We deeply respect your privacy and right to control your personal data. Our guiding principles are simple:
 

• We use data to serve our users.

• We provide meaningful choices that are easy to understand.

• We collect only what we need.

• We protect the data of our users as if it were our own.

The primary purpose of collecting your data is to improve your engagement experience. Whether you’re visiting an art gallery, engaging with ads, or looking to protect your digital assets, our goal is for you to get access to exactly what you need while preventing unauthorized individuals from taking your assets without a license. To that end, we only collect your data for clearly defined purposes. We do not and will not sell your personal data to third parties.

This Privacy Statement (the 'Statement') explains the personal information we collect from you, either directly or indirectly, and how we use it. Personal information is any information that can be used to identify you or that we can link to you. The Statement also covers the choices you can make about the data we collect, and how you can control these decisions. It applies to all products offered by ADIO ('ADIO Product(s)'), including our ADIO listener app ('ADIO app' or 'app') or services, for example, the ADIO website, ADIO Asset Tracking, as well as other offline interactions, such as visiting an ADIO-enabled event (collectively referred to as, 'Services'). Please read this Statement carefully to understand how ADIO may collect, use and share your personal information. The terms 'we', 'us', or 'ADIO' are each intended as reference to ADIO, Inc.

 

The Types of Personal Information We Collect

 

Information you provide to us

We collect information you voluntarily provide to us, such as your name, phone number and email address; for instance, when you want to learn more about ADIO Products and Services or when you contact our Customer Care group for assistance with your ADIO Products.

 

Information we collect automatically

We automatically collect information about you, such as Functional Data (as defined below) and Additional Usage Data (as defined below) about your use of ADIO Products and Services or information collected by using cookies and similar technologies when you use, access, or interact with us via our websites or app. 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, for instance, when you interact with us on social media. We protect data obtained from third parties according to the practices described in this Statement and we also apply any additional restrictions imposed by the source of data.

 

Information of children

ADIO does not target and is not intended to attract children under sixteen. Although visitors of all ages may navigate through our website or use our app, we do not knowingly collect or request personal information from those under the age of sixteen without parental consent. If, following a notification by a parent or guardian or discovery by other means, a child under sixteen has been improperly registered on our site using false information, we will cancel the child's account and delete the child's personal information from our records.

​

Customer Interactions with ADIO

To make the information in this Statement easy to understand, we have highlighted different occasions when ADIO could potentially collect personal information from customers. The customer interactions with ADIO are broken down into the following segments:

​

Learning about ADIO

As you gather more information about ADIO, you may virtually or physically visit a site that we own. Examples include browsing our website, calling our in-house sales representatives, or physically attending ADIO-sponsored events. To learn more about ADIO Products, you may voluntarily provide personal information, such as your name and email address during these interactions. We may also collect information about you online via cookies or similar technologies when you visit our websites.

We collect: name, email address, IP address, and information provided by cookies or similar technology.

Why: We use this information to share news about events and products offered by ADIO. Additionally, the IP address helps us to understand geographic information about our websites’ visitors better so that we can improve our website for everyone. It is our legitimate interest to process your personal data for these purposes.

​

Functional Data:

This data is absolutely necessary for your ADIO Product or Service, including ADIO Radio, to perform its basic functions in a secure way and you will not be able to opt out from this data collection, sharing and/or processing if you want to continue to use your ADIO Products.

We collect:

• Audio/Microphone Data. ADIO functions by processing the ambient audio as detected by the microphone on your device. It uses software local to your device to detect the presence of audio-based data packets. Once it detects a data packet, your device sends information regarding that interaction to our SaaS platform in order to deliver the desired experience back to you.
  ADIO never records, stores, or transmits, in whole or in part, ANY of the audio received from the microphone. Only decoded data packets are logged, transmitted, or processed.

Why we collect Functional Data: We collect this information to help ensure that your ADIO Products are working properly, to provide you with customer support and to honor your audio preferences which is necessary for the performance of the agreement we have with you. We also collect this information to guide product improvement and customer support decisions which is our legitimate interest.

​

Additional Usage Data:

In order to improve your experience with ADIO Products and to offer better, personalized ADIO Products and Services that meet the needs and expectations of our customers, we collect the following Additional Usage Data. The processing of this information is in our legitimate interest as further set out below (under Why). 

We collect:

• Performance Information. This includes things like information about how often you use the ADIO app, flow of interactions within the ADIO app, the flow of interactions within the ADIO app, duration of ADIO Product use, and, as required for certain Services location-based data using GPS (or similar technology, where available) and crowdsourced Wi-Fi access points and cell tower locations collected from your third party device when the ADIO app is in use.

• Activity Information. This includes duration of use, information about content you engage with, frequency of engagement.

