We at 5for5 Soundtracks value your privacy and are committed to protecting the personal information of our users (the “Personal Information”). We have adopted this Privacy Policy (the “Policy”) to be clear about the data we collect, why we collect it, whom we share it with, how you can access it, and correct it when necessary.

We have always safeguarded your Personal Information and recognize our duty to handle your data in a responsible manner. We do not and will not sell your data to third parties.

This Policy applies to the use of the 5for5soundtracks.com website (the “Website”). Please read it carefully in order to understand when you may provide Personal Information to us and how 5for5 Soundtracks uses the Personal Information provided. By using our Website, you agree to the use of your Personal Information as described in this Policy. The terms “we”, “us”, “5for5” or “5for5 Soundtracks” are each intended as a reference to 5for5 Soundtracks (9362-4625 Québec inc.).

To make this Policy as clear as possible, we have determined the occasions when a user would potentially share Personal Information with 5for5 Soundtracks. The Policy is therefore divided as follows:

• Learning about 5for5 Soundtracks
• Signing up for a 5for5 Soundtracks subscription
• Downloading a track from 5for5 Soundtracks
• Purchasing an exclusive licence from 5for5 Soundtracks
• Contacting 5for5 Soundtracks

We have then added different sections explaining in more detail how your Personal Information is used, how and when it might be shared, how you can access it and control your Personal Information, the ways we make sure your Personal Information is safe, and how to contact us.

Learning about 5for5 Soundtracks

As you look into your needs and gather information regarding what 5for5 Soundtracks can do for you, you may visit our Website or voluntarily provide us with Personal Information, such as your name and your email address when contacting us through our contact form, or by sending us an email.

We collect: first name, last name, email address, phone number, country of residence (as well as any other information you provide us when contacting us), Internet Protocol (“IP”) address, and information provided by cookies or similar technology, such as the type and version of the browser you are using to access our Website, the page you were on before heading to our Website, the amount of time you spend on our Website, the pages you decide to visit, as well as the date and time you are accessing our Website on.

Why: The Personal Information collected allows us to analyze how our Website is used and accessed in order to increase our Website’s functionality and ultimately, optimize it to better meet our users’ needs. It also allows us to respond to your inquiries when you are in the process of learning more about us and to ensure you receive a high standard of service when you first contact us.

Applicable legal basis under the GDPR: contract performance, legitimate interests

Signing up for a 5for5 Soundtracks subscription

Once you have gathered enough information about 5for5 Soundtracks and what we can do for you, you may decide to purchase a subscription from us.

When buying a 5for5 Soundtracks subscription, you will be asked to provide Personal Information such as your first name, your last name, and your email address, as well as to create an account on our Website.

We collect: first name, last name, phone number, email address, billing address, and payment information.

Why: We use this information to complete your transaction, to process payments for the duration of your subscription, to fulfill any legal obligations we might have towards you once you have purchased a subscription from us, and to contact you in the future about your account or for promotional purposes.

Please note that if you refuse to provide us with such Personal Information, we will not be able to process your orders and make the 5for5 Soundtracks subscription you have purchased available to you.

Applicable legal basis under the GDPR: contract performance, consent

Downloading a track from 5for5 Soundtracks

Once you have purchased a 5for5 Soundtracks subscription, you will be able to download tracks as per the subscription plan you have chosen. When downloading tracks on 5for5 Soundtracks, we will collect information about your activity on our Website.

We collect: the name of the tracks you download, date of purchase, and all other relevant information about your purchase history.

Why: We use this information to fulfill any legal obligations we might have towards you, to keep track of the activity on our Website, to ensure you have not surpassed the limits of your subscription plan, and to keep a log of downloads on our Website in case we receive any third-party complaints.

Applicable legal basis under the GDPR: contract performance, consent, legal obligations

Purchasing an exclusive licence from 5for5 Soundtracks

If you stumble upon a track on our Website that you wish to get an exclusive license for, you may decide to contact us in order to get said exclusive license.

We collect: first name, last name, email address, phone number, country of residence, billing address, payment information as well as any information you share with us in the context of our communications.

Why: We use this information to respond to your request, complete your transaction, to process your payment, to fulfill any legal obligations we might have towards you once you have purchased an exclusive license, and to contact you in the future about your account, for promotional purposes or about the specific license you purchased.

Applicable legal basis under the GDPR: contract performance, consent, legal obligations

Contacting 5for5 Soundtracks

From time to time, you may decide to contact us with questions or any other requests. To be able to offer you the best assistance possible, we may collect certain information from you.

We collect: contact information such as your first and last name, email address, phone number, your country of residence and the content of your communications with us.

Why: we collect this Personal Information to identify you, to give you the best assistance possible and to fulfill your demand or answer your questions.

Applicable legal basis under the GDPR: contract performance

HOW WE USE YOUR PERSONAL INFORMATION

We use the Personal Information we collect to improve and personalize your experience on our Website. We also use the Personal Information we collect to communicate with you about your account, the licences or subscription you have purchased or to inform you of any relevant news.

