Privacy Policy

We at Groove know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy.

Last Updated: May 1st, 2020

We at Groove know you care about how your personal information is used andshared, and we take your privacy seriously. Please read the following to learnmore about our Privacy Policy. By using or accessing the Services in anymanner, you acknowledge that you accept the practices and policies outlined inthis Privacy Policy, and you hereby consent that we will collect, use, andshare your information in the following ways.

Remember that unless you and Groove have otherwise entered into a writtenagreement specifically governing your use of Groove’s Services (andspecifically excluding the Terms of Service), your use of Groove’s Services isat all times subject to theTerms of Service, which incorporates thisPrivacy Policy. Any terms we use in this Policy without defining them have thedefinitions given to them in theTerms of Service.

What does this Privacy Policy cover?
This Privacy Policy covers our treatment of personally identifiableinformation (“Personal Information”) that we gather when you are accessing orusing our Services, but not to the practices of companies we don’t own orcontrol, or people that we don’t manage. We gather various types of PersonalInformation from our users, as explained in more detail below, and we use thisPersonal Information internally in connection with our Services, including topersonalize, provide, and improve our services, to contact you to fulfill yourrequests for certain products and services, and to analyze how you use theServices. In certain cases, we may also share some Personal Information withthird parties, but only as described below.

Will Groove ever change this Privacy Policy?
As noted in the Terms of Service, we donot knowingly collect or solicit personal information from anyone under theage of 13. If you are under 13, please do not attempt to register for theServices or send any personal information about yourself to us. If we learnthat we have collected personal information from a child under age 13, we willdelete that information as quickly as possible. If you believe that a childunder 13 may have provided us personal information, please contact us

We’re constantly trying to improve our Services, so we may need to change thisPrivacy Policy from time to time as well, but we will alert you to changes byplacing a notice on the website at, by sending you anemail, and/or by some other means. Please note that if you’ve opted not toreceive legal notice emails from us (or you haven’t provided us with youremail address), those legal notices will still govern your use of theServices, and you are still responsible for reading and understanding them. Ifyou use the Services after any changes to the Privacy Policy have been posted,that means you agree to all of the changes. Use of information we collect nowis subject to the Privacy Policy in effect at the time such information isused.


What Information does Groove Collect?
Information You Provide to Us:

We receive and store any information you knowingly provide to us. For example,if you sign in to the Services through a third party site or service orotherwise connect your third party accounts to the Services, we may haveaccess to some contents or information in those third-party accounts, such asyour email address or log-in credentials, in order to provide Services to you.You understand that any such information transmitted to our Services iscovered by this Privacy Policy. Certain information may be required to takeadvantage of some of our features.

We may communicate with you if you’ve provided us the means to do so. Forexample, if you’ve given us your email address, we may send you promotionalemail offers, or email you about your use of the Services. Also, we mayreceive a confirmation when you open an email from us. This confirmation helpsus make our communications with you more interesting and improve our services.If you do not want to receive communications from us, please indicate yourpreference by emailing us at

Information Collected Automatically
Whenever you interact with our Services, we automatically receive and recordinformation on our server logs from your browser or device, which may includeyour IP address, device identification, “cookie” information, the type ofbrowser and/or device you’re using to access our Services, and the page orfeature you requested. “Cookies” are identifiers we transfer to your browseror device that allow us to recognize your browser or device and tell us howand when pages and features in our Services are visited and by how manypeople. You may be able to change the preferences on your browser or device toprevent or limit your device’s acceptance of cookies, but this may prevent youfrom taking advantage of some of our features.

If you click on a link to a third party website or service, a third party mayalso transmit cookies to you. Again, this Privacy Policy does not cover theuse of cookies by any third parties, and we aren’t responsible for theirprivacy policies and practices. Please be aware that cookies placed by thirdparties may continue to track your activities online even after you have leftour Services, and those third parties may not honor “Do Not Track” requestsyou have set using your browser or device.

