Aureon Music Group Legal Centre

Privacy Policy

Version 1.0Last updated 3 August 2026

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AUREON MUSIC GROUP

PRIVACY POLICY

Version: 1.0Effective Date: 2 August 2026Last Updated: 2 August 2026

1. INTRODUCTION

Welcome to Aureon Music Group ("Aureon", "Aureon Music Group", "we", "our", or "us").

Your privacy is important to us.

This Privacy Policy explains how Aureon Music Group collects, uses, stores, protects, shares, transfers, and otherwise processes personal information when you access or use:

The Aureon Music Group website;

User accounts;

Listener subscriptions;

Creator subscriptions;

Commercial licensing services;

Digital music purchases;

Streaming services;

Artist pages;

Playlists;

Mobile applications;

Customer support services;

Marketing communications;

Social media integrations;

APIs (where available);

Any products or services operated by Aureon Music Group (collectively, the "Platform").

This Privacy Policy applies whenever you:

Visit our website;

Create an Account;

Purchase music;

Subscribe to our services;

License music;

Contact our support team;

Subscribe to newsletters;

Apply as an artist;

Interact with Aureon through social media;

Otherwise use the Platform.

By using the Platform, you acknowledge that your personal information will be processed in accordance with this Privacy Policy.

Where your consent is required by law, Aureon will obtain that consent before processing personal information requiring consent.

2. OUR PRIVACY COMMITMENT

Aureon Music Group is committed to protecting your personal information through responsible, transparent, and lawful data processing practices.

We are guided by the following principles:

Lawfulness

Fairness

Transparency

Data minimisation

Accuracy

Purpose limitation

Storage limitation

Integrity

Confidentiality

Accountability

Privacy considerations are incorporated into the design, development, and operation of our Platform ("Privacy by Design" and "Privacy by Default") wherever reasonably practicable.

3. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy explains:

What personal information we collect;

Why we collect it;

How we use it;

How long we retain it;

Who we share it with;

How we protect it;

Your rights regarding your personal information;

How you may exercise those rights;

How to contact Aureon regarding privacy matters.

This Privacy Policy is intended to help you make informed decisions about using our services.

4. WHO THIS POLICY APPLIES TO

This Privacy Policy applies to all individuals interacting with Aureon Music Group, including:

Website Visitors

Individuals who browse the Platform without creating an Account.

Registered Users

Individuals who create Aureon Accounts.

Listener Subscribers

Users subscribing to Aureon's personal music streaming services.

Creator Subscribers

Users obtaining commercial music licences through Creator Subscription plans.

Commercial Customers

Businesses purchasing commercial licences or enterprise services.

Artists

Artists represented by Aureon or submitting materials through authorised submission channels.

Business Partners

Licensors, publishers, distributors, marketing partners, and authorised representatives interacting with Aureon.

Customer Support Users

Individuals contacting Aureon through support channels.

Newsletter Subscribers

Individuals subscribing to Aureon marketing communications.

5. SERVICES COVERED

This Privacy Policy applies to all Aureon-operated services, including but not limited to:

Digital Music Store

Purchasing digital singles, albums, EPs, and other digital products.

Streaming Platform

Listening to music through free or paid services.

Listener Subscription Services

Recurring subscription services for personal listening.

Creator Subscription Services

Commercial licensing subscriptions for content creators.

Commercial Licensing

Business, advertising, podcast, corporate, film, television, and enterprise music licensing.

User Accounts

Account registration, authentication, profile management, playlists, favourites, and purchase history.

Artist Services

Artist submissions, promotional opportunities, distribution services, publishing administration, and related services.

Future Services

This Privacy Policy also applies to future Aureon products and services unless a separate privacy notice expressly states otherwise.

6. RELATIONSHIP WITH OTHER POLICIES

This Privacy Policy should be read together with Aureon's:

Cookie Policy;

Licensing Agreement;

Creator Licence Agreement;

Commercial Licensing Agreement;

Listener Subscription Terms;

Refund & Cancellation Policy;

AI Music Policy;

Acceptable Use Policy;

Community Guidelines;

Artist Submission Agreement.

Where another policy specifically governs a particular service, that policy supplements this Privacy Policy.

7. INTERNATIONAL OPERATIONS

Aureon Music Group operates internationally.

As a result:

users may access the Platform from different countries;

personal information may be processed across multiple jurisdictions;

local privacy laws may differ depending upon where you reside.

Aureon will process personal information in accordance with applicable privacy legislation and implement appropriate safeguards where international data transfers occur.

8. APPLICABLE DATA PROTECTION LEGISLATION

Depending upon your location, Aureon seeks to comply with applicable data protection laws including, where relevant:

General Data Protection Regulation (EU) 2016/679 ("GDPR");

Irish Data Protection Acts;

UK GDPR;

EU ePrivacy requirements;

Consumer privacy legislation applicable within jurisdictions where Aureon operates.

Nothing in this Privacy Policy limits any rights that cannot lawfully be restricted under applicable law.

9. CHANGES TO THIS PRIVACY POLICY

Aureon may update this Privacy Policy periodically to reflect:

changes in legislation;

changes in our services;

technological developments;

operational improvements;

security enhancements;

regulatory guidance.

Where material changes are made, Aureon will provide appropriate notice through one or more of the following methods:

Website notification;

Account notification;

Email notification;

Other reasonable electronic communication.

Your continued use of the Platform following the effective date of an updated Privacy Policy constitutes acceptance of the revised Policy, where permitted by applicable law.

10. YOUR RESPONSIBILITY

While Aureon takes appropriate measures to protect personal information, Users are responsible for:

providing accurate information;

keeping account information up to date;

protecting login credentials;

promptly notifying Aureon of unauthorised account activity;

ensuring contact information remains current.

Failure to maintain accurate information may affect Aureon's ability to provide services.

11. ACCEPTANCE OF THIS PRIVACY POLICY

By accessing or using the Platform, creating an Account, purchasing products, subscribing to services, or otherwise interacting with Aureon Music Group, you acknowledge that:

you have read this Privacy Policy;

you understand how Aureon processes personal information;

you agree to the collection, use, disclosure, storage, and protection of your personal information as described in this Privacy Policy;

where consent is required under applicable law, you consent to such processing.

Where you do not agree with this Privacy Policy, you should discontinue use of the Platform and any services that require the processing of your personal information.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 2 – DATA CONTROLLER & CONTACT INFORMATION

12. DATA CONTROLLER

For the purposes of applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 ("GDPR"), Aureon Music Group is the Data Controller for the personal information processed through the Platform, except where this Privacy Policy or a separate agreement expressly states otherwise.

As the Data Controller, Aureon Music Group determines:

the purposes for which personal information is collected;

the categories of personal information processed;

the lawful basis for processing;

how personal information is used;

how long information is retained;

how personal information is protected; and

when and with whom information is shared.

Where Aureon processes personal information on behalf of another organisation, Aureon may act as a Data Processor in accordance with the applicable agreement.

13. COMPANY DETAILS

Unless otherwise notified, the Data Controller is:

Aureon Music Group

Registered in the Republic of Ireland.

Principal place of business:

Republic of Ireland

Official website:

https://www.aureonmusic.com

Official support contact:

Support details published on the Platform.

Official legal notices:

Legal contact details published on the Platform.

If Aureon establishes regional subsidiaries or affiliated entities, this Privacy Policy may be updated to reflect those changes.

14. DATA PROTECTION CONTACT

Users may contact Aureon regarding:

privacy questions;

requests relating to personal information;

correction of personal data;

deletion requests;

data portability requests;

marketing preferences;

security concerns;

suspected privacy breaches;

complaints relating to data processing.

Privacy enquiries should be submitted using the designated privacy contact information published on the official Aureon website.

Aureon will make reasonable efforts to respond within the timeframes required by applicable law.

15. DATA PROTECTION OFFICER (DPO)

Where Aureon is legally required to appoint a Data Protection Officer ("DPO"), the DPO will oversee Aureon's compliance with applicable data protection legislation.

Where a DPO has been appointed, users may contact the DPO regarding:

GDPR rights;

privacy concerns;

data processing enquiries;

complaints regarding personal information;

requests to exercise statutory privacy rights.

If Aureon is not legally required to appoint a DPO, privacy matters will be managed by an appropriately authorised privacy or compliance representative.

16. REPRESENTATIVES IN OTHER JURISDICTIONS

Where required by applicable law, Aureon may appoint authorised privacy representatives in jurisdictions outside the Republic of Ireland.

Such representatives may act on Aureon's behalf regarding:

regulatory enquiries;

supervisory authority communications;

user privacy requests;

local compliance obligations.

Information regarding appointed representatives will be published where legally required.

17. HOW TO CONTACT US

You may contact Aureon regarding this Privacy Policy for matters including:

General Privacy Questions

Questions regarding how Aureon processes personal information.

Access Requests

Requests to access personal information held by Aureon.

Correction Requests

Requests to correct inaccurate or incomplete personal information.

Erasure Requests

Requests for deletion of personal information where applicable law permits.

Restriction Requests

Requests to restrict certain forms of processing.

Objection Requests

Objections to specific processing activities.

Data Portability

Requests for personal information in a portable format where applicable.

Marketing Preferences

Requests relating to marketing communications or consent.

Security Concerns

Reporting suspected security incidents affecting personal information.

Privacy Complaints

Complaints regarding Aureon's handling of personal information.

18. RESPONSE TIME

Aureon will acknowledge and respond to valid privacy requests within the timeframes required under applicable law.

Where requests are:

unusually complex;

involve multiple requests;

require identity verification; or

require consultation with third parties,

response times may be extended where permitted by law.

Where an extension is necessary, Aureon will notify the requester where required.

19. IDENTITY VERIFICATION

To protect personal information, Aureon may require reasonable verification of identity before responding to requests relating to personal data.

Verification measures may include:

Account authentication;

Email confirmation;

Multi-factor authentication;

Government-issued identification where reasonably necessary;

Additional information confirming identity.

Aureon will request only the information reasonably necessary to verify identity.

20. AUTHORISED REPRESENTATIVES

Where permitted by applicable law, an authorised representative may submit privacy requests on behalf of another individual.

Aureon may require:

written authorisation;

proof of legal authority;

identity verification for both the requester and the data subject.

Where sufficient authority cannot be demonstrated, Aureon may decline the request to protect personal information.

21. COMPLAINTS TO SUPERVISORY AUTHORITIES

If you believe Aureon has processed your personal information unlawfully, you may have the right to lodge a complaint with the competent data protection supervisory authority.

For users located in the Republic of Ireland, the competent supervisory authority is generally the Data Protection Commission (DPC).

Users residing in other jurisdictions may also have the right to contact the supervisory authority responsible for data protection in their country or region, where applicable.

We encourage users to contact Aureon first so that we have an opportunity to investigate and resolve concerns promptly.

22. COMMUNICATION METHODS

Aureon may communicate regarding privacy matters through:

Email;

Secure Account notifications;

Website notices;

Customer support correspondence;

Other secure electronic communication methods.

Users are responsible for ensuring that their contact details remain accurate and current.

23. LEGAL NOTICES

Formal legal notices relating to privacy or data protection should be submitted using the designated legal contact information published on the official Aureon website.

Electronic notices will be deemed received in accordance with applicable law unless otherwise specified.

24. FUTURE CONTACT DETAILS

Aureon reserves the right to update:

company contact details;

privacy contact information;

legal contact information;

customer support information;

regulatory contact details.

Updated contact information will be published on the Platform and, where required by law, reflected in this Privacy Policy.

25. TRANSPARENCY COMMITMENT

Aureon is committed to maintaining clear, accessible, and transparent communication regarding the processing of personal information.

We aim to ensure that:

privacy notices are written in clear language;

users understand how their information is processed;

users can easily exercise their statutory rights;

privacy enquiries are handled professionally and respectfully;

regulatory obligations are met in accordance with applicable law.

End of Privacy Policy – Section 2: Data Controller & Contact Information

Recommendation before publishing

One section should be updated with your actual legal entity details once your company structure is finalised. Replace the placeholders with:

Full registered company name (e.g. Aureon Music Group Limited if applicable)

Companies Registration Office (CRO) registration number

Registered office address

Trading address (if different)

Dedicated privacy email (info@aureonmusic.com)

Legal notices email (info@aureonmusic.com)

Support email (info@aureonmusic.com)

Including these details will strengthen transparency and help meet GDPR information requirements.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 3 – PERSONAL INFORMATION WE COLLECT

26. OVERVIEW

Aureon Music Group collects only the personal information reasonably necessary to provide, maintain, secure, improve, and lawfully operate the Platform.

