Overview
AUTO/PILOT is working hard to make sure that we comply with the European Union’s General Data Protection Regulation (“GDPR”). We value your privacy and your rights to own and control your personal data. We will never sell your data to third parties.
The data that we do collect is meant to improve your user experience.
Unless otherwise stated, Epicwin Ltd. (“AUTO/PILOT”) is the data controller for the personal data we collect through AUTO/PILOT’s website, emails, and third-party applications where applicable (herein collectively referred to as “Services”) subject to this Privacy Policy (“Policy”) and under applicable data protection laws. Our website URL (the “Site”) is https://autopilot.audio.
ATTENTION: PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICES. USING THE SERVICES INDICATES THAT YOU ACCEPT AND UNDERSTAND THIS PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT USE THE SERVICES.
Each of the AUTO/PILOT entities, now in existence or hereafter created, separately make the disclosures in this Policy. The data protection officer of AUTO/PILOT can be contacted at the following email address: [support@autopilot.audio](mailto:support@autopilot.audio)
This Policy explains what personal information we collect from you, either directly or indirectly, and how we use it. Please read this Policy carefully to understand how AUTO/PILOT (also referred to herein as “we”, “us”, and “our”) may collect, use, and share your personal information.
This Policy does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot be linked to a living individual (such as anonymized data, aggregated data, or coded data which, in a given form, cannot effectively be used to extract your personal data) (“Anonymized and Aggregated Data”). We reserve the right to generate Anonymized and Aggregated Data extracted out of any databases containing your personal data and to make use of any such Anonymized and Aggregated Data as we see fit.
AUTO/PILOT may modify or update this Policy when necessary to reflect customer feedback and changes in our AUTO/PILOT Products and Service. Please review it regularly. When we update this Policy, we will revise the ‘Last Update’ date at the top of the Policy. If there are material changes to the Policy or in how AUTO/PILOT uses your personal data, we will notify you either by posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to regularly review this Policy to learn more how AUTO/PILOT is using and protecting your information.
Please review the Privacy Policy each time you use the Service. BY USING THE SERVICE, YOU ACKNOWLEDGE AND ACCEPT THE MOST RECENT VERSION OF THE PRIVACY POLICY.
Information we may collect
We automatically collect information about you, your use of our website, or information collected by using cookies and similar technologies when you use, access or interact with our website. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our websites, and whether and how you interact with content available on our websites.
Information Obtained from Other Sources.
We may receive information about you from other sources, including third parties, such as music service partners and partners with whom we offer co-branded services or engage in joint marketing activities. We may also receive information about you from social media platforms. We protect data obtained from third parties according to the practices described in this Policy and we also apply any additional restrictions imposed by the source of data.
For Your Reference, We May Collect the Following Data:
- Forms filled out by you including site registrations (where applicable)
- Subscriptions or orders placed on the Site;
- Participation in discussion boards or other social media functions on the Site;
- Entering competitions, promotions, or surveys;
- Correspondence with us by phone, e-mail, or otherwise;
- Reporting a problem or requesting support for the Site
The customer interactions with AUTO/PILOT are broken down into the following segments:
Basic User Data.
This includes name, email address, IP address, and information provided by cookies or similar technology to share news about events and products offered by AUTO/PILOT. The IP address helps us to understand geographic information about our websites’ visitors to better improve our website. It is our legitimate interest to process your personal data for these purposes.
Purchasing Data.
Once you have decided to buy a AUTO/PILOT product including the AUTO/PILOT software (“Products”), we offer a way for customers to buy directly from us at our Site.
To effectuate such transactions, we may collect: your name, phone number, email address, delivery/shipping address, and payment information. This information is used solely to complete your transaction, follow up with you about your purchase, help with any delivery issues, handle returns, and other issues related to the purchase of your AUTO/PILOT Products. We only use payment information in connection with the purchase of AUTO/PILOT Products.
Why: We collect this information to help get your AUTO/PILOT services processing correctly. We may also use your email to send you AUTO/PILOT-related notifications, such as promotional messages, information about AUTO/PILOT Products and/or Services, and to share exciting AUTO/PILOT news and Product offerings. It is our legitimate interest to process your personal data for these purposes.
Registration Data.
This data includes your email address, location, language preference, Product serial number, IP address, and AUTO/PILOT account login information (as described above).
Device Identifiers.
