Jymo Privacy Policy

Welcome to Jymo, a service provided by [Beijing Dui Niu Tan Qin Technology Co., Ltd. (北京对牛弹琴科技有限公司)] ( “we”, “our” or “us”). Capitalized terms used in this Privacy Policy that are not specifically defined shall have the meanings given to the applicable capitalized terms in the Jymo Terms of Use.

Your privacy is important to us. This Privacy Policy explains how we collect, store, use, disclose and otherwise process your personal data when you use Jymo Service. This Privacy Policy applies to any Apps or Services by Jymo that refers to this Privacy Policy.

This Privacy Policy explains the following, amongst other things:

· Who Controls Your Data

· Legal Basis for Data Processing

· Personal Data We Collect

· Personal Data You Provide

· Personal Data We Collect Automatically

· Personal Data We Obtain From Third Parties

· How We Use Your Personal Data

· How We Share Your Personal Data

· Cookies and Similar Technology

· Information Security

· International Data Transfers

· Children

· Our Activity On Social Networks

· Your Choices and Controls

· Exercising Your EU/EEA/U.K. Privacy Rights

· Additional Disclosure for Users Who are Residents of Certain U.S. States

· Contact Information

· Changes to this Privacy Policy

Information relating to our use of cookies and similar technologies is set out in our Privacy Policy.

Please take some time to read this Privacy Policy, along with our terms of use, in order to ensure you understand and are comfortable with our use and disclosure of your personal data and to understand the choices available to you.

Please note that this Privacy Policy only applies to Jymo Apps and Services (together, the “Platform”). When using the Platform, you may find links to other websites, apps and services, or tools that enable you to share information with other websites, apps and services. Jymo is not responsible for the privacy practices of these other websites, apps and services and we recommend that you review the privacy policies of each of these websites, apps or services before connecting your Jymo account or sharing any personal data.

IF YOU DO NOT AGREE TO ANY OF THE PROVISIONS OF THIS PRIVACY POLICY, YOU SHOULD NOT USE THE PLATFORM. If you have any questions or concerns about this Privacy Policy, you can contact us at [support@Jymo.fun].

This Privacy Policy is to give you information about what personal data we collect about you, why we collect it, and how we use and share it.

Who Controls Your Data

With regard to data processing within the framework of Jymo’s internal administration and joint procedures through centralized systems, we act as controller. The processes particularly pertain to the operation and use of joint databases, platforms and IT systems. With respect to the processes, we determine the purposes and means of processing, how the respective tasks and responsibilities of the processing of personal data are structured and who fulfils which data protection obligations. In particular, it is determined how an appropriate level of security and how your rights as a data subject can be ensured, how the information duties under data protection law can be jointly fulfilled and how potential data protection incidents can be monitored. This includes reporting and notification obligations.

We may share your data within our corporate group of companies that are related by common ownership or control (“Jymo Group”) .

For Users in the EU/EEA/U.K.: Legal Basis for Data Processing

The collection and processing of your data is governed by the law applicable to your respective Data Controller, as outlined above.
With that being said, Jymo follows European law and the GDPR where applicable. Data collection and processing under GDPR may be based on your consent, contractual purposes or, in exceptional cases, for legitimate purposes, which we weigh against your data protection interests. We have specified the legal bases for individual data processing activities in more detail below.
We may also use our user’s personal data under GDPR if:

· Processing is necessary to fulfil a legal obligation to which the person responsible is subject;

· Processing is necessary to protect the vital interests of the data subject or another natural person; or

· Processing is necessary for the performance of a task that is in the public interest or takes place in the exercise of official authority that has been assigned to the person responsible.

For Users in Mainland China

Data collection and processing comply with the Personal Information Protection Law of the People’s Republic of China, Cybersecurity Law, Data Security Law, and other relevant regulations.

Data is stored within servers located in Mainland China. Cross-border data transfers require explicit user consent and approval from the Cyberspace Administration of China.

For Users in Hong Kong, Macao, and Taiwan

Hong Kong Users: Comply with Hong Kong’s Personal Data (Privacy) Ordinance. Users may file complaints with the Office of the Privacy Commissioner for Personal Data, Hong Kong.

Macao Users: Follow Macao’s Personal Data Protection Law. Data is stored locally by default (cross-border transfers require explicit consent).

Taiwan Region Users: Data collection purposes, scope, and cross-border transfer restrictions comply with Taiwan’s Personal Data Protection Act.

Personal Data We Collect

Any personal data we collect falls into one of three general categories:

· Personal data you provide to us,

· Personal data we collect automatically,

· Personal data we obtain from third parties.

Personal Data You Provide

We ask for and collect the below personal data when you use the Platform. This personal data is necessary for the adequate performance of the platform, to meet the requirements of the contract present between you and us and to comply with our obligations thereunder.

