Privacy Policy

LAST UPDATED: January 2025

This Privacy Policy describes how Positive Grid (the "Site", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from positivegrid.com (the "Site") or otherwise communicate with us regarding the Site (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.

GDPR Readiness Assessment Powered by Positive Grid LTD Privacy Note

We take the private nature of your personal information very seriously and are committed to protecting it. To do that, we've set up procedures to ensure that your information is handled responsibly and in accordance with applicable data protection and privacy laws. We're grateful for your trust, and we'll act that way.

This privacy policy explains how we use any personal information we collect about you when you use this website, our products, our wider services, and what choices we offer you to access, update, and control it.

As part of our efforts in implementing the latest policies, practices, and processes, we will be reviewing these policies, practices, and processes from time to time. We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. Any amended Privacy Policy will be posted on our website, update the "Last updated" date, and, where required by law, we will notify you of significant changes. You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

Glossary of Terms

PERSONAL INFORMATION: Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

Name
Age
Gender
Email
Country
Language
Phone
Address

WHAT IS A DATA CONTROLLER? For general data protection regulation purposes, the “data controller” means the person or organization who decides the purposes for which and the way in which any personal data is processed.

WHAT IS A DATA PROCESSOR? A “data processor” is a person or organization which processes personal data for the controller.

Whose data we collect?

We collect and process data from a range of our customers:

Visitors to our website at www.positivegrid.com and other related websites.
Customers who use our software (including software demos) or our services.
Customers who bought our hardware or software directly or from our agencies.

You will fall into one or more of these categories of customers.

What data is being collected?

COLLECTION OF PERSONAL DATA OFFLINE

If Positive Grid processes personal data offline (e.g., printed forms), the party concerned must be given an information notice regarding the processing to obtain their consent, whenever necessary; this also applies to situations in which the data are collected from forms downloaded from the website (the privacy statement is set out on the forms together with, whenever necessary, the request for express consent to the specific handling operation in question).

COLLECTION OF PERSONAL DATA ONLINE

As regards to the collection of data directly on the website (e.g., registration forms, data sent in order to benefit from services online), the basic information relating to the processing is provided on each individual form found on the site (e.g., at the end of each registration form); this page can however be accessed at any time in order to view the Privacy Policy applied more generally by Positive Grid.

Every request for information regarding the processing of personal data, whether optional, explicit or voluntary, made by electronic mail, necessarily requires the address of the sender/applicant to be given, as well as any further personal data included in the message, in order that a reply can be submitted.

Data on how a user interacts with our software products may be analyzed. For example, but not limited to: the features they use and how often, playing into or through the product, recording, amp or effects selecting, selected backing or play-a-long tracks, uploading to Tone Cloud, and file types saved, imported, and exported.

We collect data from you directly or receive them from third-party services (e.g., Google Analytics, Shopify, etc.). You can opt out and delete all your data at any time from your account settings.

Legal Basis for Data Processing

Positive Grid processes personal data based on the following legal grounds:

Consent: When you provide clear consent for the processing of your personal data for specific purposes (e.g., marketing communications, participation in surveys).
Contract Performance: When processing is necessary to perform a contract to which you are a party or to take steps at your request before entering into a contract.
Legal Obligation: When processing is necessary for compliance with a legal obligation to which Positive Grid is subject (e.g., tax reporting, fraud prevention).
Legitimate Interests: When processing is necessary for the legitimate interests of Positive Grid or a third party, except where such interests are overridden by your fundamental rights and freedoms (e.g., improving our services and ensuring network security).

Children’s Privacy

Positive Grid does not knowingly collect personal data from children under the age of 13 without verifiable parental consent. If we become aware that personal data has been collected from a child under 13 without parental consent, we will take steps to delete such data promptly.

If you believe that we might have collected information from or about a child under 13, please contact us at privacy@positivegrid.com.

Personal Data Profiling

Name
Age
Gender
Email
Country
Language
Phone
Address
Avatar

Technology

Encrypted device UUID (Universally Unique Identifier)
OS version
Browser
Device

Behavior

Interaction with functions and contents presented on given platform (if applicable):

Viewing/Browsing
Searching
Clicking
Playing
Recording
Adding to cart
Purchasing
Uploading
Downloading
Login
Leaving/Abandoning

Transaction

Product purchased
Amount
Payment method

Cookies and Tracking

We (along with third parties that provide content, advertising or other functionality on our Services) may uses cookies, pixel tags, local storage,and similar tracking technologies to enhance your browsing experience and deliver personalized content. These technologies may collect information about your device, browser, and browsing activity. Below are the types of cookies we use:

Types of Cookies

Essential Cookies: These are necessary for the website to function and cannot be disabled. They enable core functionalities such as security, network management, and accessibility.
Performance and Analytical Cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. This data helps us improve website performance and user experience.
Functionality Cookies: These cookies enable the website to remember your preferences (e.g., language, region,currency) and provide enhanced, personalized features.
Marketing Cookies: These cookies are used to deliver advertisements that are relevant to you. They track your browsing habits across websites and may share this information with third parties, such as advertising networks.

Managing Your Cookie Preferences

You can manage or disable cookies through your browser settings. Please note that disabling certain types of cookies may impact your experience on our website and limit the availability of some features.

Our website also recognizes the Global Privacy Control (GPC) signal, which enables you to opt out of certain uses or disclosures of your information. If you notify us of your preference through GPC, we will treat such signal as a valid request to opt out of sharing/targeted advertising for the associated browser or device. To learn more about GPC, you can visit https://globalprivacycontrol.org/.