When you access or use the Services using a mobile device, we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Services. A device identifier may remain persistently on your device to enhance your navigation on the Services. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.
Advertising Identifiers.
Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Certain advertising identifiers may be modified or disabled by users in the operating system’s settings.
How we use personal information
AUTO/PILOT uses the data we collect to provide you with the AUTO/PILOT Products and Services we offer, which includes using data to improve and personalize your experiences. We also use the data to communicate with you, for example, informing you about your account, new AUTO/PILOT Products or Services available, security and other types of updates.
AUTO/PILOT Uses the Data for The Following Purposes:
- We may use data to respond to customer inquiries, diagnose Product problems, and provide other customer care and support services. This processing is necessary to serve our legitimate interest.
- We may use data for research purposes and to develop and improve our AUTO/PILOT Products and Services, including maintaining and improving the performance of our AUTO/PILOT Services, using search queries and clicks to improve the relevance of search results and using usage data to determine what new features to prioritize. This processing is necessary to serve our legitimate interest.
- We may use data to protect the security and safety of our AUTO/PILOT Products and our customers, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.
- We may use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.
- Where you sign up for the Services through an account with a third party content or platform provider, we may use data to report to that third party and to communicate with it in relation to your activities on the platform or in relation to the content.
- We may use the data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means of electronic communication to inform you about new AUTO/PILOT Products or Services, and security updates, to update you on a support issue, to invite you to take part in a survey, or to send you Services-related notices (e.g., account verification, technical notices). This processing is necessary to serve our legitimate interest.
Children.
This Site is not directed toward children nor does AUTO/PILOT knowingly collect information from children without parental consent except where in compliance with applicable laws. If, following a notification by a parent or guardian or upon discovery, a child under sixteen has been improperly registered, we will delete the child’s personal information from our records.
Data security and storage
AUTO/PILOT is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.
We use a variety of appropriate technical and organizational measures and industry standards to protect your personal information and help prevent information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, we ensure that our third-party data center vendors provide adequate security measures.
You can only access your AUTO/PILOT account information and our service through the use of an individual user login and password. To protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person. Please alert us immediately if you believe your password has been misused. Additionally, always log out and close your browser when you finish your session. Please note, we will never ask you to disclose your password.
If you have any questions about the security of your personal information, you can contact us at [support@autopilot.audio](mailto:support@autopilot.audio).
Storage.
Personal data collected by AUTO/PILOT may be stored and processed in your region, in the United States (for instance in our major data centers), or in any other country where AUTO/PILOT or its affiliates, subsidiaries or service providers are located or maintain facilities. AUTO/PILOT has put in place adequate mechanisms to protect personal information when it is transferred internationally, for example by using the Standard Contractual Clauses as approved by the European Commission.
AUTO/PILOT will retain your personal information for as long as we deem it necessary to enable you to use the website and your AUTO/PILOT Product, to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Policy and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to [support@autopilot.audio](mailto:support@autopilot.audio).
Your rights and choices
We want you to be in control of how your personal information is used by us. Subject to local law, you can do this in the following ways:
- you can ask us for a copy of the personal information we hold about you;
- you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you;
- in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
- in certain situations, you can also ask us to send the personal information you have given us to a third party.
- You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you.
- You can stop receiving promotional emails from us by following the unsubscribe instructions in those emails. Note that unsubscribe is not available for certain emails concerning your relationship or dealings with us.
Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.
We rely on you to ensure that your personal information is complete, accurate and current. Please inform us promptly of any changes to, or inaccuracies of, your personal information by contacting [support@autopilot.audio](mailto:support@autopilot.audio).
We will respond to your request as soon as possible. For more information about how you can control the collection and use of additional usage data and your communication, marketing and advertising preferences, please continue reading below.
We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.
AUTO/PILOT Account.
If you wish to access, edit or remove profile information, change your password, close your account or request deletion of your personal data, you can do it by logging in to your AUTO/PILOT account or AUTO/PILOT app or sending an email to [support@autopilot.audio](mailto:support@autopilot.audio). If you cannot access certain personal information collected by AUTO/PILOT via the AUTO/PILOT account, you can always contact us by sending an email to [support@autopilot.audio](mailto:support@autopilot.audio). We will respond to any request to access or delete your personal data as soon as possible.
Your Communication, Marketing and Advertising Preferences.
You can opt out of receiving direct marketing communications from AUTO/PILOT. We respect your choice, and we will stop sending you promotional emails once you unsubscribe or change your communication settings.
