Privacy Policy

Effective Date: September 17, 2024

We know that your privacy is important to you, and we work hard to earn and keep your trust. Authentic Music Operating Company LLC d/b/a Humanable (collectively with its subsidiaries and affiliates, “HUMANABLE,” “we,” “us,” and “our”), respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”). The words “you”, “your”, or “user” refer to you as a user of the Services (defined below), either as a visitor or registered customer.

This Policy describes:

• The types of personal information we collect from you or that you may provide when you access the HUMANABLE website, currently located at Humanable.com and all associated websites and subpages existing now or in the future (collectively, “Website”), any and all related mobile applications we may make available (collectively, “Application”), together with all enabled features, functionality and services, including, without limitation, HUMANABLE's human-made art authentication services, HUMANABLE’s merchandise shop, the license to the HUMANABLE marks set forth in the Terms and Conditions, and HUMANABLE's anticipated forthcoming artist and fan social media service offered by us in connection with the Website and Application (all of the foregoing, collectively, “Services”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that personal information.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Other Online Services And Third-Party Features”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Services. By using our Services, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Updates To Our Privacy Policy”). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

1. Personal Information We Obtain

The types of personal information HUMANABLE may obtain include:

• contact details (such as name, email, postal address, telephone number, and online identifiers, such as account name);
• information about the devices you use to access the Service (such as IP address);
• information about your use of the Services, including personal information typed into forms on our Website, whether or not you submit the form;
• contact information for friends or others you would like us to contact; and
• other information you may provide to us or authorize others to provide to us.

AGGREGATED AND DE-IDENTIFIED DATA. We may also collect, use and discloseaggregated and de-identified datasuch as statistical or demographic data for any purpose. Aggregated and de-identified data could be derived from your personal information but is not considered personal information under applicable law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated or de-identified data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Policy.

FREE-TEXT BOXES. The information that you provide in each case will vary. In some cases, you may be able to provide personal information via email or free text boxes, such as contacting HUMANABLE to request further information. When providing your personal information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our Services.

USERNAME AND PASSWORD. We may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous.

SOURCES. We may obtain the personal information listed above from the following categories of sources:

• Directly from you . For example, when you:
• register yourself with the Services;
• place an online order;
• subscribe to one of our e-newsletters;
• review or comment on our Services; or
• otherwise communicate with us, such as contacting us for more information.
• Indirectly from you . For example, through information we collect from you in the course of providing our Services to you.
• Directly and indirectly from activity on our Website . For example, from Services usage details that are collected automatically. For more information on automatic information collection, please review the “Cookies and Automated Information Collection” section below.
• Other Sources . We may collect information about you from third party sources and add such information to the information that you have provided to us.

1. Cookies and Automated Information Collection

WEBSITE. In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:

1. Cookies . A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:

1. session cookies, which do not stay on your device after you close your browser, and
2. persistent cookies, which remain on your device until you delete them or they expire.

We may use the following categories of cookies on our Website.

• Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested cannot be provided.

• Performance Cookies. These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.

• Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.

• Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the websites you visit and that information is shared with other parties, such as advertisers.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

1. Google Analytics and Google Tag Manager . The Website sends aggregated non-Personal Information to Google Analytics and Google Tag Manager for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance. For more information on how Google Analytics and Google Tag Manager support the Website and use information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites , Google’s data privacy practices for Google Analytics at https://support.google.com/analytics/answer/6004245 and, Google’s data privacy practices for Google Tag Manager at https://support.google.com/tagmanager/answer/9323295?hl=en .
2. Microsoft Clarity . We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with the Website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement .
3. Meta Pixel .With the help of the Meta pixel, also known as the Facebook Pixel, Meta is able to determine the visitors of our Website as a target group for the presentation of advertisements. With the help of the Meta pixel, we want to make sure that our ads are in line with the potential interest of users and do not have a nuisance effect.Using the Meta pixel, we can also track the effectiveness of Meta or Facebook ads for statistical and market research purposes.Meta’s processing of the data is governed by Meta’s Data Usage Policy, which is available at https://www.facebook.com/policy.php .For specific information and details about the Meta pixel and how it works, please visit the Meta Business Help Center: https://www.facebook.com/business/help/651294705016616 .
4. LinkedIn Insight Tag . The LinkedIn Insight Tag is a piece of lightweight JavaScript code that we have added to our Website to enable in-depth campaign reporting and to help us unlock valuable insights about our Website visitors. The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. The LinkedIn browser cookie is stored in a visitor's browser until they delete the cookie or the cookie expires. You can permanently opt out on this link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .For more information on the LinkedIn Privacy Policy, go to https://www.linkedin.com/legal/privacy-policy .
5. Third-party Websites and Services . We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.

