Airbuds Privacy Policy

Effective Date: April 30, 2025 

This Privacy Policy governs how Capps, dba Airbuds (“Airbuds”, “we”, “our”, “us”) collects, stores, and uses your personal data (as defined below), as well as other data and information arising out of and/or relating to you and/or your use of the Airbuds Widget mobile application (the “App”), and any related websites, other technologies, features, content, and other services we offer (collectively, the “Services”). Airbuds is the data controller of your personal data subject to this Privacy Policy. Our contact information is found under Contact Us.

We encourage you to review our Terms of Service to understand how your personal data will be treated as you make full use of our Services.

This Privacy Policy does not apply to third-party websites, applications, products, services, or other properties, even if they may link to our Services or our Services may link to them. We recommend you review the privacy practices of those third parties before connecting with and/or accessing third-party offerings, and before sharing any personal data with those third parties.

If you are a visually impaired individual, an individual with another disability, or seek support in other language, you may access this Privacy Policy by emailing us at privacy@airbuds.fm.

Linkable Table of Contents

It is important that you read and understand the entire Privacy Policy before using our Services. For ease of review, below is a table of contents that links to each section. You can click on the headings to be taken to the full explanation.

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1. Personal Data We May Collect, Use, and Disclose

As used in this Privacy Policy, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal data includes “personal information” as that term is defined in applicable privacy laws.

Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information. “Publicly available information” includes information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience. 

We may create aggregated, de-identified, or anonymous information from data by removing certain data components (such as your name, email address, or linkable tracking identifier) that makes the data identifiable, or through aggregation, obfuscation or other means. Subject to applicable law, our use and disclosure of such aggregated, de-identified, or anonymized information is not personal data or subject to this Privacy Policy.

Please note that because of the overlapping nature of certain of the categories of personal data identified above, which are required by state law, some of the personal data we collect may be reasonably classified under multiple categories.

2. Sources of Personal Data

We may collect personal data about you from the following categories of sources:  

• Directly from you.
• From users of our App, including if a user imports or syncs their address book with the App.
• Through cookies and other tracking technologies, as discussed in more detail in Cookies & Other Tracking Technologies.
• From other third parties, including service providers, business and marketing partners, affiliates, analytics providers, ad network providers, ad agencies, and advertisers.
• From music streaming services, such as Spotify, Apple Music, SoundCloud, Amazon Music, Musi, and Deezer if you connect to your account with those streaming services through the App.
• From social media and other content platforms, such as Google, Meta, Snapchat, and TikTok, if you interact with us on these platforms.

3. Disclosure of Personal Data

We may disclose personal data that we collect to the following:

• Our affiliates. We may disclose personal data among our affiliates to provide our Services and for internal business purposes.
• Our service providers. We disclose personal data with our service providers to provide services on our behalf, such as payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services.
• Your friends and other users on the App. Your friends on the App will be able to see your username, profile picture, music listening activity, and interactions you have with them, including messages you send, reactions to their music listening activity, questions you ask, and responses you provide them. Other users on the App who are not your friends will be able to see your username, profile picture, music listening history, and reactions. If you use our “Your School” feature, which allows you to join a group of fellow students at your school, the other users in your school group will be able to see your username, profile picture, music listening history, and reactions.
• Compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities, and/or in response to a threat of harm involving an individual’s health and/or safety.
• Change of ownership. If we or our subsidiaries are involved in a merger, acquisition, asset sale, or other corporate combination, your personal data may be transferred to the acquiring or surviving entity; provided, your text messaging originator opt-in and consent data and information will not be shared with any third parties under any circumstances.
• Our artist partners. With your consent, we may share personal data with certain artist partners to facilitate requested services and information.

