Effective October 4, 2021

PHOENIX TALES Privacy Policy

Your Privacy is important.

1. About this Policy

This Policy describes how we process your personal data at Phoenix Tales Podcast

It applies to your use of:

  • all Phoenix Tales streaming services as a user. This includes use of these services under our free or paid options (each a "Service Option"); and

  • other Phoenix Tales services which include a link to this Privacy Policy (e.g. Phoenix Tales websites, Customer Support and the Community Site).

From now on, we'll collectively call these the "Phoenix Tales Service".

From time to time, we may develop new or offer additional services. They'll also be subject to this Policy, unless stated otherwise when we introduce them.

This Policy is not...

  • the Phoenix Tales Terms of Use. That's a separate document, outlining the legal contract between you and Phoenix Tales for using the Phoenix Tales Service. It also describes the rules of Phoenix Tales and your user rights.

  • about your use of other Phoenix Tales services which have their own dedicated privacy policy, such as Anchor, Soundtrap, Megaphone and Greenroom.

2. Your personal data rights and controls

Privacy laws, including the General Data Protection Regulation ("GDPR"), give rights to individuals over their personal data.

It’s your right to...

Access: Be informed of the personal data we process about you and to request access to it

Rectification: Request that we amend or update your personal data where it’s inaccurate or incomplete

Erasure: Request that we delete certain of your personal data

Restriction: Request that we temporarily or permanently stop processing all or some of your personal data

Object:

  • Object to us processing your personal data at any time, on grounds relating to your particular situation

  • Object to your personal data being processed for direct marketing purposes

Data portability:

Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service

Not be subject to automated decision-making:

Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect

How to exercise your rights with Phoenix Tales

Access: To request a copy of your personal data from Phoenix Tales, email phoenixtalespodcast@gmail.com

Your other rights: You can contact Phoenix Tales directly to exercise your rights at any time.

3. Personal data we collect about you

The information below set out the categories of personal data we collect and use.

Collected when you sign up for the Phoenix Tales Service or when you update your account:

User Data

Personal data that we need to create your Phoenix Tales account and enables you to use the Phoenix Tales Service. 

The type of data collected depends on the type of Service Option you have, how you create your account, the country you are in, and if you use third-party services to sign in. This may include your: 

  • name

  • email address

  • phone number

We receive some of this data from you e.g. from the signup form or account page. 

Collected through your use of the Phoenix Tales Service

Usage Data

Personal data is collected about you when you’re accessing and/or using the Phoenix Tales Service.

There are a few types of information this includes, detailed in the following sections.

Information about how you use Phoenix Tales

Examples include: 

  • Information about your Phoenix Tales Service Option.

  • Your actions with the Phoenix Tales Service (including date and time), such as:

    • search queries 

    • streaming history

    • playlists you create

    • your library

    • browsing history

    • account settings

    • interactions with other Phoenix Tales users

    • your use of third party services, devices and applications in connection with the Phoenix Tales Service

  • Inferences (i.e., our understanding) of your interests and preferences based on your usage of the Phoenix Tales Service.

  • Content you post to any part of the Phoenix Tales Service, such as images, text, playlist titles, communications, and other types of content.

Your technical data include:

  • URL information 

  • Online identifiers such as cookie data and IP addresses

  • Information about the devices you use such as: 

    • device IDs

    • network connection type (e.g. wifi, 4G, LTE, Bluetooth)

    • provider

    • network and device performance

    • browser type

    • language 

    • information enabling digital rights management

    • operating system

    • Phoenix Tales application version 

  • Information (such as the device name, device identifiers, brand, and version) which enables us to discover and connect with third-party devices and applications such as those listed below: 

    • devices on your wifi network (such as speakers) that can connect to the Phoenix Tales Service 

    • devices made available by your operating system when connecting via Bluetooth, plugin, and installation

    • Phoenix Tales partner applications to determine whether the application is installed on your device

Your general (non-precise) location

This may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency). 

We need this to meet geographic requirements in our agreements with the owners of content on the Phoenix Tales Service, and to deliver content and advertising that’s relevant to you.

