Privacy Policy

Last Updated and Effective: January 2, 2026

French | Spanish (for US and Canada residents)

This Privacy Policy explains how TouchTunes Music Company, LLC (and our wholly owned subsidiaries) (the “Company,” “we,” “us,” or “our”) collects, uses, and shares your personal data and the rights that you have with respect to such data.

This Privacy Policy covers all products and services that we make available, as well as our advertising, marketing, promotions, and communications (e.g., sweepstakes, surveys) (the “Company Services”). Your accessing or use of any or all of the Company Services, and any dispute over privacy or our handling of your personal data, are subject to both this Privacy Policy and our Terms of Service.

These Company Services include, without limitation, our TouchTunes-branded digital jukeboxes and mobile application(s); our service currently branded “TouchTunes Unlimited”; our BullShooter- or Spider-branded dartboards and our BullShooter-branded mobile application(s); our payment services; our league and tournament products, services and mobile application(s); our wagering functionalities; our sweepstakes, contests, and promotional events; our current consumer loyalty program (the “Loyalty Program”) and venue staff loyalty program (the “Staff Program”); and our websites, push notifications, emails, in-app messages, text messages, social media posts, and other forms of communications.

Additional terms and conditions may apply to you, depending on where you reside. Please see Exhibit A of this Privacy Policy for such terms and conditions.

If you are a resident of California: Please refer to Exhibit A California Notice at Collection and Privacy Rights, which includes additional information about the personal data that we may collect about you and your rights under California privacy laws.

In some cases, additional or supplemental privacy policies may be provided and will apply to certain personal data collected and processed by us. These additional policies or notices will control only to the extent that there is a conflict with this Privacy Policy and only with respect to your personal data that is subject to that additional notice.

WE MAY, AT ANY TIME AND FROM TIME TO TIME, IN OUR SOLE DISCRETION, WHEN PERMITTED BY LAW WITHOUT PRIOR NOTICE TO YOU, CHANGE ANY AND ALL TERMS AND CONDITIONS OF THIS PRIVACY POLICY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE AS OF THE DATE OF POSTING THE REVISED VERSION ON THIS PAGE. ANY CHANGES TO THIS PRIVACY POLICY WILL SUPERSEDE AND REPLACE IN ITS ENTIRETY THE PREVIOUS VERSION OF THIS PRIVACY POLICY AT THE TIME OF SUCH POSTING AND WILL BE APPLICABLE TO ALL FUTURE DISPUTES BETWEEN YOU AND THE COMPANY. IT IS YOUR RESPONSIBILITY TO REVIEW THIS PRIVACY POLICY FROM TIME TO TIME TO KEEP INFORMED OF ANY CHANGES. IF YOU CONTINUE TO ACCESS OR USE ANY OF THE COMPANY SERVICES FOLLOWING ANY SUCH CHANGES, SUCH ACCESS OR USE WILL CONSTITUTE YOUR ACCEPTANCE OF SUCH CHANGES. 
 

CONTENTS
 

1. Collecting Your Personal Data

2. Using Your Personal Data

3. Using Aggregated and De-Identified Data

4. Sharing Your Personal Data

5. Cookies and Tracking

6. Mobile Phone Data

7. International Data Transfers

8. Your Privacy Choices

9. Retention of Your Personal Data

10. Your Privacy Rights

11. Children's Data

12. Security

13. Contact Us

1.  Collecting Your Personal Data

As part of your access to and use of one or more Company Services (including without limitation, for example, visiting our websites, creating a user account, using our hardware (e.g., jukeboxes, dartboards), entering our sweepstakes, engaging with our social posts, taking our surveys), we collect and in some cases generate personal data related to you (or, in certain cases, we engage with third-party providers to do so on our behalf). This data may vary depending on the Company Service and we may, in certain circumstances, collect or receive personal data related to you separate from the Company Services. For example, we collect different personal data when you create a user account than when you comment on one of our social posts, and we collect different personal data to create an account for our music services than we do to create an account for our bar games services, as our bar games services may offer leagues, tournaments, rankings, prizes, and other opportunities.

Personal data that you provide to us

• Account data: We collect the personal data that you provide to us in creating and updating your account(s), building your public and private account profiles, or otherwise engaging with the Company Services. Such personal data may include, without limitation, your name, location, user name, social media account handles, email address, and if you have signed up for our Staff Program, your employer, job title, and mobile phone number. Certain engagement with the Company Services may require that we collect additional personal data, such as your gender, birthdate, social security number (or equivalent), or tax information in order to qualify you to access certain Company Services (e.g., gender- or age-specific darts tournaments) or so that we may comply with applicable local, state, provincial, national, and international laws, rules, regulations, and government orders (“Applicable Law”) (e.g., to provide sweepstakes winners with prizes).
   