We may use this data to improve the Services – for example, this data providesgeneral statistics regarding use of the Services and can tell us how oftenusers use a particular feature of the Services, and we can use that knowledgeto make the Services interesting to as many users as possible.

Information Collected From Other Websites and Do Not Track Policy
Through cookies we place on your browser or device, we may collect informationabout your online activity after you leave our Services. Just like any otherusage information we collect, this information allows us to improve theServices and customize your online experience, and otherwise as described inthis Privacy Policy. Your browser may offer you a “Do Not Track” option, whichallows you to signal to operators of websites and web applications andservices (including behavioral advertising services) that you do not wish suchoperators to track certain of your online activities over time and acrossdifferent websites. Our Services do not support Do Not Track requests at thistime.

Will Groove Share Any of the Personal Information it Receives?
Groove will not share your Personal Information with a third party exceptwhere Groove utilizes third parties as part of our internal data use policy.

Information that’s been de-identified. We may de-identify your PersonalInformation so that you are not identified as an individual, and provide thatinformation to our service providers in order to improve our Services to you.For example, we may provide aggregate usage information to Google Analytics,who may use such information to analyze and review our Services internally.However, we never disclose aggregate usage or de-identified information to apartner (or allow a partner to collect such information) in a manner thatwould identify you as an individual person.

Agents: We employ other companies and people to perform tasks on our behalfand need to share your information with them to provide products or servicesto you; for example, we may use a payment processing company to receive andprocess your credit card transactions for us. Also, we may employ resellers toassist with the implementation of and customer support for our Services.Unless we tell you differently, our agents do not have any right to use thePersonal Information we share with them beyond what is necessary to assist us.

In cases of onward transfer to third parties of data of EU individualsreceived pursuant to the EU-US and Swiss-US Privacy Shield, Groove ispotentially liable.

Business Transfers: We may choose to buy or sell assets, and may share and/ortransfer customer information in connection with the evaluation of and entryinto such transactions. Also, if we (or our assets) are acquired, or if we goout of business, enter bankruptcy, or go through some other change of control,Personal Information could be one of the assets transferred to or acquired bya third party. We will provide an individual opt-out or opt-in choice beforewe share their data with third parties other than our agents, or before we useit for a purpose other than which it was originally collected or subsequentlyauthorized.

Protection of Groove and Others: We reserve the right to access, read,preserve, and disclose any information that we believe is necessary to complywith law or court order; enforce or apply ourTerms of Service and other agreements;or protect the rights, property, or safety of Groove, our employees, ourusers, or others.

Groove also may be required to disclose an individual’s personal informationin response to a lawful request by public authorities, including to meetnational security or law enforcement requirements.

Is Personal Information about me secure?
For your privacy and security, the third party account you chose to connect toour Services are protected by a password or any additional or differentsign-on protections via that third party site or service. You must preventunauthorized access to your account and Personal Information by selecting andprotecting your password and/or other sign-on mechanism appropriately andlimiting access to your computer or device and browser by signing off afteryou have finished accessing our Services.

We endeavor to protect the privacy of your account and other PersonalInformation we hold in our records, but unfortunately, we cannot guaranteecomplete security. Unauthorized entry or use, hardware or software failure,and other factors, may compromise the security of user information at anytime.

What if I want to stop using the Groove products?
You may stop using our products by disconnecting your third party accountsfrom our Services. After you disconnect your third party accounts, we do nothave access to or any control over the contents or information in your thirdparty accounts, except we will only keep your email address on our record inorder to provide our Services to you in the future (should you choose toresume the use of our Services).

You may be able to view, update, and delete information in your third partyaccount via that third party site or service. Again, we have no control overand are not responsible for the policies and practices of third party websitesor services as to privacy or anything else. If you have any questions aboutviewing or updating information we have on file about you, please contact usat

Under California Civil Code Sections 1798.83-1798.84, California residents areentitled to ask us for a notice identifying the categories of PersonalInformation which we share with our affiliates and/or third parties formarketing purposes, and providing contact information for such affiliatesand/or third parties. If you are a California resident and would like a copyof this notice, please submit a written request to:

What choices do I have?
You can always opt not to disclose information to us, but keep in mind someinformation may be needed to register with us or to take advantage of some ofour features.

