Updated date: January 2021

PRIVACY POLICYThis Group Privacy Policy (“​Privacy Policy​”) concerns BELIEVE SAS, a French company, registered with
the Trade and Corporate Registry of Paris under the number 481 625 853, with its main office located
24 rue Toulouse Lautrec 75017 PARIS ("Believe SAS") and its subsidiaries around the World, including
TUNECORE, hereafter collectively referred to as "​Believe”​,​ ​"​We​", or "​Us​".
This Privacy Policy describes Believe's personal data processing practices for the digital distribution ofmusic, the supply of products ("​Products"​) and services ("​Service(s)"​), in general or through our
websites and/or other electronic communications services (widgets, mobile applications or API),
collectively or individually "​Site(s)"​). Believe SAS acts as data controller and its subsidiaries as dataprocessor
We attach particular importance to the secure processing of data, their confidentiality, theprotection of privacy and associated rights. Please take time to read our Privacy Policy carefully.
By visiting this Website, providing Believe with Your personal data or other information on theSites, or by subscribing to the Services, or by entering into a contract with Us, you expressly
acknowledge that you have read and agreed to the terms of this Privacy Policy​.
This Privacy Policy is independent of other privacy, confidentiality policies or any other service
practises published by third party companies, such as Facebook Inc., Apple Inc., Google LLC,
Microsoft Corp., Twitter, TIK TOK or any mobile service operator or any third party operating a site oran application or service to which the Site(s) or Services refer to or redirect(s) to, notably byhypertext link, which We do not publish. We assume no liability in this respect.
If you are a performing artist, an artist representative (producer, manager, independent label), a
customer, visitor of the Sites (​“User(s)”​), a service provider, supplier, partner, or processor who hasentered into a contract with Us (collectively or individually "​You"​; ​"Your"​), this Privacy Policy applies
to You.
Minors (as defined by law in various countries) (“​Minors​”) cannot subscribe to the Services orpurchase Products on the Sites without first having their parents or legal guardians' consent andaccept this Privacy Policy. Parents and legal guardians are responsible for the use that is made of theServices, Products, Sites by their Minors.
Pursuant to the General Data Protection Regulation 2016/679 (“​GDPR”​) and other data protection
laws, We reserve the right to amend this Privacy Policy at any time. A notification on the Site(s)'home page will alert You, or a message will be posted in Service(s), or in specific cases, You will
receive an e-mail.
1. What information or personal data do We collect from You and why?

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We may collect and process personal data and other information as listed below (collectively
referred to as "​Data​") to perform our obligations under the contract You signed with Us, or toprovide Products or Services to You.
Please note that We do not collect or process any sensitive personal data (i.e., data which directly or
indirectly reveals racial or ethnic origins, political, philosophical or religious opinions or trade union
membership, as well as genetic, biometric data for the purpose of identifying a single natural person
or which relates to health or sexual life, and for any such purpose). Therefore, We ask You to abstain
from sending any such data over to Us.
Our contracts and registration forms indicate any specific Data which You are required to provide.
1.1 Personal Data
Personal Data means information that directly or indirectly relates to You as an identified or
identifiable natural person. This may concern, depending on the contract, the Sites, the Products orServices, Your status and/or the means of collection, all or part of the following Personal Data:
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Name(s) and surname;
Postal address (invoicing or delivery);Landline or mobile (personal or professional) phone number;
Email address;
Banking information (bank or other account information, bank account details, credit/charge
card information, number, expiry date, visual cryptography);
Passport number or ID number;
Spoken language or chosen language for the Sites or Services
Any confidential information to help You recall Your personal identifiers or passwords;
For Minors: their parents or legal guardian’s last name, first name, and email address;
For performing artists or their representatives only: their stage name, textual, graphic,
photographic or video elements ​or sound and date elements related to a sound recording
reproducing the performance ("​Recording​") or videos reproducing an audio-visual work
produced by setting images to illustrate the interpretation of a musical work and dates that is
the subject of a Recording ("​Music Video"​);sleeves, words, videos, titles of works(compositions with or without words), dates, names, stage names, pseudonyms, biographies,
videos and photos of performing artists, names of songs and albums and associated artists,
the year of release of songs and albums and the name of the person or entity that holds therights to album songs, arrangements, and/or illustrations;necessary metadata to identify the works fixed on the Recordings and Music Videos, andtheir assigns, in particular the authors', composers', publishers' names, or all assigns, ISWC,
ISRC, UPC codes, etc ;only in case of registration for Services requiring the collection of such information: the tax
identification number;Content of the cart of Products or Services;
IP address (number automatically assigned by your Internet Access Service Provider or the
MAC address of your electronic devices from which access to the Site(s) is made and which
are subject to an automatic identification and recording for each use of the Site(s);Demographic data on Users (e.g. age, gender, place of residence);
Data on Users' tastes, musical preferences (playlists) or other shared data collected frommusic platforms;
Technical information, such as cookies (for more information ​Cookie Policy

