Effective as of February 16, 2024.        

California Notice at Collection: If you are a California resident, see the California Privacy Rights Statement section below for important information about your rights under California law.

This “Privacy Policy” describes the privacy practices of Storytel Audiobooks USA LLC and our subsidiaries and affiliates (collectively, “Company”, “we”, “us”, or “our”).  This Privacy Policy describes how we collect, use, disclose and otherwise process personal information in connection with our websites, mobile apps, and other services, and explains the rights and choices available to individuals with respect to their information. For convenience, our website (https://www.audiobooks.com/) and mobile app are collectively referred to as the “Sites,” and, together with our other services, collectively referred to as the “Services.” This Privacy Policy governs any of the Services on which the Privacy Policy is posted.

Individuals located in the European Union should be sure to read the important information provided here.

Personal Information We Collect

Sensitive personal information

Changes to your personal information

How We Use Your Personal Information

How We Share your Personal Information

Your Choices

Security

International Transfer

Other Sites and Services

User Generated Content

Children

Changes to this Privacy Policy

Questions?

California Privacy Rights Statement

Additional Information for EEA and UK Users

Personal Information We Collect

We collect personal information about you in the following ways:

Information you give us

Personal information that you may provide through the Services or otherwise communicate with us includes:

• Personal and Business Contact information, such as your first name, last name, postal address, email address, telephone number, job title, and employer name;
• Profile information, such as your username and password. (Members are not required, but can also choose to share profile pictures, gender, their birthdate, listening preferences, as well as other optional information. Member profiles will also contain the member’s followers and profiles that the member follows); 
• User Generated Content. We may make available on or through our Services, or link to, features that allow you to share information online, namely through reviews of audiobooks and our Services;
• Feedback, correspondence and reviews, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Services, receive customer support or otherwise correspond with us, or reviews of the Services, including audiobooks that we offer for download through the Services;
• Transaction and Payment information, such as details about purchases you make through the Services, registrations you make through the Services, and billing details (please note that all information relating to payments for our Services and Products is collected, stored and processed by Braintree, our payment processor. We do not collect or store card numbers or other payment information. All payment information you provide to us will be stored in accordance with the Braintree privacy policy, which you should read carefully);
• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;

 

Information from Social Networking Sites. Our Sites include interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Sites you authorise us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. If signing in through Facebook, we will collect your email, first name, last name, and Facebook ID. If signing in through Google, we will collect your email, first name, last name, and Google ID. If signing in through Amazon, we will collect your email, first name, last name, postal/zip code, and Amazon ID. We will access, use and store that information in accordance with this Notice. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information We Get from Others. We may also get information about you from other third-party sources, for example through our analytics providers, and we may add this to information we get from our Sites or the Services. 

Information automatically collected

We may automatically log information about you and your computer or mobile device when you access our Sites. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Sites, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Sites.  We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section for more details.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

Automated Decision Making.

We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.

Changes to your personal information

It is important that the personal information we hold about you is accurate and current.  Please let us know if your personal information changes during your relationship with us by updating your registration profile via the self-service "My Account" portal at www.audiobooks.com or emailing us at [email protected].

 

Cookies and Similar Technologies

We may collect information using “cookies” and similar tracking technologies. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.

We use two broad categories of cookies:

•  first party cookies, served directly by us to your computer or mobile device; and

•  third party cookies, which are served by our partners or service providers on our Sites.

Cookies we use

Our Sites use the following types of cookies for the purposes set out below:

Type of cookie	Purpose
Essential Cookies	These cookies are essential to provide you with services available through our Sites and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies	These cookies allow our Sites to remember choices you make when you use our Sites. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered may include the number of visitors to our Sites, the websites that referred them to our Site, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information.  We use this information to help operate our Sites more efficiently, to gather broad demographic information, monitor the level of activity on our Sites, and improve the Sites.   We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here.
Targeted and advertising cookies	These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.
Social Media Cookies	These cookies are used when you share information using a social media sharing button or “like” button on our Sites or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.




Pixel tags

 

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Sites to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can manage our content more effectively.