Please note, regardless of your communication settings, we will continue to communicate with you regarding changes to terms and conditions, policy updates, routine customer service messages such as information about current or past purchase, delivery of products, service interruptions, or data breaches.
Your California Privacy Rights.
California residents may opt out of having their personally identifiable information shared with third parties for those third parties’ direct marketing purposes by contacting us at [support@autopilot.audio](mailto:support@autopilot.audio). Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. AUTO/PILOT currently does not take action in response to these signals.
Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure if any, of information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to [support@autopilot.audio](mailto:support@autopilot.audio) with “Request for California Privacy information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide to you via email a list of the categories of information disclosed to third parties for their direct marketing purposes during the immediately-preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by Section 1798.83’s requirements.
How to Control Identifier Settings.
You can control how these identifiers are used, including the ability to reset them, through your device settings.
AUTO/PILOT may work with third-party advertisers that use cookies and similar technologies to provide more relevant advertising about AUTO/PILOT Products and Services on our websites and across the internet. To provide this ‘interest-based advertising’, the parties combine non-personal data about your online activities acquired over time, which help cater advertising that we deliver to you. Examples of this may include an AUTO/PILOT advertisement on a Facebook page, or a Google-owned page such as a search results page or YouTube, or on a site within Google’s advertising network. We do not share your personal information as part of this process. Where necessary we obtain your consent to this process. At all times, you can opt out of these personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI websites and DAA websites. Opting out may make the ads you see across the internet less relevant to you.
If you have opted out of receiving communications from us, we will not use your email for interest-based advertising.
If you have any questions about the use of your personal information, please send an email to [support@autopilot.audio](mailto:support@autopilot.audio).
Users of sites in the European Economic Area
This section of this Policy applies only if you use the Site from a country that is a Member State of the European Economic Area, and supplements the information in this Policy.
Users based in the European Union have the following legal rights in respect of their information:
- a. The right to require AUTO/PILOT to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;
- b. The right to require AUTO/PILOT to rectify inaccurate information without undue delay;
- c. The right to request the erasure of their information. Subject to certain conditions, AUTO/PILOT may be required to erase the information in response to such request where: (i) the information is no longer necessary in relation to the purpose for which it was collected, such as where a user chooses to terminate his or her use of the Service; (ii) where the processing of the information is based on the user’s consent, if the user withdraws his or her consent; or (iii) the user objects to the processing of his or her information and there are no overriding legitimate grounds for the processing.
- d. Where AUTO/PILOT has disclosed the information of a European Union user to a third party and the user requests the erasure or rectification of the data, AUTO/PILOT will take all reasonable steps to inform the third party of such request.
- e. The right to restrict AUTO/PILOT from processing their information in certain circumstances, such as where the accuracy of that information is disputed or an objection has been raised (see below). In such circumstances, AUTO/PILOT will only process that information with the express consent of the user, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
- f. The right to receive their information from AUTO/PILOT in a structured, commonly used and machine-readable format;
- g. The right to object to the processing of their information by AUTO/PILOT where AUTO/PILOT has relied on the ‘legitimate interest’ basis for processing that information (see ‘Legal Basis for Data Processing’ below), in which case we will immediately stop processing the user’s information unless we have compelling legitimate grounds which override the interests, rights, and freedoms of the user; or the information is used for direct marketing purposes, in which case we will immediately stop processing the user’s information for such purposes.
- h. The right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides.
- i. The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.
Legal Basis for Data Processing.
We process personal data for the purposes set out in this Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract between you and us (for example, to provide you with the services you request and to identify and authenticate you so you may use the Site); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve the Site); and based on consent by our customers (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time (by using preference settings in emails or on our Sites, or emailing us as set out above) without affecting the lawfulness of processing based on consent before its withdrawal.
We may use automated decision-making technologies, including profiling, to support our data processing activities. Our automated decision-making capabilities include logic that attempts to identify artists, music, communications, products, or offers that we believe may interest you. By using this logic, it helps us personalize your interactions with AUTO/PILOT and AUTO/PILOT artists. For you, this means that you may see online advertisements, direct marketing communications (if you have subscribed), or other advertising or marketing messages or special offers based on your activity on our Sites or interactions with AUTO/PILOT or our third-party partners.
In some instances, you may be required to provide us with personal data for processing as described above, in order for us to be able to provide you to use all the features of the Site.