• Purchase data: We collect personal data related to any purchases that you make or subscriptions you enter into with respect to the Company Service(s), such as your Credit balance; your authorizations to enable, send, or receive Company credits (“Credits”); and, if applicable, your delivery address for physical goods.
   
• Your content: We collect all content and communications that you send, upload, or otherwise provide to, post or store on, or otherwise communicate via or in connection with the Company Services (“Your Content”) and personal data related thereto. This personal data may include your name, image, likeness, and/or voice, depending on the contents of Your Content.
   
• Communications: If you contact us directly (such as when you contact our customer service team) or otherwise communicate with us (such as by completing a survey), we may collect your name, email address, other identifying or account data, and any other personal data that you choose to provide in connection with those communications (which may, depending on the circumstances, include demographic identifiers). 
   

Personal data we collect or generate when you access or use the Company Service(s)

• Device data: We may receive personal data about the device and software that you use to access the Company Service(s), such as your IP address, device ID, web browser type, operating system version, phone carrier and manufacturer, your network (and network devices and device identifiers), mobile advertising identifiers, device permissions, and push notification tokens. Some of this personal data may be generated by device sensors, which can measure the motion of your device, or via your device’s microphone or connected headphones. If you have granted device-level permissions, this personal data may also include data about your device phonebook (e.g., your contacts, call records) and images and other data from your device’s camera or gallery.
   
• Location data: We may receive your location data, which may include your precise geolocation data vis-à-vis our hardware locations (such as jukeboxes and dartboards), inferred from your IP address, and/or derived from WiFi or GPS signals.
   
• Purchase data: We may receive data regarding your purchases, such as your purchase history and patterns and your Credit balance, redemption history, and sharing history.
   
• Usage data: We may receive or generate personal data regarding your use of the Company Service(s), such as the time you spend engaging with the Company Service(s), pages or content that you view or engage with, the searches you perform, your song plays on our jukeboxes, your plays, scores, and win-loss data from our dartboards, the performance of Your Content, your purchases of our merchandise, your attendance at dart leagues, tournaments, and other events, and/or the advertising or marketing that you engage with. This personal data may include patterns, such as when you engage with our hardware, how many songs or games you play, or data that generates player rankings (e.g., for tournaments).
   
• Images and audio-video recordings: We may generate images and audio and/or video recordings of darts leagues, tournaments, and individual matches, as well as of other in-person events that we may authorize, operate, or otherwise provide (including without limitation marketing and promotional events). We use this personal data: (a) to validate scoring and win-loss data, as well as to prevent cheating and other fraudulent or unethical behavior; and (b) if this personal data is collected at an in-person event, for marketing, advertising, and other promotional purposes. If you are participating in a darts match on, or you are located in the vicinity of, one of our dartboards, whether in a public or private location, or you are otherwise in attendance at such an in-person event, these images and recordings may include your image, including without limitation your likeness and voice.
   
• Loyalty Program & Staff Program personal data: We may receive personal data regarding your use of our Loyalty Program and, if you have signed up, our Staff Program, such as your qualifying activities, points balance and accumulation patterns, and selected rewards.
   
• Cookies and other trackers: We may receive personal data provided by cookies, pixel tags, or similar technologies, such as pages you visit on our websites (and in which order), searches you perform, and similar data. 

Personal data we receive from third parties

• Third-party source data: We may receive personal data from third-party sources, such as social media companies, publicly available databases, marketing partners, advertising partners, measurement services, and recommendation engines, which help us update or supplement the personal data we hold about you. This may include demographic identifiers and data about your preferences and interests. This may also include personal data from third-party partners that enable linking your third-party partner account with your Company Service account, such as to use your third-party partner credentials to log in to your Company Service account. We may also receive your contact information from other users.

2. Using Your Personal Data

We use your personal data in a number of ways, such as to provide you with the Company Service(s) that you wish to access and use. In some cases, we may have to collect and process personal data to provide you with the requested Company Services. If you do not allow us to use your personal data for these purposes, you may not access or use the relevant Company Service(s) at all. You may access your privacy choices on the Privacy Settings page of your applicable Company Service account, and we may provide other tools to opt in or opt out of certain uses (such as an “unsubscribe” link on the bottom of our marketing communications).

• Provide the Company Services: We use the personal data that we collect in order to operate, deliver, maintain, and improve the Company Services, including without limitation for research, analytics, reporting, and service improvements purposes. For example, we use your login credentials in order to allow you to access your Company Service account, and we use your precise geolocation data to allow you to access our jukeboxes and dartboards so that you can play a song or a match. We also use this personal data to ensure that the Company Services continue to work smoothly and effectively, such as with the latest devices and operating systems.
  • For UK users, we have a permitted lawful reason for this processing because it is contractually necessary to provide you with your requested Company Services pursuant to our Terms of Service.
     