You don’t need to register for a Jymo account in order to visit or use our Platform. However, certain Services require that you register for an account and, by doing so, you will need to provide us with certain personal data:

· Account Information - When you register with any kind of Jymo account, and from time to time thereafter, you will need to provide your email address (except when you sign-up with Google or Apple and don’t give your permission to share it with Jymo), your age or birthdate, postal code, a username (which may be your real name or a pseudonym) and a password.

· Profile Information - you may choose, at your discretion, to provide additional personal data for your public profile on Jymo – for example:

· your real name

· your gender

· the city and country in which you live

· a profile picture, profile header image or avatar

· any content associated with your uploads (all audio (including podcasts), text, pictures, graphics, comments, and other content, data or information that you upload (“Materials”).

· details of your other websites and social media profiles, including links to those pages

· any personally identifiable data from your profile page in accordance with our Terms of Use. This personal data will be publicly accessible and may be viewed by anyone and using our API or other Services. Please be aware that a profile picture is mandatory when you request profile verification via your Settings in the “Account” tab.

· Paid Subscriptions - If you purchase a Paid Subscription, you must provide your real name, billing address, payment verification information, and, if applicable, school affiliation. Please be aware that we only get payment verification information and no further details of your payment, as outlined in the respective section of this Privacy Policy. Any use of such personal data is for contractual purposes.

· Intelligent Health Music Recommendation Feature - We provide intelligent music recommendation services based on health data by analyzing your exercise status, physiological indicators, and music listening behavior to deliver personalized exercise music recommendations and health music analysis reports. We may collect your account information, device sensor data (accelerometer, gyroscope, etc.), and health data from authorized third-party health platforms (Apple Health, Google Fit, Huawei Health, etc.), including exercise step counts, heart rate, and other physiological indicators (which may contain sensitive personal information), and obtain corresponding device and health data access permissions.Please note that this feature is for entertainment and reference purposes only. It has no medical functionality and cannot replace professional medical advice or be used for medical diagnosis.To use this feature, you must enable it separately and provide explicit authorization. You may disable the feature or withdraw authorization at any time. When sharing content involving others' health information, you must obtain their consent beforehand.

· Communications - When you communicate with Jymo by email or through the Platform, or use the Platform to communicate with other users, we collect personal data about your communication and any personal data you choose to provide based on contractual purposes.

· Survey Information - If you participate in any survey, you may provide certain personal data as part of your response, unless you respond anonymously. The personal data you provided is only processed based on your consent.

· Information You Post - You may provide personal data when you post comments, when you like or repost a track, or when you contribute to community discussions. This is based on your own choice, and in accordance with our Terms of Use, we may use such data for contractual purposes.

· Identity Verification Information - We may collect personal data sufficient to verify your identity for the purpose of your participation in the Jymo.

· Information Provided For Tax or Financial Reasons

· Tax ID/VAT - We also collect your tax ID or VAT number if applicable.

· Other Tax Payee Information and W9 Certifications (US Only) - If you are located in the U.S., we will collect certain personal data and certifications from you, which enables us to report eligible payouts to the Internal Revenue Service.

Personal Data We Collect Automatically

There is certain personal data that we collect automatically as the result of your use of the Platform, subject to the choices you make in your settings, or through the use of cookies and other web analytics services. This personal data generally includes:

· Usage Information - We collect personal data about your interactions with the Platform, including the pages that you visit and links you click on, streaming, offline listening or downloading Tracks, uploading or recording Tracks, connecting your Facebook, Google or Apple account, sharing a Track with another user, following or unfollowing another user, posting a comment, performing a search, the time, frequency and duration of your visits to the Platform, and whether you interact with email messages, for example, if you opened, clicked on, or forwarded the email message. This use of your personal data is based on contractual purposes should you have accepted our Terms of Use. If you have not registered on Jymo, the use of this personal data is based on our legitimate interest. Please be aware that we need such usage data as we are under contractual obligation to track use of content by our content providers.

· Log Data – We automatically collect log information when you use the Platform, even if you have not registered for an account or logged in. That personal data includes, among other things: details about how you’ve used the Platform (including links to third party sites or services), Internet Protocol (IP) address, access times, your browser type and operating system, device information, device event information (e.g., crashes, browser type), and the page you’ve viewed or engaged with before or after using the Platform. This personal data is essential for our service and is therefore either based on contractual purposes or on legitimate interest if no contract exists. Please be aware that we need log data as we are under contractual obligation to track use of content by our content providers.

· Cookies – We use cookies and other similar technologies, such as pixels, local storage, and mobile device identifiers and may also allow our business partners to use these tracking technologies on the Platform, or engage others to track your behavior on our behalf. Type, number and function of cookies can vary depending on your individual selection. For more information on our use of these technologies.

