Introduction

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Audrey Limited (“Audrey”) is committed to protecting and respecting your privacy. The Audrey team are customers themselves of other apps and fully appreciate and respect the importance of privacy on the web. We know that you care how information about you is used and shared, and we appreciate your trust in us to do that carefully and sensibly. We have designed the Audrey app and our systems with your security and privacy in mind.

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Audrey provides a Service for listening to digital audiobooks via the Audrey mobile application that is available for download on your device (the "App").

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This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (”personal information”) through your use of the Audrey website, services and mobile application (together the “Service”). Please ensure that you have read this Privacy Policy and understood how we use your personal information before accessing or using the Service.

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Who is responsible for the use of your personal information?

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Audrey Limited of Churchill House, 137 Brent Street, London, NW4 4DJ is the controller of the personal information we hold about you in connection with your use of the Service. This means that we determine and are responsible for how your personal information is used.
 

What personal information do we collect from you and how do we use it?
 

We collect your personal information in order to provide and continually improve our products and services. Here are the types of personal information we collect:

Information you provide to us directly*.* We collect personal information that you voluntarily submit directly to us when you use the Service. This can include information you provide to us through the website; when you download, set up an account and use the App; correspond with us by e-mail or otherwise; subscribe to our mailing lists or other forms of marketing communications; when you report a problem with the Service or use some other feature of the Service.

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We also collect information and content you choose to post to the Service, such as text, reviews, ratings, photos, audio, and other media, each of which you present through technology available through the Service, including but not limited to our Audrey in-app community.

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If you choose not to provide such personal information, we may not be able to provide those parts of the Service to you or respond to your other requests.

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Information we collect automatically

 

We also automatically collect personal information indirectly about how you access and use the Service, your interaction with content and services and information about the device you use to access the Services. For example, we may collect: Information about the features you use and the pages you view; Information about your device such as your IP address, device identifier, device type, model and manufacturer, connection information such as device application or browser type and version, browser plug-in types and versions, operating system, or time zone setting; the location of your device or computer; and information about your usage patterns (for example, how often you use the Service); Login, e-mail address, and password; content interaction information, such as content and digital audiobook downloads, streams, playback details, listening behaviour like start and stop points, listening duration, reading behaviour (e.g. when and how regularly you listen), and network details for streaming and download quality, including information about your internet service provider, application usage, connectivity data, and any errors or event failures; Audrey Service metrics e.g. the occurrences of technical errors, your interactions with service features and content, your settings preferences and backup information; Purchase and content use history, which we sometimes aggregate with similar information from other customers to create features; cookie number; products and/or content you viewed or searched for, page response times, download errors, page interaction information such as scrolling and clicks; we may also use device identifiers, cookies, and other technologies on devices, applications and our web pages to collect browsing, usage or other technical information for fraud prevention purposes.

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You provide information to us when you: Search for products or services; place an order; download, stream, view digital audiobooks or use content on a device or through a service or application; download or use an application on a device; provide information in Your Profile or on your Bookshelf Page; Configure your settings on, provide data access permissions for, or interact with the Audrey Service; Communicate with us by phone, e-mail, or otherwise; Complete a questionnaire, a support ticket, or feedback form; Upload or stream text, images, audio, videos or other files; Participate or contribute in community features, like providing referrals, reviews and ratings.

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As a result of those actions, you might supply us with such information as: your name, phone number; IP address; payment information; your location information; people to whom you’ve sent products, content of reviews and e-mails to us; credit history information; and device log files and configurations.

Examples of information you can access through Audrey Services include: The status of your orders (including invoices and subscriptions); Your order history; Personally identifiable information (including name, e-mail, password, profile picture, communications); Payment settings; Notification settings; Digital audiobooks that you recently listened to.

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We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

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We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include: research, data analysis, improving the Service and developing new products and features. We may also share such anonymised and aggregated information with others e.g. audiobook rights owners and book publishers.

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We do not collect any Special Categories of Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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For what purposes does Audrey process your personal information?

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We process your personal information to operate, provide, and improve the Audrey Services that we offer to our customers. These purposes include:

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• To provide you with the features and functionality of the Service, to monitor and improve the Service and to develop new products and services.

• Purchase and delivery of products and services. We use your personal information to take and handle orders, deliver products and services, process payments, and communicate with you about orders, products, services, and promotional offers.

• Provide, troubleshoot, and improve the Audrey Service. We use your personal information to provide functionality, analyse performance, fix errors, and improve usability and effectiveness of the Audrey Service.

• Recommendations and personalisation. We use your personal information to identify your preferences, recommend content, features, products and services that might be of interest to you, and personalise your experience with the Audrey Service.

• Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property or personal safety of Audrey, its users or others.

• Communicate with you. We use your personal information to communicate with you in relation to Audrey Services via different channels (e.g., by phone, text, email, chat).

• Fraud Prevention and Credit Risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our customers, Audrey Limited, and others.
   

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 your data for that purpose.

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How long will we store your personal information?

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We will usually store the personal information we collect about you for no longer than necessary for the purposes set out above, in accordance with our legal obligations and legitimate business interests.

We may, however, need to retain your personal information for longer if we are required to do so by law.

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Does Audrey share your personal information?

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We may also share your personal information with the following:

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• Other service providers and advisors. We may share your personal information with third party service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, publishers and rights owners, mailing, email or chat services, fraud prevention, cloud or web hosting, or analytic services. Examples: Sending in-app notifications: SendGrid; Firebase Cloud Messaging. Web, Mobile Analytics and Bug Tracking: Mixpanel; Sentry; Google Analytics. App Distribution: Google Play Store; Apple App Store and TestFlight. Storing and Processing of User Data: Cloud Functions for Firebase; Firebase Firestore. User Account Registration and Authentication: Firebase Authentication. Web hosting (access logs): Wix. These third party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.

