Privacy Policy

We take your privacy rights very seriously. HA9 and our subsidiaries and affiliates (“HA9”) collect and process some personal information about you and we want to take some time to tell you about it. This privacy policy (“Privacy Policy”) is intended to help you better understand what and how we collect, use, store, share and protect your information when you visit our website or use our app and services.

Throughout this Privacy Policy we’ll refer to our website and app and our other services collectively as “Service” or “Services”.

We are Eoun SL (dba HA9), an Andorran based company located in Andorra la Vella. You can contact us here. This Privacy Policy does not apply to any third party services or websites.

By using our Services, you agree that you have understood the content of this Privacy Policy.

If you don't agree with the terms of this Privacy Policy, or if you’re under the age of 18, please don't use our Services.

1. The Information We Collect and When

In connection with the Services, we collect and store personal information about and from you when you:

  • Visit our website
  • Register on and use our app and/or website
  • Upload music through our app and/or website
  • Make a payout through our app, website and the provided payout method
  • Make a payment through our app, website and the provided payment methods
  • Invite or have invited someone to the PRO tools.
  • Contact customer support or in any other way contact us
  • Connect to us through third party services
  • Connect to third party services via us
  • Sign up to one of our newsletters
Registration data

When you create a user account with the Services, we will ask for username, artist name, password, mobile phone number, email address, date of birth, address, postal code and country.

If you connect to the Service using credentials from a third party like Google or Facebook, you authorize us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available, like your name, profile picture, age, country, hometown, email address, date of birth and gender.

You can also voluntarily provide us with your Soundcloud, Instagram and/or Twitter account username.

Music upload and creator data

When you upload music via our app or website, some additional personal information is provided by you when you do. This includes:

  • Audio files
  • Track/album titles
  • Artwork
  • Artist name
  • Name of songwriter(s)
  • Name of other contributors (if applicable)
  • Information on whether you’re a label, artist, manager or producer etc.
  • We also collect information about how your music streams on distribution platforms.
Usage information

When you use or interact with the Service, we collect information about how the Service is accessed and used. This information includes:

  • Information on how you interact with our Service
  • Content that you post to the Service; and
  • Technical data, which may include URL information, location, session time, cookie data, which ad platform you came from, IP address, and the device and network ID you are using to access or connect to the Service.
Payment Data

When you make a payout through our third party payment provider, we may receive information like personal identification number, name, address, VAT-number and whether you’re a private person or a business, from them. We only obtain enough information to be able to make the payout, to comply with our legal (including, but not limited to, tax) obligations and to prevent and detect fraud.

When you make a payment through a third party provider, we may receive information like name, address from them. We only obtain enough information to be able to process the payment, comply with applicable laws and third party provider terms as well as provide you with services.

Information from third party sources

We may integrate with third party sources from time to time and may receive information about you from them.

If you choose to use features provided by HA9 that connect to your third party online profiles, accounts or services, we may collect information upon your approval. For example, if you prelove an HA9 release on Spotify, we may collect information from Spotify about your listening activity.

HA9 PRO

When inviting a person to HA9 PRO, you will provide email address or telephone number of the person you wish to invite. Make sure you have the approval from the person to do so. The person you invite will receive an email from us, stating your username.

If you are invited to access the HA9 PRO tools, we will receive access to your email address or telephone number. We will send you an email with information about the user who invited you. If you accept the invite, you will have to register an Account with HA9.

2. How We Use the Information We Collected

We will process your information for the following purposes:

  • To administer your account, to enable and provide the Services and, if applicable, provide integration with a third party.
  • To provide, personalize and improve your experience and any advertising made available on or outside the Service;
  • To make sure the Service is technically functional and to develop new products and services.
  • Analyze your use of the Service and how you interact with our ads to be able to make great business decisions.
  • To communicate with you for Service related or research purposes via emails, notifications, text messages, or other ways of messaging you, which you have agreed to receive.
  • To communicate with you, either directly or through one of our partners, for marketing and promotional purposes via emails, notifications, or other messages, subject to your consent.
  • To promote the Service, either within or outside the Service.
  • To process your payouts, payments and prevent or detect fraud.
  • To enforce this Privacy Policy, the Terms of Use and any other terms that you have agreed to, including to protect the rights, property, or safety of HA9, its users, or any other person, or the copyright-protected content of the Service.
  • As otherwise stated in this Privacy Policy.

3. For How Long Do We Store It?

The data we collect from you will be held for as long as:

  • You use our Services
  • We have to because of legal reasons and obligations
  • We need to process any payments remaining and/or owed to you
  • We need to, to prevent fraud, stream farming and any criminal activity

4. How We Share Information

We never share or sell your personal data to third parties for their own purposes. We only do this for the purpose of providing you with and enable the Services as well as provide us with services.