4. Cookies & Other Tracking Technologies
We use cookies and similar tracking technologies and analytics services to track activity on and gauge the effectiveness of our Services. Cookies are files with a small amount of data which may include unique identifier. Cookies are sent to your browser from a website or mobile application and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

a. Examples of cookies we use

• Strictly Necessary. We may use cookies that we consider are strictly necessary to allow you to use and access our websites or App, including cookies required to prevent fraudulent activity, and improve security.
• Performance/Analytics. We may use cookies that are useful to assess the performance of our websites or App, including as part of our analytic practices or otherwise to improve our Services.
• Functionality. We may use cookies that are required to offer you enhanced functionality when accessing our website or App, including identifying you when you sign in to our website or keeping track of your specified preferences, including in terms of the presentation of content on our websites or App.
• Targeting or Advertising. We may use cookies to deliver content, including ads, relevant to your interests on our website and App based on how you interact with advertisements or content. We do not use your information for targeted advertising on third-party platforms.

b. Analytics and Development

We may use third-party service providers to monitor and analyze the use of our Services and to automate the development process of our Services.

For example, we use Amplitude, an analytics service provided by Amplitude Analytics, Inc. We also use Firebase, an analytics service provided by Google Inc. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en

For more information on what type of information Firebase collects, please visit the Google Privacy Terms.

5. Legal Bases for Processing

We rely on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our Terms of Service; (ii) as necessary to pursue our legitimate business interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.

We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests generally include:

• Providing, improving, and developing our Services, including to deliver your requested services, send you messages and provide user support, customize the Services to better fit your needs as a user, develop new products and services, and perform internal analytics and research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
• Protecting you and others and to create and maintain a trusted environment, such as to comply with our legal obligations, to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research and profiling based on your interactions on various Services, content you submit to the Services, and information obtained from third parties.
• Providing, personalizing, measuring, and improving our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing. This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.

6. Data Security

The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal data against unauthorized access, destruction, loss, alteration, disclosure or misuse. We encourage you to secure your account with a strong password and to keep your password private.

7. Data Retention

We will retain your personal only for as long as is necessary to provide you with Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain certain personal data for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable given our legal position, including regard to applicable statutes of limitations, litigation, or regulatory investigations.

8. International Transfers of Data

We may transfer, store, and use information we collect and maintain about you, including personal data outside of your state, province, country or other governmental jurisdiction. For example, if you are located outside United States and choose to provide information to us, please note that we transfer personal data to United States and process it there.

The data protection laws in the jurisdiction in which we process personal data may differ from those of your jurisdiction, and in certain circumstances, your personal data may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions.

9. Children’s Privacy

Our Services have a minimum age limit depending on your state, country, or region. We do not direct our Services or knowingly collect information from individuals whose age:

• is under 13 years
• makes it illegal to process their personal data, or
• requires parental consent to process their personal data

If you become aware that a child has provided us with personal data, we strongly encourage you to Contact Us, and we will do our best to promptly remove such information from our records.

10. Your Privacy Choices & Rights  

You may have certain choices and rights regarding our collection, use, and disclosure of your personal data, based on your location or place of residency.

1. Opting out of promotional electronic communications from us. 

We may use your personal data to send you updates regarding our Services, other announcements, and inquiries. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or Contact Us. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required to provide you with the Services or for other reasons disclosed in this Policy.

2. Opting out of SMS messages.

We will not send you SMS messages for marketing purposes. However, with your consent, we may send you SMS messages for internal business purposes, internal user research, and to provide customer service, including troubleshooting.

3. Stop sharing music listening activity

You can stop sharing your music listening activity with your friends for one hour at a time by activating “Ghost Mode” in the App through your account profile settings. Songs listened to in Ghost Mode won’t count in your weekly recap. Note that we will still collect music listening activity while you are using Ghost Mode. Spotify users can also stop sharing music listening activity by using the private listening option in the Spotify app. More information is found here. We do not collect music listening activity if you use Spotify’s private listening option.

4. Account deletion

You can delete your account on the App under Profile > Settings > Delete Account, and following the instructions. You can email us at hello@airbuds.fm to delete your account. In the email, please provide your Airbuds username and phone number. We will then send you a message to authenticate you and we will remove your account. You can also delete questions posted to your friends within the App.