Other than the Global Privacy Control, we do not recognize other "Do Not Track" signals that may be sent from your web browser or device.

Google Analytics

Positive Grid uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage.

Positive Grid uses Google’s program for “interest-based advertising” for some marketing operations. Users can opt out of Google’s use of these cookies by visiting the Opt-out site of Google ads.

If you want to opt-out, download and install the add-on for your web browser (https://tools.google.com/dlpage/gaoptout?hl=en).

Third Party Sites

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy policies of websites operated by third parties that are linked to our website. We encourage you to read the privacy policies of all such third-party websites you visit. Once you have left our website, you should check the applicable terms, conditions, and policies of the third-party website to determine how they will handle any information they collect from you.

Where we engage third-party service providers to process personal data on our behalf (e.g., payment processors, cloud hosting services), we ensure that appropriate data processing agreements are in place to protect your personal data in compliance with applicable laws.

How do we share your data?

We may engage and contract with third-party companies (e.g., service providers) to provide services that help us with our business activities such as cloud hosting services. These third-party service providers are limited to only using information as instructed to provide contracted services to us.

We may also disclose your personal information:

As required by law, such as to comply with a subpoena or similar legal process.
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a written government request.
We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We do not otherwise sell your personal information to third parties.

General Purpose for Which Data is Used

All personal data acquired and/or requested, either prior to or during the course of a contractual relationship, will be used to fulfill your requirements, ensuring that the contractual obligations are met and administrative and legal obligations are provided correctly by the company Positive Grid, thereby allowing the business activities associated with its objectives to be conducted as efficiently as possible. The supply of data is not mandatory but is necessary in order to set up and execute this agreement; refusal to provide such data may therefore prevent the company from establishing a working relationship with you. Furthermore, your non-sensitive personal data provided with your express consent, revocable at any time, has been obtained for the following additional uses:

Inclusion in Positive Grid’s databases for the purpose of sending business notices/information relating to commercial activities conducted by Positive Grid.
Use for statistical purposes in connection with promotional campaigns.
For analysis to provide a better user experience and products.

Processing Methods

Data will be processed using appropriate methods and tools that guarantee their confidentiality and may be processed using electronic or automated means (network data processing systems not accessible to the public) and using non-automated means (paper-based archives and records), both protected by appropriate security measures such as personalized passwords offering exclusive access, personal identity codes, and limited access to records.

Certain types of data that are considered sensitive by the law (such as data capable of revealing racial and ethnic origin, religious, philosophical, or other convictions, political opinion, membership of political parties, trade unions, associations or organizations of a religious, philosophical, political, or trade union nature, as well as personal data capable of revealing state of health or sexual activities), which we could be made aware of after being informed by yourself or after having processed documents furnished by you, at the start-up or during the course of a working relationship with our Company, may only be used with your prior written consent.

Data Transfers Outside the EEA

Where Positive Grid transfers personal data outside the European Economic Area (EEA), we ensure that such transfers are made in compliance with applicable data protection laws. This includes:

Adequacy Decisions: Transferring data to countries that the European Commission has deemed to provide an adequate level of data protection.
Standard Contractual Clauses (SCCs): Using SCCs approved by the European Commission to safeguard transferred data.
Other Legally Approved Mechanisms: Using other transfer mechanisms that are compliant with applicable privacy regulations.

If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses or any equivalent contracts issued by the relevant competent authority of the UK, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

If you would like more information on the specific safeguards we use when transferring your personal data outside the EEA, please contact us at privacy@positivegrid.com.

How do we protect our customer’s data?

We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical, physical, and managerial procedures to safeguard and secure the information we collect from you.

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long will the data be stored for?

We will retain your information for as long as you maintain an account with us and have not otherwise requested us to delete your information.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes, or enforce other agreements.

When we no longer need to use your information, we will delete or anonymize it. If deletion is not possible (for example, because your information has been stored in backup archives), we will securely store your information and isolate it from any further use until deletion is possible.

Access to Your Information, Correction, Portability, and Deletion

You are in complete control. You can object or withdraw your consent to the use of your personal data at any time.

Subject to some legal exemptions, you have the right to:

Request a copy of the personal information Positive Grid holds about you.
To have any inaccuracies corrected.
To have your personal data erased.
To place a restriction on our processing of your data.
To object to processing.
To request your data to be ported (data portability).

Depending on the scope and nature of the work required to process your access request, we may require imposing a fee to recover our administrative costs involved.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Please address any such requests to the Positive Grid Data Protection Officer by contacting privacy@positivegrid.com.

What is Positive Grid Mobile Messaging?

By subscribing to Positive Grid mobile messages, you agree to receive autodialed marketing messages to the telephone number used at the time of opt-in. Message frequency may vary. Message and data rates may apply. Consent is not required as a condition of purchasing any goods or services. In the event that you change or deactivate your mobile number, it is your responsibility to notify Positive Grid at help.positivegrid.com/hc/en-us/requests/new to have your number removed.

Terms & Conditions are subject to change. The mobile carriers are not liable for delayed or undelivered messages. You can view our privacy policy by clicking www.positivegrid.com/privacy/.

Positive Grid Alerts Mobile Messages

Text advertised keyword to 45156 to receive promotional alerts from Positive Grid.

Text STOP to 45156 to opt out.

Text HELP to 45156, or submit a ticket at help.positivegrid.com/hc/en-us/requests/new for assistance.

Questions or Concerns

If you have any feedback, questions, or concerns regarding privacy, please send us a detailed message to privacy@positivegrid.com; we will make every effort to resolve your concerns.