 

How We Use Your Personal Information

To provide and improve our Services

If you have a Company account or use our Services, we use your personal information for:

Service Delivery, Improvement and Operations, including to:

• operate, maintain, administer and improve the Services and to develop new products and services;
• manage and communicate with you regarding your Company account, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
• process and manage registrations you make through the Services, including to track and administer trainings you have registered for and attended;
• better understand your needs and interests, and personalize your experience with the Services;
• provide support and maintenance for the Services;
• help us understand user activity on the Services, including which pages are most and least visited and how visitors move around the Services;
• respond to your service-related requests, questions and feedback.

Marketing and advertising

We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Your Choices section below.
• Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Services, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your Choices section below.

Events, promotions, and contests

We may use your personal information to:

• •administer promotions and contests
• communicate with you about promotions or contests in which you participate
• contact or market to you after collecting your personal information at an event.

To communicate with you

If you request information from us, register on the Services, or participate in our surveys, promotions or events, we may send you Company-related marketing communications as permitted by law (including audiobook recommendations). You will have the ability to opt out of marketing-related communications.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent

We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Sites, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications. We may also share the contents of your personal library, wishlist, reviews, and general profile information with other members of the Company community with your explicit consent through the use of our follow features and if you make your profile public.  

To create anonymous data and for analytics

We may use your personal information for analytics purposes and to create anonymous data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.  

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share your Personal Information

Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations.  We disclose personal information to third parties under the following circumstances:

• Affiliates.  We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.  
• Service Providers. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as training, customer support, hosting, email delivery, email marketing, payment processing, analytics and database management services).
• Payment Processors. Any payment card information you use to make a purchase on the Services is collected and processed directly by our payment processor, Braintree. Braintree may use your payment data in accordance with the Braintree privacy policy.
• Professional advisors.  We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
• Compliance with Laws and Law Enforcement; Protection and Safety. Company may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
• Business Transfers. Company may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.
• Advertising Partners. We may share your personal information with third-party advertising companies for the interest-based advertising purposes described above.
• Business and Marketing Partners. We may share your personal information with third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies

Your Choices

Access, Update, Correct or Delete Your Information

All Company account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. Those who have made profile information public for the purpose of connecting with other Company members through engaging with follow and community features may revoke that access at any time and return their public profile to a private setting. Company account holders may also contact us at [email protected] to accomplish the foregoing or if you have additional requests or questions.

Marketing communications

You may opt out of marketing-related emails by clicking on a link at the bottom of each such email, or by contacting us at [email protected].  You may continue to receive service-related and other non-marketing emails.

Blocking images/clear gifs

Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Advertising choices

You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings.  Changing your internet web browser settings to block third-party cookies.  
• Privacy browsers/plug-ins.  Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.  
• Platform settings.  Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites: 
  • Google: https://adssettings.google.com/  
  • Facebook: https://www.facebook.com/about/ads/  
• Ad industry tools.  Opting out of interest-based ads from companies that participate in the following industry opt-out programs:  
  • Network Advertising Initiative: https://www.networkadvertising.org/managing/opt_out.asp 
  • Digital Advertising Alliance: https://www.youradchoices.com/appchoices 
  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.  
• Mobile settings.  Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. 

  
  You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

  Do Not Track
  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

  Linked third-party platforms
  If you choose to connect to the Services through an SNS or other third-party platform, you may be able to use your settings in your account with that SNS or other third-party platform to limit the information we receive from it. If you revoke our ability to access information from an SNS or other third-party platform, that choice will not apply to information that we have already received from that SNS or other third party.

  Testimonials
  If you gave us consent to post a testimonial or review on our Sites, but wish to update or delete it, please contact us.

  Choosing not to share your personal information

  Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account.  We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.

  Security

  The security of your personal information important to us.  We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it.  However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

  Children

  Our Sites are not directed to children under 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

  Sensitive Personal Data

  We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Sites or otherwise to us.

  If you send or disclose any sensitive personal data to us when you use the Services, you must consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data to our Services.

  International Transfer

  Company is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

  EEA and UK users should read the important information provided here about transfer of personal information outside of the EEA and UK.

  Other Sites and Services

  The Sites may contain links to other websites and services.  These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

  Changes to this Privacy Policy

  We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Service that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Sites – or a specific announcement on this page or on our blog).

  Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

  Contact Us

  If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at [email protected].

  California Privacy Rights Statement

  This section describes how we collect, use and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and the rights these users may have with respect to their Personal Information.
  