The categories of personal information collected depend upon how you interact with Aureon and the services you use.

For example, the information collected from a website visitor will differ from that collected from a Creator Subscriber or commercial licensing customer.

Aureon does not intentionally collect personal information that is unnecessary for the operation of its business.

27. INFORMATION YOU PROVIDE DIRECTLY

You may voluntarily provide personal information when you:

Create an Account;

Purchase music;

Subscribe to services;

Apply for Creator Licensing;

Apply as an artist;

Contact customer support;

Complete forms;

Subscribe to newsletters;

Participate in surveys;

Enter competitions or promotions;

Submit commercial licence enquiries;

Communicate with Aureon.

Information you provide may include the categories below.

28. ACCOUNT INFORMATION

When creating or managing an Account, Aureon may collect:

Full name;

Display name;

Username;

Email address;

Password (stored securely using industry-standard authentication methods and never in plain text);

Country or region;

Preferred language;

Time zone;

Date of birth (where required);

Profile photograph (if uploaded);

Account preferences.

29. PROFILE INFORMATION

Users may optionally provide:

Biography;

Social media links;

Website address;

Favourite artists;

Favourite genres;

Listening preferences;

Profile image;

Public playlists;

Personal interests related to music.

Providing optional information is entirely voluntary.

30. SUBSCRIPTION INFORMATION

For Listener and Creator Subscriptions Aureon may collect:

Subscription type;

Subscription status;

Billing cycle;

Renewal dates;

Subscription history;

Licence history;

Benefits activated;

Promotional eligibility.

31. PURCHASE INFORMATION

When you purchase products or services, Aureon may collect:

Order number;

Purchased products;

Purchase date;

Purchase amount;

Currency;

Transaction identifiers;

Download history;

Invoice information;

Licence identifiers.

32. PAYMENT INFORMATION

Payments are securely processed by authorised third-party payment providers.

Aureon generally does not store complete payment card numbers.

Depending upon the payment provider, payment-related information may include:

Payment token;

Payment method type;

Billing address;

Country;

Last four digits of payment card (where available);

Payment status;

Transaction reference numbers.

Full payment credentials remain under the control of the authorised payment processor.

33. COMMERCIAL LICENSING INFORMATION

Commercial customers may provide:

Business name;

Trading name;

Company registration number;

VAT number (where applicable);

Business address;

Contact person;

Job title;

Business email;

Telephone number;

Intended commercial use;

Licence requirements.

34. ARTIST INFORMATION

Artists submitting material to Aureon may provide:

Legal name;

Stage name;

Contact information;

Biography;

Music catalogue;

Social media profiles;

Publishing information;

Distribution information;

Promotional photographs;

Marketing materials;

Contracts and supporting documentation.

Additional information may be requested during the artist evaluation process.

35. CUSTOMER SUPPORT INFORMATION

When you contact Aureon, we may collect:

Name;

Email address;

Account information;

Support tickets;

Communications;

Attachments;

Technical information relating to your enquiry;

Feedback;

Complaint details.

Support conversations may be retained for quality assurance, training, fraud prevention, and legal compliance.

36. COMMUNICATION PREFERENCES

We may record your preferences regarding:

Email communications;

Marketing communications;

Product announcements;

Artist news;

Promotional offers;

Newsletter subscriptions;

Notification settings.

You may update these preferences through your Account settings where available.

37. INFORMATION COLLECTED AUTOMATICALLY

When you use the Platform, certain technical information is collected automatically.

This may include:

IP address;

Browser type;

Browser version;

Device type;

Device identifiers;

Operating system;

Screen resolution;

Language settings;

Time zone;

Referral URLs;

Pages visited;

Session duration;

Clickstream data;

Crash reports;

Error logs.

This information helps Aureon maintain, improve, and secure the Platform.

38. DEVICE INFORMATION

We may collect information regarding devices used to access the Platform, including:

Device model;

Operating system version;

Browser version;

Device identifiers;

Mobile application version;

Authentication identifiers;

Security information.

Collection of device information assists with:

Fraud prevention;

Security;

Compatibility;

Technical support.

39. USAGE INFORMATION

Aureon may collect information regarding your interaction with the Platform, including:

Music played;

Songs skipped;

Listening duration;

Playlist creation;

Playlist edits;

Favourite artists;

Search history;

Downloads;

Purchase history;

Subscription activity;

Licence activity;

Feature usage.

Usage information helps improve recommendations and Platform performance.

40. LOCATION INFORMATION

Depending on your settings and applicable law, Aureon may determine your approximate location using information such as:

IP address;

Country;

Region;

Time zone.

Aureon does not collect precise GPS location information unless:

specifically requested;

necessary for a particular feature; and

authorised by the User.

41. COOKIES AND SIMILAR TECHNOLOGIES

Aureon uses cookies and similar technologies to collect information regarding:

Authentication;

Session management;

Preferences;

Website performance;

Analytics;

Security;

Fraud prevention;

User experience.

Detailed information is provided in Aureon's Cookie Policy.

42. INFORMATION FROM THIRD PARTIES

Aureon may receive information from trusted third parties, including:

Payment providers;

Authentication providers;

Fraud prevention services;

Analytics providers;

Marketing partners;

Customer support platforms;

Identity verification providers.

Third-party information is processed only where legally permitted.

43. SOCIAL MEDIA INTEGRATIONS

Where Users interact with Aureon through social media platforms, Aureon may receive information permitted by those platforms, including:

Public profile information;

Display names;

Profile images;

Public interactions;

Messages sent to Aureon;

Public comments.

Your relationship with those platforms remains governed by their respective privacy policies.

44. INFORMATION REQUIRED BY LAW

Aureon may collect additional personal information where required to:

Comply with legal obligations;

Prevent fraud;

Verify identity;

Enforce contracts;

Protect intellectual property;

Respond to lawful requests from public authorities.

45. SENSITIVE PERSONAL INFORMATION

Aureon does not intentionally request or require special category personal data (also known as sensitive personal information), such as information concerning:

Racial or ethnic origin;

Political opinions;

Religious beliefs;

Philosophical beliefs;

Trade union membership;

Genetic data;

Biometric data used for unique identification;

Health information;

Information concerning a person's sex life or sexual orientation.

Users should not voluntarily submit such information unless specifically requested and legally required.

Where sensitive personal information is processed, Aureon will do so only where a lawful basis exists under applicable law.

46. INFORMATION WE DO NOT KNOWINGLY COLLECT

Aureon does not knowingly collect:

Complete payment card numbers;

Card security codes (CVV/CVC);

Online banking passwords;

Government-issued identity numbers unless required for legal verification;

Unnecessary sensitive personal information;

Information from children where prohibited by law.

47. AGGREGATED AND ANONYMISED INFORMATION

Aureon may create aggregated, anonymised, or de-identified information that no longer identifies an individual.

Such information may be used for:

Statistical analysis;

Platform improvement;

Business planning;

Industry reporting;

Research;

Performance measurement.

Aggregated information is not treated as personal information where it can no longer reasonably identify an individual.

48. ACCURACY OF INFORMATION

Users are responsible for ensuring that the personal information they provide is:

Accurate;

Complete;

Current;

Not misleading.

Users should promptly update Account information whenever changes occur.

49. DATA MINIMISATION

Aureon follows the principle of data minimisation.

We seek to collect only the personal information that is reasonably necessary to:

Operate the Platform;

Deliver requested services;

Protect users;

Protect intellectual property;

Comply with applicable legal obligations;

Improve the Platform.

Information that is no longer required will be deleted or anonymised in accordance with our retention policies and applicable law.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 4 – HOW WE USE PERSONAL INFORMATION

50. OVERVIEW

Aureon Music Group processes personal information only where there is a legitimate and lawful purpose for doing so.

We use personal information to operate our Platform, deliver our services, fulfil contractual obligations, protect our users, improve our products, comply with legal requirements, and support the long-term operation of Aureon Music Group.

We do not sell your personal information to third parties.

51. ACCOUNT CREATION AND MANAGEMENT

We use personal information to:

Create user accounts;

Authenticate users;

Verify account ownership;

Maintain account settings;

Update profile information;

Manage passwords;

Enable secure login;

Synchronise user preferences across devices;

Recover accounts;

Prevent unauthorised access.

52. PROVIDING OUR SERVICES

We process personal information to deliver the services you request, including:

Music streaming;

Digital music downloads;

Playlist creation;

Favourite artists;

Music recommendations;

Listener subscriptions;

Creator subscriptions;

Commercial licensing;

Artist services;

Customer support;

Future Aureon products and services.

Without certain personal information, we may be unable to provide requested services.

53. PROCESSING MUSIC PURCHASES

We use personal information to:

Process purchases;

Confirm transactions;

Deliver digital products;

Generate invoices;

Maintain purchase history;

Provide download access;

Process refunds where applicable;

Prevent duplicate purchases;

Resolve payment disputes.

54. MANAGING SUBSCRIPTIONS

Personal information is used to:

Activate subscriptions;

Renew subscriptions;

Manage billing cycles;

Confirm payment status;

Provide subscriber benefits;

Monitor subscription eligibility;

Manage cancellations;

Restore subscriptions where requested.

55. COMMERCIAL LICENSING

Where you purchase or apply for commercial licences, Aureon uses personal information to:

Verify eligibility;

Issue licences;

Generate licence documentation;

Maintain licence records;

Verify authorised commercial use;

Resolve copyright claims;

Provide customer support;

Renew licences where applicable.

56. CREATOR SUBSCRIPTIONS

For Creator Subscribers, Aureon may process personal information to:

Verify subscription status;

Administer licence rights;

Manage commercial permissions;

Monitor authorised use;

Assist with copyright claims;

Validate licensing information;

Provide commercial support services.

57. ARTIST SERVICES

Where applicable, Aureon may process artist information to:

Evaluate artist submissions;

Review music submissions;

Manage artist profiles;

Publish biographies;

Promote artists;

Distribute recordings;

Administer publishing rights;

Maintain contractual relationships;

Process royalty administration where applicable.

Separate agreements may govern certain artist services.

58. PERSONALISING YOUR EXPERIENCE

We may use personal information to personalise the Platform by:

Recommending artists;

Recommending albums;

Suggesting playlists;

Remembering listening preferences;

Displaying recently played music;

Improving search results;

Presenting relevant content.

Personalisation helps improve your experience but does not involve automated decision-making that produces legal or similarly significant effects unless separately disclosed.

59. CUSTOMER SUPPORT

Personal information may be used to:

Respond to enquiries;

Resolve technical issues;

Investigate complaints;

Process refund requests;

Assist with licensing enquiries;

Provide troubleshooting;

Improve customer service.

Support communications may be retained for quality assurance and legal compliance.

60. COMMUNICATIONS

Aureon may use personal information to communicate with you regarding:

Service Communications

Account updates;

Purchase confirmations;

Subscription renewals;

Billing notices;

Security alerts;

Password resets;

Licence updates;

Platform maintenance.

These communications are generally necessary for providing our services.

Marketing Communications

Where permitted by law, Aureon may send:

New music releases;

Artist announcements;

Promotional offers;

Product updates;

Newsletter content;

Event invitations;

Special campaigns.

You may unsubscribe from marketing communications at any time.

61. IMPROVING THE PLATFORM

We use information to improve:

Website performance;

Mobile applications;

Streaming quality;

Search functionality;

User interface;

Platform reliability;

Accessibility;

Product development;

Customer experience.

Improvements may be based on aggregated or anonymised usage information where appropriate.

62. ANALYTICS

Aureon analyses Platform usage to understand:

Listening trends;

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 5 – LAWFUL BASES FOR PROCESSING (GDPR)

77. OVERVIEW

Where the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK GDPR, or similar legislation applies, Aureon Music Group processes personal information only where a lawful basis exists.

Not every processing activity relies upon the same lawful basis.

The lawful basis depends upon:

the type of personal information processed;

the purpose of the processing;

the relationship between Aureon and the individual;

applicable legal requirements.