· Location Data – When you use certain features of the Platform, we may collect personal data about your general location. We use such personal data to deliver personalized location-based services or content. In some instances, you may be permitted to allow or deny such use of your device’s location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized services or content. We use this personal data to provide you with location-based services (such as advertising and personalized content). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings. Such use of personal data is based on your consent, either within our Platform or within your device where you provided your consent when prompted.

· Device Information – We collect personal data from and about the devices you use, including how you interact with the Platform and information about the device itself, such as the hardware model, operating system, IP addresses, cookie information, device settings, mobile carrier information, mobile device and advertising identifiers, apps installed, browser type, language, battery level and time zone. This information allows us to recognize and associate your activity, and provide personalized content and advertising, consistently across all of your devices. Such use of personal data is based on your consent given either within our Platform or within your device.

· Software Development Kits (“SDK”) - We may use third parties including our business partners and service providers who use mobile SDKs to collect personal data and information related to how mobile devices interact with the Platform. An SDK is computer code that app developers can include in their apps to enable ads to be shown, personal data to be collected and related services and functionality to be implemented. We may use this technology, for instance, to analyze how you interact with Materials and advertisements and to enable analytics or other features through mobile devices. However, such use will be based on your consent.

· Jymo Widget - Other websites may integrate Jymo widgets; when you visit a website with a Jymo widget embedded, we may receive certain personal data, including personal data about the website you visited. Jymo and the widget may be able to recognize you in order to retrieve your library of content, and in some cases the widget may be used to show personalized content. We know when you interact with a widget, and websites containing the widgets may receive this information as well. Such use is subject to the privacy policy of the third party website or app that has integrated a Jymo widget.

Personal Data We Obtain From Third Parties

· Single-Sign Ons – If you sign up for Jymo through a third party application such as Google or Apple, you authorize us to collect your authentication information, such as your username and encrypted access credentials, and other personal data available through the third party application account, including the following personal data:

· Google – You can sign up and log in to Jymo using your Google account. When you sign up using Google, Google will ask your permission to share certain information from your Google account with Jymo. This includes your Google email address, birthdate (optional), gender (optional), and avatar (optional). This information is collected by Google and is provided to us under the terms of Google’s privacy policy. You can regulate the information that we receive from Google using your Google activity controls. If you signed up using Google by mistake, you can delete your account from the Account page within your Settings at any time, or you can contact us.

· Apple - You may also sign up and log in to Jymo using your Apple ID. When you sign up using your Apple ID, Apple will ask your permission to share certain information from your Apple account with Jymo. This includes your Apple email address, birthdate (optional), gender (optional), and avatar (optional). This information is collected by Apple and is provided to us under the terms of Apple’s privacy policy. You can regulate the information that we receive from Apple using your Apple ID settings. If you signed up using Apple by mistake, you can delete your account from the Account page within your Settings at any time, or you can contact us.

· Service Providers and Business Partners – We may also receive personal data about you from our service providers and business partners, including companies that assist with payment processing, analytics, advertising, marketing, data processing and management (e.g. to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you, including for Jymo products), account management, hosting, customer and technical support, content moderation, and other services which we use to personalize your Jymo experience. We explain in more detail why and how we use this personal data below.

· Android Advertising IDs - We collect your Google Android’s Advertising ID (“AAID”). You can reset these numbers through the settings of your device’s operating system (we do not control this). Such identifiers will only be used for advertising and further analysis subject to your consent, where required by applicable law.

· Apple IDs - We collect your Apple Identifier for Advertising (“IDFA”). You can reset these numbers through the settings of your device’s operating system (we do not control this). Such identifiers will only be used for advertising and further analysis subject to your consent, where required by applicable law and in accordance with Apple’s settings.

· Cross App Tracking on Apple Devices - Starting with iOS 14.5, iPadOS 14.5, and tvOS 14.5, we will need to receive your permission through the App Tracking Transparency framework to access and track you through your device’s advertising identifier (see above “IDFA”). Tracking refers to the act of linking user or device data collected from our app with user or device data collected from other companies’ apps, websites, or offline properties for targeted advertising or advertising measurement purposes. Tracking also refers to sharing user or device data with data brokers. The use of such tracking is subject to your consent and therefore may only be exercised by us with such consent. Apple allows the ID for Vendors (IDFV) to be used for analytics across apps from the same content provider (us). The IDFV may not be combined with other data to track a user across apps and websites owned by other companies unless we have been granted permission to track by you. For further information please refer to the documentation that Apple provides.

· Payment Verification Information - We will get a verification including information on the respective payment method and your name as well as other non-personally identifiable payment information (for example the expiry date of a credit card) as well as information hashed by the respective payment provider (for example a hashed credit card number).