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Geolocation data, in particular through GPS signals sent by mobile phone devices: when
Users use geolocation services offered by the Sites, for example to offer them personalised
advertisements, We will first collect their express authorisation (opt-in). Users may in thatcase, at any time, revoke such authorisation (opt-out);
Third party's data (i.e., contacts, friends) provided by Users. You must obtain such third
party’s express consent before You share their data with Us.

1.2 Other information
We also collect other data that does not necessarily lead, directly or indirectly, to Your identification
as a natural person ("​Other Information​").
In such a case, We will process it in accordance with the conditions described and for the purposes
set out in section 3 below. These Other Information may be:
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Information on the Users' Internet browser and devices to access the Sites, such as the typeof device, screen resolution, version of operating system, type and version of the Internet
browser, as well as the type and version of the Service used. A unique identifier may be
assigned to the device from which Users access the Service(s) delivered by Us or its service
providers;
Data relating to Users' use of widgets, mobile applications or other communication services:within this context We may collect the unique identifier, as well as Other Information relating
to the connecting device in order to provide content and advertising to the devices. It may
also collect the date and time of access to the servers, as well as the downloaded files andinformation;
Server Log files to calculate the Services rate of use, manage the Services, diagnose problems
affecting the servers, or determine Users' geolocation data;
Information collected using cookies, clear gifs, web beacons, pixel tags or other similar
technologies (for more information, please read our ​Cookie Policy​;
Demographic or Other Information as long as it does not allow the person's identification;
Information on the Services' use via analytical tools enabling Us to provide You withenhanced performance level. The information thus collected may provide Us withinformation regarding the most used services and functions, the type of equipment used, its
characteristics, country, and downloading language;
Information cross-referencing to create User profiles;
Responses to a survey or questionnaire submitted by Us on the use of the Products, Services
or the Sites.

2​. How do we collect Your Data?
We collect Your Data from:
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The contract You entered into with Us;
The account You created or Services You subscribed to;
Viewing, ​download​ing or using a Site;
Your purchases;
Your subscription to newsletters or other types of communications;Your claims regarding a Product or Service;Your concert or event tickets purchase;
Public databases;
Commercial or media partnerships for marketing or promotional operations related to ouractivity;

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The use of Your User's personal account via one of the social networks, a platform or athird-party service to connect to one or more of its accounts on the Sites. In such a case,certain Personal Data from the Your social network or other third-party service’s personalaccount may be shared with ​Believe (i.e., the name, e-mail address, photos, contact list,
listening history, songs or favourite artists, and any Other Information to which BELIEVE has
access when You log on through Your personal account on a social network or on any otherthird party service);Your participation via Your personal account to a social network, a third-party platform orservice, or directly on Sites hosting games, competitions, lotteries, quizzes or any otherpromotional operation organised by Us.

We collect Your Other Information via:
● Browsers, devices, and widgets and other digital applications' use on such devices;● Server log files;● Cookies (for more information, please read our ​Cookie Policy​:● Geolocation when Users have given their express consent to Us;● The sharing of information and data.
3. What do We process Your Data for?
We process Your Data to:● Create and administer Your personal accounts;● Perform contractual obligations,● Provide Services or deliver purchased Products;● Conduct and process various payment transactions;● Respond to Your requests or inquiries, or provide and improve customer support;● Organise, implement and manage Your participation in games, contests, lotteries, quizzes, orother similar promotional campaigns, surveys or other features​;● Communicate with You (e.g., administrative, promotional or commercial communications);● Provide, improve, optimise and customize Your User experience and make it easy for You toshare functions on social media;● Implement, ensure and improve Sites or Services security, combat fraud, and prevent data
security breaches as defined by the GDPR;● Analyse, identify, improve and understand the Services and Sites functioning and the trendsof the use of the Sites or Services;● Determine, customize, and improve marketing and promotion techniques efficiency andadapt promotional and advertising campaigns to Your purposes and needs​;● Send, purchase or share gifts or links to albums or songs, music information, videos or otherServices with contacts, friends, and family members or other Users● Fulfil our legal obligations● Manage and administer Your Personal Data in compliance with GDPR
4. On what legal ground can We process Your Data?
We may process Your Data based on:● Your consent;● A contract You entered into with Us;● A legal obligation;● Our legitimate interest (for example, to improve our Products and Services, to prevent fraud,
to secure Sites and Services, or to customize our communication​.
5. Who receives Your data?