Where multiple lawful bases apply, Aureon may rely upon more than one lawful basis for the same processing activity.

78. PERFORMANCE OF A CONTRACT

The primary lawful basis relied upon by Aureon is the performance of a contract.

Processing is necessary where it enables Aureon to fulfil contractual obligations requested by the User.

Examples include:

Creating user accounts;

Authenticating users;

Processing music purchases;

Delivering digital downloads;

Providing music streaming;

Managing playlists;

Providing Listener Subscriptions;

Providing Creator Subscriptions;

Issuing commercial licences;

Processing payments;

Managing customer support requests;

Maintaining purchase history;

Managing user settings;

Providing future Platform services requested by Users.

Without this processing, Aureon may be unable to provide the requested service.

79. LEGITIMATE INTERESTS

Aureon may process personal information where it is reasonably necessary for legitimate business interests, provided such interests are not overridden by the rights and freedoms of the individual.

Examples include:

Improving the Platform;

Detecting fraud;

Preventing abuse;

Securing user accounts;

Monitoring system performance;

Improving music recommendations;

Developing new products;

Maintaining platform stability;

Protecting intellectual property;

Protecting artists;

Protecting commercial licence holders;

Preventing unauthorised commercial use;

Investigating security incidents;

Measuring business performance;

Conducting internal analytics;

Managing customer relationships;

Responding to legal claims.

Before relying on legitimate interests, Aureon considers whether the processing is necessary and whether it has an undue impact on individuals' rights and freedoms.

80. LEGAL OBLIGATIONS

Certain processing activities are necessary to comply with legal obligations imposed upon Aureon.

Examples include processing required for:

Tax legislation;

Financial reporting;

Accounting obligations;

Anti-fraud requirements;

Court orders;

Regulatory investigations;

Law enforcement requests;

Intellectual property enforcement;

Consumer protection legislation;

Data protection legislation.

Where processing is legally required, Aureon may process personal information without obtaining additional consent.

81. CONSENT

Certain processing activities require your consent.

Where consent is required, Aureon will request it before processing begins.

Examples may include:

Marketing communications where required by law;

Non-essential cookies;

Optional promotional communications;

Certain optional profile features;

Future optional services requiring consent under applicable legislation.

Consent must be:

Freely given;

Specific;

Informed;

Unambiguous.

Users may withdraw consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

82. VITAL INTERESTS

In exceptional circumstances, Aureon may process personal information where necessary to protect the vital interests of:

Users;

Employees;

Artists;

Contractors;

Members of the public.

This lawful basis is expected to be relied upon only in rare emergency situations.

83. PUBLIC TASK

Although Aureon is generally a private commercial organisation, where processing is required for the performance of a task carried out in the public interest or under official authority, Aureon may rely upon this lawful basis where applicable.

84. SPECIAL CATEGORY PERSONAL DATA

Aureon does not intentionally collect or process special category personal data unless:

legally required;

expressly authorised by applicable law;

the individual has provided explicit consent where required.

Special category personal data includes information relating to:

racial or ethnic origin;

political opinions;

religious beliefs;

philosophical beliefs;

trade union membership;

genetic data;

biometric data used for identification;

health information;

information concerning sex life or sexual orientation.

Users should not submit such information unless specifically requested by Aureon.

85. CRIMINAL OFFENCE DATA

Aureon does not routinely collect or process information relating to criminal convictions or offences.

Where such information is processed, it will only occur:

where authorised by law;

where necessary for legal proceedings;

where necessary to protect legal rights;

where otherwise permitted under applicable legislation.

86. PURPOSE LIMITATION

Personal information is collected only for specified, explicit, and legitimate purposes.

Aureon will not subsequently process personal information in a manner incompatible with those original purposes unless:

a new lawful basis exists;

additional consent is obtained where required;

processing is otherwise permitted under applicable law.

87. DATA MINIMISATION

Aureon follows the principle of data minimisation.

We seek to collect and process only the personal information that is:

adequate;

relevant; and

limited to what is reasonably necessary

for the purposes identified in this Privacy Policy.

88. ACCURACY

Aureon takes reasonable steps to ensure that personal information is:

accurate;

complete;

current;

corrected where inaccuracies are identified.

Users are encouraged to update their Account information whenever changes occur.

89. STORAGE LIMITATION

Personal information will be retained only for as long as reasonably necessary to:

provide requested services;

fulfil contractual obligations;

comply with legal requirements;

resolve disputes;

enforce legal rights;

maintain financial records;

protect against fraud.

Once retention is no longer necessary, personal information will be securely deleted, anonymised, or otherwise disposed of in accordance with applicable law.

90. INTEGRITY AND CONFIDENTIALITY

Aureon implements appropriate technical and organisational measures designed to protect personal information against:

unauthorised access;

accidental loss;

destruction;

alteration;

disclosure;

misuse;

unlawful processing.

Security measures are reviewed periodically to reflect evolving risks and industry standards.

91. ACCOUNTABILITY

Aureon is committed to demonstrating compliance with applicable data protection legislation.

Where appropriate, Aureon maintains records relating to:

processing activities;

security measures;

data protection assessments;

privacy governance;

internal policies;

staff training;

incident management.

These measures support Aureon's ongoing privacy compliance programme.

92. BALANCING LEGITIMATE INTERESTS

Where Aureon relies upon legitimate interests, we assess:

the purpose of the processing;

whether the processing is necessary;

the reasonable expectations of individuals;

the potential impact on privacy;

whether appropriate safeguards can reduce privacy risks.

Where required, Aureon will conduct documented balancing assessments.

93. WITHDRAWAL OF CONSENT

Where processing is based upon consent, users may withdraw consent at any time by:

updating Account preferences;

changing cookie settings;

unsubscribing from marketing communications;

contacting Aureon using the published privacy contact details.

Withdrawal of consent does not affect processing carried out before withdrawal.

94. LAWFUL BASIS FOR FUTURE SERVICES

As Aureon expands its products and services, additional processing activities may be introduced.

Where required by law, Aureon will identify the appropriate lawful basis before commencing new processing activities and will update this Privacy Policy accordingly.

95. TRANSPARENCY

Aureon is committed to ensuring that individuals understand:

why personal information is processed;

which lawful basis applies;

how long information is retained;

who receives personal information;

what rights individuals possess under applicable law.

Where additional transparency notices are required for specific services, Aureon will provide them at the relevant point of data collection.

96. OUR COMPLIANCE COMMITMENT

Aureon Music Group continually reviews its data processing activities to ensure they remain:

lawful;

fair;

transparent;

proportionate;

secure; and

consistent with the principles of the GDPR and other applicable data protection legislation.

We are committed to protecting the rights and freedoms of our users while delivering a secure and reliable music platform.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 6 – COOKIES & TRACKING TECHNOLOGIES

97. OVERVIEW

Aureon Music Group uses cookies and similar technologies to operate, secure, improve, and personalise the Platform.

These technologies help us:

Provide essential website functionality;

Authenticate users;

Maintain secure sessions;

Remember user preferences;

Improve website performance;

Analyse Platform usage;

Detect fraud;

Protect user accounts;

Deliver requested services;

Improve the overall user experience.

Where required by applicable law, Aureon will obtain your consent before placing non-essential cookies on your device.

98. WHAT ARE COOKIES?

Cookies are small text files placed on your computer, smartphone, tablet, or other device when you visit a website.

Cookies allow websites to:

Recognise your device;

Remember your preferences;

Improve navigation;

Maintain login sessions;

Analyse visitor behaviour;

Improve website functionality.

Cookies cannot typically access information stored elsewhere on your device.

99. TRACKING TECHNOLOGIES

In addition to cookies, Aureon may use similar technologies including:

Local storage;

Session storage;

Web beacons;

Pixel tags;

Software development kits (SDKs);

Log files;

Device identifiers;

Authentication tokens;

Similar technologies that support Platform functionality.

These technologies help provide secure and reliable services.

100. TYPES OF COOKIES WE USE

Aureon may use the following categories of cookies.

Essential Cookies

Essential cookies are necessary for the operation of the Platform.

They enable functions including:

User authentication;

Secure login;

Session management;

Shopping cart functionality;

Payment processing;

Security features;

Fraud prevention;

Load balancing;

Website navigation.

Without these cookies, many Platform features cannot operate correctly.

Where permitted by law, these cookies do not require prior consent.

Preference Cookies

Preference cookies remember your choices, including:

Language preferences;

Region;

Theme preferences;

Accessibility settings;

Playback preferences;

Music player settings;

Cookie preferences.

These cookies improve your experience by avoiding the need to repeatedly enter the same preferences.

Analytics Cookies

Analytics cookies help Aureon understand how visitors use the Platform.

Analytics information may include:

Pages visited;

Time spent on pages;

Navigation paths;

Device types;

Browser information;

General geographic region;

Traffic sources;

Feature usage;

User engagement.

Analytics information is used to improve the Platform and user experience.

Where required by law, analytics cookies are used only with your consent.

Performance Cookies

Performance cookies assist Aureon in monitoring:

Website speed;

Error rates;

Service availability;

Infrastructure performance;

Technical issues;

User experience.

These cookies help improve Platform reliability.

Functional Cookies

Functional cookies enable features including:

Music playback preferences;

Playlist synchronisation;

Recently played content;

User interface customisation;

Personal settings;

Device recognition.

Security Cookies

Security cookies help:

Detect fraudulent activity;

Protect Accounts;

Prevent unauthorised access;

Identify suspicious behaviour;

Maintain Platform integrity.

These cookies are essential for protecting both users and Aureon.

101. COOKIES WE DO NOT USE

Unless expressly disclosed in future updates to this Privacy Policy or our Cookie Policy, Aureon does not intentionally use cookies to:

Sell personal information to advertisers;

Build advertising profiles for unrelated third parties;

Track users across unrelated websites for behavioural advertising without appropriate consent;

Collect unnecessary sensitive personal information.

102. THIRD-PARTY COOKIES

Certain trusted third-party service providers may place cookies when providing services to Aureon.

These providers may include services relating to:

Payment processing;

Authentication;

Analytics;

Fraud prevention;

Cloud infrastructure;

Customer support;

Website security;

Content delivery.

Third-party cookies are governed by the privacy practices of the relevant provider.

Aureon carefully selects service providers but does not control their independent privacy policies.

103. STRIPE COOKIES

Where payments are processed through Stripe, Stripe may use cookies or similar technologies to:

Process transactions;

Detect fraud;

Verify payment security;

Authenticate payment sessions;

Maintain transaction integrity.

These technologies are necessary for secure payment processing.

104. AUTHENTICATION COOKIES

Authentication cookies may be used to:

Keep users signed in;

Verify Account identity;

Remember login sessions;

Protect secure areas of the Platform;

Prevent session hijacking.

Authentication cookies generally expire automatically after logout or after a specified period of inactivity.

105. PLAYLIST AND MUSIC PLAYER COOKIES

Cookies may be used to remember:

Recently played tracks;

Queue information;

Volume settings;

Playback preferences;

Shuffle settings;

Repeat settings;

Favourite artists;

Listening preferences.

These cookies improve the listening experience.

106. MARKETING TECHNOLOGIES

Where permitted by applicable law and based on your consent, Aureon may use cookies to:

Measure marketing campaign effectiveness;

Understand newsletter engagement;

Improve promotional communications;

Analyse advertising performance.

Users may withdraw consent at any time.

107. CONSENT MANAGEMENT

Where required by law, Aureon provides users with a cookie consent mechanism allowing users to:

Accept all cookies;

Reject non-essential cookies;

Customise cookie preferences;

Withdraw consent;

Change preferences at any time.

Your cookie choices will be respected in accordance with applicable law.

108. WITHDRAWING CONSENT

You may withdraw consent for non-essential cookies by:

Updating cookie preferences through the Platform;

Adjusting browser settings;

Clearing cookies from your device;

Using available consent management tools.

Withdrawal of consent does not affect the lawfulness of processing occurring before consent was withdrawn.

109. BROWSER SETTINGS

Most web browsers allow users to:

View cookies;

Delete cookies;

Block cookies;

Restrict cookies;

Receive notifications before cookies are stored.

Blocking certain cookies may affect:

Account login;

Music playback;

Subscription features;

Shopping functionality;

User preferences;

Overall Platform performance.