Music platforms/services and partners

The information you provide us when you register and upload a song via our app and/or website, will be used to perform and provide our Service, by delivering it to the music services, platforms and partners. When delivering the music to the platforms, we provide them with:

  • Audio file & track/album version (if applicable)
  • ISRC (International Standard Recording Code). A unique code created for every individual track.
  • UPC (Universal Product Code). A unique code created to summarize the release on a product level.
  • Track/album titles
  • Artwork
  • Artist name and full name
  • Name of contributors (if applicable)
Payouts

When requesting to receive a payout, we share your email address, name and phone number with the payout provider Hyperwallet, for them to be able to facilitate your payout.

Marketing and advertising

We may share your information with advertising partners in order to send you promotional communications about HA9. If you have agreed to receive newsletters from us, you can unsubscribe to these at any time, by clicking “unsubscribe” in the bottom of the email.

Service providers and others

We may from time to time share your information with service providers to perform functions and process user data and help provide our Services, consistent with this Privacy Policy. Where a third party processes user data on our behalf (e.g., a hosting service provider), it is subject to security and confidentiality obligations consistent with this Privacy Policy and applicable law. Where a third party processes user data on its own behalf, its processing is subject to its own Privacy Policy and applicable law.

In addition to the above, we may also share your information with third parties for these limited purposes:

  • To allow a merger, acquisition, or sale of all or a portion of our assets
  • To respond to legal process (e.g., a court order or subpoena), if we believe in good faith that it is necessary to do so
  • To comply with the requirements of mandatory applicable law
  • To protect the safety of any person
  • To protect the rights and property of HA9, including to enforce the Agreements and any other terms that you have agreed to
  • To address fraud and resolve disputes
  • To address security or technical issues
  • To publish anonymised or pseudonymised data about the use of the Service
  • To allow other companies in the HA9 group to use your information as specified in this Privacy Policy.

5. Transfer to Other Countries

If you’re a resident of Switzerland or the EEA, you understand that your information may be transferred to and stored outside of that area. The country it is transferred to might not have the same protection laws as your country. However, if we do transfer your information, we will make sure that we protect your personal data in accordance with the GDPR requirements and set up contracts with those parties to ensure this.

6. Children

We do not let children under the age of 18 to register with our Services and therefore, we do not knowingly collect personal information from children. If you are under the age of 18, please do not provide us with any personal information. If you are a guardian of a child under the age of 18 and become aware that your child has provided personal information to us, please contact Customer Support and you may request to access any information stored and/or cancel the Service.

7. How We Protect Your information

Your security is important to us. We always do our best to maintain administrative, technical and physical safeguards to help protect your personal information from loss, misuse, unauthorised access, disclosure, alteration or disclosure.

Since the Internet can’t be 100% secure, make sure you protect your password and username to prevent anyone from accessing your information.

8. Your Rights, How to Contact Us and Complaints

You are always entitled to receive information on data we have on you, free of charge. You also have the right to request to be erased and to get any inaccurate personal data blocked or corrected. Where we rely on consent to process your data, you can withdraw this consent at any time. Contact us!

To send a request, please contact us at Customer Support with your name, username and the email address you used when you registered with us.

If you’re not happy with how we handle your information, please contact us privacy@ha9.com

If you have a complaint in relation to the processing of your data, you have the right to lodge a complaint to the supervisory data authority. The contact details of the Andorran supervisory data authority can be found here.

9. Changes to the Privacy Policy

We may make changes to this Privacy Policy. If we make changes, we’ll notify you by either displaying a notice within the Service or by sending you an email. If the change is minor, we’ll just make the changes here. Please make sure you read the Privacy Policy carefully. If you do not want to continue using our Service under the new version of the Privacy Policy, please terminate your account.

10. Cookies

We and others working on our behalf employ cookies and related technologies to store information on or read information from your browser or device. They help us improve your experience, our Service and our marketing activities.

Your web browser is probably set to accept cookies by default. You can choose to change this to remove and reject cookies. If you do, this might affect certain features on our Service and some things might not work. If you use our Service on a mobile device, you can limit tracking and targeting in relation to ads. We cannot, however, control these opt out processes. You can also check www.aboutcookies.org to find out more on how you change your browser settings.

Sometimes we use pixel tags. The pixel tags are placed on certain web pages and when you access those web pages, the pixel tag generates a generic notice of the visit and permits us to ser or read our cookies. They are used together with cookies to track activity on a site by a particular device. If you turn off cookies, we can only see anonymous website visits.

We may use the following types of cookies:

  • Strictly necessary cookies. These cookies are required for the operation of our site.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and see how visitors move around our Services. This helps us improve our Service.
  • Mobile Device Identifiers and SDKs. Sometimes we use or partner with app developer platforms that use mobile SDKs to collect information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs) and information connected to how mobile devices interact with our Service and those using our Service.