Please note that we may retain your personal data even after you have deleted your account if reasonably necessary to comply with our legal obligations, resolve disputes, maintain security, detect and prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to "unsubscribe" from further messages from us. We may also retain aggregate, de-identified, or anonymized data about you. Information you have shared with others (e.g., through your chats) will remain visible after you close your account or delete the information from your own chats, and we do not control data that other users of the App have copied out of our Services.

5. Additional rights available in certain states and jurisdictions. 

Certain U.S. jurisdictions provide residents with certain rights with respect to their personal data. These rights are subject to the specific laws of that jurisdiction and that certain other rights might apply. Please review our California Privacy Notice; Nevada Privacy Notice; Privacy Notice for Residents of Other U.S. States; Europe Privacy Notice; Canada Privacy Notice; Australia and New Zealand Privacy Notice; Philippines Privacy Notice; and Brazil Privacy Notice. for more information on rights and terms specific to your location or place of residence.

6. Exercising your privacy rights. 

Please use the following information to exercise your rights. Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable law, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. If you are a visually impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at privacy@airbuds.fm.

We do not charge a fee to process or respond to your verifiable consumer request unless its excessive, repetitive, manifestly unfounded, or in accordance with applicable law.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Depending on applicable law, you may be limited in how many verifiable or authenticated consumer request you make within a twelve (12) month period. If we have inadvertently collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity. Generally, a rights request must include:

• Sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative, which must include, at a minimum, your first and last name and email address.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.

We cannot respond to your request or provide you with personal data if we cannot verify or authenticate your identity or authority to make the request and confirm that the personal data relates to you. We will only use personal data provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s, as applicable) identity or authority to make the request.

You are not required to create an account with us to submit a verifiable or authenticated consumer request. However, we do consider requests made through your account sufficiently verified when the request relates to personal data associated with that specific account. If you have an account with us, we will 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.

To exercise any of the rights applicable to you that are described in this Privacy Policy, please send your request(s) by emailing us at privacy@airbuds.fm or by filling this form.

Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.

11. California Privacy Notice

This California Privacy Notice applies to any California residents about whom we collect personal data. The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act of 2018 and other relevant California laws and regulations.

For the purposes of this California Privacy Notice, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information subject to certain federal and state regulation.

Please note that we are providing the following disclosures and rights regarding personal information in this section in the interest of transparency and our commitment to privacy; such disclosures and rights are not intended to waive any applicable exemptions under the CCPA.  

If you are a visually impaired individual, an individual who has another disability or an individual who seeks support in other language, you may access your privacy rights by emailing us at privacy@airbuds.fm.

1. Personal Information We Collect

We may collect, or have collected, the following categories of personal information:

• Identifiers
• Commercial information
• Internet or other electronic activity information
• Geolocation data
• Audio, electronic, visual, or similar information
• Characteristics of protected classifications under California or federal law
• Inferences drawn from any of the above

Certain of the personal information that we collect may constitute “sensitive personal information” as defined by California law. This may include:

• Precise geolocation

2. How We Use Your Personal Information

We use the personal information we collect about you for the following purposes:  

• Contact you and provide information
• Provide customer service
• Provide and maintain our Services
• Facilitate interactive features
• Internal analytics
• Market our products and Services directly to you
• Internal business purposes, including general business administration
• Audit, compliance, legal, policy, procedure, and regulatory obligations
• Customer claims and fraud investigation and prevention
• Systems and data security
• Protecting the safety of our employees and others
• Any other purpose consistent with your consent and expressed preferences

3. To Whom We Disclose Personal Data

We limit our disclosure of the categories of personal data above to our service providers for one or more business purposes. “Business purposes,” means the reasonably necessary and proportionate use of personal data for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal data was collected.