We may use your Personal Information for the following purposes:

• To improve our Website by developing new features, doing research and maintaining the current performance of our Website (applicable legal bases under the GDPR: legitimate interests);
• To offer you the best customer support there is (applicable legal bases under the GDPR: contract performance);
• To provide you with the downloaded tracks, licences or subscription you have purchased is (applicable legal bases under the GDPR: contract performance);
• To guide our business decisions and develop new products or services that are relevant for our clients (applicable legal bases under the GDPR: legitimate interests);
• To communicate with you, whether for marketing, advertising or account maintenance purposes. For instance, we may contact you by email to notify you of newly available features or tracks on our Website (applicable legal basis under the GDPR: contract performance, consent);
• To ensure we respect the contractual and legal obligations we have towards you when you purchase 5for5 Soundtracks licences or subscription plan (applicable legal basis under the GDPR: contract performance);
• To ensure we are paid when you purchase licenses or subscription plans from us (applicable legal basis under the GDPR: contract performance);
• To document activity on our Website in case of a third-party complaint (applicable legal basis under the GDPR: legal obligations) ;
• To fulfill any legal or regulatory obligations we might have (applicable legal basis under the GDPR: legal obligations);
• To update our files (applicable legal basis under the GDPR: legal obligations, contract performance).

OUR USE OF COOKIES

Our cookie policy is part of this Privacy Policy.

When visiting our Website, you may provide information online via cookies or similar technologies.

Cookies are files that hold a small amount of data about a certain user. That data may include an anonymous unique identifier. They are stored on the user’s computer or other devices’ hard drive. Cookies allow us to tailor your user experience whenever you visit our Website.

The cookies we use perform up to four different functions:

1) Performance cookies: we use these cookies to analyze our visitors use our Website and to improve our Website’s performance.

2) Functionality cookies: we use these cookies to allow us to remember your preferences every time you visit our Website.

3) Essential cookies: some cookies are essential for the operation of our Website. Disabling these cookies will stop you from accessing our Website or using all of its features.

4) Advertising cookies: these cookies allow us to gather information about your interests and behaviour to display advertisements based on those topics of interests.

Keep in mind that you can instruct your browser to disable the cookies we use. Doing so may however stop you from properly accessing our Website.

If you would like more information about cookies, you may visit the following website: https://www.allaboutcookies.org

WHOM WE MAY DISCLOSE YOUR INFORMATION TO AND WHY

We do not and will not sell Personal Information about our users and clients. We only disclose your Personal Information as authorized in this Policy. We may however share information with the following types of parties:

Third-party vendors: we may disclose your Personal Information to third-party vendors. For instance, we may share some of your Personal Information with payment processing platforms, IT providers or other entities hired for specific purposes such as a marketing firm.

In general, the vendors we use will only collect, use and disclose your information as necessary to provide the services they offer, such as email communications or website hosting.

However, please note that certain third-party vendors have their own privacy policies when it comes to the Personal Information we are required to provide when using their services. As for those vendors, we suggest you take the time to read their privacy policies to allow you to understand how your Personal Information will be processed. Please note that some of these parties are also located outside of the province of Quebec. Therefore, your Personal Information may be transferred to servers located outside of Quebec.

Once you leave our Website or are redirected towards a third-party’s website or application, you stop being subject to our Privacy Policy and Terms and Conditions.

List of third-party IT vendors

Digital Ocean (website hosting – United States): https://www.digitalocean.com/legal/privacy-policy
• Digital Ocean currently uses the European Commission approved Standard Contractual Clauses for data transfers outside of the EU: https://www.digitalocean.com/legal/gdpr-faq

Facebook (advertising – United States): https://www.facebook.com/policy.php
• Facebook currently uses the European Commission approved Standard Contractual Clauses for data transfers outside of the EU: https://www.facebook.com/help/566994660333381

Google (website analytics – United States) : https://support.google.com/analytics/answer/6004245?hl=fr

• To opt out of Google Analytics for Display Advertising and customize the Google Display Network ads: http://www.google.com/settings/ads
• To learn more about Google’s cookie policy: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
• To install the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout?hl=en
• Google currently uses the European Commission approved Standard Contractual Clauses for data transfers outside of the EU: https://support.google.com/publisherpolicies/answer/10437486?hl=en

Stripe (credit card processor – United States) : https://stripe.com/en-CA/privacy
• Stripe currently uses the European Commission approved Standard Contractual Clauses for data transfers outside of the EU: https://stripe.com/en-ca/privacy-center/legal

Parties with whom it might be legally necessary: we may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to:

• Conform with the law or with any legal proceedings;
• Protect the rights or property of 5for5 Soundtracks;
• Protect the safety of our Website, our users, and their Personal Information.

Parties who might take part in a financial transaction with 5for5 Soundtracks: we may transfer your Personal Information in the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of 5for5 Soundtracks. We will only do so if the party acquiring your information agrees to comply to the terms of this Policy.

