SPIN A FRIEND, INC.

We may collect personal information directly from you, automatically through your use of the Services, and from third parties that assist us in providing digital distribution and related services.

To administer royalty payments, Spin A Friend may collect information including:

• Payee name;
• Payment account information;
• Bank or electronic-payment information;
• Taxpayer information;
• Tax forms;
• Tax identification information where required;
• Payment history;
• Royalty statements;
• Revenue reports; and
• Other information necessary to process payments or satisfy financial reporting requirements.

We may be required to retain certain payment, accounting, and tax records for legal, regulatory, accounting, or fraud-prevention purposes.

Spin A Friend may receive information from participating digital stores, streaming services, social-media platforms, rights-management providers, and other distribution partners.

This information may include:

• Stream counts;
• Download counts;
• Sales information;
• Revenue information;
• Territory information;
• Platform reporting data;
• Listener or audience statistics;
• Usage information;
• Content performance information;
• Copyright or rights-management claims;
• Fraud or artificial-streaming reports; and
• Other data provided through our distribution network.

Some platform reports may contain aggregated or de-identified information rather than personally identifiable listener information.

Spin A Friend may provide artists and labels with analytics concerning the performance of their Content.

Analytics may include:

• Streams;
• Downloads;
• Views;
• Sales;
• Revenue;
• Listener locations by country, state, city, or general region where available;
• Platform performance;
• Release performance;
• Song performance;
• Audience trends;
• Content ID activity;
• Social-media activity where available; and
• Other performance information supplied by distribution partners.

Analytics are dependent on information made available by third-party platforms and may be delayed, incomplete, adjusted, or corrected.

When you access the Spin A Friend website or Services, certain information may be collected automatically.

This may include:

• Internet Protocol address;
• Browser type;
• Device type;
• Operating system;
• Device identifiers;
• General geographic location;
• Login dates and times;
• Pages viewed;
• Features used;
• Referral information;
• Session information;
• Error and diagnostic data;
• Security information; and
• Other technical usage information.

We may use cookies, pixels, local storage, software-development kits, analytics tools, or similar technologies to collect this information.

Spin A Friend may use personal information to:

• Create and manage user accounts;
• Provide digital music distribution services;
• Deliver music and Content to digital platforms;
• Process subscriptions and purchases;
• Process royalty payments;
• Generate royalty statements;
• Provide streaming and sales analytics;
• Operate optional YouTube Content ID and rights-management services;
• Review releases before distribution;
• Communicate with users about releases, payments, accounts, or support requests;
• Verify ownership or distribution rights;
• Investigate copyright complaints;
• Detect artificial streaming or fraudulent activity;
• Prevent abuse, fraud, and unauthorized access;
• Maintain and improve the Services;
• Provide customer support;
• Personalize account features;
• Send administrative notices;
• Send marketing communications where permitted;
• Comply with legal and regulatory obligations;
• Protect Spin A Friend, our users, our partners, and third parties; and
• Enforce our agreements, policies, and Terms and Conditions.

Providing digital distribution services requires Spin A Friend to provide certain Content and information to third-party digital platforms and distribution partners.

We may share information such as:

• Artist names;
• Label information;
• Audio recordings;
• Artwork;
• Song and album titles;
• Release metadata;
• Copyright information;
• Songwriter and contributor information;
• ISRC and UPC information; and
• Other information necessary for distribution.

These recipients may include digital music stores, streaming services, social-media platforms, user-generated-content platforms, rights-management providers, and other digital outlets.

Participating services may include platforms such as Apple Music, Spotify, YouTube Music, Amazon Music, TIDAL, Deezer, TikTok, Instagram, Facebook, and other distribution partners available through Spin A Friend’s network.

Each third-party platform operates under its own privacy practices and policies.

If you elect to use YouTube Content ID, audio fingerprinting, media-detection, rights-management, or related services, Spin A Friend may provide eligible recordings and ownership information to authorized rights-management providers and participating platforms.

This information may be used to:

• Create audio fingerprints;
• Detect uses of recordings;
• Administer copyright claims;
• Match recordings to online videos or media;
• Monetize eligible uses;
• Resolve ownership disputes; and
• Report and distribute applicable revenue.