We do not and have not sold personal data to third parties for any monetary value.  We do gather personal data from consumers via third-party analytics services, which may be considered a “sale” and/or “share” of personal data under California law, even though we do not receive monetary payment for sharing or disclosing personal data to these third parties. In this connection, during last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” or “shared” the following categories of personal data as those terms are defined under the CCPA:

• Identifiers
• Commercial information
• Audio, electronic, visual, or similar information
• Internet or other electronic network activity information
• Characteristics of protected classifications
• Inferences

e. Your California Privacy Rights

If you are a California resident, you the following rights under applicable California law:

• Right to know and access. You have the right to know what personal information we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
• Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal information that we collect about you.
• Right to correct. You have the right to request the correction of inaccurate personal information.
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
• Right to opt out of sale and/or sharing. You have the right to opt-out of the sale and/or sharing of your personal information.
• Right to limit use and disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
• Sharing with third parties for their own direct marketing purposes. We do not disclose personal information to third parties for their own purposes without your consent.  If you wish to request information regarding such practices under California’s “Shine the Light” Law, please Contact Us. You must include your full name, email address, and postal address in your email or mail request so that we can verify your California residence and respond.
  

How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Your Privacy Choices & Rights. We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@airbuds.fm.

f. 3

You have the right to opt-out of the sale and/or sharing of your personal data by a business. As noted above, our disclosure of personal data to third party analytics services could constitute a “sale” and/or “share” of your personal data under the CCPA. You may opt-out by following the instructions in Your Privacy Choices & Rights. You can also opt out of such sale or sharing in the App under your settings.

We do not knowingly sell or share the personal data of children under 16 years of age without legally required affirmative authorization. If you believe that your child has provided us with information, please Contact Us.  

g. Retention of Personal Information

We will retain your personal data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain certain personal data for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable considering our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.

12. Nevada Privacy Notice

Although we do not “sell” personal data as defined by Nevada Law, Nevada residents nonetheless have the right to request to opt out of any future “sale” of their personal data under Nevada SB 220 and SB 370. If you are a Nevada resident and would like to make such a request, please follow the instructions in Your Privacy Choices & Rights. You must include your full name, email address, and postal address in your email or mail request so that we can verify your Nevada residence and respond. In the event we sell your personal data after the receipt of your request, we will make reasonable efforts to comply with such request.

13. Privacy Notice for Residents of Other States

This Privacy Notice contains additional information for residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia about personal data that we collect, how we use it, what sources it is derived from, and who we disclose it to, and provides information regarding your rights, and our responsibilities, under applicable laws and regulations. For the purposes of this section, “personal data” means information that is linked or reasonably linkable to an identified or identifiable individual. Personal data does not include de-identified data or publicly available information. This section does not apply to certain personal data that is already subject to certain federal and state regulations, such as protected health information.  

The provisions contained within this section are intended to provide notices in compliance with the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Iowa Consumer Data Protection Act, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Privacy Act, the New Jersey Privacy Act, the Oregon Consumer Data Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “State Privacy Laws”).

The State Privacy Laws provide or will provide rights to residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia respectively, to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data.

a. Our Personal Data Practices

The State Privacy Laws provide rights to residents of those states, to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data. Detail about what kinds of personal data we may collect or have collected, how we collect it, why we collect it, and who we may disclose it to is found in Personal Data We May Collect, Use, and Disclose; Sources of Personal Data; and Disclosure of Personal Data.  

As noted above, our disclosure of personal data to third party analytics services could constitute a “sale” and/or “share” of your personal data.

b. Your Privacy Rights

If you are a resident Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia, you have or will have the following rights under applicable law in relation to your personal data, subject to certain exceptions:

• Right to know and access. You have the right to know what personal data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
• Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.
• Right to correct inaccurate personal data. You have the right to request the correction of inaccurate personal data.
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
• Right to opt out. You have the right to opt-out of targeted advertising, the sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.
• Rights concerning sensitive personal data. If you are a Connecticut, Colorado, Delaware, Maryland, Minnesota, Montana, Nebraska, New Jersey, Oregon, Tennessee, Texas, or Virginia resident, we cannot and will not process your sensitive data (as defined by applicable law) or your sensitive data inferences, or use your personal data for certain purposes without your affirmative consent. If you are an Iowa or Utah resident, you have the right to opt out of having your sensitive personal data processed and/or used.