Please note that you may have to leave our Website by clicking on certain links on our Website. We do not assume any responsibility for the privacy practices of these other sites and recommend that you read their privacy policies carefully.

HOW TO ACCESS AND CONTROL YOUR DATA

You may verify, modify or delete your Personal Information by sending us an email to support@5for5soundtracks.com. We will reply to your demand as soon as we can. Please make sure you provide us with enough information to be able to identify you and fulfill your demand.

You may also modify some of your Personal Information by accessing your account on our Website.

WHERE YOUR DATA IS STORED

Your Personal Information is stored locally in Laval, Canada as well as on Digital Ocean’s servers in New Jersey, United States. Your Personal Information may also be stored in other countries, following a transfer to the third parties we work with.

YOUR RIGHTS

• Access: ask if we are processing information and, if we are, request access to personal information in a structured, commonly used technological format;

• Accuracy: we are required to take reasonable steps to ensure that the Personal Information in our possession is accurate, complete, not misleading and up to date;

• Correction: request that any incomplete or inaccurate personal information we hold be corrected.

• Erasure: ask us to delete, destroy or remove personal information in certain circumstances. There are certain exceptions where we may refuse a request for erasure or destruction, for example, where the personal information is required for compliance with law or in connection with claims or required by contract between the parties;

• Restriction: ask us to suspend the processing of certain personal information, for example, to establish its accuracy or the reason for processing it;

• Transfer: request the transfer of certain personal information to another party;

• Objection: challenge when we are processing personal information based on a legitimate interest (or those of a third party) or for certain direct marketing purposes. However, we may be entitled to continue processing information;

• Automated decisions: contest any automated decision made where this has a legal or similar significant effect and ask for it to be reconsidered (GDPR only);

• Consent: where we are processing personal information with consent, withdrawal of consent in the circumstances permitted by law; and

• Complaint: make a complaint with a data protection supervisory authority.

HOW LONG WILL YOUR DATA BE KEPT FOR

We will retain all Personal Information collected through our Website or through the provision of our services as long as it is necessary to achieve the purposes for which we collected it or for other essential purposes such as compliance with legal obligations. As long as your account with us is active, we will keep your Personal Information on our systems. We will also dispose of your Personal Information if you decide to withdraw your consent. Once your Personal Information is deleted, you will receive confirmation that your request has been fulfilled.

SECURITY

We take reasonable precautions and follow industry best practices to ensure that your Personal Information is protected and that it is not lost, misappropriated, accessed, disclosed, altered, or destroyed in an inappropriate manner.

For instance, we ensure that access to your Personal Information is restricted to 5for5 Soundtracks personnel and contractors for whom this access is necessary for the performance of their duties.

Our Website uses the HTTPS protocol for communications, secured by an SSL certificate, as well as the iThemes Security plugin.

We also do not store credit card information and only use PCI-compliant payment processors.

You can also browse our list of third-party providers to learn more about their security measures.

If you have any questions about the security of your personal information, please send us an email to support@5for5soundtracks.com.

CHILDREN

We do not knowingly collect information from children or other persons who are under 14 years old. Si vous êtes un parent ou gardien et que vous réalisez qu’un mineur de moins de 14 ans nous a fourni des informations personnelles, veuillez nous contacter. If you are a parent or guardian and you know that your children have provided us with personal information, please contact us. If we learn that we have collected personal information from minor children without verification of parental consent, we will take steps to remove that information from our servers.

QUEBEC PRIVACY COMMISSIONER’S OFFICE (COMMISSION D’ACCÈS À L’INFORMATION DU QUÉBEC)

If you are not satisfied by 5for5 Soundtracks’ response following a request regarding the access of your Personal Information, you may contact the Quebec Privacy Commissioner’s Office, the public authority in charge of overseeing personal information handling practices in Quebec.

Address:

Suite 18.200
500, boul. René-Lévesque West
Montreal (Quebec) H2Z 1W7
Phone number: 514 873-4196
Fax number : 514 844-6170

Toll-free number: 1 888 528-7741
Email address: cai.communications@cai.gouv.qc.ca
Website: http://www.cai.gouv.qc.ca

EUROPEAN SUPERVISORY AUTHORITIES

If you are not satisfied with our response to a request concerning your Personal Information, you can, if you are a European resident, contact the competent supervisory authority to file a complaint. You can find a list of these authorities here.

MODIFICATIONS TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so please make sure you check this page regularly. Changes and clarifications will take effect immediately upon posting on our Website. If we make any changes to the content of this Policy, we will notify you here that it has been updated so that you know what information we collect, how we use it, and under what circumstances we disclose it, if necessary.

QUESTIONS AND CONTACT INFORMATION

If you wish to: access, correct, modify or delete any Personal Information that we have about you, file a complaint, or if you simply want to have more information, you may contact us at the following address:

5for5 Soundtracks
Attention: Privacy Officer
6923 Notre-Dame Blvd.
Laval (Quebec)
H7X 4E2 Canada
support@5for5soundtracks.com