Effective as of 1 April 2022
- About this Policy
- Your personal data rights and controls
- Personal data we collect about you
- Our purpose for using your personal data
- Sharing your personal data
- Data retention and deletion
- Transfer to other countries
- Keeping your personal data safe
- Changes to this Policy
- How to contact us
1. About this Policy
This Policy describes how we process your personal data at OPA!
It applies to your use of:
- all OPA! streaming services as a user. This includes use of these services under our free or paid options (each a "Service Option"); and
Hereinafter referred to as "OPA! Service".
From time to time, we may develop new or offer additional services. They'll also be subject to this Policy, unless stated otherwise when we introduce them.
This Policy is not...
2. Your personal data rights and controls
Privacy laws, including the General Data Protection Regulation ("GDPR"), give rights to individuals over their personal data.
Your rights and their descriptions are as follows.
It’s your right to...
Access Be informed of the personal data we process about you and to request access to it
Rectification Request that we amend or update your personal data where it’s inaccurate or incomplete
Erasure Request that we delete certain of your personal data
Restriction Request that we temporarily or permanently stop processing all or some of your personal data
Object Object to us processing your personal data at any time, on grounds relating to your particular situation. Object to your personal data being processed for direct marketing purposes
Data Portability Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service
Not be subject to automated decision-making Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect
How to exercise your rights with OPA!
Access: To request a copy of your personal data from OPA!, email us at firstname.lastname@example.org or use the contact form.
Access: Rectification: You can edit your User Data under "Edit profile" in your account. With any further demand or issues please contact us at email@example.com.
- You can remove content from your profile by selecting the relevant content and choosing to remove it. For example, you can remove any text or graphic content you uploaded to the OPA! platform
- To request erasure of your other personal data from OPA! (e.g. your User Data, Usage Data and other data listed in Section 3 'Personal data we collect about you' below), email us at firstname.lastname@example.org.
Your other rights: You can contact OPA! directly to exercise your rights at any time (see Section 11 'How to contact us').
In addition, here are more privacy resources and controls:
You also have the right to contact the Information Commissioner’s Office, the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals about any questions or concerns.
3. Personal data we collect about you
This section sets out the categories of personal data we collect and use.
Collected when you sign up for the OPA! Service or when you update your account
Personal data that we need to create your OPA! account and enables you to use the OPA! Service. The type of data collected depends on the type of Service Option you have, how you create your account, the country you are in, and if you use third party services to sign in.
This may include your:
- profile name
- email address
- phone number
- date of birth
- street address
We receive some of this data from you e.g. from the sign up form or account page.
We also collect some of this data from your device e.g. country. For more information about how we collect country, see “Your general (non-precise) location”.
Street Address Data We may ask for your street address for the following reasons:
- to check eligibility for a Service Option
- for tax administration
- to deliver physical goods or gifts requested by you
Collected through your use of the OPA! Service
Usage Data Personal data collected about you when you’re accessing and/or using the OPA! Service.
There are a few types of information this includes, detailed in the following sections.
Information about how you use OPA!
- Information about your OPA! Service Option.
Your actions with the OPA! Service (including date and time), such as:
- search queries
- streaming history
- playlists you create
- browsing history
- account settings
- interactions with other OPA! users
- your use of third party services, devices and applications in connection with the OPA! Service
- Inferences (i.e., our understanding) of your interests and preferences based on your usage of the OPA! Service.
- Content you post to any part of the OPA! Service, such as images, text, playlist titles, communications, and other types of content.
Your technical data
- URL information
- Online identifiers such as cookie data
Information about the devices you use such as:
- network connection type (e.g. wifi, 4G, LTE, Bluetooth)
- network and device performance
- browser type
- information enabling digital rights management
- operating system
Your general (non-precise) location
This may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency).
We need this to meet geographic requirements in our agreements with the owners of content on the OPA! Service, and to deliver content and advertising that’s relevant to you.
Your device sensor data
Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) if needed to provide features of the OPA! Service that require this data.
Additional data you may choose to give us
Payment & Purchase Data
If you make any purchases from OPA! (including a paid Service Option) or sign up for a trial
- Your Paypal email address
When you complete any forms, respond to a survey or questionnaire, or take part in a contest or sweepstake, we collect the personal data you provide.
