Tonara Privacy Policy

1. Who we are and what this privacy policy governs. This is the privacy policy (“Privacy Policy”) that governs how we, Tonara Ltd. (“Tonara”, “we”, “our” or “us”), use Personal Information (defined below) that we collect, receive, process and store about individuals in connection with the use of: (i) the website www.tonara.com, and any other website that we operate (each, together with its sub-domains, content and services, a “Site”); and (ii) the Tonara mobile software application, and any other mobile software application, that we license (each individually, and collectively, the “App”). The Site and the App are individually and collectively referred to herein as the “Services”.
2. What Personal Information means. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.
3. Hosting. We do not ourselves host any of the Services – all hosting is done by third party service providers that we engage. This means that data you provide us or that we collect from you (including any Personal Information, as defined above) – as further described in this Privacy Policy – is hosted with such third party service providers on servers that they own or control, and such servers may be located anywhere in the world. Your data may even be replicated across multiple servers located in multiple countries. We use commercially reasonable efforts to only work with hosting providers who have undertaken to comply with applicable data protection laws or regulations. For example, if the data is hosted on data centers in the US, we ensure that the hosting provider has adhered to the “EU-US privacy shield framework”. You can read more here: https://www.privacyshield.gov/welcome.
4. Terms of Use and EULA. Our Terms of Use are available at 4. tonara.com/terms (“Terms”) and the App’s End User License Agreement which can be viewed from within the App and which you accepted prior to downloading, installing and/or using the App for the first time (“EULA”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.
5. Modification of this Privacy Policy.  Before using the Services, we encourage you to read this Privacy Policy and understand our collection, processing and sharing of Personal Information for the purposes set forth herein. If you have questions, please contact us via 5. support@tonara.com. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site.
6. What Personal Information We Collect and How We Collect It. We do receive and/or collect Personal Information from you in the following ways:
⦁ Account. In order to use certain services that we offer via the Site and/or App, you are required to create an account (“Account”). We offer different options to create an Account, including:
⦁ Online Registration Form: You may choose to complete and submit an online registration form. You will be asked to provide us with certain mandatory information such as your name and email address, and also a password that you will use for your Account.
⦁ Third Party Accounts: You may choose to create an Account by clicking on a ‘connect’ or ‘sign-in’ button that we may display on the Site or App for a designated third party website or service (each a “Third Party Account”), such as Facebook or Twitter. Doing so will enable you to link your Service Account and your Third Party Account. If you choose this option, then you will be required to approve the connection as well as the types of information (which may include Personal Information) that we will obtain from your Third Party Account and the types of activities that we may perform in connection with your Third Party Account. Please note that in order to use this option, you will need to have, and may need to be signed-in to, an existing Third Party Account.
Regardless of which method you choose to register your Account, we may send an email to your nominated email address to instruct you how to confirm your registration.
If you choose not to provide this data or refuse to create the Account, please note that some or all of our Services may not be provided.
⦁ ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form that we make available or by sending an email to an email address that we display, you are required to provide us with certain information such as your name, phone, address and email address. We use this information to respond to your request. Our “contact us” forms and mechanisms allow you write comments or additional information. Please make sure that you only send comments or information which are legal and do not violate or infringe any third-party rights. Please do not provide any sensitive data about anyone (such as data regarding health, religion, sexual orientation, etc.). We reserve the right to delete such information immediately.
⦁ Profile. Some parts of the Site and/or App enable you to build a public profile in connection with your Account (“Public Profile”). Your Public Profile will include your name and other information that you choose to include in your Public Profile, such as your location, musical or teaching background, gender and a profile picture.
If you choose not to provide this data or refuse to create a Public Profile, please note that some or all of our Services may not be provided and/or your interactions with your Services may be less attractive.
⦁ Purchases. The Site and/or App include the option to purchase certain products or services from us (such as premium packages). We use the tools, software or services of third-party service providers to process transactions on our behalf, in which case you acknowledge that the terms of use and privacy policy of said third-party service provider will also apply. For example, Tonara currently enables payments with Stripe (see https://stripe.com/) and, therefore, Stripe’s privacy policy (available at https://stripe.com/us/privacy) also applies to the data collected and processed in such context.
⦁ Sharing Recordings and other Media. The Apps offer a feature that allows users to record their musical performances, which may include voice performances (such recordings, “Recordings”), or to create other content, including text, photos and videos. Users may then access and share the Recordings and other material from within the App to their existing social media accounts or to popular email programs (such as Gmail). If you include Personal Information in such message, the Personal Information will be delivered to the recipient of the email.