Your device sensor data

Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) if needed to provide features of the Phoenix Tales Service that require this data. 

Additional data you may choose to give us:

Voice Data

If voice features are available in your market and only where you’ve given permission, we collect voice data (audio clips of your voice).

This makes it possible for us to provide and improve Phoenix Tales’s voice features. 

Payment and Purchase Data

If you make any purchases from Phoenix Tales (including a paid Service Option) or sign up for a trial, we will need to process your payment data. 

The exact personal data collected will vary depending on the payment method, but will include information such as:

  • name

  • date of birth

  • credit or debit card type, expiration date, and certain digits of your card number (Note: For security, we never store your full card number)

  • ZIP/postal code

  • mobile phone number

  • details of your purchase and payment history

Contests, Surveys, and Sweepstakes Data

When you complete any forms, respond to a survey or questionnaire, or take part in a contest or sweepstake, we collect the personal data you provide.

Collected from other (‘third party’) sources

Authentication partners

If you register for or log in to our services using another service, we’ll receive your information from them to help create your account with us.

Third-party applications, services and devices you connect to your Phoenix Tales account

If you connect your Phoenix Tales account to a third-party application, service and/or devices, we may collect certain information from them to make the integration possible. 

These third-party apps, services or devices may include:

  • social media

  • devices including:

    • audio (e.g. speakers and headphones)

    • smart watches

    • televisions

    • mobile phones and tablets

    • automotive (e.g. cars)

    • games consoles

  • services or platforms such as voice assistants

We’ll ask your permission before we collect your information from certain third parties.

Technical service partners

We work with technical service partners that give us certain data, such as mapping IP addresses to non-precise location data (e.g., city, state).

This makes it possible for Phoenix Tales to provide the Phoenix Tales Service, content, and features.

Payment partners

If you choose to pay Phoenix Tales by invoice, we may get data from our payment partners.

This allows us to: 

  • send you invoices

  • process your payment

  • give you what you’ve purchased

Advertising and marketing partners

We may get data about you from certain advertising or marketing partners.

This may include: 

  • cookie id

  • mobile device id

  • email address

  • inferences (i.e., our understanding) of your interests and preferences

This allows us to deliver more relevant ads and marketing.

4. Our purpose for using your personal data

  • our purpose for processing your personal data

  • our legal justifications (each called a "legal basis") under data protection law, for each purpose

  • categories of personal data which we use for each purpose (see more about these categories in Section 3 'Personal data we collect about you')

Here is a general explanation of each "legal basis" to help you understand the table:

  • Performance of a Contract: When it's necessary for Phoenix Tales (or a third party) to process your personal data to: 

    • comply with obligations under a contract with you, e.g. Phoenix Tales's obligations under the Terms of Use to provide the Phoenix Tales Service to you

    • or verify information before a new contract with you begins.

  • Legitimate Interest: When Phoenix Tales (or a third party) has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Phoenix Tales users. For example, using your Usage Data to improve the Phoenix Tales Service for all users. Contact us if you want to understand a specific justification.

  • Consent: When Phoenix Tales asks you to actively indicate your agreement to Phoenix Tales's use of your personal data for a certain purpose(s).

  • Compliance with Legal Obligations: When Phoenix Tales must process your personal data to comply with a law.

Purpose for processing your data

Legal basis that permits the purpose

Categories of personal data used for the purpose

To provide the personalized Phoenix Tales Service.

  • Performance of a Contract

  • Legitimate Interest

  • Consent

  • User Data

  • Usage Data

  • Payment and Purchase Data

  • Street Address Data

  • Voice Data

To understand, diagnose, troubleshoot, and fix issues with the Phoenix Tales Service.

  • Performance of a Contract

  • Legitimate Interest

  • User Data

  • Usage Data

To evaluate and develop new features, technologies, and improvements to the Phoenix Tales Service.

  • Legitimate Interest

  • Consent 

  • User Data

  • Usage Data

  • Voice Data

For marketing, promotion, and advertising purposes.