Collected from other (‘third party’) sources
If you register for or log into our services using another service, we’ll receive your information from them to help create your account with us.
Third party applications, services and devices you connect to your OPA! account
If you connect your OPA! account to a third party application, service and/or devices, we may collect certain information from them to make the integration possible.
These third party apps, services or devices may include:
- social media
We’ll ask your permission before we collect your information from certain third parties.
Technical service partners
We work with technical service partners that give us certain data, such as mapping IP addresses to non-precise location data (e.g., city, state).
This makes it possible for OPA! to provide the OPA! Service, content, and features.
If you choose to pay OPA! by invoice, we may get data from our payment partners.
This allows us to:
- send you invoices
- process your payment
- give you what you’ve purchased
Advertising and marketing partners
We may get data about you from certain advertising or marketing partners.
This may include:
- cookie id
- mobile device id
- email address
- inferences (i.e., our understanding) of your interests and preferences
This allows us to deliver more relevant ads and marketing.
4. Our purpose for using your personal data
This section below sets out:
- our purpose for processing your personal data
- our legal justifications (each called a "legal basis") under data protection law, for each purpose
- categories of personal data which we use for each purpose (see more about these categories in Section 3 'Personal data we collect about you')
Here is a general explanation of each "legal basis" to help you understand the section:
Performance of a Contract:
When it's necessary for OPA! (or a third party) to process your personal data to:
- or verify information before a new contract with you begins.
- Legitimate interest: When OPA! (or a third party) has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other OPA! users. For example, using your Usage Data to improve the OPA! Service for all users. Contact us if you want to understand a specific justification.
- Consent: When OPA! asks you to actively indicate your agreement to OPA!'s use of your personal data for a certain purpose(s).
- Compliance with Legal Obligations: When OPA! must process your personal data to comply with a law.
|Purpose for processing your data||Legal basis that permits the purpose||Purpose for processing your data|
|To provide the personalized OPA! Service. (You can watch our video about Personalization to understand more.)||
|To understand, diagnose, troubleshoot, and fix issues with the OPA! Service.||
|To evaluate and develop new features, technologies, and improvements to the OPA! Service.||
|For marketing, promotion, and advertising purposes.||
|To comply with legal obligations and law enforcement requests.||
|To establish, exercise, or defend legal claims.||Legitimate interest||
|To conduct business planning, reporting, and forecasting.||Legitimate Interest||
|To process your payment.||
|To detect and prevent fraud, including fraudulent payments and fraudulent use of the OPA! Service.||
|To conduct research, contests, surveys, and sweepstakes.||
5. Sharing your personal data
This section sets out the categories of recipients of the personal data collected or generated through your use of the OPA! Service.
Publicly available information
The following personal data will always be publicly available on the OPA! Service:
- Your profile name
- Your profile photo
- Your public playlists
- Who you follow on the OPA! Service
- Who follows you on the OPA! Service (you can remove followers)
Personal data you may choose to share
We will only share the following personal data with those outlined in the table below:
- where sharing of particular personal data is needed for the use of a OPA! Service feature, or a third-party application, service, or device, which you have chosen to use; or
- if you otherwise grant us your permission to share the personal data, e.g., by selecting the appropriate setting in the OPA! Service or by giving your consent
|Categories of recipients||Reason for sharing|
|Third party applications, services and devices you connect to your OPA! Account||
To connect your OPA! account, and/or allow you to use the OPA! Service in connection with third party applications, services or devices.
Examples of such third party applications, services and devices include: social media applications, speaker devices, televisions, automotive platforms, or voice assistants, which interact with the OPA! Service.
You can see and remove many third party connections under “Apps” in your account.
To enable you to use the OPA! Support Community service.
When you register for an account on the OPA! Support Community, we’ll ask you to create a specific profile name. This will be publicly displayed to anyone who uses the OPA! Support Community. We’ll also display any questions or comments you post.
|Other OPA! users||
To share information about your use of the OPA! Service with other OPA! users, including your ‘OPA! Followers’.
For example, under “Social” settings you can choose whether to share your recently played artists and your playlists on your profile.
|Artists and record labels||
To receive news or promotional offers directly from artists, record labels or other partners.