  For purposes of this section, the term “Personal Information” has the meaning given in the CCPA and does not include information exempted from the scope of the CCPA.
  
  Your California privacy rights. California residents have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months: 
  • The categories of Personal Information that we have collected. 
  • The categories of sources from which we collected Personal Information.  
  • The business or commercial purpose for collecting and/or selling Personal Information.  
  • The categories of third parties with which we share Personal Information.  
  • The categories of Personal Information that we sold or disclosed for a business purpose.  
  • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose. 
• Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months. 
• Correction. You can ask us to correct inaccurate Personal Information that we have collected about you. 
• Deletion. You can ask us to delete the Personal Information that we have collected from you. 
• Opt-out. 
  • Opt-out of certain processing of Personal Information for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.  
  • Opt-out of profiling/automated decision making. You can opt-out of automated processing or profiling performed on personal information to evaluate, analyze, or predict personal aspects related to a person's economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.  
  • Opt-out of other sales of personal data. You can opt-out of other sales of your Personal Information. 
• Consumers under 16. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. 
• Limit processing of Sensitive Personal Information. The CCPA provides a right to stop the processing of your Sensitive Personal Information for purposes of inferring characteristics about you. We ask that you not provide us with Sensitive Personal Information, and we do not process Sensitive Personal Information for purposes of inferring characteristics about consumers under the CCPA. 
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA. 



Exercising your right to information/know, access, correction, and deletion. You may submit requests to exercise your right to information/know, access, correction, or deletion via live chat in our mobile apps or by email to [email protected].

Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. Like many companies, we use services that help deliver targeted ads to you as described above. California law may classify our use of some of these services as “selling” or “sharing” your Personal Information with the advertising partners that provide the services. You can submit requests to opt-out of tracking for targeted advertising purposes or other sales of Personal Information via email to [email protected], via live chat in our mobile apps, or by clicking here: Do Not Share or Sell My Info.

Verification of identity; authorized agents. We will need to verify your identity in order to process your information/know, access, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

Personal Information that we collect, use, and disclose. We have summarized the Personal Information we collect by reference below to both categories defined in the “What personal information do we collect” section of this Policy above and the categories of Personal Information specified in the CCPA and describe our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of Personal Information not described below.