• Third parties at your request. For example, you may have the option to share your content with other users of the Service.

• Business Transfers. As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the customer consents otherwise). Also, in the unlikely event that Audrey Limited or substantially all of its assets are acquired, customer information will be one of the transferred assets.

• Protection of Others. We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Audrey Limited, our users, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

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Other than as set out above, you will receive notice when personal information about you might be shared with third parties and you will have an opportunity to choose not to share the information.

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What about Cookies and other identifiers?

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Our Service uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "cookies") to distinguish you from other users. This helps us to provide you with a good experience and allows us to monitor and analyse how you use and interact with our Services so that we can continue to improve our Services.

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We use the following types of cookies:

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• Strictly necessary cookies. These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into your account.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Service when they are using it. This helps us to improve the way our Service works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our Service. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your region). If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org.

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The cookies we use are designed to help you get the most from the Service but if you do not wish to receive cookies, most browsers and devices allow you to change your cookie settings. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our Service. These settings will typically be found in the "options" or "preferences" menu of your browser. ‍ For mobile users, you have controls in your device Operating System that enable you to choose whether to allow cookies or share your advertising ID with companies like Audrey or our advertising service providers. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt out of interest-based ads’. Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

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What about tracking technologies used in our emails?

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Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.

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Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default. Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.

Does the App have links to third-party sites?

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The Service may contain links to third-party websites and apps, including news publications. If you follow a link to any of these websites, they may collect information about you when you interact with their content, advertising, and services. Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

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How do we protect, store and transfer your personal information?

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International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Service from the EEA or UK, in the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.

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We design our systems and devices with your security and privacy in mind. We work to protect the security of your personal information during transmission by using encryption protocols and software. We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal customer information. Our security procedures mean that we may ask to verify your identity before we disclose personal information to you. It is important for you to protect against unauthorised access to your password and to your computers, devices, and applications. We recommend using a unique password for your account that is not utilised for other online accounts. Be sure to sign out when you finish using a shared computer or device.

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How long do we keep your personal information?

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We keep your personal information to enable your continued use of Audrey Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Notice, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you. For example, we retain your transaction history so that you can review past purchases, re-download your content, and to improve the relevancy of products and content we curate and recommend.

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What are your rights with regard to your personal information? ‍

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If you are accessing the Service from the EEA or the UK, in accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

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• Right of access. The right to obtain: (i) confirmation of whether, and where, we are processing your personal information; (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods; (iii) information about the categories of recipients with whom we may share your personal information; and (iv) a copy of the personal information we hold about you.

• Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.

• Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

• Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

• Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
   

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

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‍If you wish to exercise one of these rights, please contact us at [email protected]

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You also have the right to lodge a complaint to your local data protection authority.

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Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
 

Whenever we transfer personal information to countries outside of the European Economic Area or the UK, we ensure that the information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection. We rely on European Commission adequacy decisions or use contracts with standard safeguards published by the European Commission (you can ask Customer Services for a copy of these) when we transfer personal information to countries outside of the European Economic Area. We rely on similar measures under UK law when we transfer personal information to countries outside of the UK.
 

What Choices Do I Have?
 

If you have any questions or objections as to how we collect and process your personal information, please contact [email protected]. As discussed above, you can choose not to provide certain information but then you might not be able to take advantage of the Audrey Service. You can add or update certain information. When you update information, we usually keep a copy of the previous version for our records. If you don't want to receive in-app notifications from us, please adjust your notification settings in the app or on your device. The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. You can manage your cookie preferences by clicking on 'Cookie Preferences'. 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 any further processing of your data for that purpose.
 

In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. If you wish to do any of these things, please contact [email protected].
 

What Information Can I Access?
 

You can access your information, including your name and purchase history in the Your Profile section of the Audrey app.
 

Are Children Allowed to Use Audrey Services?
 

The Service is not directed at persons under 18 and we do not knowingly collect personal information from any persons under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

EU General Data Protection Regulation and UK Data Protection Law
 

The EU GDPR and UK data protection law requires a legal basis for our use of personal information. Our basis varies depending on the specific purpose for which we use personal information. We use:
 

• Performance of a contract when we provide you with products or services, or communicate with you about them. This includes when we use your personal information to take and handle orders, deliver services, and process payments.

• Our legitimate business interests and the interests of our customers when we improve Audrey Services, when we detect and prevent fraud and abuse in order to protect the security of customers, ourselves, or others.

• Your consent when we 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 your data for that purpose.

• Compliance with a legal obligation when we use your personal information to comply with laws. For instance, we retain transactional records in order to comply with tax requirements.
   

These and other legal bases depending on the purpose for which we use personal information.
 

Contacts, Notices & Revisions
 

If you have any concern about privacy at Audrey Limited or want to contact one of our data controllers, please contact us on [email protected] with a thorough description of the issue and we will try to resolve it for you. Further, the data protection officer for the above mentioned data controllers can be contacted at [email protected]. You can file a complaint with the Information Commissioner’s Office for Audrey Limited.
 

Our business changes constantly and our Privacy Notice will change also. We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the "last updated" date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.
 

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by a notification within the App. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.
 

Contacting us
 

Please contact [email protected] if you have any questions, comments or requests regarding this Privacy Policy. ‍
 

Last updated: 21st April 2022