How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Your Privacy Choices & Rights. You can also opt out of such sale or sharing in the App under your settings.

How to appeal decisions about your rights. Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, and Virginia residents can appeal our decisions concerning privacy rights requests, as follows:

• Colorado residents. If you are a Colorado resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Colorado’s Office of the Attorney General by phone at (720) 508-6000 or by submitting a form here. 

• Connecticut residents. If you are a Connecticut resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Connecticut’s Office of the Attorney General by phone at (860) 808-5420 or by submitting a form here.  
• Delaware residents. If you are a Delaware resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Delaware’s Department of Justice by phone at (302) 683-8800 or by submitting a form here.  
• Iowa residents. If you are an Iowa resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Iowa’s Office of the Attorney General by phone at (888) 777-4590 or by submitting a form here. 
• Maryland residents. If you are a Maryland resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Maryland’s Office of the Attorney General by phone at (888) 743-0023 or by submitting a form here. 
• Minnesota residents. If you are a Minnesota resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Minnesota’s Office of the Attorney General by phone at (800) 657-3787 or by submitting a form here. 
• Montana residents. If you are a Montana resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Montana’s Office of the Attorney General by phone at (406) 444-4500 or by submitting a form here.  
• Nebraska residents. If you are a Nebraska resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Nebraska’s Office of the Attorney General by phone at (402) 471-2683 or by submitting a form here.  
• New Hampshire residents. If you are a New Hampshire resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact New Hampshire’s Office of the Attorney General by phone at (603) 271-3658 or by submitting a form here. 
• New Jersey residents. If you are a New Jersey resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact New Jersey’s Office of the Attorney General by phone at (800) 242-5846 or by submitting a form here.  
• Oregon residents. If you are an Oregon resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision.  If the appeal is denied, you may contact Oregon’s Office of the Attorney General by phone at (877) 877-9392 or by submitting a form here.  
• Texas residents. If you are a Texas resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision.  If the appeal is denied, you may contact Texas’s Office of the Attorney General by phone at (800) 621-0508 or by submitting a form here. 
• Virginia residents. If you are a Virginia resident and want to appeal our decision with regard to a request that you have previously made, please Contact Us or notify the Office of the Attorney General of Virginia online here. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Virginia’s Office of the Attorney General by phone at (804) 786-2071, written correspondence to 202 North 9th Street, Richmond, Virginia 23219, or online here.

14. Europe Privacy Notice

This Notice applies to any individuals located within the European Economic Area (“EEA”), the United Kingdom (“UK”), and Switzerland about whom we may have collected personal data from any source, including through your use of the Services. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, Switzerland’s Federal Act on Data Protection, and related laws, regulations, and guidance from the European Union and/or its member states (collectively, “European Privacy Laws”).

In certain circumstances, individuals located within the EEA, UK, and Switzerland are entitled to the following privacy rights:

• Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to Erasure. You have the right to request that we erase your personal data in certain circumstances provided by law.
• Right to Rectification. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
• Right to Object to Processing. You have the right to object to our processing of your personal data.
• Right to Restrict Processing. You have the right to request that we restrict the processing of your personal data.
• Right to Data Portability. You have the right to request that we provide you with a copy of your personal data in a structured, machine-readable and commonly used format.
• Right to Withdraw Consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal data.
• Right to Lodge Complaint. You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA). You can view the contact information for your data protection authority here.

To exercise your privacy rights described above, please follow the instructions in Your Privacy Choices & Rights. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

15. Canada Privacy Notice

This Notice applies to individuals in Canada about whom we may have collected personal data. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and/or provincial privacy laws.