· Payment Processing In the Apple App and Google Play Store - Payment processing services within the relevant Apps and App Stores enable Jymo to process payments. Jymo does not process or store credit card details, and uses only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Even though we do not access raw unencrypted card details of a card holder, some of these services may also enable the sending of timed messages to you, such as emails containing invoices or notifications concerning your payment.

· External Payment Providers - The payment provider you use for your payment is solely responsible for the payment. Please refer to the terms of service and privacy policy of your payment provider for further information.

How We Use Your Personal Data

We use the personal data we collect from you for a range of different business purposes according to different legal bases of processing and subject to the choices you make in your settings. We do this with the help of automated systems and decision making. Please be aware that when we refer to automated decision making, we will not use any profiling that produces legal effects concerning you or, similarly, significantly affects you. Automated decisions are concerned with content that may be more relevant for you than other content. We use your personal data to:

· Provide, Improve, and Develop the Platform - We process your personal data primarily for the adequate performance of our contract with you (e.g. Terms of Use). We may also process your personal data in light of our legitimate interest in improving the Platform and giving our users the best experience. We do this to:

· Operate and maintain your Jymo account, and to provide you with access to and use of the Platform. Your email address and password are used to identify you when you log into the Platform. Your device-IDs are used to help ensure that you are in control of the devices that have access to your Paid Subscription.

· Conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new features, and conduct audits and troubleshooting activities.

· If purchasing a Paid Subscription, to process your account subscription and renewals, to collect your payment with the use of payment verification information, and, if applicable, to verify your eligibility for discounts and promotions.

· Send you service updates and notifications about your account and other information we think may interest you, though you may opt out from our promotional communications at any time.

· Respond to you about any comment or enquiry you have submitted.

· Maintain a Safe and Secure Environment - We also process your personal data in light of our legitimate interest in improving the security of the Platform (including the security of your personal data) in order to give our users the best experience, and where it is necessary for the adequate performance of our contract with you (e.g. Terms of Use) or to comply with our legal obligations. This includes:

· The detection and prevention of fraud, spam, abuse, security incidents, and other suspicious activity.

· The verification and authentication of your identity to prevent unauthorized or illegal activity.

· The enhancement of the safety and security of our products and services.

· The conducting of security investigations and risk assessments.

· The prevention or action against activities that are, or may be, in breach of our Terms of Use or applicable law.

· The ability to provide you with customer and technical support.

· Personalized Content – We process your personal data in this case based on our performance of a contract and our legitimate interests. This includes:

· To improve your experience on the Platform by providing personalized content, recommendations, and features.

· To customize the content and measure performance of any email, push notification, or in-app message we may send to you.

· Advertising and Marketing - We may process the minimum personal data, especially your IP-address and other identifiers, necessary to provide non-personalized ads. These ads will only be based on the context on where the ads are shown or triggered. Such processing of your personal data is based on our legitimate interests. Where required by applicable law, we process your personal data in this case based on your consent. You can revisit your choices in your settings or in our cookie consent tool. This includes:

· To deliver targeted marketing for Jymo products on and off the Platform and measure the success of those campaigns. When seeing our ads on third party websites or apps, we or third party services we engage with for this purpose may collect personal data. This personal data includes the information that your browser or mobile app makes available when seeing the ad (e.g IP address, referral URL, browser details, timestamp of request). We use this information to understand, for example, if a click on our ad converted to an actual purchase of a subscription.

· To help us select which ads to show you on behalf of advertisers, as ads are more effective when they are shown to people who are likely to be interested in the product or service advertised. This includes personal data you choose to provide to us (e.g. age and gender) and make available to us when you interact with the Platform (e.g. by listening, liking or creating playlists), as well as device information and general location data. We may also display ads based on the page you’re on or Materials you have recently viewed, searched, or listened to. This allows us to show you ads that will likely be more relevant and interesting to you.

· To collect certain personal data such as cookie data and device information, if we engage with third party services such as ad-networks and exchanges that enable us to show you targeted ads. That personal data is used to sync or match users to segments and serve targeted advertising, based on device activity, inferred interests, and general location information.

· To combine personal data that we collect about you with personal data from business partners and use it to serve more relevant advertising.

· Combine information we collect about you with information from business partners and use it to serve more relevant advertising.

· Marketing Communications - Based on your consent, Jymo may send you email and push communications about Jymo’s and its affiliates’ offers and promotions. From time to time, these communications will be tailored based on your use of Jymo. Jymo may also send you tips, news, and recommendations about Jymo and our own similar services. You can withdraw your consent to receive these communications at any time in your Settings.