⦁ Log Files. We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Services, track users’ movement around the Services, and gather demographic information.
⦁ Cookies and Other Tracking Technologies. Our Services may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Services. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
⦁ Mobile Device Data. We collect limited information from your mobile device in order to provide the App. Such information include your mobile device type, mobile device id, and date and time stamps of App use. In addition, we deploy tracking technologies within the App to help us gather aggregate statistics, but we will not use Personal Information for such purposes.
⦁ Google Analytics. The Site uses a tool called “Google Analytics” to collect information about the use of the Service. Google Analytics collects information such as how often users visit the Service, what pages they visit when they do so, and what other sites they used prior to coming to the Service. We use the information we get from Google Analytics to maintain and improve the Service and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Service is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
⦁ Firebase Analytics. We also use a similar tool called “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via ⦁ identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. In addition, we bring to your attention that:
⦁ Tonara has implemented the following feature: Performance Analytics.
⦁ Tonara does not use cookies or similar tracking technologies.
Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.
⦁ Mixpanel. We collect personally identifiable information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at ⦁ https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers) You may also clear the Mixpanel opt-out cookie.
⦁ AppsFlyer. We use a tool called “AppsFlyer”, a mobile attribution & marketing analytics platform, to understand the use of our Service. AppsFlyer is exposed to the following data: (i) unique identifiers and technical data, such as IP address, User agent, IDFA (Identifier For Advertisers) or Android ID (in Android devices); (ii) technical data regarding your operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. The use of this data allows us to analyze our campaigns and performance, as well as your habits and characteristics. For example, the data AppsFlyer receives includes downloads, impressions, clicks and installations of their mobile applications, mobile device use and data regarding in-app events. AppsFlyer’s terms of use (available at https://www.appsflyer.com/terms-of-use/) and privacy policy (available at https://www.appsflyer.com/privacy-policy/) also apply to the use of AppsFlyer.
⦁ AppSee and other third party technologies. We use Appsee https://www.appsee.com/legal/terms and other third parties to collect and analyze data from our Services.
5. Publicly Available Information. Your Public Profile and any content that you post on, or via, the Services (“User Submissions”) will be publicly available to other users of the Services, and may also be accessed and used by people of the Services. The notices that we provide on the Services are intended to inform you which information will be made publicly available. If you publish your contact information in any User Submissions or as part of your Public Profile, you may receive unsolicited messages from other users of the Services or the public. We, therefore, encourage you only to post information that you are sure you want to be accessible to anyone.
6. The Way We Use Personal Information. If you submit or we collect Personal Information through the Services, then we use such Personal Information in the following ways, via any applicable communication channel, including e-mail, SMS, etc.:
⦁ We use your Personal Information to provide and improve our Services (including via analytics services), to contact you in connection with the Services and certain programs or offerings that you may have registered for, and to identify and authenticate your access to the parts of the Services that you are authorized to access.
⦁ We use your designated email address to: (i) send you updates or news regarding the Services and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your password).
⦁ We transfer your Personal Information to our foreign subsidiaries for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries. We require that these parties agree to process such information in compliance with our Privacy Policy.
⦁ We share your Personal Information with our third party service providers and partners (such as hosting companies or CRM platforms), but only to assist us with our business operations and to provide our Services to you and other users. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that comply with applicable data protection laws or regulations.
⦁ We may disclose your Personal Information or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms and EULA, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Tonara, our users, yourself or the public.
7. Use of Anonymous Information. We use Anonymous Information (as defined below) or disclose it to third party service providers in order to improve our Services and enhance your experience with the Services. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Services.
8. Opting Out. You may choose not to receive future promotional, advertising, or other Services-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Services.
9. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Services but you may be unable to access certain options, programs, offers, and services that involve our interaction with you.
10. Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may use the tools that we make available on the Services or you may submit an access request by sending an email to 10. support@tonara.com. Your email should include adequate details of your request.
11. Links to and Interaction with Third Party Products. The Services may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.
12. Children’s Privacy. The Services are not structured to attract children under the age of 16 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16 years. If we learn that we have collected Personal Information from a child under 16 years, we reserve the right to delete that information as quickly as possible. If you believe that we might have any such information, please contact us at 12. support@tonara.com
13. Security. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Service, you can contact us at 13. support@tonara.com.
14. Merger, Sale or Bankruptcy. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.
15. California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to 15. support@tonara.comPlease note that we are only required to respond to one request per customer each year.
16. Our California Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
17. Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted.  If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.  Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
18. We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Service to meet these demands. If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at 18. support@tonara.com.

Last updated: June 14, 2018