Privacy Policy

Updated: March 21, 2023
1.Introduction
CICI Great Workshop built the Pure Player app（(referred to as “Pure Player”) .By using the Pure Player app, you agree to our privacy policy. If you wish to update your personal information or any specific consent that you have provided to the Pure Player app, please contact Pure Player at pureplayer.feedback@gmail.com.
2. About this policy
While gathering information about the people who use Pure Player app, we take your privacy very seriously and make every effort to safeguard your personal data. This privacy policy is intended to inform you of what information we collect, how this information is used and what steps we take to protect this information, as well as providing you a process to update, change or delete your personal data. From time to time, we develop new services or provide additional services. Unless otherwise stated in the introduction, the aforementioned services are also governed by this policy.
3. Personal data we collect from you
The table below describes the categories of personal data we collect from you.

Collected from your use of the Pure Player service

category

illustrate

Account Data

If you login to our Services via Google, we ask for your permission to access certain information about that other account. Google makes information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. Please refer to the Link to privacy policy of Google at https://policies.google.com/privacy.

Usage Data

●   Personal data collected when you access or use Pure Player services.

●   This includes several data categories, detailed in each section.

●   Information about how you use Pure Player

●   Examples include:

●   Information about your Pure Player service options

●   Actions performed (including date and time) when you use Pure Player services, such as:

●   - search query

●   - Playlists you create

●   - your music library

●   - browsing history

 

●   your technical data

●   Examples include:

●   URL information

●   Online identifiers, including cookie dataand IP addresses

●   Information about the device you use, such as: Device ID, Internet connection type (e.g. Wi-Fi, 4G, LTE, Bluetooth), Supplier, Network and Device Performance, browser type, Language, Information for Digital Rights Management, System, Pure Player app version

Usage data will be uploaded to https://l.urpth.com, which is a private database developed for Pure Player and is safely managed by us. 
4. Purposes for which we use your personal data
The table below lists:
Purposes for which we process your personal data
The categories of personal data used for each item. Please refer to 

Purposes of processing your personal data

Legal basis for allowing this purpose

Categories of personal data for processing purposes

We provide Pure Player services under a contract with you.

For example: We will use personal data for the following purposes:

set up an account for you

personalize the account, or

When downloading the Pure Player App to the device, provide personal information to the App

Follow the contract

Account Data

Usage Data

Provide more Pure Player services.

For example: We use your personal data to allow you to share links to Pure Player content with others.

 

legal rights

The legal rights referred to here include:

carry out and maintain the Pure Player Services, and

Allow users to access and use Pure Player services

Account Data

Usage Data

To provide certain other voluntary features of the Pure Player service. In such cases, we will explicitly seek your consent.

agree

Account Data

Usage Data

Used to diagnose, repair, and troubleshoot Pure Player service issues.

Follow the contract

Account Data

Usage Data

For evaluating and developing new features, technologies and improvements to the Pure Player service.

For example:

In order to develop and improve the personalized recommendation algorithm, we will use personal data

We analyze user reactions to new features and assess whether adjustments are needed

legal rights

The legal rights referred to here include developing and improving products and functions for users.

 

Account Data

Usage Data

By law, your consent is required for marketing and advertising purposes.

For example, cookies are used to understand your interests, or your consent is required by law to send marketing emails.

agree

Account Data

Usage Data

To comply with a legal obligation.

may be:

Obligations under the laws of your country

Example: We use your date of birth when we need to perform age verification.

compliance with legal obligations

Account Data

Usage Data

Comply with the request of law enforcement, courts or other competent authorities.

COMPLIANCE WITH LEGAL OBLIGATIONS AND LEGAL RIGHTS

The legal rights referred to here include assisting law enforcement agencies in the prevention or detection of serious crimes.

Account Data

Usage Data

Fulfillment of contractual obligations with third parties.

For example: We provide pseudo-anonymized data about users' listening activities as a result of an agreement with Pure Player copyright holders.

legal rights

The legal rights referred to here include:

To maintain the relationship with the artist so that we can continue to provide the Pure Player service

Maintain relationships with other third parties for the same reasons

Account Data

Usage Data

Take appropriate action against reports of intellectual property infringement and inappropriate content.

legal rights

The legal rights referred to here include the protection of intellectual property rights and original content.

Account Data

Usage Data

To establish, exercise or defend legal rights.

For example: if a lawsuit is involved, we need to provide information related to the legal case to the lawyer.

 

legal rights

The legal rights referred to here include:

seek legal advice

Protect Pure Player, Users, and Others in Legal Proceedings

Account Data

Usage Data

For business planning, reporting or forecasting.

For example: if we plan to launch products and functions in a new country or region, we will check aggregated user data such as the number of new registrants in that place.

legal rights

The legal rights referred to here include research and planning for the smooth execution of our business.

 

Account Data

Usage Data

 

Used to maintain a secure Pure Player service, and to detect and prevent fraud.

Example: We analyze Usage Data to check whether the Pure Player service is being used for deceptive purposes.

legal rights

The legal rights referred to here include protecting Pure Player services and users from fraud and other illegal activities.

 

Account Data

Usage Data

 

Conduct research and surveys.

Example: We may contact users for feedback.

legal rights

The legal rights referred to here include gaining insight into how users perceive Pure Player and how the service is used.

Account Data

Usage Data
In jurisdictions where legitimate interest is not considered a legal basis, the basis is contractual necessity or consent.
5. Sharing your personal data
This section lists the objects that receive personal data collected or generated by the system during the use of Pure Player services.
Information We May Share
Please refer to this form to find out who you should share your data with and why.

recipient class

data type

share reasons

business acquisition

Account Data

Usage Data

Selling or negotiating to sell a business to an acquirer.

