance of a website.

Category 3: Functionality Cookies

These cookies remember choices you make such as the country you are visiting our website from, your language, or the region you are in. These can be used to provide you with an experience more appropriate to your preferences and to make visits more personalized and enjoyable. The information collected by these cookies can be anonymized and they are not capable of tracking your browsing activity on other websites.

Category 4: Targeting cookies or advertising cookies

These cookies collect information about your browsing habits so that the advertising shown to you is more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of an advertising campaign. Cookies are generally installed by third-party advertising networks that have the website operator's permission. These cookies remember the websites you visit and that information is shared with others, for example, with advertisers. Often 'targeting' cookies or advertising cookies will be linked to the site functionality provided by the other organization.

Category 5: Social Media Cookies

These cookies allow you to share what you have been doing on the website on social networks such as Pinterest, Facebook, and Twitter. We do not control these cookies. This information may be linked to targeting or advertising activities. Please consult the privacy policies of the respective social networks to understand how their cookies work.