110. COOKIE RETENTION

Cookies remain on your device for different periods depending on their purpose.

Cookies may be:

Session Cookies

Automatically deleted when your browser is closed.

Persistent Cookies

Stored until:

They expire;

You delete them;

You withdraw consent where applicable.

Retention periods vary according to the cookie's function.

111. DO NOT TRACK SIGNALS

Some browsers support "Do Not Track" ("DNT") signals.

Because no universally accepted technical standard currently exists for recognising DNT signals, Aureon may not respond consistently to all DNT requests.

If industry standards develop, Aureon may update its practices accordingly.

112. INTERNATIONAL USERS

Users accessing the Platform from different jurisdictions may be presented with different cookie consent options depending upon applicable legal requirements.

Aureon seeks to comply with local cookie consent obligations where reasonably practicable.

113. SECURITY OF COOKIE DATA

Aureon implements reasonable safeguards to protect information collected through cookies against:

Unauthorised access;

Alteration;

Disclosure;

Misuse.

Cookie information is handled in accordance with Aureon's broader security and privacy practices.

114. FUTURE TECHNOLOGIES

As technology evolves, Aureon may introduce new tracking technologies that perform functions similar to cookies.

Where such technologies involve personal information, Aureon will:

Assess applicable legal requirements;

Update this Privacy Policy and the Cookie Policy where appropriate;

Obtain consent where required by law.

115. COOKIE POLICY

This section provides an overview of Aureon's use of cookies.

Additional technical information, including detailed descriptions of specific cookies, retention periods, purposes, and third-party providers, is contained within Aureon's separate Cookie Policy, which forms part of Aureon's overall privacy framework.

116. OUR COMMITMENT

Aureon is committed to using cookies responsibly.

We seek to ensure that cookies are:

Used transparently;

Limited to legitimate purposes;

Configured appropriately;

Protected through reasonable security measures;

Consistent with applicable privacy legislation.

Users remain in control of their cookie preferences wherever consent is required by law.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 7 – PAYMENTS & THIRD-PARTY SERVICE PROVIDERS

117. OVERVIEW

Aureon Music Group relies on carefully selected third-party service providers to operate the Platform, process payments, deliver digital services, provide customer support, secure user accounts, and improve the overall user experience.

These providers process personal information only where necessary to perform services on Aureon's behalf or where they act as independent data controllers under their own legal obligations.

Aureon does not sell your personal information to third parties.

118. OUR APPROACH TO THIRD-PARTY PROVIDERS

Before engaging third-party service providers, Aureon seeks to ensure that they:

maintain appropriate security standards;

comply with applicable privacy legislation;

process personal information lawfully;

implement appropriate technical and organisational safeguards;

protect confidential information;

process personal information only for authorised purposes.

Where required by law, Aureon enters into appropriate contractual arrangements governing the processing of personal information.

119. PAYMENT PROCESSING

Payments made through the Platform are processed by authorised payment service providers.

At launch, Aureon uses:

Stripe

Stripe processes payments for:

Music purchases;

Listener Subscriptions;

Creator Subscriptions;

Commercial Licences;

Enterprise services;

Future paid services.

Depending upon the transaction, Stripe may process:

Cardholder name;

Billing address;

Payment card details;

Payment tokens;

Transaction amounts;

Currency;

Country;

Fraud prevention information;

Transaction identifiers.

Full payment card details are processed directly by Stripe and are generally not stored by Aureon.

Payment processing remains subject to Stripe's own privacy policy and legal obligations.

120. PAYMENT SECURITY

Aureon uses secure payment technologies designed to protect payment information.

Payment processing may include:

Encrypted communications;

Secure payment gateways;

Fraud detection systems;

Address verification;

Payment authentication;

Transaction monitoring;

Risk analysis.

Aureon does not receive or retain complete payment card numbers or security codes (CVV/CVC).

121. FRAUD PREVENTION PROVIDERS

To protect Users and the Platform, Aureon may work with trusted fraud prevention providers.

These providers may assist with:

Payment fraud detection;

Identity verification;

Chargeback prevention;

Suspicious transaction analysis;

Risk scoring;

Account protection.

Only information reasonably necessary for fraud prevention is shared.

122. CLOUD INFRASTRUCTURE

Aureon uses cloud infrastructure providers to securely operate the Platform.

These providers may host:

User Accounts;

Databases;

Authentication systems;

Streaming infrastructure;

File storage;

Website services;

Application services.

Cloud providers process information solely for the purpose of delivering infrastructure services.

123. AUTHENTICATION SERVICES

To secure user accounts, Aureon may use authentication providers.

Authentication services may process:

Email addresses;

Authentication tokens;

Device identifiers;

Security logs;

Password reset requests.

Authentication providers help maintain the security of user accounts and reduce unauthorised access.

124. CONTENT DELIVERY NETWORKS (CDNs)

Aureon may use Content Delivery Networks ("CDNs") to improve Platform performance.

CDNs may process limited technical information including:

IP address;

Browser type;

Device information;

Requested files;

General geographic location.

This information helps deliver content efficiently and securely.

125. ANALYTICS PROVIDERS

Aureon may engage analytics providers to better understand how users interact with the Platform.

Analytics providers may process information including:

Website visits;

Session duration;

Navigation paths;

Device information;

Browser information;

General location information;

Feature usage.

Analytics information assists Aureon in improving services and user experience.

Where required by law, analytics processing will occur only with appropriate consent.

126. CUSTOMER SUPPORT PROVIDERS

Where customer support services are provided through third-party platforms, those providers may process:

Names;

Email addresses;

Support tickets;

Communications;

Attachments;

Technical information relating to support requests.

Support providers process information solely to assist Aureon in providing customer support.

127. EMAIL COMMUNICATION PROVIDERS

Aureon may use secure email service providers to deliver:

Purchase confirmations;

Subscription notices;

Password reset emails;

Security notifications;

Marketing communications;

Customer support responses;

Platform announcements.

Email providers process personal information only for the purpose of delivering communications on Aureon's behalf.

128. MUSIC STREAMING INFRASTRUCTURE

To provide streaming services, Aureon may process information relating to:

Playback requests;

Device compatibility;

Streaming quality;

Listening sessions;

Buffering performance;

Playback history.

This processing is necessary to deliver streaming services efficiently.

129. DIGITAL DOWNLOAD DELIVERY

Where users purchase music downloads, Aureon or its authorised service providers may process information required to:

Verify purchases;

Deliver downloads;

Maintain download history;

Prevent fraudulent downloads;

Restore previous purchases where appropriate.

130. SOCIAL MEDIA INTEGRATIONS

Where Users choose to interact with Aureon through social media platforms, Aureon may receive limited information made available through those services.

Examples include:

Public profile information;

Usernames;

Profile photographs;

Public interactions;

Messages directed to Aureon.

The operation of those platforms remains governed by their own privacy policies.

131. BUSINESS PARTNERS

Where necessary, Aureon may share limited personal information with trusted business partners involved in:

Music licensing;

Publishing administration;

Distribution;

Royalty administration;

Rights management;

Artist services.

Information is shared only where necessary to provide requested services or fulfil contractual obligations.

132. LEGAL AND PROFESSIONAL ADVISERS

Aureon may disclose personal information to:

Solicitors;

Barristers;

Accountants;

Auditors;

Insurance providers;

Regulatory advisers;

Compliance consultants.

Such disclosures occur only where reasonably necessary for legitimate business or legal purposes.

133. REGULATORY AUTHORITIES

Aureon may disclose personal information where required to:

Comply with legal obligations;

Respond to lawful governmental requests;

Comply with court orders;

Protect legal rights;

Prevent fraud;

Investigate criminal activity;

Comply with regulatory investigations.

Disclosure occurs only where permitted or required by applicable law.

134. CORPORATE TRANSACTIONS

If Aureon undergoes:

A merger;

Acquisition;

Sale of assets;

Corporate restructuring;

Investment transaction;

Business transfer;

personal information may be transferred as part of the transaction where legally permitted.

Any successor organisation will remain subject to applicable data protection obligations.

135. INTERNATIONAL SERVICE PROVIDERS

Some authorised service providers may process personal information outside the Republic of Ireland.

Where international transfers occur, Aureon seeks to ensure that appropriate safeguards are implemented, including where applicable:

Adequacy Decisions;

Standard Contractual Clauses;

Equivalent safeguards recognised under applicable law.

136. THIRD-PARTY WEBSITES

The Platform may contain links to third-party websites.

Aureon is not responsible for:

The privacy practices of those websites;

Their content;

Their security;

Their services.

Users should review the privacy policies of third-party websites before providing personal information.

137. DATA PROCESSING AGREEMENTS

Where required by law, Aureon enters into appropriate Data Processing Agreements ("DPAs") with service providers acting as processors.

Such agreements typically require processors to:

Process information only on Aureon's documented instructions;

Maintain confidentiality;

Implement appropriate security measures;

Assist with data subject rights;

Report security incidents;

Delete or return information upon termination where appropriate.

138. DATA MINIMISATION

When working with service providers, Aureon seeks to share only the personal information reasonably necessary for the relevant service.

Service providers are not authorised to use personal information for unrelated purposes.

139. MONITORING OF PROVIDERS

Aureon periodically reviews its service providers to help ensure they continue to maintain appropriate standards of:

Security;

Privacy;

Compliance;

Operational reliability.

Aureon may replace providers where appropriate to improve services or maintain compliance.

140. NO SALE OF PERSONAL INFORMATION

Aureon does not sell personal information to:

Data brokers;

Advertising networks;

Marketing databases;

Unrelated third parties.

Personal information is shared only where necessary to operate the Platform, fulfil contractual obligations, comply with legal requirements, or with your consent where required.

141. FUTURE SERVICE PROVIDERS

As Aureon expands its business, additional service providers may be engaged.

Where those providers process personal information, Aureon will:

Assess privacy risks;

Implement appropriate contractual safeguards where required;

Update this Privacy Policy where necessary;

Comply with applicable legal requirements before processing begins.

142. OUR COMMITMENT

Aureon is committed to working only with service providers that support our commitment to:

Security;

Privacy;

Transparency;

Accountability;

Compliance with applicable data protection legislation.

We continually review our relationships with third-party providers to ensure they continue to meet our privacy and security expectations.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 8 – DATA SHARING & INTERNATIONAL TRANSFERS

143. OVERVIEW

Aureon Music Group is committed to protecting your personal information and shares it only where there is a legitimate business purpose, a contractual necessity, your consent, or a legal obligation.

We do not sell your personal information.

We do not rent your personal information.

We do not trade your personal information for commercial gain.

Where personal information is shared, Aureon seeks to ensure that appropriate legal, contractual, and technical safeguards are in place.

144. WHEN WE SHARE PERSONAL INFORMATION

Aureon may share personal information only where reasonably necessary to:

Provide requested services;

Deliver purchased products;

Process payments;

Administer subscriptions;

Provide commercial licences;

Operate the Platform;

Protect users;

Prevent fraud;

Enforce legal rights;

Comply with legal obligations.

Information is shared only to the extent reasonably necessary for those purposes.

145. INTERNAL SHARING

Personal information may be accessed by authorised personnel within Aureon where necessary for legitimate business purposes.

Access may be provided to personnel responsible for:

Customer Support;

Technical Operations;

Engineering;

Information Security;

Finance;

Licensing;

Legal;

Compliance;

Marketing;

Artist Relations;

Platform Administration.

Access is granted on a role-based basis and limited to information necessary for the individual's responsibilities.

146. AFFILIATED COMPANIES

Where Aureon operates through affiliated companies, subsidiaries, or future group entities, personal information may be shared between those entities where necessary to:

Provide services;

Manage subscriptions;

Support customer accounts;

Administer licensing;

Improve operations;

Comply with legal obligations.

Each affiliated entity will process personal information in accordance with applicable privacy legislation.

147. SERVICE PROVIDERS

Aureon shares personal information with trusted service providers that assist in operating the Platform.

Examples include providers of:

Payment processing;

Authentication;

Cloud infrastructure;

Database hosting;

Streaming infrastructure;

File storage;

Email delivery;

Analytics;

Customer support;

Fraud prevention;

Identity verification;

Security monitoring.

These providers process information only for authorised purposes and are contractually required to protect personal information where applicable.