Participation in these optional services may require additional information concerning ownership and rights.

If Content submitted to Spin A Friend was generated, materially generated, or assisted by artificial intelligence, Spin A Friend may collect information relating to that AI use where necessary for legal, compliance, distribution, or platform-policy purposes.

This may include:

• Whether Content was AI-generated or AI-assisted;
• Whether synthetic vocals were used;
• Whether voice cloning or voice synthesis was used;
• Information concerning ownership or authorization;
• Information regarding AI tools or services used; and
• Documentation demonstrating rights or permissions.

Spin A Friend may provide AI-related disclosures or metadata to digital platforms where required by applicable platform rules or law.

Spin A Friend does not claim ownership of an Artist’s Content merely because artificial intelligence was used during creation.

Spin A Friend may share personal information with trusted third-party service providers that perform services on our behalf.

These providers may include:

• Payment processors;
• Cloud-hosting providers;
• Digital distribution providers;
• Rights-management providers;
• Data-storage providers;
• Analytics providers;
• Email and communication providers;
• Fraud-prevention providers;
• Customer-support providers;
• Accounting providers;
• Professional advisers; and
• Security providers.

These service providers may access information only as reasonably necessary to perform services for Spin A Friend, subject to their contractual and legal obligations.

Spin A Friend may disclose personal information when we reasonably believe disclosure is necessary to:

• Comply with applicable law;
• Respond to a subpoena, court order, warrant, or other legal process;
• Respond to governmental or regulatory requests;
• Enforce our contracts or policies;
• Investigate copyright infringement or other intellectual-property disputes;
• Investigate fraud or artificial streaming;
• Protect the security of our Services;
• Protect the rights, property, or safety of Spin A Friend, our users, partners, or others; or
• Prevent unlawful activity.

If Spin A Friend is involved in a merger, acquisition, financing transaction, corporate restructuring, sale of assets, bankruptcy, or similar business transaction, personal information may be transferred as part of that transaction.

Any successor entity may continue to use personal information subject to applicable law and the privacy commitments applicable at the time of the transfer.

Spin A Friend does not sell ownership of an Artist’s music, master recordings, compositions, artwork, or other Content merely because the Artist uses our distribution services.

Our rights to Artist Content are governed by the applicable Digital Music Distribution Agreement and other service agreements.

Spin A Friend may use cookies and similar technologies to:

• Keep users signed into their accounts;
• Remember preferences;
• Maintain security;
• Understand website usage;
• Improve website performance;
• Diagnose technical issues;
• Provide analytics; and
• Support marketing activities where permitted.

Users may be able to control cookies through their browser or device settings.

Disabling certain cookies may affect the operation of some features of the Services.

Spin A Friend may send promotional emails, product updates, service announcements, offers, or other marketing communications where permitted by law.

Users may unsubscribe from marketing emails by using the unsubscribe option provided in applicable messages.

Administrative, transactional, legal, security, royalty, payment, or account-related communications may still be sent where necessary.

Spin A Friend uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against:

• Unauthorized access;
• Loss;
• Misuse;
• Destruction;
• Alteration; and
• Unauthorized disclosure.

However, no website, network, computer system, transmission method, or data-storage system can be guaranteed to be completely secure.

Users are responsible for protecting their passwords and account credentials.

Users should notify Spin A Friend promptly if they believe their account has been compromised.

Spin A Friend may retain personal information for as long as reasonably necessary to:

• Maintain an active account;
• Provide distribution services;
• Process royalties and payments;
• Maintain transaction and accounting records;
• Fulfill contractual obligations;
• Resolve disputes;
• Investigate fraud or copyright matters;
• Comply with tax, accounting, or legal obligations; and
• Enforce our agreements.

When information is no longer reasonably necessary, Spin A Friend may delete, anonymize, or securely dispose of it, subject to applicable legal requirements.

Users may request closure of their Spin A Friend account subject to outstanding contractual, financial, legal, or distribution obligations.

Closing an account may not immediately remove Content from third-party platforms because digital platforms control their own takedown processing schedules.