· Market Research Studies - Based on our legitimate interest, from time to time we will ask you to participate in market research studies and surveys or to do research studies based on anonymized and/or pseudonymized data. There is no obligation to participate in our studies. In the case that you do participate, it will be based on the consent you provide when answering the survey. We deem that the use of anonymized and/or pseudonymized data is covered by our legitimate interest as we will only use such analysis to further improve our research and Platform for the benefit of understanding your needs and enhancing your experience. We will only use the data you provide when answering the market study for other reasons, such as customized product recommendations or notifications based on your consent which you provide ahead of your participation in the market study.

How We Share Your Personal Data

This section describes how the personal data collected or generated through your use of the Platform may be shared by you or by us.

· Through Your Profile – Any personal data in your public profile (other than your email address) will be accessible by other users of the Platform, who may view your profile information, add themselves to your list of followers, and send you messages. Similarly, if you publish comments on the Platform, your comments will be available to all users of the Platform together with your profile name and picture.

· Service Providers – We use a variety of service providers, some of whom may be located outside of the European Economic Area (“EEA”), to provide services to us or to our users on our behalf. These service providers have access to your personal data solely to perform these tasks on our behalf, and are contractually bound to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us. We need to share your personal data in order to ensure the adequate performance of our contract with you. For instance, we work closely with service providers in the area of customer servic, with technical service providers or music service providers and payment service providers. These service providers may generally only process your personal data on our behalf under special conditions.

· Advertising on the Platform – We share the personal data collected about you in hashed, aggregated, or de-identified forms with advertisers and business partners in order to serve ads on our Platform that we think will interest you and to measure the reach and effectiveness of those ads, including whether you took an action (e.g. purchased a product). We may also share cookie data and device identifiers with our partners for data matching purposes, in order to improve ad targeting. If you live in the EU/EEA/U.K., You can find a detailed overview of our advertisers. Please be aware that where such personal data of yours is identifiable, we will only use it with your consent. For users outside of the EU/EEA/U.K., you can turn off our use of third-party data to inform the ads you see on Jymo by adjusting your settings.

· Ads about Jymo – Where permissible under applicable law we may share your email address (in hashed form, so that it does not identify you personally) with advertising partners, including social networks, in order to target you with ads for Jymo products on third party websites and applications. We also allow advertising partners, including social networks, to collect personal data through cookies and similar technologies like pixels in order to serve ads for Jymo on those third party websites and apps and drive users to our Platform. In order to measure the effectiveness of and optimize these marketing campaigns, these technologies track activity taken across devices after a user sees a Jymo ad, in order to determine performance metrics like sign ups, visits to the Platform, and purchases. For users within the EU/EEA/U.K., we only engage in these activities with your explicit consent. For users outside of the EU/EEA/U.K., you may opt out of these disclosures by adjusting your settings in the Cookie Manager.

· Aggregated Data – We may also share aggregated and anonymized personal data (personal data about our users that we render in such a way that it no longer identifies or references an individual user) and other pseudonymized personal data for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

· API Integrations – Jymo has an open application-programming interface (API), which enables application developers to integrate elements of the Platform into other apps. Some of these developers may be located outside of the EEA but will always, if user data is concerned, sign a Data Processing Addendum and accordingly (where applicable) EU-US Standard Contract Clauses. Any personal data you choose to make public on the Platform, including your public profile information and any public Tracks, may be accessible to these developers, subject to our API Terms of Use. Please bear this in mind when deciding what information to publish on your profile. For information on how to limit the information that is available through the API, please see the Your Choices and Controls section below.

· Third Party Applications – If you choose to connect your Jymo account to other apps or social networks, you may be sharing certain personal data with these apps or networks. Materials that you share with social media networks will appear on your timeline (or similar functions) as well as in news feeds that may be viewed by the public or by certain followers, subject to the terms and conditions of such social media networks. In the case of connected apps, you will need to provide the app developer with full access to your Jymo account. Jymo is not responsible for these other apps or networks, so please make sure you only connect your account with apps or services that you trust. For information on how to control the personal data that you share, and how to disconnect your account from these apps, please see the Your Choices and Controls section below. If you do not want this information shared with such social media networks or other Third Party Applications, please change your Jymo Settings on our Platform or in those networks.

· Use of Your Name and Other User Identifiers in Sharing Links - When sharing personal data from our platform on other platforms, we may use your pseudonymized data. If a user clicks on your shared link and is led to our platform, the user will be presented with a banner telling the user that you (in this context, your profile name will be displayed) are using Jymo and/or that you shared this link, and the user will then be asked if they want to follow you. Such use by us is considered a legitimate interest as it enriches our user experience and the way our users connect with each other. As we assume that you share links responsibly with people whom you want to interact with, we also assume that your interest in the safekeeping of your personal data is not affected, especially since we only use pseudonymized data within the link itself. Please be aware that your shared link may be shared further by other parties.