• Necessary Communications Regarding the Company Services: Certain communications are necessary to provide the Company Service(s), such as those relating to account management, purchase or Credit redemption confirmations, and completion of qualifying activities or reward selection for our Loyalty Program or Staff Program. We will also use the personal data we collect to communicate with you following your requests, such as when you contact our customer service team. We will use your personal data to provide these communications to you unless you choose not to access or use any of the Company Services (and, when applicable, delete your user account(s)).
  • For UK users, we have a permitted lawful reason for this processing because it is contractually necessary to provide you with your requested Company Services pursuant to our Terms of Service or because the processing is within our legitimate interests to address your customer service requests, manage billing processes effectively, and improve our user experiences.
     
• Communicate New Elements of the Company Services and Other Related Offers: We use the personal data that we collect to communicate with you regarding the Company Services with which you have engaged (e.g., by creating a user account), such as when new songs are available, darts tournaments are announced, or we have launched new features or functionalities.
  • For UK users, we will have a permitted lawful reason to do so when you have signed up (consented) to receive communications of this nature from us.
     
• Personalize Your Company Service Experiences: We use the personal data that we collect to personalize your experiences on the Company Services, such as by using your past song plays to recommend additional songs that you may like.
  • For UK users, we have a permitted lawful reason for this processing because it is within our legitimate interests to offer a tailored platform to you.
     
• Personalize Your Promotional Offers: We use the personal data that we collect to provide you with more personalized promotional offers, such as free Credits on your birthday or an offer from your most-visited jukebox location for discounted food and beverage.
  • For UK users, we have a permitted lawful reason for this processing because it is within our legitimate interests to offer rewards to and promote loyalty for our customers.
     
• Personalize Your Advertising: We provide third-party advertising in connection with the Company Services and we use the personal data that we collect to provide you with more relevant advertising.
  • For UK users, we will have a permitted lawful reason to do so when you consent to us using cookies or tracking technologies on our platform(s) for advertising purposes.  
     
• Market Other Company Services: We use the personal data that we collect to provide you with marketing communications regarding additional Company Services that may interest you.
  • For UK users, we will have a permitted lawful reason to do so when you have signed up (consented) to receive communications of this nature from us.
     
• Research, Analytics, Reporting, and Improvements: We use the personal data that we collect to gather research and generate analytics regarding your access to and use of the Company Services. We then use these insights to improve the Company Services, both for your and other users’ enjoyment.
  • For UK users, we have a legitimate interest to analyse the performance of the Company Services, including without limitation our platform(s), to ensure that we operate effective services and platforms.
     
• Safety, Security and Legal Compliance: We use the personal data we collect to enhance the safety and security of the Company Services, to verify your identity, and to prevent fraud and other illegal activities. We will also use the personal data that we collect to enforce our Terms of Service, this Privacy Policy, and other Company agreements and policies. This includes investigating and reporting conduct that violates our Terms of Service or Applicable Law, responding to requests from law enforcement (including without limitation subpoenas and court orders), complying with our legal requirements, and pursuing and defending claims, disputes, and legal actions.
  • For UK users, we have a permitted lawful reason for this processing because it is necessary for us to comply with a legal obligation or because the processing is within our legitimate interests to ensure a safe and secure user experience and protect our business.

3. Using Aggregated and De-Identified Data

Research, analytics, reporting, and improvements: We may use and disclose aggregated, de-identified and other non-identifiable data related to our business and the Company Services for quality control, analytics, research, development, reporting, product improvements, and other purposes. Where we use, disclose, or otherwise process de-identified data (meaning data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device), we will maintain and use the information in de-identified form and not attempt to re-identify the information, except in order to determine whether our de-identification processes are reasonable and adequate pursuant to Applicable Law.

4. Sharing Your Personal Data

We may, in certain circumstances, share your personal data with service providers (who provide services to us and process personal information on our behalf) and third parties.

• Other Company Service Users: As you access or use the Company Service(s), we will provide certain personal data to other users of those same Company Services (which, for clarity, may include individuals who do not have an account for such Company Service(s)), such as direct messages to other users, Your Content to the applicable communities, boards, or feeds (which may be available for anyone to join), data regarding Credit sharing, or the data included in your public profile. We may elect to limit such data sharing to only certain other users or to permit you to block individual users on the Company Service(s), but whether or not we offer those features is in our sole discretion. In any event, any such block functionality will not extend to users who do not have an account or to individuals who you may encounter on our social media accounts, at our in-person events, or in either virtual or in-person locations that we do not control. You also may find that certain users, in violation of our Terms of Service, may create multiple accounts, and therefore may still have access to Your Content and your public profile, even after you have blocked that user on a different account.
   