Spin A Friend may retain certain information after account closure where necessary for:

• Royalty accounting;
• Tax reporting;
• Financial records;
• Fraud prevention;
• Intellectual-property disputes;
• Legal compliance; or
• Enforcement of applicable agreements.

Depending on where you live, you may have certain rights relating to your personal information.

These rights may include the ability to:

• Request access to personal information;
• Request correction of inaccurate information;
• Request deletion of certain personal information;
• Request information about categories of data collected;
• Request information about how personal information is used or disclosed;
• Restrict or object to certain processing where applicable;
• Withdraw certain consent where processing depends on consent; and
• Exercise other privacy rights provided under applicable law.

Some requests may be limited where Spin A Friend is legally permitted or required to retain information.

We may take reasonable steps to verify a person’s identity before completing a privacy request.

Residents of certain U.S. states may have additional privacy rights under applicable state law.

Where required, Spin A Friend will honor legally valid requests involving access, correction, deletion, portability, or other rights available under applicable law.

Spin A Friend will not unlawfully discriminate against a user for exercising privacy rights.

Spin A Friend’s Services are not intended for children who are not legally permitted to enter into the applicable agreement or use the Services without appropriate parental or guardian authorization.

Spin A Friend does not knowingly seek to collect personal information from children in violation of applicable law.

If we learn that information from a child was collected in circumstances requiring parental consent that was not obtained, we may take reasonable steps to delete or otherwise appropriately address that information.

Spin A Friend may provide services to users located outside the United States.

Personal information may be processed, transmitted, or stored in the United States or other jurisdictions where Spin A Friend, its distribution partners, or service providers operate.

Privacy and data-protection laws may vary between jurisdictions.

Where required by applicable law, Spin A Friend will use appropriate mechanisms for international transfers of personal information.

The Services may contain links to third-party websites, music platforms, payment processors, social-media platforms, or other services.

Spin A Friend is not responsible for the privacy practices of third parties.

Users should review the privacy policies of third-party services before providing personal information to them.

Spin A Friend may collect and process personal information when investigating copyright infringement, trademark disputes, ownership disputes, Content ID claims, artificial-intelligence disputes, or other rights complaints.

Information may be shared with:

• The Artist;
• The complaining party;
• Attorneys or professional advisers;
• Digital platforms;
• Rights-management providers;
• Distribution partners; or
• Government or legal authorities,

when reasonably necessary to investigate, resolve, defend, or comply with a rights-related matter.

Spin A Friend may use account, transaction, usage, distribution, and platform information to detect:

• Artificial streaming;
• Payment fraud;
• Identity theft;
• Account compromise;
• Copyright abuse;
• Fraudulent Content ID claims;
• Unauthorized access;
• Misrepresentation; and
• Other unlawful or abusive activity.

Spin A Friend may suspend or restrict accounts where reasonably necessary to investigate suspected fraud or security risks.

Spin A Friend may use automated technologies to assist with certain operations, including:

• Fraud detection;
• Release validation;
• Metadata checks;
• Audio-file validation;
• Copyright or content matching;
• Security monitoring;
• Customer-service assistance; and
• Analytics.

Where required by applicable law, users may have rights relating to certain automated decisions.

Spin A Friend may update this Privacy Policy periodically to reflect changes in:

• Our Services;
• Business operations;
• Technology;
• Artificial-intelligence practices;
• Digital-platform requirements;
• Distribution relationships; or
• Applicable laws and regulations.

When material changes are made, Spin A Friend may provide notice through the website, user account, email, or another reasonable method.

The “Last Updated” date at the top of this Privacy Policy will indicate when the policy was most recently revised.

Questions, concerns, or privacy requests regarding this Privacy Policy may be directed to:

Users requesting access, correction, deletion, or another privacy right should provide sufficient information for Spin A Friend to reasonably verify the request and identify the applicable account.

By creating an account or using Spin A Friend’s Services, you acknowledge that you have received and reviewed this Privacy Policy.

Where consent is legally required for a particular processing activity, Spin A Friend will request that consent separately as appropriate.

This Privacy Policy should be read together with the Spin A Friend, Inc. Digital Music Distribution Agreement, Terms and Conditions, subscription terms, payment terms, and any other policies applicable to the Services.