· Compliance with Laws – We may disclose your personal data to courts, law enforcement agencies, and governmental authorities (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Jymo, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Use and other agreements with users, or (v) to protect the rights, property or personal safety of Jymo, its employees, and members of the public.

· Protecting our Rights – We may disclose your personal data if we feel it is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors, officers, or shareholders, and/or to ensure the safety and security of the Platform and/or the Jymo community.

· Change of Control – We may also share your personal data as part of a sale, merger or change in control of Jymo, or in preparation for any of these events. Any other entity that buys us or part of our business will have the right to continue to use your personal data, but only in the manner set out in this Privacy Policy.

Cookies and Similar Technology

As further described in our Privacy Policy we use cookies and similar technologies (e.g. pixels, local storage, and device identifiers) to recognize you and/or your device(s) on and off the Platform, and across devices. To the extent allowed by your settings or your device and in accordance with your choices, we also allow third parties to use cookies as described in our Privacy Policy in order to track user behavior on and off the Platform in order to show you ads based on your interests and preferences. You can control cookies through your browser and other tools as described in the Privacy Policy.

For users in the EU/EEA/U.K., please be aware any use of cookies is subject to your consent, except for technical storage or access for transmitting communication, or as strictly necessary to provide a service which was explicitly requested by a user. You will find information regarding the use of cookies from specific third parties when making the choice of cookies you want to allow within our cookie consent tool. Further information is provided in your account settings under “advertising”, where you may as well toggle your choices after your first decision.

International Data Transfers

Jymo operates globally and may share your personal data internally within the Jymo Group and third parties for the purposes described in this Privacy Policy. Personal data collected within the EEA may, for example, be transferred to countries outside of the EEA for the purposes as described in this Privacy Policy. We utilize appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, or another legally approved mechanism, to ensure the lawful transfer of your personal data outside of the EEA. The Standard Contractual Clauses can be accessed at any time. Alternatively, you can request these documents from us using the contact details given below.

Children

Jymo is not intended for use by children whose age:

· is under the age of 13 years;

· makes it illegal to process their personal data; or

· requires parental consent to process their personal data.

We do not knowingly collect or use any personal data from any children under the applicable age limit. If you're under the applicable age limit, do not use our Service, and do not provide any personal data to us. If it comes to our attention that we have collected or used personal data from a person under the applicable age limit, we will take reasonable steps to delete such personal data as quickly as possible. This may require us to delete the Jymo account for that child. If you have reason to believe that we may have collected any such personal data, please notify us immediately.

Our Activity On Social Networks

To allow us to communicate with you on third party social networks and inform you about our services, we run pages on third party social networks. If you visit our pages on any of these third party social media pages, we and the provider of the third party social media network are joint controllers regarding the processing operations thereby triggered, which concern personal data. We are not the original provider of these pages, but only use them within the scope of the options offered to us by the respective providers.

For our EU/EEA/U.K. based users, we would like to point out that your personal data may also be processed outside of the EU, EEA, or the U.K. Use of these networks may therefore involve data protection risks for you since the protection of your rights may be difficult, e.g. your right to information, erasure, objection, etc. Processing on social networks frequently takes place directly for advertising purposes or for the analysis of user behavior by network providers, and we have no control over this. If the provider creates user profiles, cookies are often used or user behavior may be assigned directly to your own member profile on the respective social network (if you are logged in).

The processing operations of personal data described are carried out on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you get asked to grant your consent to the respective providers to process your personal data as a user, your consent is the legal basis for this processing.

Since we have no access to these providers’ databases, we would like to point out that you would be best situated to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider.

Your Choices and Controls

We work to give you meaningful choices regarding the amount of personal data you provide to us, and the control you have over that personal data.

· Managing Jymo Settings - If you register an account, you may manage the content and personal data you share when you use Jymo through your account settings, including for the features explained below. You are solely responsible for keeping your settings up-to-date.

· Email & Device Notifications – You can adjust your Settings in the “Notification” tab to disable email and device notifications (other than important service updates and essential notifications about the Platform or your account). All commercial emails and newsletters also allow you to unsubscribe at any time.

· Analytics – To control whether we collect analytics and usage information, including through cookies and similar technologies, you can adjust your Settings in the “Privacy” tab (“Cookie Manager”).

· Marketing – If you do not want to receive marketing messages for Jymo products or services, you can adjust your Settings in the “Notifications” tab.

· Advertising on the Platform – If you do not want Jymo to deliver “interest based” or personalized ads for third party products, you can adjust your Settings in the “Advertising” tab (for EU/EEA/U.K. and California users, under “Cookie Manager”). Please note, however, that even if you opt out of personalized ads, you may still see ads, but they may not be as tailored to your interests.