You may be able to disconnect your third party accounts from our Services asexplained above. When you do so, however, we may maintain a copy of your emailaddress in our records.

Groove acknowledges that individuals have the right to access the personalinformation/data that we maintain about them. An individual who seeksaccess, or who seeks to correct, amend, or delete inaccurate data, shoulddirect his query to If requested to remove data, we willrespond within a reasonable timeframe.

A Note about Children
The Groove’s website and the Services are not currently directed to childrenunder the age of 13. Groove respects the privacy of parents and children andare committed to complying with the Children’s Online Privacy Protection Act(“COPPA”). Groove does not knowingly collect or solicit any information fromanyone under the age of 13 or knowingly allow such persons to use its websiteor Services. In the event that we learn that we have collected personalinformation from a child under age 13 without parental consent, we will deletethat information as quickly as possible. If you believe that we might have anyinformation from or about a child under 13, please contact us immediately.

Privacy Shield Framework
Groove has certified that it complies with the EU-US Privacy Shield Frameworkas set forth by the US Department of Commerce regarding the collection, use,and retention of personal information from European Union member countries. Ifthere is any conflict between the policies in this privacy policy and thePrivacy Shield Framework, the Privacy Shield Framework shall govern. To learnmore about the Privacy Shield Framework, and to view our certification page, please visit

In compliance with the EU-US Privacy Shield Framework, Groove commits toresolve complaints about your privacy and our collection or use of yourpersonal information. European Union individuals with inquiries or complaintsregarding this privacy policy should first contact Groove at:

Legal Department
Groove Labs, Inc.
660 4th Street #684
San Francisco, CA94107

Groove has further committed to refer unresolved privacy complaints under theEU-US Privacy Shield Framework BBB EU PRIVACY SHIELD, a non-profit alternativedispute resolution provider located in the United States and operated by theCouncil of Better Business Bureaus. If you do not receive timelyacknowledgment of your complaint, or if your complaint is not satisfactorilyaddressed, please visit for more information and to file a complaint.

As a last resort and under limited circumstances, individuals with unresolvedcomplaints may invoke a binding arbitration option before a Privacy ShieldPanel.

Groove is subject to the investigatory and enforcement powers of the FederalTrade Commission (FTC).

US-Swiss Privacy Shield Framework
Groove has certified that it complies with the US-Swiss Privacy ShieldFramework as set forth by the US Department of Commerce regarding thecollection, use, and retention of personal information from Switzerland. Ifthere is any conflict between the policies in this privacy policy and thePrivacy Shield Framework, the Privacy Shield Framework shall govern. To learnmore about the US-Swiss Privacy Shield Framework and to view our certificationpage, please visit

In compliance with the US-Swiss Privacy Shield Framework, Groove commits toresolve complaints about your privacy and our collection or use of yourpersonal information. Swiss citizens with inquiries or complaints regardingthis privacy policy should first contact Groove at the address below, or ifyour complaint is not satisfactorily addressed,please visit for more information and to file a complaint.

Legal Department
Groove Labs, Inc.
660 4th Street #684
San Francisco, CA94107

Your California Privacy Rights

If you are a California resident, California law may provide you withadditional rights regarding our use of your personal information. To learnmore about your California privacy rights, visit

Privacy Notice for California Residents

Effective Date : January 2020

Last Reviewed on: January 2020

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category A: Identifiers

Examples: A real name, Internet Protocol address, email address, or other similar identifiers.

Collected: YES

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: YES, with your consent

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: NO

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Groove has not disclosed personal information for a business purpose.

Sales of Personal Information
In the preceding twelve (12) months, Groove had not sold personal information.

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions, by emailing us at . Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message to Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic-mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights
While Groove does not sell any personal information, you have the right, if you are 16 years of age or older, to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by sending us a message to

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email to

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