APPLICATION. In addition to the information that you provide to us, we may also collect information about you during your visit to our Application. We collect this information using automated technology. This technology may collect information about your behavior and your device, such as your internet address (IP Address), the pages you have viewed, the actions you have taken while using the Application, saved preferences, and log-in Session ID. This information is not personally identifiable or capable of being used to identify you in the scope of this Policy. You can manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies, by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

1. How We May Use The Personal Information We Obtain

As described further below, HUMANABLE uses your personal information to provide you the Services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal information for other purposes with your consent. You consent to the following uses of your personal information:

• to communicate with you and respond to your questions;
• to create and manage online accounts that you establish on the Services;
• to send news and updates about HUMANABLE and its affiliates and other communications (such as communications about products and services offered by our marketing partners and affiliates);
• offer you products or services we believe may be of interest to you;
• communicate with you about, and administer participation in, special events, programs, surveys, and other offers and promotions;
• operate, evaluate and improve our business and that of our affiliates entities (including developing new products and services; analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions); or
• perform data analyses (including market and consumer research).

We learn how to best tailor our Services to our visitors by collecting information through cookies, web beacons and other analytics tools on our website. We may use website analytics to determine how much time visitors spend on each web page of our website, how visitors navigate through the Website, and how we may change our Website to better meet the needs of our visitors. We may also use cookies to customize visits to our Services and deliver content. We may use IP addresses to help diagnose problems with our server and to administer our Services. We also may use IP addresses to help identify and gather demographic information about visitors to our Services.

We do not collect personally identifiable information about a consumer’s online activities over time or across third-party websites or online services.

We also may use the information we obtain about you in other ways when we provide specific notice at the time of collection.

1. Personal Information We Share

We never sell or rent personal information about you.

We do not share or disclose personal information except as described in this Privacy Policy.

1. DISCLOSURE OF PERSONAL INFORMATION

We may share data and other personal information we obtain about users of HUMANABLE with:

• Service Providers. We disclose personal information collected through the Services with third-party Service Providers who act for or on behalf of HUMANABLE. These third parties may need information about you to perform their functions. “Service Providers” may include suppliers, dealers, distributors, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, order fulfillment, information technology and related infrastructure support, customer service, email delivery, and auditing.
• Our Affiliates. We may disclose the information collected through the Services with our affiliates, subsidiaries, or other related entities in order to provide our products, services, and effective customer support.
• In Aggregate or De-Identified Form. We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of HUMANABLE. Such use shall not include personal information or information that can identify you as an individual or reasonably be used to identify you.
• Government Agencies, If Required By Law. We may disclose your personal information to government agencies and law enforcement to the extent required by law, as further provided below (see “DISCLOSURES FOR OTHER PUPOSES”).
• Other Third Parties. Other third parties with your express consent (such as when you choose to use a service or participate in a program that we may offer jointly with another entity).

1. DISCLOSURES FOR OTHER PURPOSES

We may disclose information we obtain about you:

• if law or legal process requires us to do so (such as a court order or subpoena);
• in response to requests by government agencies (such as law enforcement authorities);
• to establish, exercise or defend our legal rights;
• when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss;
• in connection with an investigation of suspected or actual illegal activity; or
• otherwise with your consent or at your direction.

We reserve the right to transfer information we have about you when our affiliate launches its forthcoming HUMANABLE artist and fan social media platform and/or if we sell or transfer all or part of our business or assets, as permitted or required by law. Should such a transfer occur, we will use reasonable efforts to direct the transferee to use the personal information in a manner that is consistent with this Privacy Policy.

We also may share the information we obtain about you in other ways when we provide specific notice at the time of collection.

1. Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your personal information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the personal information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

1. How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized: destruction, alteration, access, disclosure or use. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your personal information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us immediately of any actual or suspected unauthorized use of the Services or your information.

1. Other Online Services And Third-Party Features

Our website and other services may integrate and/or provide links to other online services for your convenience and information. This may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of these third parties, including details on the information they may collect, are subject to the privacy statements of these parties. We strongly suggest you review them. To the extent any linked online services or third-party features are not owned or controlled by us, HUMANABLE is not responsible for their information practices. Without limiting the generality of the above statement, you agree to the privacy practices and policies of Stripe ( https://stripe.com/privacy ) and Plaid ( https://plaid.com/legal/#consumers ).

1. Retention Of Personal Information

You may request that we remove any personal information we maintain about you.

To request removal of your personal information as described above, you may contact us as indicated in Section 11 of this Privacy Policy.

We will honor your requests, except that we may retain limited information to comply with your request not to be contacted in the future.

1. Children's Personal Information

We recognize the importance of protecting children's online privacy. The HUMANABLE website is intended for an artist audience and is not directed to children. We do not knowingly collect personal information online from children under the age of 13. We encourage parents and guardians to provide adequate protection measures to prevent children from providing information unwillingly on the internet. If we learn that we have collected personal information online from a child under the age of 13, we will take steps to securely remove it from our systems.

1. Updates To Our Privacy Policy

We may update this Privacy Policy periodically to reflect new HUMANABLE program features or changes in our personal information practices. We will post a notice at the top of this Privacy Policy of any significant changes to this Privacy Policy. We will also state there when this Privacy Policy was most recently updated. We will provide other notice to you as required by law.