· Material Sharing – It’s not possible to make your account entirely private. However, you do have the option to make all of your playlists and other uploads private. This means that no one will be able to access and listen to your playlists without your explicit permission.

· Third Party Apps – If you have chosen to connect your account to a third-party application, like Facebook or Google, you can disable permission for the app by adjusting your Settings in the “Account” tab.

· Deleting Your Jymo Account – If you have an account and would like to delete it, you may do so by adjusting your Settings in the account tab. If you delete your account, all personal data associated with your account (except for backup copies), including the playlists and the usage data associated with those Tracks, will be deleted and may not be recoverable. We therefore advise you to copy or backup all Materials uploaded to your account before deletion. Even if you delete your account, it is possible that your personal data may still show up in some internet search results for a short while afterwards, if the search engine maintains a temporary cache of web pages. Search engines’ caching processes are outside of Jymo’s control and therefore we cannot be responsible for any personal data that remains cached by search engines after that personal data has been removed from the Platform. Please note that deleting any Jymo Apps, or any third party apps to which your account is connected, will not delete your account. Similarly, if you delete a third party app that is connected to your account over our API, this will not necessarily delete all personal data about your activity on the Platform from within that third party app. You will need to refer to the app provider’s terms of use and privacy policy to find out how to delete personal data about your activity on the Platform from that third party app.

· Messages From Other Users - If you do not want to receive messages from users you don’t follow, you can adjust your settings in the “Privacy” tab. If you want to block users, you will have to do so on their respective profiles. Any blocked user will be shown in your settings in the “Privacy” tab.

· Managing Device Settings

· On your mobile device, you may disable the “Allow Apps to Request to Track” setting in your iOS phone’s settings, or enable the setting to “Opt out of Ads Personalization” in your Android phone’s settings. To opt-out of location tracking when using our Apps, you can use the settings of your device. You can disable mobile analytics and bug reporting through these same settings as well.

· Managing Browser Settings

· You may also control cookies in your browser settings. You can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that if you choose to block cookies, doing so may impair the Platform or prevent certain elements of it from functioning.

Exercising Your EU/EEA/U.K. Privacy Rights

If you are a user residing in the EU/EEA/U.K., you may exercise any of the rights described in this section by contacting us. Please note that we may ask you to verify your identity before taking further action on your request.

· Data Access and Portability - You may be entitled to request copies of your personal data held by us. While a lot of the personal data you provide to us can be accessed in your account settings, you may also be entitled to request copies of personal data you have provided to us in machine-readable format.

· Change or Correct Data - Where you cannot update personal data yourself through an account, you have the right to ask us to correct, change, update or rectify your personal data.

· Data Retention and Deletion - We generally retain personal data for as long as is necessary to provide services to you under your account or for as long as is necessary to provide the Platform to you as a unregistered user. You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also terminate and delete your account through the Settings at any time as described in the Terms of Use. We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (e.g. under applicable tax or commercial law or to prevent fraud and abuse and maintain and enhance security). Afterwards, we delete the personal data immediately, unless we need the personal data until the expiry of the statutory period of limitation for the purpose of providing evidence for civil law claims or because of statutory storage obligations (e.g. for accounting reasons).

· Objection to Processing - You have the right to object to processing your personal data on grounds relating to your particular situation at any time (in particular, where we don’t have to process the personal data to meet a contractual or other legal requirement, or where we are using the personal data on the basis of our legitimate interests). If you object to such processing, Jymo will no longer process your personal data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims or obligations. Where your personal data is processed for direct marketing purposes, you have the right to object to such processing of your personal data at any time and ask Jymo to cease processing your data for these direct marketing purposes. However, please be aware that any objection to processing will not necessarily have an impact on the personal data processing before such objection was made, thus such processing will generally be deemed as permissible and will be subject to the usual retention and deletion periods.

· Restriction of Processing - You have the right to restrict the processing of your personal data where one of the following applies: your personal data is not accurate anymore; the processing is unlawful and instead of erasing the personal data you request the restriction of use; the personal data is no longer needed by us but required by you for the establishment, exercise or defense of legal claims; you have objected to the use and the decision on the legitimate grounds for objection is pending.

· Withdrawing Consent - Where you provide consent to the processing of your personal data by Jymo, you may withdraw your consent at any time by changing your account settings or by sending a communication to Jymo specifying the specific consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

· Lodging Complaints - You have the right to lodge complaints about the data processing activities carried out by Jymo before a competent data protection authority. A list of EU data protection authorities is available.

Additional Disclosure for Users Who Are Residents of Certain U.S. States

If you are a resident of California, Colorado, Connecticut, Utah, and Virginia, this section applies to you. Some state privacy laws require additional disclosures, which we cover in this section.