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The Data You send to Us, directly or indirectly, is accessed exclusively by authorised individuals, only
when necessary, and for the sole purposes referred to in Section 3 above. We make sure that suchaccess complies with the security measures that We implement.
Data recipients may be:● Our subsidiaries;● Third-party providers with whom We work to facilitate the Services' provision or access to
Sites, such as but not limited to hosting services, data analysis, processing of paymenttransactions and repayment of royalties or orders of Products and Services, providing
infrastructure services, information technology services, customer services, e-maildistribution services, audit or other similar services;● For performing artists or their representatives only: the provided information may, amongst
others, be used to track how certain Recordings sell for ranking purposes. By using ourServices, they agree that Believe may provide sales' Records or Music Videos information tothird parties (e.g. platforms), aggregate this information in diagrams, charts and/or othercomparative information support materials, and also release it in accordance with the
General Terms and Conditions of Sale of the Services.
● Third-party providers or performing artists or managers, producers or labels may send
advertising and promotional communications to Users, subject to the contract they enteredinto with Us. In that case Users will be deemed to have agreed to receive such content via
traditional, digital media or other means of communication;● Third party organisers or managers of promotional campaigns, such as games, contests,lotteries, etc.
Believe ​may also communicate Your Data to duly authorised individuals, only when necessary ​for thesole purposes referred to in Section 3 above, ​in the following cases:
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To comply with applicable law, including the law of countries outside Your place of residence;
To respond to injunctions or requests from public or governmental authorities, including
those outside Your country of residence;
To perform under or enforce the contract, the General Terms and Conditions of Sale and Useof our Services, or to protect our activities or those of our subsidiaries or our performing
artists, managers', labels' and producers' activities;
To protect the rights, security and property of Believe or those of Believe’ subsidiaries,
artists, labels, managers or producers;
To exercise or defend our legal rights or to have such rights recognized;
To make any necessary recourse or to limit damages or any sentences that may bepronounced against Believe or its subsidiaries;
For a reorganisation, merger, acquisition, joint venture or any other form of transfer of all orpart of Believe or its assets to any such third party;
To perform specific data transfers upon receiving Your explicit consent;
To satisfy a public interest;
To protect You, or third parties, from fraud, abuse, illegal acts or breach of contract, or of thegeneral terms of use of the Sites or Services or sale of Products;
You may also decide to communicate Your Data by using the available features on message
boards, discussion forums, chats, share profiles on social networks, blogs or via any othermeans proposed by service providers. In that case, such service providers will be responsible5●for processing Your Data and You will need to carefully read their privacy or confidentiality
policies.
Information, documents or data published or communicated by You in connection with theServices become public domain information and may therefore be made available to otherusers of the Services or generally distributed on the Internet or on other communication
networks. Under no circumstances whatsoever should We be held liable for theconsequences arising from the use or communication of any information or data that was
the subject of a voluntary communication by You through any of the Services.We may use
and communicate such Data in accordance with the general terms and conditions of use ofServices or Products.

6. How long do We use Your Data for? (data retention period)
We keep Data only for the time necessary to execute the contract, achieve the objective pursued,
meet Your needs, execute the contract or meet our legal obligations.
The data retention criteria We established includes:● The term of the contract entered into by You with Us;● The retention period required by applicable law (i.e., accounting or archiving
obligations);● The duration of the Your consent for a specific use​;● For prospects (in the absence of any subscription to a Service or purchase of a Product):
1 year or less from the day of the Data collection;● 6 months or less for cookies or 13 months in specific cases (for more details, please readour ​Cookie Policy
When We no longer need to process Your Data, We delete it from our systems and databases oranonymise it so that You can no longer be identified.
7. Hosting-storage and transfer of your data outside the European Union
Our Services and Sites are controlled and operated from France. This Privacy Policy is subject toFrench law. We take all necessary measures to host and store Your Data on servers located in theEuropean Union.
Due to our global presence, certain Data may be collected, transferred, hosted and/or moregenerally processed outside Your country or jurisdiction of residence. Data protection and data
security requirements differ from place to place and may not offer the same level of protection as
those of Your country or jurisdiction of residence or of origin. However, Believe and its subsidiaries
take appropriate measures to protect the transfer of Your Data. Such measures include the use datatransfer methods approved by the European Commission, and written agreements with ourprocessors to ensure they process the Data they receive from Us according to the law.
In light of the above, User Data may be accessed by law enforcement and/or regulatory authorities
according to the applicable laws of such foreign jurisdictions.
We may, as specified in section 5 above, when needed, disclose Your Data to third parties' partners
in order to ensure the Sites' or Services' maintenance and security, offer certain features, or to
improve the Sites' and Services' functioning and appearance or create new features.
We require such third parties to provide adequate confidentiality and security guarantees, to takethe necessary physical, organisational and technical measures to protect and secure Your Data, in
accordance with applicable law. Any transfer of data outside the European Union shall be governed

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by guarantee mechanisms approved by the European Commission and/or the local competentauthorities.