Why: We collect this information so that we can help ensure ADIO Products are functioning properly, provide a personalized experience for our customers, determine what types of Product or feature improvements would please our customers most and to help predict potential problems with ADIO Products. Collecting this data is our legitimate interest to support a user-friendly experience that meets your needs and help you with issues you may experience. It is your choice if you want us to collect this information.

Microphone Access:

ADIO functions by processing the ambient audio as detected by the microphone on your device. It uses software local to your device to detect the presence of audio-based data packets. Once it detects a data packet, your device sends information regarding that interaction to our SaaS platform in order to deliver the desired experience back to you.

ADIO never records, stores, or transmits, in whole or in part, ANY of the audio received from the microphone. Only decoded data packets are logged, transmitted, or processed.

We collect: Functional Data, Additional Usage Data, and certain Audio Data

Why: This information is needed to fulfill the agreement we have with you, to ensure proper functionality and to help improve these features which is also our legitimate interest.

​

 

How We Use Personal Information

ADIO uses your personal information we collect to provide you with the ADIO Products and Services we offer, which includes using data to improve and personalize your experiences. We also use your personal information to communicate with you, for example, informing you about your account, new ADIO Products or Services available, security and other types of updates. Additionally, as described below, we may use other data related to your interactions with ADIO Products and Services in order to provide certain ADIO Services and for advertising purposes.

ADIO uses the data for the following purposes:

Product Experience, Recommendations and Personalization

We use data to provide, operate, support and improve the ADIO Products and Services we offer to ensure our customers can listen as effortlessly as possible. We use your personal information to recommend features, Products, and Services that might be of interest to you, identify your preferences, and personalize your experience with ADIO Products and Services. This processing is necessary for the performance of our agreement we have with you as well as to serve our legitimate interest.

 

Customer Support

We use data to respond to customer inquiries, diagnose Product problems, repair customers' ADIO Products and provide other customer care and support services. This processing is necessary for the performance of our agreement we have with you, as well as to serve our legitimate interest.

 

Product Improvement

We continually use data for research purposes and to develop and improve our ADIO Products and Services, including maintaining and improving the performance of our ADIO Products and Services, developing and adding new features or capabilities, such as using error reports to improve security features, using search queries and clicks to improve the relevance of search results and using usage data to determine what new features to prioritize. We use your personal information to provide functionality, analyse performance, fix errors, and improve usability and effectiveness of ADIO Products and Services. This processing is necessary to serve our legitimate interest.

 

Security, Safety, and Dispute Resolution

We use data to protect the security and safety of our customers, ADIO Products and Services, to detect and prevent fraud, to resolve disputes and enforce our agreements. We may use third parties to assess and manage credit risks. This processing is necessary to serve our legitimate interest.

 

Business Operations

We 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.

 

Communication, Marketing and Advertising

We 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 (including through the ADIO app and ADIO Products via voice enabled technologies) to inform you about new ADIO Products or Services, new music services available in your area and security or software updates, to update you on a support issue or to invite you to take part in a survey. If you choose to use ADIO Radio, we may use information such as your interactions with ADIO site, ADIO Radio content, ADIO Products, ADIO app and other Services to display interest-based ads for features, products, and services that might be of interest to you. We do not use information that personally identifies you to display interest-based ads. This processing is necessary to serve our legitimate interest.

We also use cookies and similar technologies to provide the most relevant ADIO advertising to you.

​

Purposes for which we seek your consent

We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop processing of your personal information for that purpose.

​

How We May Share Personal Information

ADIO does not and will not sell personal information about our customers. We want you to understand that information about our customers is an important part of our business. We only disclose your data as described in this Statement. We may share information with the following types of third parties.

 

Third Party Vendors

ADIO uses a variety of third-party vendors to carry out services like website management and hosting, cloud-related services, online Product purchases and shipping (including fulfilling orders for Products or Services, sending postal mail and email), email communications, analysing data, providing marketing assistance, transmitting content, if applicable scoring credit risk, and providing customer service. We only share your personal information as necessary, such as to complete a transaction or to provide a Product or Service you have requested or authorized and only with vendors or agents working on our behalf for the purposes described in this Statement. In this case, your personal information will be shared with these agents or contractors but only for the purpose of performing services on behalf and under the instructions of ADIO and in accordance with this Statement. It is our legitimate interest to share information with these parties for these purposes. For questions about third-party vendors, please send an email to privacy@adiotech.com.

​

Transactions involving Third Parties

ADIO makes available to you services, features and/or skills provided by third parties for use on or through ADIO Products. We also offer services and/or sell product lines jointly with third-party businesses. Depending on your use of the third-party products, features, skills and/or services, we may share certain personal information we have about you with these third parties to enable the functionality and/or provide customer support. Please note that functionally of these third-party products, features, skills and/or services is subject to these third-party terms of use or service and their respective privacy notices. We encourage you to read these third-party terms carefully before you enable them on your ADIO Products.
​

Sale or Merger

We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you via email and/or a prominent notice on our website and inform you of your rights.