Collection, Disclosure, Sale and Sharing of Personal Data

· Personal Data that We “Share,” “Sell,” or Use for “Targeted Advertising”

We disclose the following categories of personal information to third parties for the purpose of advertising to you on non-affiliated sites and services and to inform the ads we show you on our Platform, including to measure and improve the effectiveness of advertising. These activities may be considered “sales” or “sharing” or use of personal information for “targeted advertising” under certain State Laws.

We do not knowingly sell or share the personal data of individuals ages 13–15 without consent.

· Sources of Personal Data - As described above, we collect this personal data from you, from affiliates via single-sign ons, and from our trusted service providers and business partners.

· Retention Period - We retain personal data for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

· The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal data to address issues that may arise;

· Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

· Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

· We generally do not collect information that is considered “sensitive” under state privacy laws. In the limited circumstances that we do, such as collection of your account username and password, which is designated as “sensitive” under the California Consumer Privacy Act, we do not use or disclose such sensitive personal information for the purpose of inferring characteristics about you.

Individual Rights and Requests
If you are a California, Colorado, Connecticut, Utah or Virginia resident, you may, subject to applicable law, make the following requests, to which Jymo will respond consistent with our obligations under applicable law:

· Request to Know - You may request to know whether we process your personal data.

· If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:

· The categories of personal data we’ve collected about you and the categories of sources from which we collected such personal data;

· The business or commercial purpose for collecting, selling or sharing personal data about you;

· The categories of personal data about you that we sold or shared and the categories of third parties to whom we sold or shared such personal data; and

· The categories of personal data about you that we otherwise disclosed and the categories of third parties to whom we disclosed such personal data.

· Request for a Copy – You may request to receive a copy of your personal data, including, where applicable, in a portable, readily usable format. If you are a Utah or Virginia resident, this right applies to personal data you provided to us;

· Request to Correct – If you are a California, Colorado, Virginia, or Connecticut resident, you may request to correct inaccuracies in your personal data.

· Request to Delete - You may request that we delete your personal data. If you are a California or Utah resident, this right applies only to personal data we have collected from you.

To make a Request to Know, a Request for a Copy, a Request to Correct, or a Request to Delete, please use the Help Center or contact us. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal data subject to the request. We may request additional personal data from you in order to verify your identity and protect against fraudulent requests, such as your email address or a picture and then use that information to match it with information we already have. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing, correcting, or deleting your personal data. If you make a Request to Delete, we may ask you to confirm your request before we delete your personal data.

If you want to make a Request to Know, a Request for a Copy, a Request to Correct, or a Request to Delete as an authorized agent on behalf of another individual, you may use the submission methods noted above. Not all kinds of requests can be made by authorized agents in all states. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent. In addition, we may require that the individual who is the subject of the request verify their identity, as set forth above or confirm that they provided you (the agent) with permission to submit the request.

· Request to Opt Out of Sales and Shares – If you are a California resident, you may request to opt-out of any future “sale” or “share” (as defined by applicable law) of personal data about you by contacting us. If you want to make a Request to Opt Out as an authorized agent on behalf of another individual, you may use the submission methods noted above. As part of our verification process, we may request, as applicable:

· Proof of your registration with the California Secretary of State to conduct business in California;

· Signed permission that the individual has authorized you to make a Request to Opt-Out on their behalf. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.

· Request to Opt Out of Targeted Advertising – You may request to opt-out of any future targeted advertising under Colorado, Connecticut, Utah, and Virginia laws by adjusting your account Settings in the “Advertising” tab, or by contacting us.

· Right to Non-Discrimination - You have the right to be free from unlawful discriminatory treatment for exercising your rights under applicable state laws.

· Right to Appeal – If you are a Colorado, Connecticut, or Virginia consumer and we refuse to take action on your request, you may appeal the refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us.

· Your Right to Request Removal of Content - Pursuant to California Business & Professions Code section 22581, if you are a resident of California, under 18, and a registered user of the Platform, you may ask us to remove content or information that you have posted to the Platform by writing to us. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

· Other Rights - You can request certain information about our disclosure of personal data to third parties for their own direct marketing purposes during the preceding calendar year. This request may be made once a year.

· De-Identified Data - Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

Contact Information

If you have questions or complaints about this Privacy Policy or our practices, please contact our Data Protection Officer by email at [support@Jymo.fun]

Changes to this Privacy Policy

We may update this Privacy Policy from time to time at our sole discretion. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Platform and update the “Last Amended” date below. Please be sure to periodically check this page to ensure that you are aware of any changes to this Privacy Policy. Any material changes to this Privacy Policy will be communicated to registered users by a notification to their account. Your continued access to or use of the Platform after the effective date of such changes will be subject to the revised Privacy Policy.

Effective as of: [September 8th], 2025

Last Amended: [September 8th], 2025