For the purposes of this Notice, "personal data" means information about an identifiable individual. Personal data does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work email address. Personal data also does not include information that has been de-identified, anonymized, or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other available information.

• Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to Correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
• Right to Withdraw Consent. If you have already consented to the collection, use, and/or disclosure of your personal data, you may subsequently withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

To exercise your privacy rights described above, please follow the instructions in Your Privacy Choices & Rights. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

If you have any questions or concerns about our privacy practices, please Contact Us. You may also contact the Office of the Privacy Commissioner at (800) 282-1376 if you are unsatisfied with our response to your privacy concern.

16. Australia and New Zealand Privacy Notice

This Notice applies to any individuals located within Australia and New Zealand about whom we may have collected personal data. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Australia Privacy Act 1988 and the New Zealand Privacy Act 2020.    

In certain circumstances, individuals located within Australia and New Zealand are entitled to the following privacy rights, subject to certain exceptions:

• Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to Correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.

To exercise your privacy rights, please follow the instructions in Your Privacy Choices & Rights. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

17. Philippines Privacy Notice

This Notice applies to any residents and citizens of the Philippines about whom we may have collected personal data. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Philippines Data Privacy Act 2012, Republic Act. No. 10173.

In certain circumstances, individuals in the Philippines are entitled to the following privacy rights, subject to certain exceptions:

• Right to Access. You have the right to access, review and request a physical or electronic copy of personal data held about you. You also have the right to request information on the source of your personal data

• Right to Correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
• Right to Suspend, Withdraw, or Delete. You have the right to suspend, withdraw, or order the blocking, removal or destruction of your personal data from our database if your personal data is: incomplete, outdated, false, or unlawfully obtained; being used for purposes not authorized by you; subject to unlawful data processing; or if your rights have been violated.
• Right to Object. You have the right to object to processing of your personal data, including processing for direct marketing, automated processing, or profiling.
• Right to Withdraw Consent. Where we rely on consent to process your personal data, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.
• Right to File Complaint. You have the right to file a complaint about the processing of your personal data. If we do not satisfactorily deal with your complaint, then you may contact and raise your privacy concerns to the National Privacy Commission through the website www.privacy.gov.ph.

To exercise your privacy rights, please follow the instructions in Your Privacy Choices & Rights. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

18. Brazil Privacy Notice

This Notice applies to any Brazilian residents about whom we may have collected personal data. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Brazilian General Data Protection Law (“LGPD”)

In certain circumstances, individuals located in Brazil are entitled to the following privacy rights, subject to certain exceptions:

• Right of Confirmation and Access. You have the right to obtain confirmation as to whether your personal data is being processed, as well as access to the personal data along with certain information, including the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data have been or will be disclosed. 
• Right to Rectification. You have the right to rectify your inaccurate personal data and to complete any incomplete personal data.  
• Right to Erasure. You have the right to request that we erase your personal data if we originally requested your consent to process the personal data and you wish to withdraw it.
• Right to Anonymization, Blocking, or Deletion. You have the right to anonymization, blocking, or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD. 
• Right to Object. You have the right to object to our processing of your personal data carried out based on one of the situations of waiver of consent, if there is noncompliance with the provisions of the LGPD. 
• Right to Data Portability. Under certain circumstances, you have the right to transmit your personal data to other service providers or product providers. 
• Right to Withdraw Consent. If you have provided us with your consent for the processing of your personal data, you may withdraw your consent at any time to stop any further processing.  
• Right to Petition. You have a right to petition with Brazilian Data Protection Authority if you believe that our processing of your personal data violates the LGPD.

To exercise your privacy rights, please follow the instructions in Your Privacy Choices & Rights. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

19. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the “Effective Date” at the top of this Privacy Policy. We recommend reviewing this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

20. Contact Us

If you have any questions about this Privacy Policy, please email us at privacy@airbuds.fm.

Individuals in Europe, New Zealand, and Brazil can also contact our Data Protection Officer at dpo@airbuds.fm