148. PAYMENT PROVIDERS

Where payments are made through the Platform, relevant payment information is shared with authorised payment providers for the purpose of:

Processing transactions;

Preventing fraud;

Verifying payments;

Managing recurring subscriptions;

Processing refunds;

Meeting financial regulatory requirements.

Payment providers process personal information under their own legal obligations and privacy policies.

149. COMMERCIAL LICENSING

Where users obtain commercial music licences, Aureon may share limited information with:

Rights management organisations;

Publishing administrators;

Licensing partners;

Royalty administrators;

where necessary to administer licences or protect intellectual property rights.

Only information reasonably necessary for those purposes will be shared.

150. ARTISTS AND RIGHTS HOLDERS

Where reasonably necessary, Aureon may share limited information with:

Artists;

Producers;

Publishers;

Songwriters;

Record labels;

Rights holders;

to:

Resolve licensing enquiries;

Investigate copyright claims;

Administer royalty reporting;

Protect intellectual property rights.

Personal information is shared only where appropriate and lawful.

151. BUSINESS PARTNERS

Aureon may share limited personal information with trusted business partners where necessary to:

Deliver requested services;

Fulfil commercial contracts;

Provide enterprise licensing;

Support artist services;

Manage promotional campaigns;

Operate authorised business programmes.

Business partners are expected to process information in accordance with applicable legal obligations.

152. PROFESSIONAL ADVISERS

Personal information may be disclosed where reasonably necessary to Aureon's:

Solicitors;

Barristers;

External legal advisers;

Accountants;

Auditors;

Insurance providers;

Regulatory advisers;

Compliance consultants.

Such disclosures occur only for legitimate legal, financial, regulatory, or business purposes.

153. LEGAL DISCLOSURES

Aureon may disclose personal information where required to:

Comply with applicable law;

Respond to lawful governmental requests;

Comply with court orders;

Respond to subpoenas;

Cooperate with law enforcement;

Protect legal rights;

Defend legal claims;

Prevent fraud;

Protect the safety of individuals.

Aureon reviews legal requests where appropriate before disclosing information.

154. BUSINESS TRANSFERS

If Aureon undergoes:

A merger;

Acquisition;

Sale of assets;

Corporate restructuring;

Investment transaction;

Insolvency proceedings;

Business transfer;

personal information may form part of the transferred business assets.

Any acquiring organisation will remain responsible for complying with applicable privacy legislation.

Where required by law, Aureon will provide notice before such transfers occur.

155. WITH YOUR CONSENT

Where required by law, Aureon will share personal information with third parties only after obtaining your consent.

You may withdraw consent at any time where processing relies upon consent.

Withdrawal of consent does not affect processing carried out before consent was withdrawn.

156. INTERNATIONAL OPERATIONS

Aureon operates internationally.

As a result, personal information may be processed in countries outside your country of residence.

These transfers may occur because:

Cloud infrastructure operates internationally;

Payment processors operate internationally;

Customer support services operate internationally;

Service providers maintain global infrastructure;

Users access the Platform from different countries.

157. INTERNATIONAL TRANSFERS

Where personal information is transferred outside the European Economic Area ("EEA"), the United Kingdom, or other jurisdictions with transfer restrictions, Aureon seeks to ensure that appropriate safeguards are implemented.

Depending on the destination country, safeguards may include:

European Commission Adequacy Decisions;

UK Adequacy Regulations;

Standard Contractual Clauses ("SCCs");

International Data Transfer Agreements ("IDTAs");

Binding Corporate Rules where applicable;

Other legally recognised transfer mechanisms.

158. TRANSFER RISK ASSESSMENTS

Where required, Aureon may conduct transfer risk assessments before transferring personal information internationally.

These assessments may consider:

Local legal protections;

Security measures;

Technical safeguards;

Nature of the personal information;

Risks to individuals' rights and freedoms.

159. DATA SECURITY DURING TRANSFERS

Where personal information is transferred internationally, Aureon seeks to protect information through appropriate safeguards including:

Encryption in transit;

Secure communication protocols;

Access controls;

Authentication measures;

Contractual confidentiality obligations;

Security monitoring.

160. STORAGE LOCATIONS

Depending upon the service used, personal information may be stored in one or more jurisdictions.

Storage locations may change as Aureon expands its services or changes infrastructure providers.

Aureon will continue to apply appropriate safeguards regardless of storage location.

161. USER RESPONSIBILITY

Users acknowledge that international internet services naturally involve the transmission of information across international networks.

By using the Platform, Users understand that their personal information may be processed internationally in accordance with this Privacy Policy and applicable law.

162. CHILDREN'S INFORMATION

Aureon does not knowingly share children's personal information with third parties except where:

Necessary to provide requested services;

Required by law;

Authorised by a parent or legal guardian where applicable.

Additional safeguards may apply where children use the Platform in accordance with applicable legislation.

163. MARKETING PARTNERS

Where marketing partners assist Aureon with promotional activities, personal information will only be shared:

With your consent where required by law;

Where otherwise permitted under applicable legislation.

Aureon does not sell subscriber lists or customer databases.

164. ANONYMISED INFORMATION

Aureon may share anonymised or aggregated information that no longer identifies individual users.

Such information may be used for:

Industry analysis;

Business reporting;

Platform statistics;

Market research;

Product development.

Anonymised information is not considered personal information where individuals cannot reasonably be identified.

165. THIRD-PARTY RESPONSIBILITY

Where third parties act as independent data controllers, they are responsible for complying with their own legal obligations regarding personal information.

Users should review the privacy policies of those third parties before using their services.

166. DATA PROCESSING AGREEMENTS

Where service providers process personal information on Aureon's behalf, Aureon seeks to ensure that appropriate contractual protections are in place.

Such agreements typically require processors to:

Process information only on Aureon's documented instructions;

Maintain confidentiality;

Implement appropriate security measures;

Assist Aureon in responding to data subject requests where appropriate;

Notify Aureon of personal data breaches without undue delay;

Delete or return personal information upon termination of services where appropriate and legally permissible.

167. FUTURE INTERNATIONAL EXPANSION

As Aureon expands internationally, additional service providers and infrastructure may be introduced.

Before engaging new providers that process personal information, Aureon will:

Assess privacy implications;

Implement appropriate contractual safeguards where required;

Update this Privacy Policy where necessary;

Comply with applicable legal requirements governing international transfers.

168. OUR COMMITMENT

Aureon is committed to ensuring that personal information shared with third parties receives an appropriate level of protection, regardless of where it is processed.

We continually review our international data transfer practices to ensure they remain:

Lawful;

Transparent;

Secure;

Proportionate;

Consistent with evolving privacy legislation and recognised international data protection standards.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 9 – DATA RETENTION

169. OVERVIEW

Aureon Music Group retains personal information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes, enforce agreements, protect intellectual property, and operate the Platform.

We do not retain personal information indefinitely unless a legal or legitimate business reason requires continued retention.

When personal information is no longer required, Aureon will securely:

Delete it;

Anonymise it;

De-identify it; or

Dispose of it using appropriate security measures.

170. RETENTION PRINCIPLES

Aureon applies the following principles when determining retention periods:

Information is retained only for legitimate purposes.

Retention periods are proportionate to the purpose of processing.

Information is reviewed periodically.

Information is securely deleted when no longer required.

Legal obligations take precedence where mandatory retention applies.

Security and fraud prevention may justify longer retention where appropriate.

171. FACTORS USED TO DETERMINE RETENTION

Retention periods are determined by considering factors including:

The purpose for which information was collected;

Contractual obligations;

Subscription status;

Legal requirements;

Tax obligations;

Accounting obligations;

Regulatory obligations;

Fraud prevention requirements;

Intellectual property protection;

Ongoing disputes;

Litigation risks;

Security investigations;

Technical requirements.

Different categories of personal information may therefore be retained for different periods.

172. ACCOUNT INFORMATION

Account information is generally retained while your Account remains active.

Following Account closure, Aureon may retain limited Account information where necessary to:

Verify previous purchases;

Prevent fraud;

Maintain financial records;

Resolve disputes;

Enforce contractual obligations;

Comply with legal obligations;

Protect intellectual property.

Where continued retention is no longer required, Account information will be securely deleted or anonymised.

173. PURCHASE HISTORY

Purchase records may be retained for an extended period where reasonably necessary to:

Verify ownership of purchased music;

Restore previous purchases;

Process refunds;

Resolve payment disputes;

Maintain accounting records;

Comply with tax legislation;

Detect fraud;

Enforce licensing rights.

Purchase history may therefore remain available after Account closure where legally or operationally necessary.

174. SUBSCRIPTION INFORMATION

Subscription records may be retained to:

Verify subscription history;

Process renewals;

Investigate billing enquiries;

Resolve disputes;

Maintain financial records;

Comply with tax obligations;

Prevent fraudulent subscription activity.

Inactive subscription records may be archived before eventual deletion.

175. COMMERCIAL LICENSING RECORDS

Commercial licensing records may be retained for longer periods because they may be necessary to:

Verify licence validity;

Resolve copyright claims;

Demonstrate authorised commercial use;

Protect Aureon's intellectual property;

Comply with legal obligations;

Defend legal claims.

Licence documentation may therefore be retained after the licence itself has expired.

176. ARTIST INFORMATION

Information relating to artists, rights holders, and commercial partners may be retained for the duration of the relevant contractual relationship and for an appropriate period thereafter where necessary to:

Administer royalties;

Protect copyright;

Maintain ownership records;

Resolve contractual disputes;

Comply with accounting obligations;

Defend legal claims.

177. CUSTOMER SUPPORT RECORDS

Customer support communications may be retained for purposes including:

Quality assurance;

Staff training;

Resolving recurring technical issues;

Handling complaints;

Fraud prevention;

Legal compliance;

Defending legal claims.

Support records may be securely archived once no longer required for operational purposes.

178. SECURITY LOGS

Security logs may be retained where reasonably necessary to:

Detect fraud;

Investigate security incidents;

Protect user accounts;

Prevent unauthorised access;

Maintain Platform security;

Comply with regulatory obligations.

Security logs are periodically reviewed and deleted when no longer required.

179. WEBSITE LOGS

Website logs may include:

IP addresses;

Browser information;

Device information;

Access timestamps;

Error reports;

Technical diagnostics.

Such information is retained only for as long as reasonably necessary to:

Maintain Platform performance;

Diagnose technical issues;

Detect malicious activity;

Improve system reliability.

180. ANALYTICS INFORMATION

Analytics information may be retained to:

Measure Platform performance;

Analyse user engagement;

Improve services;

Develop new features;

Conduct statistical analysis.

Where possible, analytics information is aggregated or anonymised.

181. MARKETING INFORMATION

Marketing preferences are retained until:

Consent is withdrawn;

The User unsubscribes;

Marketing communications cease;

Retention is no longer justified.

Users may unsubscribe from marketing communications at any time.

Certain records demonstrating compliance with consent requirements may be retained where legally required.

182. PAYMENT INFORMATION

Aureon generally does not retain complete payment card details.

Payment providers retain payment information in accordance with:

Financial regulations;

Payment industry standards;

Anti-fraud requirements;

Applicable law;

Their own privacy policies.

Aureon may retain transaction identifiers and limited payment-related information necessary for accounting and customer support purposes.

183. LEGAL OBLIGATIONS

Certain information may be retained where necessary to comply with:

Tax legislation;

Financial reporting requirements;

Court orders;

Regulatory investigations;

Anti-fraud legislation;

Consumer protection laws;

Intellectual property enforcement.

Such information will be retained only for the period required by applicable law.

184. LITIGATION HOLDS

Where Aureon reasonably believes that information may be relevant to:

Actual litigation;

Anticipated litigation;

Arbitration;

Regulatory investigations;

Legal claims;

Government investigations;

relevant information may be retained until the matter has been fully resolved, notwithstanding standard retention schedules.

185. ACCOUNT DELETION REQUESTS

Where Users request deletion of their Account, Aureon will take reasonable steps to delete or anonymise personal information where:

No legal obligation requires retention;

No unresolved dispute exists;

No fraud investigation is ongoing;

No intellectual property enforcement action requires retention.

Deletion of an Account does not necessarily result in the immediate deletion of all associated information.

186. ANONYMISATION

Where operationally appropriate, Aureon may anonymise personal information rather than permanently delete it.