8. Security measures
We implement appropriate physical, technical, administrative and organisational security measuresin order to best protect, Your Data against loss, theft, misuse, abusive use, fraudulent access,disclosure, alteration and destruction.
No data transmission on the Internet can be 100% secure but We are committed to implementing
security standards recognised in our industry and designed to protect and prevent unauthorised
access, disclosure and use of Data.
These measures include but are not limited to:● Storage on secure servers within the European Union;● Protection, including through data encryption processes, such as Secure Sockets Layer(“​SSL​”) for credit card transactions and other bank payment transactions that require theuse by Users of an SSL-enabled browser, such as Safari, Netscape Navigator 3.0 (or later
version), Chrome, Firefox or Internet Explorer;● Limited access of employees or third-party staff to databases containing the Data;● Contractual obligations for our staff handling Data which impose confidentiality
requirements they must fulfil.
In addition, You have the opportunity,on the Sites or when using the Services, to create an accessaccount or user account containing an identifier and password that You only are deemed to know toprotect access to Your account. In order to further protect Your Data, We recommend that You
periodically change your password and under no circumstances should You disclose Your identifiers
to anyone.
9. Your rights
If You reside in France you benefit from the protection of the law of 6 January 1978, known as the
French Data Protection Act. Residents of the European Union/European Economic Area benefit fromthe ​GDPR ​as follows:● Right to Information​: right to obtain clear, transparent and understandable information on how
We use Your Personal Data;● Right of access​: right to access Your Personal Data held by Us about You;
● Right of rectification, opposition or limitation​: right to have Your Personal Data corrected if they
are inaccurate or incorrect and/or to complete them;● Right to erasure/right to be forgotten: right to request the erasure or deletion of Your Personal
Data. This right may, however, be limited by Us by legal grounds or legitimate interest in
maintaining said Personal Data. Such a request will result in the termination of User's
customer/user account and the User will no longer be able to access the Sites or Services;● Right to object to direct marketing​: right to request or modify Your choice at any time to nolonger receive communications relating to the offers of Services, Products, news or events fromUs or third-party partners. In this case, You may use the hyperlink provided for this purpose ineach email or promotional communication received or the STOP SMS in each promotional SMS
received. Users may also request to receive non-personalised communications on the Products
and Services. We will then use our best efforts to inform our third-party partners unless such
communication proves impossible or requires disproportionate efforts. In this case, You will be
responsible for contacting the third party in question directly in order to request de-registration/
unsubscribing/ withdrawal from receipt of said communications;

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Right to withdraw consent at any time for consent-based data processing: ​right to withdraw
Your consent to the processing of Your Personal Data when such processing is based on consent;
Right to data portability​: right to request copying, transferring Your Personal Data to anotherdatabase. This right applies only to Personal Data provided by Users, and provided that theprocessing is based on an agreement or consent and made using automated processes. We will
return to Users the Data in a structured manner and in a legible format.

In order to exercise these rights, please use ​this form​.
If we do not satisfy Your request, You may contact Your local data protection authority. For France,
You may contact the CNIL “​Commission Nationale de l’Informatique et des Libertés” ​via www.cnil.fr
or
CNIL, 3 Place de Fontenoy TSA 80715 - 75334 Paris Cedex 07.
10. What if a data breach occurs?
In accordance with articles 33, 34 and 55 of the GDPR, if We are victim of a Data breach or are awareof such breach, We will report it to the competent local authority and when legally required, notify
You of such breach.
BELIEVE will comply with other applicable law containing information security breach
reporting/notification requirements, as applicable, depending on the location of the data subjects
and other relevant factors.
11. How can You contact us?
To contact Us please go to: ​https://www.believemusic.com/contact/

Special notes to:
TUNECORE Users, ​please read
California residents, ​please read
UK residents, ​please read
Italy residents, ​please readSingapore residents: You can contact the Believe Data Protection Officer at
dposingapore@believe.com
People’s Republic of China residents, please ​click here​ to contact Us about data protection

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