  • Legitimate Interest

  • Consent

  • User Data

  • Usage Data

  • Contests, Surveys and Sweepstakes Data

To comply with legal obligations and law enforcement requests. 

  • Compliance with legal obligations

  • Legitimate interest 

  • User Data

  • Usage Data

  • Payment and Purchase Data

  • Street Address Data

  • Voice Data

  • Contests, Surveys and Sweepstakes Data

To:

  • fulfill contractual obligations with third parties, for example our agreements with owners of content on the Phoenix Tales Service, and

  • take appropriate action with reports of intellectual property infringement and inappropriate content.

  • Legitimate interest 

  • User Data

  • Usage Data

  • Payment and Purchase Data

To establish, exercise, or defend legal claims.

  • Legitimate interest 

  • User Data

  • Usage Data

  • Payment and Purchase Data

  • Street Address Data

  • Contests, Surveys and Sweepstakes Data

To conduct business planning, reporting, and forecasting.

  • Legitimate Interest

  • User Data

  • Usage Data

  • Payment and Purchase Data

To process your payment.

  • Performance of a Contract

  • Compliance with legal obligations

  • User Data

  • Payment and Purchase Data

To detect and prevent fraud, including fraudulent payments and fraudulent use of the Phoenix Tales Service.

  • Performance of a Contract

  • Compliance with legal obligations

  • Legitimate Interest

  • User Data

  • Usage Data

  • Payment and Purchase Data

  • Street Address Data

To conduct research, contests, surveys, and sweepstakes.

  • Performance of a Contract

  • Legitimate Interest

  • Consent

  • User Data

  • Usage Data

  • Contests, Surveys and Sweepstakes Data

5. Sharing your personal data

This section sets out the categories of recipients of the personal data collected or generated through your use of the Phoenix Tales Service.

Publicly available information

The following personal data will always be publicly available on the Phoenix Tales Service:

  • Your profile name

  • Your profile photo

  • Your public playlists

  • Who you follow on the Phoenix Tales Service

  • Who follows you on the Phoenix Tales Service (you can remove followers)

Personal data you may choose to share

We will only share the following personal data with those outlined in the table below:

  • where sharing of particular personal data is needed for the use of a Phoenix Tales Service feature, or a third party application, service or device, which you have chosen to use; or

  • if you otherwise grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Phoenix Tales Service or by giving your consent

Categories of recipient

Reason for sharing

Third-party applications, services and devices you connect to your Phoenix Tales Account

To connect your Phoenix Tales account, and/or allow you to use the Phoenix Tales Service in connection with third-party applications, services or devices.

Examples of such third-party applications, services and devices include: social media applications, speaker devices, televisions, automotive platforms, or voice assistants, which interact with the Phoenix Tales Service.

You can see and remove any third-party connections under “Apps” in your account.

Other Phoenix Tales users

To share information about your use of the Phoenix Tales Service with other Phoenix Tales users, including your ‘Phoenix Tales Followers’. 

For example, under “Social” settings you can choose whether to share your recently played artists and your playlists on your profile. 

Artists and record labels

To receive news or promotional offers directly from artists, record labels or other partners. 

You may choose to share personal data (for example, your email address) for this purpose. You’ll always have the option to change your mind and withdraw your consent at any time.

Information we may share

See details of who we share to and why.

Service providers 

So they can provide their services to Phoenix Tales.

These service providers may include those we hire to: 

  • give customer support

  • operate the technical infrastructure we need to provide the Phoenix Tales Service

  • assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)

  • help market Phoenix Tales’s (and our partners’) products, services, events and promotions

Payment processors

So they can process your payments, and for anti-fraud purposes.

Advertising partners

So our ad partners can help us deliver more relevant advertising to you on the Phoenix Tales Service. 

For example, our ad partners help us facilitate tailored advertising:

  • This is when we use third-party information to tailor ads to be more relevant to you (also known as interest-based advertising). 

  • An example of a tailored ad is when an ad partner has information suggesting you like cars, which could enable us to show you ads about cars.

  • You can control tailored advertising in your account privacy settings under “Tailored Ads”. 