Once information has been irreversibly anonymised so that it can no longer reasonably identify an individual, it may be retained for:

Statistical analysis;

Business reporting;

Platform improvement;

Research;

Product development.

Anonymised information is no longer treated as personal information.

187. BACKUPS

Personal information may temporarily remain within secure system backups after deletion from active systems.

Backups are maintained for:

Disaster recovery;

Business continuity;

Security;

Operational resilience.

Backup copies are protected using appropriate security measures and are deleted or overwritten in accordance with Aureon's backup retention procedures.

188. DELETION METHODS

When personal information reaches the end of its retention period, Aureon seeks to securely dispose of it using methods appropriate to the type of information.

These methods may include:

Secure deletion;

Cryptographic erasure;

Database deletion;

Physical destruction of storage media where applicable;

Irreversible anonymisation.

189. PERIODIC REVIEW

Aureon periodically reviews retained personal information to determine whether continued retention remains necessary.

Information that no longer serves a legitimate purpose will be deleted, anonymised, or securely destroyed.

190. CHANGES TO RETENTION PERIODS

Retention periods may change where required because of:

Changes in legislation;

Regulatory guidance;

Court decisions;

Security requirements;

Operational improvements;

Business changes.

Where material changes affect Users, Aureon will update this Privacy Policy accordingly.

191. OUR COMMITMENT

Aureon Music Group is committed to retaining personal information responsibly.

We continually review our retention practices to ensure that personal information is:

Retained only where necessary;

Protected throughout its lifecycle;

Deleted or anonymised when no longer required;

Managed in accordance with applicable privacy legislation.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 10 – YOUR PRIVACY RIGHTS

192. OVERVIEW

Aureon Music Group respects the privacy rights of all individuals whose personal information we process.

Depending on your country of residence and the applicable data protection legislation, you may have certain rights regarding your personal information.

These rights may vary between jurisdictions.

Where applicable law grants you specific rights, Aureon will honour those rights in accordance with the relevant legislation.

Nothing in this Privacy Policy limits any mandatory rights granted under applicable law.

193. RIGHT TO BE INFORMED

You have the right to receive clear and transparent information regarding:

What personal information Aureon collects;

Why personal information is collected;

How personal information is used;

The lawful basis for processing;

Who receives your information;

How long information is retained;

Your legal rights;

How to contact Aureon regarding privacy matters.

This Privacy Policy forms part of Aureon's commitment to transparency.

194. RIGHT OF ACCESS

Subject to applicable law, you may request confirmation of whether Aureon processes your personal information.

Where applicable, you may request access to information including:

Categories of personal information processed;

Purposes of processing;

Recipients of personal information;

Retention periods;

Source of the information where applicable;

Information regarding international transfers;

Information regarding automated decision-making where applicable.

Where permitted by law, Aureon will provide a copy of your personal information.

195. RIGHT TO RECTIFICATION

You have the right to request correction of inaccurate personal information.

You may also request completion of incomplete personal information where appropriate.

Users are encouraged to keep Account information current through their Account settings whenever possible.

196. RIGHT TO ERASURE ("RIGHT TO BE FORGOTTEN")

Subject to applicable law, you may request deletion of your personal information where:

The information is no longer necessary;

Consent has been withdrawn and no other lawful basis exists;

You successfully object to processing;

Processing was unlawful;

Deletion is required by applicable law.

This right is not absolute.

Aureon may retain information where retention remains necessary for:

Legal obligations;

Tax requirements;

Accounting obligations;

Fraud prevention;

Legal claims;

Intellectual property protection;

Contract enforcement.

197. RIGHT TO RESTRICT PROCESSING

Where permitted by applicable law, you may request that Aureon temporarily restrict processing of your personal information where:

Accuracy is contested;

Processing is alleged to be unlawful;

Information is required for legal claims;

An objection to processing is being considered.

During restriction, Aureon may continue to store personal information but may limit other processing activities as required by law.

198. RIGHT TO DATA PORTABILITY

Where processing is based upon consent or contract and carried out by automated means, you may request that Aureon provide your personal information in a structured, commonly used, and machine-readable format.

Where technically feasible and legally permitted, you may also request transmission of that information to another service provider.

199. RIGHT TO OBJECT

Where Aureon relies upon legitimate interests as the lawful basis for processing, you may object to that processing.

Following a valid objection, Aureon will cease processing unless:

Compelling legitimate grounds override your interests;

Processing is necessary for legal claims;

Processing is otherwise authorised by applicable law.

200. RIGHT TO OBJECT TO DIRECT MARKETING

You have the right to object at any time to the processing of your personal information for direct marketing purposes.

Where you object:

Marketing communications will cease;

Marketing profiles will no longer be used for direct marketing;

Withdrawal will not affect previous lawful marketing activities.

Service-related communications necessary for providing the Platform may still be sent.

201. RIGHT TO WITHDRAW CONSENT

Where processing is based upon your consent, you may withdraw that consent at any time.

Examples include consent relating to:

Marketing communications;

Optional cookies;

Certain optional Platform features;

Future optional services requiring consent.

Withdrawal of consent does not affect processing carried out before consent was withdrawn.

202. RIGHTS RELATING TO AUTOMATED DECISION-MAKING

Where applicable law provides such rights, you may have the right not to be subject to decisions based solely on automated processing where those decisions produce legal effects or similarly significant effects.

Aureon does not ordinarily make such decisions.

Where automated decision-making is used in circumstances covered by applicable law, Aureon will implement appropriate safeguards.

203. RIGHT TO LODGE A COMPLAINT

If you believe Aureon has processed your personal information unlawfully, you may have the right to lodge a complaint with the appropriate supervisory authority.

For individuals located in Ireland, the competent authority is generally the Data Protection Commission (DPC).

Individuals located in other jurisdictions may also have the right to contact the supervisory authority responsible within their country or region.

Aureon encourages users to contact us first so we may attempt to resolve concerns promptly.

204. EXERCISING YOUR RIGHTS

You may exercise your privacy rights by contacting Aureon using the privacy contact details published on the Platform.

Requests should include sufficient information to allow Aureon to:

Verify your identity;

Understand your request;

Locate relevant information;

Respond appropriately.

Aureon may request additional information where reasonably necessary to verify identity.

205. IDENTITY VERIFICATION

To protect personal information from unauthorised disclosure, Aureon may require reasonable proof of identity before responding to requests.

Verification measures may include:

Account authentication;

Email confirmation;

Multi-factor authentication;

Government-issued identification where reasonably necessary;

Additional supporting documentation.

Only information reasonably necessary for verification will be requested.

206. RESPONSE TIMES

Aureon aims to respond to valid privacy requests within the timeframes required by applicable law.

Where requests are:

Particularly complex;

Numerous;

Require consultation with third parties;

Require additional verification;

response periods may be extended where permitted by law.

Where an extension is required, Aureon will notify the requester where applicable.

207. REQUESTS MADE BY AUTHORISED REPRESENTATIVES

Where permitted by applicable law, authorised representatives may submit requests on behalf of another individual.

Aureon may require:

Written authorisation;

Proof of legal authority;

Verification of identity;

Additional documentation confirming authority to act.

208. LIMITATIONS TO PRIVACY RIGHTS

Certain privacy rights may be limited where processing remains necessary for purposes including:

Compliance with legal obligations;

Prevention of fraud;

Detection of criminal activity;

Protection of intellectual property;

Exercise or defence of legal claims;

Protection of the rights of other individuals;

National security where required by law.

Where Aureon cannot comply fully with a request, we will explain the reasons where permitted by law.

209. NO DISCRIMINATION

Where required by applicable law, Aureon will not discriminate against individuals solely because they choose to exercise their privacy rights.

However, certain services may become unavailable where personal information necessary for providing those services is deleted or processing is restricted.

210. ACCOUNT MANAGEMENT

Many privacy rights can also be exercised directly through your Aureon Account, including:

Updating profile information;

Changing contact details;

Updating communication preferences;

Managing subscription settings;

Updating password information;

Reviewing certain account activity.

Using self-service tools may allow faster processing than submitting manual requests.

211. RECORD OF REQUESTS

Aureon may maintain records of privacy requests in order to:

Demonstrate legal compliance;

Improve privacy processes;

Prevent fraudulent requests;

Maintain audit records.

Such records will be retained only for as long as reasonably necessary.

212. OUR COMMITMENT TO YOUR RIGHTS

Aureon Music Group is committed to respecting and protecting the privacy rights of every user.

We continually review our privacy practices to ensure that individuals are able to:

Understand how personal information is processed;

Exercise their statutory rights;

Contact Aureon easily regarding privacy matters;

Receive fair, transparent, and lawful treatment.

Protecting personal information is a core part of Aureon's commitment to operating a trusted global music platform.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 11 – CHILDREN'S PRIVACY

213. OVERVIEW

Aureon Music Group is committed to protecting the privacy and safety of children and young people.

The Platform is intended primarily for individuals who are legally capable of entering into binding agreements within their jurisdiction.

Where children or minors access certain services, Aureon seeks to process their personal information in accordance with applicable child privacy legislation and appropriate parental or guardian involvement where required.

Protecting younger users is an important part of Aureon's privacy and safeguarding commitments.

214. MINIMUM AGE REQUIREMENTS

Unless otherwise permitted by applicable law:

Users must meet the minimum age required to create an Account within their jurisdiction.

Certain services may require users to be at least eighteen (18) years of age.

Commercial licensing services are intended for adults or legally authorised business representatives.

Artist agreements generally require legal capacity to enter into binding contracts unless a parent, guardian, or authorised representative is involved.

Where the law requires parental consent before processing a child's personal information, Aureon will seek to comply with those legal requirements.

215. USERS UNDER THE AGE OF MAJORITY

Where permitted by applicable law, children or minors may use limited features of the Platform with the involvement or permission of a parent or legal guardian.

Examples may include:

Listening to music;

Creating playlists;

Maintaining a personal music library;

Accessing educational or family-friendly content.

Parents and guardians are encouraged to supervise children's use of online services.

216. PARENTAL OR GUARDIAN CONSENT

Where required by applicable law, Aureon will seek to obtain verifiable consent from a parent or legal guardian before collecting or processing a child's personal information.

Where appropriate, Aureon may:

Request confirmation of parental responsibility;

Request age verification;

Request additional verification before activating certain services.

If valid parental consent cannot be obtained where legally required, Aureon may refuse or suspend access to the relevant service.

217. INFORMATION COLLECTED FROM CHILDREN

Where Aureon lawfully provides services to children, we seek to collect only the minimum personal information reasonably necessary to provide those services.

This may include:

First name or display name;

Account identifier;

Email address (where appropriate);

Listening preferences;

Playlist information;

Basic technical information necessary to operate the Platform.

We seek to minimise the collection of personal information relating to children wherever reasonably practicable.

218. INFORMATION WE DO NOT INTENTIONALLY COLLECT

Unless specifically required for lawful operation of the Platform, Aureon does not intentionally request or encourage children to provide:

Government-issued identification numbers;

Financial information;

Payment card information;

Sensitive personal information;

Precise geolocation data;

Unnecessary contact information;

Information unrelated to the requested service.

Children should never publicly disclose personal information through community features.

219. COMMERCIAL SERVICES

The following services are intended only for individuals with legal capacity or appropriately authorised business representatives:

Creator Subscriptions;

Commercial Licensing;

Enterprise Licensing;

Artist contracts;

Business accounts;

Corporate licensing;

Royalty administration.

Where minors participate in such activities, Aureon may require parental, guardian, or legal representative involvement.

220. MARKETING TO CHILDREN

Aureon does not intentionally direct marketing communications toward children where prohibited by applicable law.

Where marketing consent is required:

Consent will be obtained from the appropriate individual;

Marketing preferences may be managed by the parent or guardian where applicable;

Children will not be knowingly targeted with inappropriate commercial communications.

221. CHILD SAFETY

Aureon is committed to maintaining a safe online environment.

Users must not use the Platform to:

Exploit children;

Harass children;

Groom children;

Share child exploitation material;

Encourage harmful behaviour;

Publish inappropriate content directed at children;

Request personal information from children unlawfully.

Any suspected child exploitation or abuse may be reported to the appropriate authorities where required or permitted by law.