• The Public: In certain circumstances, we may share your personal data with the public, such as on our social media accounts, in tournament announcements, brackets, and leaderboards, and even broadcast on television or streaming platforms (e.g., ESPN®, YouTube®). In most cases, we will ask your permission prior to sharing, but in certain circumstances, your permission or consent may not be required under Applicable Law.
   
• Our Affiliates. We have a number of subsidiaries and other affiliates and we share your personal data with our affiliates in order to operate our business.
   
• Our Service Providers: We engage service providers, acting at our direction, to provide services that help us operate the Company Services or perform other related operations (e.g., marketing). We may share your personal data with these service providers for the sole purpose of assisting them in their performance of such services for us. In certain cases, you may be providing your personal data to both us and the service provider or such service provider may be collecting your personal data on our behalf.
   
• Third-party Products and Services: We may, from time to time, elect to offer third-party products and services in connection with one or more Company Services. For example, our wagering functionality is provided by a third party. If you choose to engage with those products or services, we may share your relevant personal data with the applicable third party and/or you may be asked to provide your personal data directly to such third party.
   
• Photobooth Functionality: If you choose to access or engage with our photobooth functionality, which allows you to take and send pictures of yourself on our jukeboxes, we may share your personal data (including without limitation your image and likeness) with the owner of the email address where the photos are sent, and in certain cases, the public.
   
• League and tournament operators: If you register for a league or tournament, or access or use our league/tournament Company Service, we may share your personal data with third parties operating, providing services for, and/or hosting such league or tournament.  
   
• TouchTunes Unlimited venues: If you use the service currently known as “TouchTunes Unlimited,” we may share your personal data with the third party that owns, operates, or controls access to the premises on which the applicable jukebox is located.
   
• Sponsors and co-sponsors: We may, from time to time, conduct marketing events, sweepstakes, contests, giveaways, and/or other events or promotions with one or more external presenters, sponsors, or co-sponsors. If you participate in any such event or promotion, the personal data we collect from you in connection with your participation may be disclosed to our presenters, sponsors, or co-sponsors.
   
• Analytics partners: We may, from time to time, use third-party analytics services, such as Google Analytics™, to collect and process certain of your personal data.
   
• Advertising partners: We work with advertising partners to host and serve both our advertising and third-party advertising on the Company Services and in other locations. We may share your personal data with these partners (or our relevant service providers may collect your personal data on our behalf) to enable our advertising sales and target advertising to you. We and these partners may use cookies, web beacons, device identifiers, and other technologies to collect personal data (such as IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile applications, links clicked, and conversion data) about your use of the Company Services and other third-party products and services. We may share and use this personal data to better understand your online activity and to target advertising that may be of interest to you, and we may disclose your personal data to our partners to enable targeted advertising.
   
• Measurement partners: We may disclose your personal data to measurement partners.
   
• Artificial intelligence tools: We may share your personal data with a number of artificial intelligence tools in order to operate our business, such as by identifying and remedying errors in the Company Service(s), providing certain features and functionalities (such as generating recommendations for a more personalized user experience), performing analytics and reporting, and if we elect to offer this option in the future, permitting you to generate content using artificial intelligence-powered tools.  
   
• Safety and security providers: We may share your personal data with our safety and security partners, such as those who offer multi-factor authentication or engage in combatting fraud.
   
• Law enforcement, courts, arbitrators, and legal service providers: We may share your personal data with law enforcement, courts, arbitrators, investigators, and our legal service providers to comply with our legal obligations (such as responding to subpoenas and court orders, and handling data access or deletion requests); to assist law enforcement; to investigate and enforce our Terms of Service (and other Company agreements and policies); to protect the rights and safety of the Company (and its affiliates), our employees, our users, and the public; and to pursue and defend claims, disputes, and legal actions.
   
• Potential purchasers or investors: If we seek to restructure or sell (or negotiate to sell) our business, or seek additional investors in our business, we may transfer your personal data to potential buyers and investors (including without limitation to their legal and financial advisors), and ultimately transfer your personal data in connection with such transaction.
   
• Additional third parties with your permission: We may disclose personal data in ways not described above. If we do so, we will notify you, and if required by Applicable Law, obtain your consent.

5. Cookies and Tracking

We, our service providers, and our third parties partners may use cookies, pixel tags, and other similar tracking technologies to automatically collect information about browsing activity, device type, and similar information within our Company Services. This information, which may be considered personal data in some jurisdictions, is used, for example, to analyze and understand how you access, use, and interact with our Company Services; to identify and resolve bugs and errors in our Company Services; to assess, secure, protect, optimize, and improve the performance of our Company Services; to personalize content on our Company Services; and for marketing, advertising, measurement, analytics, and reporting purposes. We may also de-identify and/or aggregate such information to analyze trends, administer our Company Services, and gather broad demographic information for aggregate uses, and for any other lawful purposes.

• Cookies. Cookies are alphanumeric identifiers used for tracking purposes. Some cookies allow us to make it easier for you to navigate our Company Services, while others are used to enable a faster log-in process, to support the security and performance of the Company Services, or to allow us to track activity and usage data within and across our Company Services.
   
• Pixel Tags and Similar Technologies. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. We may use these tracking technologies to understand users’ activities, to help manage content and compile usage statistics, and in emails to let us know when they have been opened or forwarded so we can track response rates and gauge the effectiveness of our communications.
   
• Local Storage Objects. Local storage is a web storage mechanism that allows us to store data on a browser that persists even after the browser window is closed. Local storage may be used by our web servers to cache certain information in order to enable faster loading of pages and content when you return to our websites. You can clear data stored in local storage through your browser. Please consult your browser help menu for more information.
   
• Analytics. We use analytics tools, such as Google Analytics™, to evaluate usage and traffic on our websites. These analytics providers use cookies, pixels, and other tracking technologies to collect usage data to provide us with reports and metrics that help us analyze, improve, and enhance performance and user experience.
   
• Cross-Device Tracking. We and advertising partners we work with may use the data we collect about you within our Company Services, and on other third-party websites and services, to help us and these partners identify other devices that you use (such as a mobile phone, tablet, computer) to interact or engage with us or the Company Services.
   
• Advertising Networks. We work with advertising networks, channel partners, mobile ad networks, analytics and measurement services, and others (“ad networks”) to personalize content, as well as to manage our advertising on third-party websites, mobile applications, and online services. We may share certain information with such ad networks, and we may each use cookies, pixels tags, and other tools to collect usage and browsing information within the Company Services, as well as on third-party websites, mobile applications, and services. This information may include IP address, location information, cookie and advertising IDs, and other identifiers, as well as browsing information.
   
• Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email address, and other contact information) with third parties so that: (a) we can better target advertising, marketing, and other content to you across third-party sites, platforms and services; and (b) in some cases, these third parties can help us enhance our customer lists with additional demographic or other information, so we can better target our advertising, marketing, and other content.
   
• Do-Not-Track. Currently, our Company Services do not recognize web browser “do-not-track” requests. You may, however, disable certain tracking as discussed below (such as by disabling cookies). 

6. Mobile Phone Data

You may elect to provide your mobile phone number in connection with your Staff Program account. Notwithstanding Section 4 (Sharing Your Personal Data), mobile phone numbers and related information and records (such as your permission or consent to receive text messages from us) will not be shared with third parties, except: (a) with service providers who assist us in sending text messages; (b) if we believe disclosure is required by Applicable Law, to comply with law enforcement requests, or as part of legal processes or procedures; (c) in connection with a corporate transaction in which we are acquired by or merged with another company or sell, liquidate, or transfer all or a portion of our assets; (d) when necessary to provide you with the Company Services you have requested; or (e) when you have consented to or directed disclosure at the time of collection.

7. International Data Transfers

We are a global company with offices in multiple countries and we engage third-party consultants and service providers around the world. To enable our business, we may collect your personal data from, transfer it to, and store and process it in the United States or in other countries outside of where you live. Whenever we share personal data outside of where you live, we ensure safeguards are in place to protect your personal data, as required by Applicable Law.

• For UK users, this safeguard is the UK addendum to the EU SCCs/UK international data transfer agreement. You have a right to request a copy of these safeguards, which may be redacted to protect commercially sensitive information. 

8. Your Privacy Choices

• For Mobile Application Users: Privacy Settings Page: You may modify most of your consents and permissions with respect to your personal data at any time by using the Privacy Settings page in your account for the applicable Company Service(s). If you wish to restrict the collection, use, or sharing of your personal data beyond what is offered on the Privacy Settings page (or via other Company and third-party tools), you must elect to cease using the Company Services and request that we delete your user account(s).
   
• For Website Users: Cookie Settings: You can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to the applicable Company Services who disable cookies will be able to browse, but some features may not function. If you visit the applicable Company Services from a different device or from a different browser on the same device, you will need to apply your cookie settings for that browser and/or device as well. You can also review or change your preferences for many cookies on our website, other than those that are necessary, by adjusting your cookie settings through our cookie preference manager.
   
• Device settings: Certain privacy settings, such as our access to your precise geolocation data, are managed on your device and you must adjust your settings on such device.
   
• Analytics. We use analytics tools, such as Google Analytics™, to evaluate usage and traffic on the Company Services. These analytics providers use cookies, pixels, and other tracking technologies to collect usage data to provide us with reports and metrics that help us analyze, improve, and enhance performance and user experience. You can learn more about how Google® uses your information at www.google.com/policies/privacy/partners/ (“How Google uses information from websites or mobile applications that use our services”). You can also download the Google Analytics Opt-out Browser Add-on to prevent your information from being used by Google Analytics™ at https://tools.google.com/dlpage/gaoptout.
   
• Industry Ad Choice Programs: You can control how participating ad networks use the information that they collect about your visits to our websites and those of third parties, in order to display more relevant targeted advertising to you. You can obtain more information and opt out of receiving targeted advertising from participating ad networks at aboutads.info/choices (Digital Advertising Alliance). If you are in Europe, this information is available at www.youronlinechoices.eu (European Interactive Digital Advertising Alliance).
   
• Marketing Emails: If you wish to stop receiving our marketing emails, you can use the opt-out method detailed in the emails (such as using the “unsubscribe” link).
   
• Text Messages: If you wish to stop receiving text messages from us, you can use the opt-out method detailed in the text messages (such as by replying “STOP” or “UNSUBSCRIBE”).

9. Retention of Your Personal Data

As a general rule, we keep personal data as long as we need it to provide the Company Services or engage in related activities (e.g., to investigate violations of our policies) or, if longer, as required by Applicable Law. For example, we will retain your account login credentials for as long as you retain your user account for a Company Service or continue sending you marketing messages until you elect to unsubscribe. How long we keep personal data also depends on the sensitivity of the data and the specificity of the data. For example, we may retain de-identified or anonymized information for longer periods of time than we do your non-anonymized information.

10. Your Privacy Rights

Depending on where you are located or live, you may have the following rights:

• Access and Update Your Personal Data: If you have a user account for one or more Company Services, you can access and update most of your account information in your user account. If you do not have a user account, or if you otherwise prefer, you can request access to your personal data using our request form (TouchTunes, BullShooter). You can also request information about this notice and the categories of personal data that we collect and process about you
   
• Correct/Rectify Your Personal Data: You can request the correction of inaccurate personal data that we hold about you.
   
• Deletion: Subject to certain limited exceptions, you may submit a request for us to delete the personal data that we have collected or inferred about you with respect to any or all Company Services. Please be aware that deleting this personal data will require that we delete all of the user account(s) that you may have for any Company Service(s), and when we delete those user accounts, you will lose all of your personal data, Credits, and any points accumulated under the Loyalty Program and/or the Staff Program. If you make a deletion request, we may require confirmation of your decision before we delete your personal data and we may retain a backup copy of certain of your personal data to the extent permitted by Applicable Law.
   
• Object to Processing: Subject to certain limited exceptions, you may request that we stop processing certain personal data we have collected about you. In certain circumstances in accordance with Applicable Law, you may limit the use and disclosure of sensitive personal data.
   
• Complain: You may also have the right to submit a complaint to us or to a relevant regulator if you believe we have not acted in compliance with Applicable Law.

To exercise any of these rights that you may have, you may submit your request using the applicable tool in your user account for the applicable Company Service(s) or, if you reside in the United Kingdom, do not have a user account, or otherwise prefer, by using our request form (TouchTunes, BullShooter).  We will verify and respond to your request in accordance with Applicable Law, taking into account the type and sensitivity of the personal data requested. In certain circumstances, we may refuse to comply with your request if the law or right you are invoking does not apply or when an exception applies. 
 

11. Children’s Data

None of the Company Services are directed at children who are not yet the age of majority in the jurisdiction where they live. You must confirm that you are at least 18 years of age (or, if greater, the age of majority in the applicable jurisdiction) in order to create an account and access or use the Company Service(s). If we have actual knowledge that you are not yet of age, we will stop providing the Company Service(s) to you and delete your account and your personal data.

12. Security

We make reasonable efforts to protect your personal data by using a combination of physical, technical, and administrative safeguards designed to enhance the security and safety of the data we maintain. No electronic transmission or storage of information can be completely secure, however, and we do not offer any promises or guarantees as to the security or privacy of your personal data. 

13. Contact Us

If you have any questions about our Privacy Policy, or our collection or use of your personal data, please contact us at:

If you reside or are located in the US or Canada: 
TouchTunes Music Company, LLC
730 Third Avenue, 21st Floor
New York City, New York 10017
general@touchtunes.com

If you reside or are located in the UK: 
TouchTunes UK Ltd
Suite 25
Dorset House
25 Duke Street
Chelmsford
Essex
CM1 1TB
UK
general@touchtunes.com

For EU residents: datarequest@datarep.com (reference TouchTunes UK Ltd in the subject line) or online webform: www.datarep.com/data-request
 

EXHIBIT A

JURISDICTION-SPECIFIC TERMS AND CONDITIONS

UNITED STATES

Certain individuals may have additional rights under applicable privacy laws, as described in this Exhibit A, subject to certain exceptions.

Residents of certain U.S. states require additional disclosures under applicable privacy laws.

Sale of Personal Data. While we do not disclose personal data to third parties in exchange for monetary compensation, we may “sell” or “share” (as those terms are defined under applicable privacy laws) the following categories of personal data: identifiers, such as unique personal identifiers, online identifiers, IP address, or other similar identifiers; commercial information; location data; and internet and network activity information. We may disclose these categories to service providers and third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising and to improve and measure our advertising and marketing campaigns.

Consumer Rights. Residents of certain U.S. states may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

• Access. To confirm whether we are processing their personal data and to obtain a copy of their personal data in a portable and, to the extent technically feasible, readily usable format
   
• Know Categories of Third Parties. Certain residents have the right to obtain a list of the categories of third parties to which the controller has disclosed their personal data or a list of the categories of third parties to which the controller has disclosed any consumer's personal data if the controller does not maintain this information in a format specific to the consumer
   
• Deletion. To delete their personal data provided to or obtained by us
   
• Correction. To correct inaccuracies in their personal data
   
• Opt Out. To opt out of certain types of processing, including without limitation:
  • to opt out of the “sale” of their personal data
  • to opt out of targeted advertising by us
  • to opt out of any processing of personal data for purposes of making decisions that produce legal or similarly significant effects

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws through our request form (TouchTunes, BullShooter) or by emailing us at general@touchtunes.com.

We will respond to your request as required under applicable U.S. privacy law(s). When you submit a request, we will take steps to verify your identity and request by matching the personal data provided by you with the personal data we have in our records. In some cases, we may request additional personal data in order to verify your identity or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request. If your request is denied, we will explain the basis for the denial. If we deny your request, in certain jurisdictions you may be able to appeal our decision according to the instructions we provide in our response.

To the extent required under applicable U.S. privacy laws, you may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents may be required to provide proof of their authorization and we may also require the relevant consumer to directly verify the identity and authority of the authorized agent.

California Notice at Collection and Privacy Rights

This section of our Privacy Policy provides additional information for California residents and describes our data practices pursuant to applicable privacy laws, such as the California Consumer Privacy Act and the regulations issued thereto (each as amended, together, the “CCPA”). If you are a California resident, and we collect your “personal information,” as defined in and subject to the CCPA, the following terms and conditions apply. This section does not address or apply to our handling of personal information that is exempt under the CCPA, such as publicly available information or de-identified or aggregated information.

Categories of Personal Information Collected and Disclosed. While our collection, use, and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we collect and disclose (and have, in the prior 12 months, collected and disclosed) personal information about consumers.  We may disclose each category of personal information listed below to our service providers who perform services on our behalf. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see Section 1 (Collecting Your Personal Data) and Section 2 (Using Your Personal Data) of the Privacy Policy.

• Identifiers including without limitation your name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, other government identifiers, or other similar identifiers
   
• Customer Records including without limitation your account and profile information and customer records that contain personal information, such as name, demographics and other characteristics or descriptions, contact information, and financial or payment information
   
• Commercial Information including without limitation records of Company Services purchased, obtained, or considered, or other purchasing or use histories or tendencies
   
• Internet or Other Electronic Network Activity Information including without limitation browsing history, clickstream data, search history, information regarding interactions with the Company Services, advertisements, and emails, as well as other usage data related to your use of any of the Company Services or other similar online services
   
• Location Data including without limitation general and precise geolocation information about a particular individual or device
   
• Audio, Electronic, Visual, or Similar Information including without limitation information collected via call recordings or chat logs (e.g., if you are interacting with us in a customer service capacity), recorded meetings and webinars, videos, and photographs.
   
• Inferences drawn about you, including without limitation from any of the information described above, such as inferences reflecting consumer preferences, characteristics, behaviors, attitudes, abilities, and aptitudes
   
• Protected Classifications: We may collect some information that is considered a protected classification under California or federal law, which may include your gender, age, date of birth, citizenship, marital status, disability status, gender identity or expression, and medical condition.
   
• Sensitive Personal Information: In some circumstances, we may collect payment card information and related details, precise geolocation data, and social security, driver’s license, or state identification card number.
   

Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” as disclosing or making available personal information to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information: identifiers; commercial information; location data; and internet and network activity information. We may disclose these categories to third-party advertising networks, analytics providers, and social networks for purposes of advertising and marketing and to improve and measure advertising and marketing campaigns. We may also share limited information, such as name and email address to data brokers for purposes of advertising and marketing and to improve and measure advertising and marketing campaigns.

We do not sell or share sensitive personal information, nor do we sell or share personal information about individuals we know are under the age of eighteen (18).

Sources of Personal Information. We generally collect personal information from the following categories of sources: directly or indirectly from you; our affiliates; business partners; vendors and service providers; government officials; third-party websites and services; data brokers; public databases; social media platforms and websites; internet service providers; operating systems and platforms; and marketing and data analytics providers.

Purposes of Collection, Use and Disclosure. As further described in Section 2 (Using Your Personal Data) and Section 3 (Using Aggregated and De-Identified Data) of the Privacy Policy, we may collect, use, disclose, and otherwise process the above-listed personal information for the following business or commercial purposes and as otherwise directed or consented to by you:

• Provide the Company Services
• Necessary Communications Regarding the Company Services
• Communicate New Elements of the Company Services and Other Related Offers
• Personalize Your Promotional Offers
• Personalize Your Company Service Experiences
• Personalize Your Advertising
• Market Other Company Services
• Research, Analytics, Reporting, and Improvements
• Safety, Security, and Legal Compliance 

Sensitive Personal Information. We collect, use, infer, or disclose “sensitive personal information” about you for analytics, marketing, and advertising purposes.

Retention. We retain the personal information that we collect only as reasonably necessary for the purposes described above or as otherwise disclosed to you at the time of collection. For example, we will retain your account information for as long as you have an active account with us and additional information as necessary to comply with our tax, accounting, and recordkeeping obligations, to provide you with the Company Services you have requested, as well as an additional period of time as necessary to protect, defend, or establish our rights, defend against potential claims, and comply with our legal obligations. In some cases, rather than delete your personal information, we may de-identify or aggregate it and use it in compliance with the CCPA.

California Resident’s Rights. Under the CCPA, California residents have the following rights (subject to certain limitations):

• To Opt Out of Sales and Sharing: The right to opt out of our sale and sharing of your personal information
   
• To Limit Certain Uses and Disclosures of Sensitive Personal Information: The right to limit our use and disclosure of sensitive personal information to what is necessary to perform the Company Services or as permitted by the CCPA.
   
• Deletion: The right to the deletion of their personal information that we have collected, subject to certain exceptions
   
• To Know/Access: The right to know what personal information we have collected about them, including without limitation the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them
   
• Correction. The right to correct inaccurate personal information that we maintain about them
   
• Non-retaliation: The right not to be subject to retaliatory treatment for exercising their rights under the CCPA
   

Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below:

• Right to Know, Delete, and Correct: California residents may submit CCPA requests to access/know, delete, and correct their personal information by using our request form (TouchTunes, BullShooter) or by calling 888-690-4462.

  When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial.

  You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization and we may also require the relevant consumer to directly verify the identity and the authority of the authorized agent.
   

• Right to Opt Out of Sales and Sharing: To exercise your right to opt out of the “sale” or “sharing” of your personal information or to limit our use and disclosure of your sensitive personal information, you may do so via our cookie preference manager on our website or in the privacy settings in your device. We will apply your opt out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. You may also click the “Your Privacy Choices” link in the footer of our website for applicable Company Services.

  In addition, if we detect that your browser or device is transmitting an opt out preference signal, such as the GPC signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your personal information. If you come to our website or use our Company Services from a different device or from a different browser on the same device, you will need to opt out, or use an opt out preference signal, for that browser and/or device as well. More information about GPC is available at: globalprivacycontrol.org.
   

• Right to Limit the Use and Disclosure of Sensitive Information: To exercise your right to limit the use and disclosure of sensitive information, you may do so in the privacy settings in your account. We will apply your opt out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request.
   

Notice of Financial Incentive. With respect to some of our Company Services, we may make available certain programs or offerings, and other sweepstakes, contests, or similar promotional offerings (each a “Program”) which may include certain offers, rewards, discounts, services, perks, and promotions (“Rewards and Offers”). These Programs may be considered “financial incentives” under the CCPA. We provide these Rewards and Offers to participating users in order to understand and improve customer satisfaction and experiences and to foster positive customer relationships.

As a basis for offering these Rewards and Offers, we have valued the personal information we obtain based on a reasonable and good faith calculation determined by considering expenses related to the Programs. In doing so, we value the personal information collected through the programs as the equivalent of the costs and expenses incurred to provide the program, including without limitation IT, administration, direct costs, third-party costs, discounts, and Program development costs.

Your personal information is collected and retained, and may be disclosed to our business partners, vendors and service providers, and other third parties, as described in this Privacy Policy, including without limitation in order: (a) to administer the Program; (b) for research and analytics purposes; (c) to improve our products and Company Services; (d) to better reach you with more relevant, targeted offers; and (e) to send you updates and offers by email and postal mail (in accordance with your communications preferences).

You may withdraw from participating in a Program at any time by contacting us at general@touchtunes.com. Please note that if you withdraw from a Program (or submit a CCPA request to delete your Program information), your participation in that Program will be terminated, which means that you will no longer be eligible to earn, use, access or redeem any Rewards and Offers, subject to the applicable Program terms.

California Shine the Light Rights. California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) permits California residents who provide us certain personal information to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing purposes. To make a California Shine the Light request, please email us at general@touchtunes.com. Requests may be made once per calendar year.