Last updated August 5, 2022
Thank you for choosing to be part of our community at Themes & Variations Inc., doing business as Musicplay (“Musicplay”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
1. WHAT DO WE DO TO PROTECT STUDENTS?
In Short: We do not collect personal information from students. Students can only access through a class code provided by their teachers, and will access without providing any personal information.
We do our best to ensure that students’ privacy is protected in anything we do. As of the posting date above, students do not provide any Personally Identifiable Information in order to access any content on the site.
Students can only access using a generated class code from their teacher, which allows students to access the content without providing any personal information.
We take the following additional steps to ensure student privacy is respected:
- Any tools that we use for data collection and monitoring the stability of our platform are set to *not* track any user identifiable information, or behavior tracking while a student is logged into the appropriate account.
All the above are steps we’ve taken to ensure compliance with the following laws:
2. WHAT INFORMATION DO WE COLLECT?
The personal information you disclose to us
In Short: We collect personal information that you provide to us. Persons under 18 years old are not permitted to register for an account.
We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services (such as entering competitions, contests or giveaways) or otherwise contacting us. Also based on requirements, when you sign up for an account you need to verify that you are over the age of 18, as MusicplayOnline accounts are only available to users over the age of 18. We have taken steps to ensure known student email domains are prevented from registering for an account.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
- Publicly Available Personal Information. We collect first name, maiden name, last name, and nickname; email addresses; and other similar data.
- Personal Information Provided by You. We collect school address (name, town/city, province/territory, country); and other similar data.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Online Identifiers. We collect devices; tools and protocols, such as IP (Internet Protocol) addresses; cookie identifiers, or others such as the ones used for analytics; and other similar data.
3. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
- To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
- To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
- To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.
- To deliver services to the user. We may use your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. We do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following third parties.
We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
- Content Optimization: YouTube video embed, Vimeo video and SproutVideo
- Data Backup and Security: Pagely
- Functionality and Infrastructure Optimization: Pagely
- Invoice and Billing: Stripe
- Web and Mobile Analytics: Google Analytics and Google Tag Manager
- Website Hosting: Pagely
- Website Performance Monitoring: New Relic
Note: Google Analytics remarketing (Signals) features are disabled.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in United States. If you are accessing our Services from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in and other countries.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process, including encrypting your data while in motion and at rest, limiting the data we collect, use of access controls to mitigate risk in the event of a breach, and requiring strong, unique passwords for all employees. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from persons under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from people under age 18, please contact us at email@example.com.
11. DO WE ADVERTISE TO MINORS?
In Short: We do not target marketing or advertisements to children under 18 years of age. We do not use your data for targeted advertising.
We do not knowingly advertise to persons under 18 years of age. We do not use data to display personalized advertising, inform, influence, or enable marketing, or other commercial efforts. We do not share, sell, rent, or trade any of your information with third parties for their promotional purposes, and have contracts retaining full ownership and usage permissions of any data shared with third parties. This means that they cannot do anything with your personal information unless we have instructed them to do it.
12. DATA VISIBILITY & USER-GENERATED CONTENT
In Short: No personal information is displayed publicly or is searchable by other users. User-generated content (ex. MyList) is also not public.
We do not make your personal data or user-generated content publicly accessible to registered or non-registered users. You can access, edit and review your own data through your dashboard. User-generated content (ex. My List) is private to that specific user and their associated class code. We may provide a method in the future where some user-generated content could be shared with other trusted users. We would take appropriate steps to monitor and filter personal information, and users would need to opt in to share their created content.
13. INTERACTIONS BETWEEN USERS
In Short: We do not allow interactions between users on MusicplayOnline. Links to our social media or online communities are not accessible to students.
We do not support interactions between trusted users, including forums, comments, chat or other user-to-user communications. Registered users will have access to links to our social media and online communities. These platforms are monitored by our team both when joining the private communities and for content shared. Links to our social media or online communities are not accessible to students or are targeted for student use.
14. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights, you may email us at firstname.lastname@example.org.
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact us using the contact information provided.
- Log into your account settings and update your user account.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may contact us using the contact information provided.
15. DATA BREACH
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure, or disposal of personal information. You will be notified about data breaches when Themes & Variations Inc. believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Themes & Variations Inc. becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Themes & Variations Inc. will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
16. CONTROLS FOR DO-NOT-TRACK FEATURES
17. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
18. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
19. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at email@example.com or by post to:
Themes & Variations Inc.
3-4664 Riverside Drive
Red Deer, Alberta T4N 6Y5
20. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please go to your account dashboard or contact firstname.lastname@example.org. We will respond to your request within 30 days.