222. PARENTAL RIGHTS

Where applicable law grants parents or legal guardians rights regarding a child's personal information, they may request:

Access to personal information;

Correction of inaccurate information;

Deletion of personal information;

Restriction of processing;

Withdrawal of consent;

Closure of a child's Account where appropriate.

Aureon may require reasonable verification of parental authority before responding to such requests.

223. AGE VERIFICATION

Aureon may implement reasonable age verification measures where necessary to:

Comply with legal obligations;

Protect children;

Restrict access to age-limited services;

Prevent fraudulent age declarations.

Users who provide false age information may have their Accounts suspended or terminated.

224. DISCOVERY OF UNDERAGE ACCOUNTS

If Aureon becomes aware that personal information has been collected from a child in violation of applicable law, Aureon will take appropriate steps which may include:

Suspending the Account;

Requesting parental consent where legally permissible;

Deleting unlawfully collected information;

Restricting access to certain services;

Implementing additional safeguards.

Such action will be taken within a reasonable period after becoming aware of the issue.

225. EDUCATIONAL SERVICES

If Aureon introduces educational products or services in the future, additional privacy notices may apply.

Those notices may address:

Educational institutions;

Teachers;

Parents;

Students;

Educational licences;

Classroom features.

Additional safeguards may be implemented depending upon applicable law.

226. INTERNATIONAL CHILD PRIVACY LAWS

Because Aureon operates internationally, child privacy obligations may vary between jurisdictions.

Where applicable, Aureon seeks to comply with relevant child privacy legislation, including laws relating to:

Consent requirements;

Minimum age thresholds;

Educational services;

Children's online safety;

Data protection.

Local legal requirements may therefore affect the services available to younger users.

227. REPORTING CONCERNS

Users who believe that a child may be at risk through the Platform are encouraged to notify Aureon immediately using the official support or legal contact channels.

Reports should include sufficient information to allow Aureon to investigate appropriately.

Aureon will treat reports involving child safety with appropriate priority.

228. RETENTION OF CHILDREN'S INFORMATION

Where personal information relating to children is lawfully processed, Aureon seeks to retain such information only for as long as reasonably necessary to:

Provide requested services;

Comply with legal obligations;

Protect the child;

Resolve disputes;

Protect legal rights.

Information relating to children may be deleted or anonymised sooner where appropriate.

229. OUR COMMITMENT TO CHILDREN'S PRIVACY

Aureon Music Group recognises that children deserve enhanced protection when using online services.

Accordingly, Aureon is committed to:

Collecting the minimum information reasonably necessary;

Applying appropriate safeguards;

Respecting parental rights where applicable;

Complying with child privacy legislation;

Continuously reviewing child safety practices as our Platform evolves.

Protecting children and young users remains an important part of Aureon's commitment to operating a responsible, secure, and trustworthy global music platform.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 12 – SECURITY MEASURES

230. OVERVIEW

Aureon Music Group is committed to protecting the confidentiality, integrity, availability, and security of the personal information entrusted to us.

We implement appropriate technical, organisational, and administrative safeguards designed to protect personal information against:

Unauthorised access;

Unlawful processing;

Accidental disclosure;

Loss;

Destruction;

Alteration;

Theft;

Misuse.

Although no online service can guarantee absolute security, Aureon continually reviews and improves its security measures in accordance with evolving industry standards and applicable legal requirements.

231. SECURITY PRINCIPLES

Aureon's information security programme is based upon principles including:

Confidentiality;

Integrity;

Availability;

Accountability;

Least privilege;

Defence in depth;

Privacy by Design;

Privacy by Default;

Continuous improvement.

These principles guide the development, operation, and maintenance of the Platform.

232. TECHNICAL SAFEGUARDS

Aureon implements technical safeguards appropriate to the nature of the services provided.

These safeguards may include:

Encryption;

Secure communication protocols;

Authentication systems;

Role-based access controls;

Multi-factor authentication for administrative systems where appropriate;

Network monitoring;

Security logging;

Intrusion detection;

Secure cloud infrastructure;

Automated backups;

Malware protection;

Vulnerability management.

Security measures are reviewed periodically to address emerging risks.

233. ENCRYPTION

Where appropriate, Aureon uses encryption technologies to protect personal information.

This may include:

Encryption of information transmitted over public networks;

Encryption of sensitive information while stored;

Secure cryptographic protocols;

Encrypted authentication tokens;

Encrypted backup storage where appropriate.

Encryption standards are periodically reviewed to reflect current security practices.

234. ACCOUNT SECURITY

To protect user accounts, Aureon may implement measures including:

Secure authentication;

Password hashing using industry-recognised algorithms;

Session management;

Suspicious activity detection;

Rate limiting;

Device recognition where appropriate;

Password reset verification;

Account recovery procedures.

Users remain responsible for protecting their own login credentials.

235. PASSWORD SECURITY

Passwords are treated as confidential authentication credentials.

Aureon does not store passwords in plain text.

Users are encouraged to:

Create strong passwords;

Use unique passwords;

Avoid password sharing;

Change passwords if compromise is suspected;

Enable multi-factor authentication where available.

236. ACCESS CONTROLS

Access to personal information is restricted to authorised personnel who require access for legitimate business purposes.

Access controls may include:

Role-based permissions;

Least-privilege access;

Authentication requirements;

Administrative approval procedures;

Access logging;

Periodic access reviews.

Personnel are expected to access personal information only where necessary to perform their responsibilities.

237. EMPLOYEE CONFIDENTIALITY

Employees, contractors, consultants, and authorised personnel with access to personal information are expected to comply with confidentiality obligations.

Such obligations may include:

Confidentiality agreements;

Internal privacy policies;

Information security policies;

Acceptable use requirements;

Ongoing compliance obligations.

Unauthorised disclosure of personal information may result in disciplinary or legal action where appropriate.

238. SECURITY MONITORING

Aureon may monitor Platform activity for purposes including:

Detecting fraud;

Identifying suspicious behaviour;

Monitoring security events;

Detecting unauthorised access;

Protecting user accounts;

Investigating incidents;

Improving Platform security.

Monitoring is carried out in accordance with applicable law.

239. FRAUD PREVENTION

Security measures may include systems designed to identify:

Payment fraud;

Account compromise;

Credential theft;

Automated attacks;

Bot activity;

Chargeback abuse;

Unauthorised commercial licensing;

Suspicious login behaviour.

Fraud prevention measures help protect users and the integrity of the Platform.

240. NETWORK SECURITY

Aureon seeks to protect Platform infrastructure through measures including:

Firewalls;

Network segmentation;

Secure infrastructure configuration;

Traffic monitoring;

DDoS mitigation where available;

Secure cloud architecture;

Continuous infrastructure monitoring.

241. SOFTWARE SECURITY

Aureon follows secure software development practices where reasonably practicable.

Security activities may include:

Secure coding standards;

Dependency management;

Vulnerability remediation;

Software updates;

Security testing;

Configuration management;

Change management procedures.

Security improvements are implemented as the Platform evolves.

242. THIRD-PARTY SECURITY

Where Aureon engages third-party service providers, we seek to ensure they maintain appropriate security measures.

Where required, Aureon may assess providers by considering:

Security certifications;

Privacy compliance;

Technical safeguards;

Incident response capabilities;

Contractual security obligations.

Service providers are expected to maintain security standards appropriate to the services they provide.

243. DATA BACKUPS

Aureon maintains backup procedures designed to support:

Business continuity;

Disaster recovery;

Data resilience;

Operational continuity.

Backup systems are protected using appropriate security measures and access controls.

244. BUSINESS CONTINUITY

Aureon seeks to maintain appropriate business continuity and disaster recovery procedures designed to:

Restore critical services;

Protect user information;

Minimise operational disruption;

Recover from security incidents.

Recovery procedures are reviewed periodically.

245. SECURITY INCIDENT RESPONSE

Aureon maintains procedures for responding to suspected security incidents.

Response activities may include:

Incident identification;

Containment;

Investigation;

Risk assessment;

Mitigation;

System recovery;

Documentation;

Process improvement.

Incident response procedures are reviewed and updated where appropriate.

246. PERSONAL DATA BREACHES

If Aureon becomes aware of a personal data breach, we will respond in accordance with applicable law.

Where legally required, Aureon may:

Investigate the breach;

Contain the incident;

Assess potential risks;

Notify competent supervisory authorities;

Notify affected individuals;

Implement corrective measures;

Review security controls.

Not every security incident constitutes a reportable personal data breach.

247. USER RESPONSIBILITIES

Users also play an important role in protecting personal information.

Users should:

Protect Account credentials;

Use secure devices;

Install software updates;

Use antivirus protection where appropriate;

Avoid phishing attempts;

Keep recovery information current;

Report suspected unauthorised access immediately.

Failure to follow basic security practices may increase the risk of unauthorised access.

248. REPORTING SECURITY ISSUES

Users who discover suspected security vulnerabilities or unauthorised access relating to the Platform are encouraged to notify Aureon promptly.

Reports should include sufficient information to assist Aureon in investigating the issue.

Aureon appreciates responsible disclosure of genuine security vulnerabilities.

249. RETENTION OF SECURITY RECORDS

Security-related records may be retained where reasonably necessary to:

Detect recurring threats;

Investigate fraud;

Maintain audit trails;

Protect legal rights;

Comply with legal obligations;

Improve security controls.

Retention periods are determined in accordance with Aureon's Data Retention Policy and applicable law.

250. LIMITATIONS OF SECURITY

Although Aureon implements appropriate safeguards, no method of electronic transmission, storage, or internet communication can be guaranteed to be completely secure.

Accordingly:

No security system is infallible;

No website can guarantee absolute protection against every cyber threat;

Users share responsibility for protecting their own Accounts and devices.

Nothing in this Privacy Policy constitutes a guarantee that unauthorised access can never occur.

251. SECURITY REVIEWS

Aureon periodically reviews its security programme to reflect:

Technological developments;

Emerging cyber threats;

Regulatory changes;

Industry best practices;

Operational improvements;

Lessons learned from security incidents.

Security measures continue to evolve alongside the Platform.

252. OUR SECURITY COMMITMENT

Protecting personal information is a core responsibility of Aureon Music Group.

We are committed to maintaining security measures that are:

Reasonable;

Appropriate;

Risk-based;

Proportionate;

Continuously improved;

Consistent with recognised information security practices and applicable privacy legislation.

We continually assess and strengthen our security controls to support a safe, secure, and trustworthy global music platform.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 13 – MARKETING COMMUNICATIONS

253. OVERVIEW

Aureon Music Group may communicate with Users regarding products, services, artists, subscriptions, licensing opportunities, promotions, and other information relevant to the Platform.

We are committed to conducting marketing activities in a lawful, transparent, and respectful manner.

Where required by applicable law, Aureon will obtain your consent before sending direct marketing communications.

Users remain in control of their marketing preferences at all times.

254. TYPES OF COMMUNICATIONS

Aureon may send two broad categories of communications:

Service Communications

These communications are necessary for providing the Platform and generally do not require separate marketing consent.

Examples include:

Account verification;

Password reset emails;

Purchase confirmations;

Subscription renewals;

Billing notices;

Security alerts;

Licence updates;

Customer support responses;

Important policy updates;

Technical maintenance notices.

These communications cannot generally be disabled while an Account remains active if they are necessary to provide the requested service.

Marketing Communications

Marketing communications may include:

New music releases;

Album launches;

Artist announcements;

Exclusive content;

Promotional offers;

Discount campaigns;

Subscription promotions;

Commercial licensing opportunities;

Product updates;

Company news;

Event announcements;

Competitions and giveaways;

Surveys and promotional invitations.

Marketing communications will be sent only where permitted by applicable law.

255. HOW WE MAY CONTACT YOU

Where authorised, Aureon may communicate with Users through:

Email;

In-Platform notifications;

Mobile application notifications;

SMS or text messages (where consent has been obtained where required);

Push notifications;

Other electronic communication methods supported by the Platform.

The communication methods used may depend upon your preferences and applicable legal requirements.

256. CONSENT TO MARKETING

Where required by law, Aureon will request your consent before sending direct marketing communications.

Consent requests will be:

Clearly presented;

Specific;

Freely given;

Informed;

Separate from other agreements where legally required.

Users are under no obligation to consent to marketing in order to use the Platform unless a particular communication is essential to the requested service.