 

Sharing and Disclosure of Aggregate Data

We share data in aggregate form and/or in a form which does not enable the recipient of such data to identify you, with third parties, for example, for industry analysis.

Please note, our ADIO Products include links to products or applications of third parties whose privacy practices may differ from ADIO. If you provide personal data to any of those third parties or their products, your data is governed by their privacy statements, and we encourage you to read these privacy statements carefully.

When sharing data with third parties, your personal information may be transferred to countries where data protection laws may provide a lower standard of protection for your personal information than your country. We take great care in protecting your personal information and have put in place adequate mechanisms to protect it when it is transferred internationally. We will transfer your personal information in compliance with applicable data protection laws and will implement suitable safeguards to ensure that your personal information is adequately secured by any third party that will access your information (for instance, by using the Standard Contractual Clauses as approved by the European Commission). If you have questions or wish to obtain more information about the international transfer of your personal information or the implemented safeguards, please send us an email to privacy@adiotech.com.

​

The Legal Bases for Using Personal Information

There are different legal bases that we rely on to use your personal information, namely:

 

Consent

Where legally required, we may rely on your consent to use your personal information. When this is the case, we provide you with more specific information when we actually request your consent. You may withdraw your consent at any time by sending us an email to privacy@ADIO.com. Your withdrawal will not affect the lawfulness of processing based on your consent before your withdrawal.

 

Compliance with legal obligation

We may use your relevant personal information to ensure compliance with applicable laws, for example to comply with lawful requests from law enforcement, and for regulatory investigations and compliance.

Legitimate interests

We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyze and improve our ADIO Products and Services and the content on our websites and app, to send you notifications about software updates or information about ADIO Products and Services, and to use your relevant personal data for administrative purposes and for fraud detection and prevention. Furthermore, except where consent is required under applicable local law, we rely on our legitimate interest to send you relevant marketing communications.

When using personal data to serve our legitimate interests, we will always balance your rights and interests in the protection of your personal data against our rights and interests.

Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you (e.g. in your ADIO Product settings), you may exercise your right to object by sending an email to privacy@adiotech.com.

​

Security, Storage and Retention of Personal Information We Collect

Security

ADIO 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. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. Additionally, we ensure that our third-party data center vendors provide adequate security measures. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transmission over the Internet. Moreover, your password is stored using one-way hash, which means that it cannot be recovered (or disclosed) by anyone, including ADIO (it can only be reset).

You can only access your ADIO 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.
 

Storage

Personal data collected by ADIO 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 ADIO or its affiliates, subsidiaries or service providers are located or maintain facilities. ADIO 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.

 

Retention

ADIO will retain your personal information:

• for as long as we have a customer relationship with you and/or as necessary to enable you to use the website, your ADIO account and/or your ADIO Product(s);

• for the period required to provide services that you request from us;

• for the period required to provide marketing or other promotional materials that you request from us;

• to comply with our legal obligations, including requirements of regulators and governmental agencies that have authority over us such as tax and/or accounting obligations, which usually require retaining certain transaction data for periods between 7 and 10 years after a transaction has occurred;

• for the period required to resolve disputes with any parties and/or to investigate or defend against potential legal claims; and

• otherwise as necessary to allow us to conduct our business in compliance with applicable laws and regulations.

All personal information we retain will be subject to this Privacy Statement and our internal retention guidelines. ADIO will delete your personal data when it is no longer required for the above-mentioned purposes. If there is any personal data that, for technical reasons, we are unable to delete entirely from our systems, ADIO will implement appropriate measures to prevent any further processing or use of such data.

​

 

Your Rights and Choices

Your Rights

We want you to be in control of how your personal information is used by us. Subject to local law, including the General Data Protection Regulation and the California Consumer Privacy Act, 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.

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 will respond to your request as soon as possible but certainly within 30 days. For more information about how you can control the collection and use of Additional Usage Data and your Communication, Marketing and Advertising Preferences, please visit Your Choices sections 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.

Your Choices

ADIO Account and ADIO App

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 ADIO account or ADIO app or sending an email to privacy@ADIO.com. If you cannot access certain personal information collected by ADIO via the ADIO account, the ADIO app or directly via the ADIO Product that you use, you can always contact us by sending an email to privacy@ADIO.com. We will respond to any request to access or delete your personal data as soon as possible but certainly within 30 days.

Additional Usage Data

You can always opt out of Additional Usage Data collection by logging in to your ADIO app for iOS or Android. Do it in just a couple of clicks. To opt out please follow the instructions below.