Personal Information ("PI") we collect	CCPA statutory category	Source of PI	Business/ commercial purpose for PI collection	Categories of third parties to whom we "disclose" PI for a business purpose	Categories of third parties to whom we "sell" or "share" PI
• Personal and Business Contact Information	• Identifiers • Commercial information • California customer records	• You • Third-party sources	• Service delivery, improvement and operations • Marketing & advertising • Communications • Events, promotions, and contests • To comply with law • With your consent • To create anonymous data and for analytics • For compliance, fraud prevention and safety	• Affiliates • Service providers • Advertising partners • Payment processors • Professional advisors • Authorities and others • Business transferees • Business and marketing partners • Linked third-party platforms • Other users and the public	• Advertising partners (to facilitate online advertising) • Business and marketing partners
• Profile information	• Identifiers • Commercial information • California customer records	• You • Third-party sources	• Service delivery, improvement and operations • Marketing & advertising • Communications • Events, promotions, and contests • To comply with law • With your consent • To create anonymous data and for analytics • For compliance, fraud prevention and safety	• Affiliates • Service providers • Advertising partners • Professional advisors • Authorities and others • Business transferees • Business and marketing partners • Linked third-party platforms • Other users and the public	• Advertising partners (to facilitate online advertising) • Business and marketing partners
• Feedback, correspondence and reviews	• Identifiers • Commercial information • California consumer records • Internet or Network Information	• You • Third-party sources • Automatic collection	• Service delivery, improvement and operations • Marketing & advertising • Communications • To comply with law • With your consent • To create anonymous data and for analytics • For compliance, fraud prevention and safety	• Affiliates • Service providers • Advertising partners • Professional advisors • Authorities and others • Business transferees • Business and marketing partners • Other users and the public	• Advertising partners (to facilitate online advertising) • Business and marketing partners
• Transaction and payment information	• Commercial information • California consumer records • Financial information	• You • Third-party sources	• Service delivery, improvement and operations • Marketing & advertising • Communications •To comply with law • With your consent • To create anonymous data and for analytics • For compliance, fraud prevention and safety	• Affiliates • Service providers • Advertising partners • Payment processors • Professional advisors • Authorities and others • Business transferees • Business and marketing partners	• Advertising partners (to facilitate online advertising) • Business and marketing partners
• Marketing data	• Identifiers • Commercial information • California customer records • Internet or Network Information	• You • Third-party sources	• Service delivery, improvement and operations • Marketing & advertising • Communications • Events, promotions, and contests • To comply with law • With your consent • To create anonymous data and for analytics • For compliance, fraud prevention and safety	• Affiliates • Service providers • Advertising partners • Professional advisors • Authorities and others • Business transferees • Business and marketing partners • Linked third-party platforms	• Advertising partners (to facilitate online advertising) • Business and marketing partners
• User-generated content	• Sensory Information • California consumer records	• You	• Service delivery, improvement and operations • Marketing & advertising • Communications • Events, promotions, and contests • To comply with law • With your consent • To create anonymous data and for analytics • For compliance, fraud prevention and safety	• Affiliates • Service providers • Advertising partners • Professional advisors • Authorities and others • Business transferees • Business and marketing partners • Other users and the public	• Advertising partners (to facilitate online advertising) • Business and marketing partners
• Usage information and automatically collected information	• Identifiers • Commercial information • Internet or Network Information	• Automatic collection	• Service delivery, improvement and operations • Marketing & advertising • Communications • To comply with law • With your consent • To create anonymous data and for analytics • For compliance, fraud prevention and safety	• Affiliates • Service providers • Advertising partners • Professional advisors • Authorities and others • Business transferees • Business and marketing partners • Linked third-party platforms	• Advertising partners (to facilitate online advertising) • Business and marketing partners
• Data derived from the above	• Inferences	• N/A	• Service delivery, improvement and operations • Marketing & advertising • Communications • To comply with law • With your consent • To create anonymous data and for analytics • For compliance, fraud prevention and safety	• Affiliates • Service providers • Advertising partners • Professional advisors • Authorities and others • Business transferees • Business and marketing partners	• Advertising partners (to facilitate online advertising) • Business and marketing partners
• Other Sensitive Personal Information • We do not intentionally collect this information, but it may be revealed in identity data or other information we collect	• Protected Classification Characteristics	• N/A	• N/A	• N/A	• None

Additional Information for EEA and UK

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Storytel Audiobooks LLC has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

•  by using EDPO’s online request form: https://edpo.com/gdpr-data-request/  
•  by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium  

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, Storytel Audiobooks USA LLC has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

•  by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/  
•  by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom  

Legal bases for processing

We only use your personal information as permitted by law.  We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below.  If you have questions about the legal basis of how we process your personal information, contact us.

Processing purpose (click link for details)	Legal basis
To provide the Services	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.
To communicate with you To create anonymous data for analytics  For compliance, fraud prevention and safety	These processing activities are carried out in pursuit of our legitimate interests in improving, marketing and monitoring the Sites and Services and keeping them safe and secure for you and other users.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with law	Processing is necessary to comply with our legal obligations
With your consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at [email protected].

 

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and

Transaction Information) for six years after they cease being customers for tax purposes.

 

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

 

• Opt-out. Stop sending you direct marketing communications.  You may continue to receive service-related and other non-marketing emails.
• Access.  Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct.  Update or correct inaccuracies in your personal information.
• Delete.  Delete your personal information.
• Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict.  Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.  

 

You can submit these requests by email to [email protected] or our postal address provided above.  We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request.  If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction.  You can find your data protection regulator here.  

Data Transfers

We are a U.S.-based company. Although we do not have an establishment within the European Economic Area (“Europe”), because we target the Site at individuals who are located in Europe, the GDPR (which is a European piece of data protection legislation) applies to us.

 

For this reason, we take appropriate steps to ensure that when we process your Personal Data (despite the fact that we are not based in Europe) we do so in accordance with the GDPR.

 

In addition, where we transfer your Personal Data to any of the third parties outlined above, we also take appropriate steps to ensure that we have implemented appropriate safeguards to ensure that such protection is maintained and is not undermined as a result of that disclosure.

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.