1. How To Contact Us

If you have any questions or comments about this Privacy Policy, any privacy-related complaints, or would like exercise your rights under this Privacy Policy, you may:

1. write to us at:legal@humanable.com

or

1. write to us at:

Humanable

1030 16th Ave. S

Floor 2

Nashville, TN 37212

1. Location of the Services

We do not warrant or represent that this Policy or the Services’ use of your personal information complies with the laws of every jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your personal information in accordance with this Policy.

1. For Users Outside The United States

Under the (i) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), (ii) Data Protection Act 2018, (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (i.e., “UK GDPR”) as provided in the Data Protection Act 2018, and (iv) any other applicable data protection legislation of any country or other jurisdiction (collectively “International Data Protection Laws”) individuals have specific rights with respect to their personal information, or “personal data” as defined under the International Data Protection Laws. For the purposes of this Policy, HUMANABLE operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

The Data Controller is:

NAME: Authentic Music Operating Company LLC d/b/a Humanable

ADDRESS: Humanable 1030 16th Ave. S Floor 2 Nashville, TN 37212

EMAIL ADDRESS: legal@humanable.com

You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

• Access . You may request a copy of the personal data our Services currently contain.

• Automated Processing and Decision-Making . You may request that we stop using your personal data for automated processing, such as profiling. When contacting HUMANABLE, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.

• Correction or Rectification . You can correct what personal data our Services currently contains by accessing your account directly, or by emailing us (as provided below) to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.

• Restrict Processing . When applicable, you may restrict the processing of your personal data by submitting a request via email (to the email provided below). In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Object to Processing . When applicable, you have the right to object to the processing of your personal data by submitting a request via email to (to the email provided below). When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Portability . Upon request and when possible, we can provide you with copies of your personal data. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.

• Withdraw Consent . At any time, you may withdraw your consent to our processing of your personal data through the Services by notifying us via email (to the email provided below). Using the same email address associated with your Services account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Erasure . If you should wish to cease use of our Services and have your personal data deleted from our Services, then you may submit a request by emailing us at the email provided below. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

Exercising your rights . If you are a data subject that has rights under the International Data Protection Laws, who chooses to exercise the rights listed above, you can submit a request via email at mailto:legal@humanable.com.

Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described above. If you reside in a European Union member state or the United Kingdom, you may also lodge a complaint with the supervisory authority in your country.

1. For Users Located in the United States CALIFORNIA.

• Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your personal information with third parties for the purposes of third-party marketing to you without your prior consent.
• Do Not Track Signals. Other than as disclosed in this Policy, the Website does not operate any differently when it receives Do Not Track signals from your internet web browser.
• WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” personal information, as those terms are defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your personal information.

YOUR CONSUMER RIGHTS.

Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Florida Digital Bill of Rights, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “U.S. State Privacy Laws"). Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our Services. If you reside in a state that provides additional rights with respect to your personal information, you may exercise each of your rights as identified below, subject to our verification of your identity.

1. Access . You have the right to request that we disclose certain information to you about our collection, use and disclosure of your personal information over the past twelve (12) months.
2. Correction . You can correct what personal data our Services currently contains by contacting us to request that we correct or rectify any personal data that you have provided to us.
3. Limit Use and Disclosure of Sensitive Personal Information . If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
4. Portability . Upon request and when possible, we can provide you with copies of your personal information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
5. Deletion . You have the right to request that we delete any of your personal information, subject to certain exceptions. 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. Where applicable, we will ensure such changes are shared with trusted third parties.
6. Opt-out of Processing . You have the right to request that we do not sell your personal information, use your personal information for targeted advertising, or use your personal information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
7. Non-Discrimination . If a consumer exercises his or her rights under applicable U.S. State Privacy Laws, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
8. Exercising your rights . If you are a consumer that has rights under applicable U.S. State Privacy Laws who chooses to exercise the rights listed above, you can:

1. Submit a request via email at legal@humanable.com; or write to us at Humanable, 1030 16th Ave. S, Floor 2, Nashville, TN 37212.

Identity verification. We may need to verify your identity before providing a substantive response to your request for your personal information. We take the privacy and security of your personal information seriously. Therefore, we will verify your identity by asking you to provide certain information about yourself. Once your identity is verified, we will provide your requested information in a timely manner.

Authorized agents. Under applicable U.S. State Privacy Laws, you may have the opportunity to empower an “authorized agent” to submit requests on their behalf. We may require proof that you gave the agent permission to submit the request.

Response to requests. We will make every effort to fulfill or respond to your request within forty-five (45) days. If we are unable to do so, we will notify you. We will also inform you when we have fulfilled your request or provide an explanation for why we are unable or not required to do so. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the Services you have requested.

THE INFORMATION WE COLLECT

The length of time HUMANABLE intends to retain personal information, including sensitive personal information, if any, is for as long as reasonably necessary to carry out HUMANABLE’s intended business purpose for such information.