Using the ADIO app for iOS or Android:

1. Select “Settings” tab

2. Open “Data & Privacy” and look for Additional Usage Data option

3. In IOS app, disable/slide off the “Turn usage sharing on”. In Android, untick the box that reads “Turn usage data sharing on”

You may change your preferences at any time following the same steps.

Your Communication, Marketing and Advertising Preferences

You can opt out of receiving direct marketing communications from ADIO by following the instructions included in every email sent to you via the “Unsubscribe” tab. You can also opt out of email subscriptions or in-app messaging by updating your Profile and Contact Options in your ADIO account. 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, ADIO Product software updates, routine customer service messages such as information about current or past purchase, delivery of products, service interruptions, data breaches or other significant information about a Product you own such as discontinuation of support or safety issues.

You can adjust the amount of interest based advertising you may receive by changing your cookie settings, changing your device settings, and/or opting out of certain advertising networks. If you have opted out of receiving emails from us, we will not use your email for interest-based advertising activities.

​

Advertising and Modern Marketing Tools

To help more people listen to more music on ADIO, we use several modern marketing tools in support of our advertising efforts.

ADIO may work with third-party advertisers that use cookies and similar technologies to provide more relevant advertising about ADIO 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 a ADIO 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. Users that enjoy rights under EU data protection laws can visit www.youronlinechoices.com to learn how to opt out of having their data used for interest-based advertising by the European Interactive Digital Advertising Alliance (EDAA) member companies. Canadian users can visit www.youradchoices.ca.

If you have opted out of receiving communications from us, we will not use your email for interest-based advertising.

​

Our Use of Cookies and Other Similar Technologies

We use cookies and similar technologies like pixels, tags, web beacons, and other identifiers to help us personalize our websites for you, remember your preferences, understand how users are using our websites or app, and help customize our marketing offerings.

Cookies

A 'cookie' is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. ADIO uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted. We use the following types of cookies on our website.

• Strictly necessary cookies. These cookies are essential for you to browse our website and use its features. Without these cookies, services like shopping baskets cannot be provided.

• Performance cookies. These cookies collect information about how you use our websites. This data may be used to help optimize our website and make it easier for you to navigate.

• Functional cookies. These cookies allow our websites to remember choices you make and personalize your experience. We may store your geographic location in a cookie, for instance, to ensure that we show you the websites relevant to your area.

• Third Party cookies. Third-party cookies are those placed by websites and/or parties other than ADIO. These cookies may be used on our websites to improve our products or services or to help us provide more relevant advertising. These cookies are subject to their respective privacy policies for these external services, for example, Facebook Data Use Policy.

• Analytics cookies. We use analytics cookies, like those offered by Google Analytics, to help us understand things like how long a visitor stays on our websites, what pages they find most useful and how they arrived at ADIO.com. To learn more about Google Analytics and your data, visit this Google webpage.

​
 

How to Control Cookie Settings

Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impact your overall user experience. Some browsers offer a “Do Not Track” (“DNT”) signal whereby you may indicate your preference regarding tracking and cross-site tracking. Although we do not currently employ technology that recognizes DNT signals, we will only process your personal data in accordance with this Statement. Below you can learn about how to control cookie settings on popular web browsers:

• Google Chrome

• Internet explorer

• Safari

• Firefox

 

Pixels

In addition to cookies, we sometimes use small graphic images known as 'pixels' (also known as web beacons, clear GIFs, or pixel tags). We use pixels in our email communications to you (if you have selected to receive such communications) to help us to understand whether our email communication has been viewed. We also use third-party pixels (such as those from Google, Facebook, and other advertising networks) to help us provide advertising that is relevant to your interests.

​

Other Identifiers

When you use our app, we collect a unique ad-tracking identifier from your device (the Advertising Identifier or “IDFA” on iOS devices and the Google Ad ID or “AID” on Android devices) so that we can learn more about users of our app and provide the most relevant messaging and marketing. Although these identifiers are unique to your device, they do not contain any of your personal information such as name or email address.

How to Control Identifier Settings
You can control how these identifiers are used, including the ability to reset them, through your device settings. Below you can learn about how to control cookie settings on popular web browsers:

• Apple iOS

• Android

​

How to Contact Us

If you have any questions about the use of your personal information, please send an email to privacy@adiotech.com. California residents can also reach us toll free at 1-866-TRY-ADIO.

Unless otherwise stated, ADIO, Inc. is a data controller for personal data we collect through the ADIO Products and Services subject to this Privacy Statement. Our address is 48 Wall St., 11th floor, New York, NY 10005, USA.
 

Changes to Our Privacy Statement

ADIO may modify or update this Statement when necessary to reflect customer feedback and changes in our ADIO Products and Service. Please review it regularly. When we update this Statement, we will revise the 'Last Update' date at the top of the Statement. If there are material changes to this Statement or in how ADIO 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 Statement to learn more how ADIO is using and protecting your information.