  • If you are “opted out” of Tailored Ads, you may still get advertising on ad-supported services (such as podcasts or the Free Service Option) based on your registration information and ads based on the content you are streaming on our Services. For example, if you are streaming a cooking podcast, you may hear an ad for a food processor or if you are streaming a workout playlist, you may hear an ad for sports clothing.

Marketing Partners

To promote Phoenix Tales with our partners. We share some personal data with these partners where necessary to:

  • enable you to participate in Phoenix Tales promotions, including trials or other bundled offers

  • to promote Phoenix Tales in media and advertising published on other online services

  • help us and our partners to measure the effectiveness of Phoenix Tales promotions 

Examples of partners include: 

  • marketing or sponsorship partners

  • websites and mobile apps who sell us advertising space on their services 

  • device, app and mobile partners who also offer Phoenix Tales promotions

Our partners may also combine the personal data we share with them with other data they collect about you (e.g. your use of their services). We and our partners may use this information to present you with offers, promotions, or other marketing activities that we believe will be relevant to you. 

Other partner sharing 

We may share personal data with partners to help us understand and improve the performance of our products and partnerships. 

You can see and remove many partner connections under “Apps” in your account.

Academic researchers

For activities such as statistical analysis and academic study, but only in a pseudonymised format. Pseudonymised data is where your data is identified by a code rather than your name or other information that directly identifies you.

Other Phoenix Tales group companies

Where we have offices, to carry out our daily business operations and so we can maintain and provide the Phoenix Tales Service to you.

Law enforcement and other authorities

When we believe in good faith it’s necessary for us to do so, for example: 

  • to comply with a legal obligation 

  • to respond to a valid legal process (such as a search warrant, court order, or subpoena)

  • for our own or a third party’s justifiable interest, relating to:

    • national security

    • law enforcement

    • litigation (a court case)

    • criminal investigation

    • protecting someone’s safety 

    • preventing death or imminent bodily harm.

Purchasers of our business

Where we sell or negotiate to sell our business to a buyer or possible buyer. 

In this situation, Phoenix Tales will continue to ensure your personal data is kept confidential. We’ll give you notice before your personal data is transferred to the buyer or a different privacy policy starts to apply.

6. Data retention and deletion

Retention

We keep your personal data only as long as necessary to provide you with the Phoenix Tales Service and for Phoenix Tales's legitimate and essential business purposes, such as:

  • maintaining the performance of the Phoenix Tales Service

  • making data-driven business decisions about new features and offerings

  • complying with our legal obligations

  • resolving disputes

Deletion

If you close or request that we close your account, we'll delete or anonymise your personal data so it no longer identifies you, unless we're required to keep something or we still need to use it for a legally justifiable reason.

Here are some examples of situations where we're legally allowed or required to keep some of your personal data:

  • if there's an unresolved issue relating to your accounts, such as an outstanding credit or unresolved claim or dispute

  • for our legal, tax, audit and accounting obligations

  • for our legitimate business interests such as fraud prevention or to maintain security.

7. Transfer to other countries

When carrying out the activities described in this Policy, Phoenix Tales shares your personal data internationally with Phoenix Tales group companies, subcontractors and partners. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.

Whenever we transfer personal data internationally, we use tools to:

  • make sure the data transfer complies with applicable law

  • help to give your data the same level of protection as it has in the EU

We do this using a variety of protections, as appropriate for each data transfer. For example, we use:

  • Standard Contractual Clauses (or an alternative legal tool) to require the third party to protect your data and to provide you with EU-level rights and protections

  • technical protections, such as encryption and pseudonymisation

  • policies and processes to challenge disproportionate or unlawful government authority requests

You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.8. Keeping your personal data safe

We're committed to protecting our users' personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

We have implemented various safeguards including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

To protect your user account, we encourage you to:

  • always use a strong password that is unique to your Phoenix Tales account

  • never share your password with anyone

  • limit access to your computer and browser

9. Changes to this Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Phoenix Tales Service or send you an email or device notification.

10. How to contact us

For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways: