PRIVACY POLICY

MOOMBIX

Last updated: [•] 2024

  1. Who We Are

    1. Moombix ehf. is a private limited company established in Iceland, with registration number 430921-0100, having its registered office at Bjargargata 1, Reykjavík (“Moombix”). When used in this Privacy Policy, “Moombix”, “we”, “us” or “our” refers to Moombix ehf.

    2. Moombix operates a comprehensive marketplace and learning platform designed for live, online music lessons. It facilitates one-on-one or group music lessons and serves as a turnkey solution, encompassing a dynamic marketplace, booking and payment system, communication timeline, calendar, lesson planner, and a learning platform tailored for online music lessons (collectively, the “Moombix Platform”).

    3. This privacy policy describes how we use your personal information in relation to your use of the Platform. Depending on where you live and what you are doing on the platform you may also have specific rights under further described in Addendum I- State-Specific Supplements for the United States.

  2. About this Privacy Policy

    1. This Privacy Policy describes how we process your personal data at Moombix. It applies to your use of the Moombix Platform.

    2. Moombix collects, uses and is responsible for certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation (“GDPR”) which applies across the European Union. We are responsible as 'processor' of that personal information for the purposes of those laws, the 'controller' being the user who has created an account to use the Moombix Platform.

  3. Information That We Collect

    1. Moombix processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and only process your personal information as specified in this Privacy Policy.

    2. We only collect personal information which you submit to us. The personal data that we collect concerns:

    User Data such as: (1) Name; (2) Email address; (3) Password; (4) Phone number; (5) Date of birth; (6)Authentication data; and (7) Country.

    Usage Data such as: (1) Browsing history; (2) Account settings; (3) Profile information; including languages, music instruments and styles, two pictures and other things you choose to include in your bio; (4) Class history, including how many lessons you have participated in, with whom, at what time, etc.; (5) Chat history.

    Technical Data such as: (1) IP addresses; (2) URL information; (3) Cookie data; (4) Information about the devices you use (device IDs, network connection type, browser type, language, network and device performance, etc.).

    Payment Data: Our payment provider (Stripe) holds all payment card details and we do not have access to them.

  4. The purposes and reasons for processing your personal data

    1. We process your personal data to perform a contract with you when we set up an account for you to access the Moombix Platform, provide a digital music teaching and learning service, and ensure that orders are completed.

    2. We aldo process your personal data for our legitimate interest when to keep the Moombix Platform running and functional, improve and develop our services and to allow users to access and use the Moombix Platform.

    3. We will occasionally send you marketing information where we have assessed that it is beneficial to you as a user of the Moombix Platform and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.

  5. Your Rights

    1. Under certain circumstances, by law you have the right to:

      1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

      2. Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

      3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

      4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

      5. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

      6. Request the transfer of your personal data to another party.

    2. If you would like to exercise any of those rights, please email us at info@moombix.com.

    3. You have the right to lodge a complaint to any relevant supervisory authority. The supervisory authority in Iceland is the Data Protection Authority which may be contacted at www.personuvernd.is

  6. Sharing and Disclosing Your Personal Information

    1. Your profile name and profile photo will always be publicly available on the Moombix Platform.

    2. We will share the following personal data with those outlined in the table below:

Recipients Categories of data that we share Reason for sharing data
Marketing partner
The Rocket Science Group LLC (Mailchimp)
User Data
Usage Data
 We share certain User Data and Usage Data with our marketing partner to promote Moombix and help market Moombix’s services.
Service provider
Jitsi (8x8, Inc.)
SendGrid
User Data
Usage Data
 We share certain User Data and Usage Data with this service provider in order for us to be able to offer Moombix users with in-app conferencing.
Technical service provider
Heroku (Salesforce, Inc.)
Vercel, Inc.
Mezmo, Inc.
Google Cloud EMEA Limited
Redis, Inc.
 Technical Data We share certain Technical Data with our technical service providers so they can operate the technical infrastructure we need to provide services on the Moombix Platform, and assist in protecting and securing our systems and services.

  1. We may also share your information with other third-parties including third-party service providers and other entities in the group.

  2. We share your personal data where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

  3. We may share your personal data with other third parties, for example in the context of the possible sale or reconstructing of the business.

  4. We may also need to share your personal data with a regulator or to otherwise comply with the law. This may include reports or disclosure to tax authorities.

  1. Safeguarding Measures

    1. We have put various safeguards in place to guard against unauthorized access and unnecessary retention of personal data in our systems. These include pseudonymisation, encryption, access, and retention policies.

    2. Third parties will only process your personal data on our instruction and where they have agreed to treat the information confidentially and keep it secure.

  2. Transfers Outside the EU

    1. We may transfer your personal data outside the European Economic Area. If we do, you can expect a similar degree of protection in respect of your personal data.

  3. How Long We Keep Your Data

    1. We keep your personal data only as long as necessary to provide you with the services related to the Moombix Platform and for Moombix’s legitimate and essential business purposes, such as maintaining and improving the performance of the Moombix Platform, complying with our legal obligations, and resolving disputes

    2. It’s your right to request that we delete your personal data. Moombix will delete all personal information about you when you delete your account to the Moombix Platform.

  4. Changes to this Privacy Policy

    1. We may occasionally make changes to this Privacy Policy. Our updated Privacy Policy will be displayed on the Moombix website. The effective date set forth at the top of the Privacy Policy indicates when the policy was last changed.

  5. How to Contact us

    1. Please contact info@moombix.com if you have any questions about this Privacy Policy or the information we hold about you.

Addendum I - State-Specific Supplements for the United States

Colorado Connecticut Delaware Iowa Montana Nevada Oregon Texas Virginia Appeal of Consumer Rights Requests To appeal a refusal to take action on your request, please see the instructions in our response to your request or submit your appeal in writing by contacting info@moombix.com with the subject “Appeal of Consumer Rights Request.”
California Data Retention We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:
  • The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
Whether retention is allowed by applicable law (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
California De-Identification Consistent with applicable law, we commit to maintain and use information in de-identified form and not to attempt to re-identify the information, except that we may attempt to re-identify the information solely for the purpose of determining whether its de-identification processes satisfy the requirements of the California Privacy Rights Act.
Colorado Connecticut Delaware Montana Oregon Texas Utah Virginia De-Identification Consistent with applicable law, we commit to maintain and use information in de-identified form and not to attempt to re-identify the information. We may use such information in de-identified form consistent with applicable law.
California Information Pertaining to California Consumer Requests You can find information about consumer requests we received and processed under the California Consumer Privacy Act during the previous calendar year here
California Information Sharing by Moombix Payments Moombix Payments will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by law.
California Limit Use and/or Disclosure of Sensitive Personal Information Certain categories of personal information that we collect and use might be “sensitive” under data privacy laws. Consistent with applicable law, you may limit certain uses or disclosures of your sensitive personal information and may exercise this right by using the form linked here.
Connecticut Delaware Montana Oregon Online Contact Information If you have any questions, you may also contact us at info@moombix.com with the subject “Privacy Contact.”
Colorado Connecticut Delaware Montana Oregon Texas Personalized Advertising Opt-Out We do not sell personal information. However, we do process personal information for purposes of displaying advertisements that are selected based on users’ online activities over time and across different sites, services, and devices. We also engage in automated processing that could affect you. Consistent with applicable law, you may opt out of such processing by using the form linked here. We strive to honor opt-out preference signals where required by applicable law. When we detect an opt-out preference signal, we will make reasonable efforts to honor such opt outs for jurisdictions that require them. Please note that your opt-out preference signal might only apply to the particular browser, device, or technology that you use to opt-out. The opt-out preference signals are offered by a third party that we do not control. Please see the opt-out preference signal settings and policies for more information.
California Right of Non-Discrimination We do not sell personal information to third parties; we are not data brokers and do not put personal information on the open market. We do not knowingly sell or share the personal information of individuals who are younger than 16. We do allow third parties to collect personal information through the Moombix Platform and share personal information with third parties for the business purposes described in the Privacy Policy including, without limitation, advertising and marketing on the Moombix Platform and elsewhere based on users’ online activities over time and across Moombix, services, and devices. Consistent with applicable law, you may opt out of such processing by using the form linked here. We do not share any categories of personal information to advertisers for cross-context behavioral advertising.
California Colorado Connecticut Delaware Iowa Montana Nevada Oregon Texas Utah Virginia Right to Access Consistent with applicable law, you may submit a verifiable consumer request to access, in a portable and (if technically feasible) readily-usable form, the personal information that we have collected about you as well as more information about our data practices. For more information about how we collect, use, and disclose personal information for business purposes, please review our Privacy Policy.
California Connecticut Delaware Montana Oregon Texas Virginia Right to Correct Consistent with applicable law, you may submit a verifiable consumer request to correct inaccuracies in your personal information held by Moombix.
Colorado Right to Correct Consistent with applicable law, you may submit a verifiable consumer request to correct inaccuracies in your personal information held by Moombix by visiting the link here.
Nevada Right to Correct Consistent with applicable law, you may submit a verifiable consumer request to correct inaccuracies in your personal information held by Moombix.
California Colorado Connecticut Delaware Iowa Montana Nevada Oregon Texas Utah Virginia Right to Delete Consistent with applicable law, you may submit a verifiable consumer request to delete your personal information.
Colorado Connecticut Delaware Montana Oregon Texas Virginia Right to Opt-Out for the Purposes of Profiling for Decisions That Produce Legal or Similarly Significant Effects Consistent with applicable law, you may have the right to opt-out of processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise any right you may have, please click here.
California Sale and Sharing of Data We do not sell personal information to third parties; we are not data brokers and do not put personal information on the open market. We do not knowingly sell or share the personal information of individuals who are younger than 16. We do allow third parties to collect personal information through the Moombix Platform and share personal information with third parties for the business purposes described in the Privacy Policy including, without limitation, advertising and marketing on the Moombix Platform and elsewhere based on users’ online activities over time and across Moombix, services, and devices. Consistent with applicable law, you may opt out of such processing by using the form linked here. We do not share any categories of personal information to advertisers for cross-context behavioral advertising.
Colorado Sensitive Data Inferences We may process inferences from your sensitive data for the purposes discussed in our Privacy Policy In the event that we do, we will retain the inferences until we have fulfilled the purpose for which we collected them. We will delete such inferences in accordance with our Privacy Policy.

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