You may choose to share personal data (for example, your email address) for this purpose. You’ll always have the option to change your mind and withdraw your consent at any time.
Information we may share
See this table for details of who we share to and why.
|Categories of recipients||Reason for sharing|
So they can provide their services to OPA!.
These service providers may include those we hire to:
|Payment processors||So they can process your payments, and for anti-fraud purposes.|
So our ad partners can help us deliver more relevant advertising to you on the OPA! Service.
For example, our ad partners help us facilitate tailored advertising:
To promote OPA! with our partners. We share some personal data with these partners where necessary to:
|Other partner sharing||
We may share personal data with partners to help us understand and improve the performance of our products and partnerships.
You can see and remove many partner connections under “Apps” in your account.
|Academic researchers||For activities such as statistical analysis and academic study, but only in a pseudonymised format. Pseudonymised data is where your data is identified by a code rather than your name or other information that directly identifies you.|
|Other OPA! group companies||Where we have offices, to carry out our daily business operations and so we can maintain and provide the OPA! Service to you.|
|Law enforcement and other authorities||
When we believe in good faith it’s necessary for us to do so, for example:
|Purchasers of our business||
Where we sell or negotiate to sell our business to a buyer or possible buyer.
6. Data retention and deletion
We keep your personal data only as long as necessary to provide you with the OPA! Service and for OPA!'s legitimate and essential business purposes, such as:
- maintaining the performance of the OPA! Service
- making data-driven business decisions about new features and offerings
- complying with our legal obligations
- resolving disputes
If you close or request that we close your account, we'll delete or anonymise your personal data so it no longer identifies you, unless we're required to keep something or we still need to use it for a legally justifiable reason.
Here are some examples of situations where we're legally allowed or required to keep some of your personal data:
- if there's an unresolved issue relating to your account, such as an outstanding credit or unresolved claim or dispute
- for our legal, tax, audit and accounting obligations
- for our legitimate business interests such as fraud prevention or to maintain security.
7. Transfer to other countries
When carrying out the activities described in this Policy, OPA! shares your personal data internationally with OPA! group companies, subcontractors and partners. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.
transfer personal data internationally, we use tools to:
- make sure the data transfer complies with applicable law
- help to give your data the same level of protection as it has in the EU
We do this using a variety of protections, as appropriate for each data transfer. For example, we use:
- Standard Contractual Clauses (or an alternative legal tool) to require the third party to protect your data and to provide you with EU-level rights and protections
- technical protections, such as encryption and pseudonymisation
- policies and processes to challenge disproportionate or unlawful government authority requests
You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.
8. Keeping your personal data safe
We're committed to protecting our users' personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.
We have implemented various safeguards including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
To protect your user account, we encourage you to:
- use a strong password that is unique to your OPA! account
- never share your password with anyone
- limit access to your computer and browser
- log out once you have finished using the OPA! Service on a shared device
- read more detail on protecting your account
If other individuals have access to your OPA! account (for example if you've given them permission to use your account on a shared device), then they can access personal data, controls and the OPA! Service available in your account.
It's your responsibility to only provide individuals with permission to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your OPA! account may impact your personalised recommendations and be included in your data download.
The OPA! Service has a minimum "Age Limit" in each country. The OPA! Service is not directed to children whose age:
- is under the age of 13 years
- or, makes it illegal to process their personal data
- or, requires parental consent to process their personal data
We do not knowingly collect personal data from children under the applicable Age Limit. If you're under the Age Limit, please do not use the OPA! Service, and do not provide any personal data to us.
If you're a parent of a child under the Age Limit and become aware that your child has provided personal data to OPA!, please contact us.
If we learn that we've collected the personal data of a child under the applicable Age Limit, we'll take reasonable steps to delete the personal data. This may require us to delete the OPA! account for that child.
When using a shared device on the main OPA! Service, you should be cautious about playing or recommending any content to individuals under 18 years old which could be inappropriate for them.
10. Changes to this policy
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the OPA! Service or send you an email or device notification.
11. How to contact us
For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:
- Use our contact form
- Email email@example.com
- Write to us at: CCA, 350 Sauchiehall Street,Glasgow, G2 3JD
OPA! is the data controller of personal data processed under this Policy.