In such event, we may transfer your personal data to the successor or its affiliates as part of the transaction.

 

Other companies in the Pure Player group, including companies acquired by Pure Player

Account Data

Usage Data

To conduct day-to-day business operations to maintain, improve and provide Pure Player and its acquired companies services.

For example:

To enable employees of different companies in the group to develop and improve the functions of the Pure Player service

Share data with measurement companies to measure the effectiveness of advertising campaigns executed on the Pure Player service

Share data with podcast companies to gain insight into users' listening trends

Service Providers

Account Data

Usage Data

 

Pure Player engages service providers to perform functions and provide services to us. We may share your Personal Information with such service providers subject to confidentiality obligations consistent with this Privacy Policy, and on the condition that the third parties use your Personal Data only on our behalf and pursuant to our instructions.

Law and Harm

Account Data

Usage Data

Pure Player may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Pure Player’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party's, including a government's, request to disclose your information.

6.Data storage
We will keep your personal data only as long as it is necessary to provide Pure Player services to you, and for the following legitimate and necessary business purposes of Pure Player:
●  Maintain Pure Player service performance
●  Make data-driven business decisions for new features and products
●  compliance with legal obligations
●  resolve disputes
The categories of data retention periods include:
●  Data is kept until you remove it
You have the right to ask us to delete certain personal data. For more information, please refer to the "Right to Erasure" section of "Section 2"Personal Data Rights and Controls".
●  Materials that expire after a specified period
We will set a specific retention period for data, so some data will expire after a specific period.
●  Data is kept until the Pure Player account is deleted
We will keep the data until the Pure Player account is deleted. When your Pure Player account is deleted, your data will also be deleted or kept anonymous.
●  Extension of data retention period based on limited purpose
After account deletion, we will only extend the retention period for certain data for limited purposes.
The criteria used to determine the retention period include:
What is the appropriate data retention period for performance purposes?
Our system automatically expires data by default based on a clear data retention period. We choose data retention periods based on legitimate business purposes.
Do we need to retain data to ensure the service users expect? 
We will keep personal data for an appropriate period in order to provide users with long-term personalized services. 
Can users update or delete data themselves? 
If the user can view and update personal information by himself, we will retain the information according to the period selected by the customer.
Do we need to preserve data to comply with the rules while keeping the service secure? 
We may retain material that has been removed from the Pure Player service for a period of time for the following purposes:
● to ensure user safety
● in order to protect the platform from potentially harmful content, and;
● To take action on reports of intellectual property infringement
This practice also helps us investigate possible violations of our user guidelines and platform rules.
Does Pure Player have a legal or contractual obligation to retain or delete material? 
Examples of these include mandatory data retention laws, government orders requiring data to be retained in connection with an investigation, or data retained for litigation purposes. Conversely, if the law requires removal of illegal content, we will follow the law.
7.Links to Other Sites
This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by me. Therefore, we strongly advise you to review the Privacy Policy of these websites. we have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
8.Third-Party Software Use Acknowledgement
Our platform incorporates software tools like SDKs from third-party providers. By utilizing these third-party services on our site, you consent to their direct information gathering and processing methods, such as embedding code or widgets. Please note that these providers operate under their own privacy policies, which differ from ours. We make efforts to verify the legitimacy of these third parties and ensure they adhere to legal, compliant, and secure standards. For your data security, we urge you to review the privacy policies of these third-party tools before use. Should you identify any risks associated with these tools, we advise discontinuing use and contacting us promptly. A complete list of third-party SDKs used on our platform can be found here: https://pureplayer.net/thirdparty
9. Ensuring the security of personal data
We promise to protect the security of users' personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data. Note, however, that no system is completely secure.
In order to prevent unauthorized access, or to retain unnecessary personal data in the system, we have adopted a number of security measures, including pseudo-anonymization, encryption, access and retention principles.
To protect your user account, we encourage you to:
● Never share your password with others
● Restrict computer and browser access
● Sign out immediately after finishing using Pure Player service on a shared device
● For more information, see  Securing your account and more
If someone else has access to your Pure Player Account, they will also be able to access the Personal Data, Controls and Pure Player Services provided by your account. Example: You may have allowed someone else to use your account on a shared device. Only allow someone to use your account if you feel comfortable sharing your personal information with them. If you allow others to use your Pure Player account, it may affect your personalized recommendations and their material may be included in your material downloads.
10. Children
Please Note: This policy does not apply to Kids. There are minimum "age restrictions" for the Pure Player service in each country. The Pure Player service does not apply to the following:
●  children under the age of 13, or
●  a child whose personal data is being processed at an unlawful age, or
●  Children who are still young and require parental consent to process their personal data
We do not knowingly collect personal information from children under the applicable age. If you are under the age limit, please do not use the Pure Player service and do not provide any personal information. We recommend that you use a  Pure Player Kids account instead.
If you are the parent of a child under the age limit and you know that the child has provided personal data to Pure Player, please contact us 
If it is found that the personal data of children under the applicable age has been collected, reasonable steps will be taken to delete it. Therefore, we may have to delete the child's Pure Player account.
When using the main Pure Player service on shared devices, be careful not to play or recommend any inappropriate content to users under the age of 18.
11. Changes to this policy
We may change the content of this policy from time to time.
If there are substantial changes to this policy, an important notice will be provided in due course. For example, to display important notifications in the Pure Player service, or to send you device notifications.
12. How to contact us
If you have any questions or concerns about this Policy, please contact us: pureplayer.feedback@gmail.com.