257. LEGITIMATE INTERESTS

Where permitted under applicable law, Aureon may rely upon legitimate interests to send certain communications relating to:

Existing customer relationships;

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 14 – CHANGES TO THIS PRIVACY POLICY

273. OVERVIEW

Aureon Music Group may update, revise, or replace this Privacy Policy from time to time to reflect changes in our business operations, technology, legal obligations, regulatory guidance, or the services we provide.

We are committed to ensuring that any changes are communicated in a transparent and appropriate manner.

Users are encouraged to review this Privacy Policy periodically to remain informed about how their personal information is collected, used, protected, and processed.

274. WHY THIS PRIVACY POLICY MAY CHANGE

Aureon may update this Privacy Policy for reasons including, but not limited to:

Changes to applicable laws or regulations;

New guidance issued by regulatory authorities;

Court decisions;

Changes to our products or services;

Introduction of new Platform features;

Expansion into additional countries or jurisdictions;

New subscription services;

New licensing products;

Changes to payment providers;

Changes to cloud infrastructure;

Security improvements;

Technological developments;

Business acquisitions or restructuring;

Operational improvements;

Customer feedback.

Updates are intended to ensure that this Privacy Policy remains accurate, transparent, and legally compliant.

275. MATERIAL CHANGES

Where Aureon makes material changes that significantly affect the way personal information is processed, we will provide appropriate notice before those changes become effective where required by applicable law.

Material changes may include:

New categories of personal information collected;

New purposes for processing;

Significant changes to international data transfers;

Changes to Users' privacy rights;

Changes affecting lawful bases for processing;

Significant changes to data sharing practices;

Major changes to marketing practices.

276. NON-MATERIAL CHANGES

Minor or administrative updates may be made without separate notice where they do not materially affect Users' rights or the way personal information is processed.

Examples include:

Typographical corrections;

Formatting improvements;

Clarifications of existing provisions;

Updated contact details;

Cross-reference corrections;

Administrative amendments.

Such updates may take effect immediately upon publication unless otherwise required by law.

277. HOW WE WILL NOTIFY USERS

Where notification is appropriate, Aureon may communicate changes using one or more of the following methods:

Notices displayed on the Platform;

Account notifications;

Email communications;

Mobile application notifications;

Customer support communications;

Website announcements;

Other reasonable electronic communication methods.

The method of notification may depend upon the nature and significance of the changes.

278. EFFECTIVE DATE OF CHANGES

Each version of this Privacy Policy will display:

An effective date;

A last updated date; and

Where appropriate, a version number.

Unless otherwise stated, updates become effective on the date specified within the revised Privacy Policy.

279. CONTINUED USE OF THE PLATFORM

Where permitted by applicable law, continued access to or use of the Platform after the effective date of an updated Privacy Policy constitutes acknowledgement of the revised Privacy Policy.

Where applicable law requires additional consent for specific processing activities, Aureon will obtain that consent before commencing the relevant processing.

Nothing in this section limits any statutory rights that cannot lawfully be excluded.

280. CONSENT FOR NEW PROCESSING ACTIVITIES

If Aureon intends to process personal information for a materially different purpose that requires a new lawful basis or fresh consent under applicable law, we will:

Clearly explain the new purpose;

Identify the relevant lawful basis;

Update this Privacy Policy where appropriate;

Obtain any required consent before commencing the new processing activity.

Users will have the opportunity to make informed decisions regarding any new processing that requires their consent.

281. HISTORICAL VERSIONS

Aureon may retain previous versions of this Privacy Policy for purposes including:

Demonstrating legal compliance;

Responding to regulatory enquiries;

Resolving disputes;

Maintaining internal records;

Auditing privacy practices.

Previous versions may be made available upon reasonable request where required by applicable law.

282. REVIEW OF THIS PRIVACY POLICY

Aureon periodically reviews this Privacy Policy to ensure that it remains:

Accurate;

Transparent;

Current;

Consistent with our services;

Consistent with applicable legislation;

Reflective of recognised privacy best practices.

Reviews may occur whenever significant legal, operational, or technological developments arise.

283. USER RESPONSIBILITY

Users are encouraged to review this Privacy Policy periodically to remain informed about:

Changes to privacy practices;

New services;

Updated rights;

New security measures;

Changes to data processing activities.

Where Users continue to use the Platform following updates, they should ensure they understand the revised Privacy Policy.

284. QUESTIONS REGARDING CHANGES

If you have questions regarding changes to this Privacy Policy, you may contact Aureon using the official privacy contact details published on the Platform.

Aureon will make reasonable efforts to respond to privacy enquiries within the timeframes required by applicable law.

285. VERSION CONTROL

For transparency, each published version of this Privacy Policy should include:

Document title;

Version number;

Effective date;

Last updated date.

Where appropriate, Aureon may also provide a summary of significant changes introduced in each version to help Users understand how the Privacy Policy has evolved.

286. OUR COMMITMENT

Aureon Music Group is committed to maintaining a Privacy Policy that evolves responsibly alongside our Platform.

Whenever changes become necessary, we aim to ensure they are:

Transparent;

Clearly communicated;

Legally compliant;

Fair to Users;

Consistent with recognised privacy principles.

Maintaining an accurate and up-to-date Privacy Policy is an important part of Aureon's commitment to protecting the personal information of our global community of listeners, creators, artists, and commercial partners.

AUREON MUSIC GROUP

PRIVACY POLICY

SECTION 15 – COMPLAINTS & CONTACT DETAILS

287. OVERVIEW

Aureon Music Group is committed to handling privacy enquiries, data protection requests, and complaints in a fair, transparent, timely, and professional manner.

If you have any questions regarding this Privacy Policy or believe that your personal information has not been handled appropriately, we encourage you to contact Aureon first so that we have an opportunity to investigate and resolve the matter.

Nothing in this Privacy Policy limits your right to contact the relevant supervisory authority or pursue any remedies available under applicable law.

288. CONTACTING AUREON

Users may contact Aureon regarding matters including:

Privacy enquiries;

Questions regarding this Privacy Policy;

Data protection requests;

Requests to exercise privacy rights;

Account privacy concerns;

Marketing preferences;

Cookie preferences;

International data transfers;

Data security concerns;

Suspected unauthorised access;

Personal data breaches;

Complaints regarding the handling of personal information.

Aureon aims to respond to all legitimate enquiries as promptly as reasonably practicable.

289. PRIVACY CONTACT DETAILS

Privacy enquiries should be submitted using Aureon's official privacy contact details published on the Platform.

Once available, Aureon's primary privacy contact details will include:

Support Email

info@aureonmusic.com

Website

https://www.aureonmusic.com

If these contact details change, the updated information will be published on the Platform and reflected in this Privacy Policy where appropriate.

290. SUBMITTING A PRIVACY REQUEST

To assist Aureon in responding efficiently, privacy requests should include, where applicable:

Full name;

Account email address;

Username (if applicable);

Description of the request;

Relevant dates;

Supporting documentation where appropriate;

Preferred method of contact.

Providing sufficient information helps Aureon locate relevant records and process requests efficiently.

291. IDENTITY VERIFICATION

Before responding to certain privacy requests, Aureon may require reasonable verification of identity to protect personal information against unauthorised disclosure.

Verification may include:

Account authentication;

Email confirmation;

Multi-factor authentication;

Government-issued identification where reasonably necessary;

Additional supporting information.

Aureon requests only the information reasonably necessary for verification.

292. RESPONSE TIMES

Aureon seeks to respond to valid privacy requests within the timeframes required by applicable law.

Where requests are:

Complex;

Numerous;

Require additional verification;

Require consultation with third parties;

response periods may be extended where permitted by law.

Where an extension is required, Aureon will notify the requester where applicable.

293. PRIVACY COMPLAINTS

If you believe Aureon has failed to comply with applicable privacy legislation or this Privacy Policy, you may submit a formal privacy complaint.

Complaints should include sufficient information describing:

The nature of the complaint;

The relevant circumstances;

The personal information involved;

The outcome sought.

Aureon will investigate complaints in good faith and seek to resolve them fairly and promptly.

294. SECURITY INCIDENT REPORTS

Users who become aware of suspected:

Unauthorised access;

Account compromise;

Data breaches;

Fraudulent activity;

Identity theft;

Security vulnerabilities;

Suspicious Platform activity;

should notify Aureon immediately using the official support or security contact channels.

Prompt reporting assists Aureon in protecting users and investigating potential incidents.

295. REPORTING COPYRIGHT OR LICENSING ISSUES

Questions relating to:

Commercial licensing;

Intellectual property;

Artist rights;

Licence verification;

Content ownership;

should be submitted using Aureon's designated legal contact channels.

Separate procedures may apply to copyright notices and licensing disputes.

296. REPORTING CHILD SAFETY CONCERNS

Reports concerning:

Child safety;

Child exploitation;

Unlawful content involving minors;

Grooming;

Child abuse material;

should be reported immediately using Aureon's designated reporting channels.

Where required by law, Aureon may report such matters to the appropriate law enforcement or child protection authorities.

297. COMPLAINTS TO SUPERVISORY AUTHORITIES

If you believe Aureon has processed your personal information in a manner that violates applicable law, you may have the right to lodge a complaint with the relevant data protection supervisory authority.

For users located in the Republic of Ireland, the competent supervisory authority is generally:

Data Protection Commission (DPC)

Users residing in other jurisdictions may also have the right to contact the supervisory authority responsible for privacy regulation within their own country or region.

Aureon encourages users to contact us first so we may attempt to resolve concerns promptly and amicably.

298. DISPUTE RESOLUTION

Where appropriate, Aureon seeks to resolve privacy concerns through constructive dialogue before formal legal proceedings become necessary.

Nothing in this Privacy Policy prevents:

Users from exercising statutory rights;

Complaints to supervisory authorities;

Court proceedings where permitted by applicable law.

299. COMMUNICATION METHODS

Aureon may communicate regarding privacy matters through:

Email;

Secure Account notifications;

Website notices;

Customer support correspondence;

Other secure electronic communication methods.

Users are responsible for ensuring that their contact details remain current to facilitate effective communication.

300. DOCUMENT INFORMATION

Document Title

Aureon Music Group Privacy Policy

Version

1.0

Effective Date

2 August 2026

Last Updated

2 August 2026

Applicable Services

This Privacy Policy applies to all Aureon Music Group products and services including:

Website;

User Accounts;

Music Streaming;

Digital Music Store;

Listener Subscriptions;

Creator Subscriptions;

Commercial Licensing;

Artist Services;

Playlists;

Mobile Applications;

Future Aureon-operated services unless expressly stated otherwise.

301. ENTIRE PRIVACY POLICY

This Privacy Policy forms part of Aureon's overall legal framework and should be read together with the:

Cookie Policy;

Licensing Agreement;

Creator Licence Agreement;

Commercial Licensing Agreement;

Listener Subscription Terms;

Refund & Cancellation Policy;

AI Music Policy;

Acceptable Use Policy;

Community Guidelines;

Artist Submission Agreement.

Where another policy specifically governs a particular service or processing activity, that policy supplements this Privacy Policy.

302. FINAL PRIVACY COMMITMENT

At Aureon Music Group, we believe that privacy is fundamental to the trust placed in us by our listeners, creators, artists, commercial partners, and the wider music community.

We are committed to:

Processing personal information lawfully;

Being transparent about our practices;

Protecting personal information using appropriate safeguards;

Respecting the rights of individuals;

Continuously improving our privacy programme;

Complying with applicable data protection legislation wherever we operate.

We appreciate the trust you place in Aureon Music Group and remain committed to protecting your personal information while delivering a secure, innovative, and world-class music platform.

End of Privacy Policy

Document Information

Document Title: Aureon Music Group Privacy Policy

Version: 1.0

Effective Date: 2 August 2026

Last Updated: 2 August 2026

Governing Jurisdiction: Republic of Ireland (without limiting any mandatory rights available under applicable privacy legislation)

Applies To: Website, User Accounts, Music Streaming, Digital Downloads, Listener Subscriptions, Creator Subscriptions, Commercial Licensing, Artist Services, Mobile Applications, APIs, and all other Aureon Music Group services unless a separate privacy notice expressly applies.

Document Status: Official Privacy Policy of Aureon Music Group.