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    Privacy Policy

    PRIVACY POLICY

    Last updated September 03, 2026



    This Privacy Notice for ACAPLY LTD (doing business as ACAPLY) ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:
    • Engage with us in other related ways, including any marketing or events
    Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@acaply.com.


    SUMMARY OF KEY POINTS

    This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

    What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

    Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

    Do we collect any information from third parties? We do not collect any information from third parties.

    How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

    In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

    How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

    What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

    How do you exercise your rights? The easiest way to exercise your rights is by visiting http://www.acaply.com/contact, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

    Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.


    TABLE OF CONTENTS



    1. WHAT INFORMATION DO WE COLLECT?

    Personal information you disclose to us

    In Short: We collect personal information that you provide to us.

    We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

    Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
    • names
    • phone numbers
    • email addresses
    • job titles
    • passwords
    • contact preferences
    • contact or authentication data
    • billing addresses
    • debit/credit card numbers
    Sensitive Information. We do not process sensitive information.

    Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/gb/privacy.

    Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called 'HOW DO WE HANDLE YOUR SOCIAL LOGINS?' below.

    All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

    Information automatically collected

    In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

    We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

    Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: http://www.acaply.com/cookies.

    The information we collect includes:
    • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
    • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
    • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

    Google API

    Our use of information received from Google APIs will adhere to     Google API Services User Data Policy, including the Limited Use requirements.


    2. HOW DO WE PROCESS YOUR INFORMATION?

    In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

    We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
    • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. (Retention period: For the duration of the account, plus 30 days after account deletion to allow for reactivation requests.)
    • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. (Retention period: For the duration of the account. Download event logs retained for 5 years after account termination (anonymised) for vocalist analytics and commission dispute resolution.)
    • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. (Retention period: 2 years after the inquiry is resolved.)
    • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. (Retention period: For the duration of the account.)
    • To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services. (Retention period: 6 years from the end of the accounting period in which the transaction occurred)

    • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user. (Retention period: Submission and messaging thread content retained for 6 years after account termination (anonymised on account deletion) for commission audit purposes.)

    • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services. (Retention period: 1 year.)
    • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below. (Retention period: Until the user unsubscribes, or 2 years after their last meaningful interaction with acaply's communications, whichever comes first)
    • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. (Retention period: 12 months. Security and authentication logs, device registration records, 2FA attempt logs.)
    • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them. (Retention period: 2 years.)
    • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you. (Retention period: 2 years.)
    • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

    3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

    In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

    If you are located in the EU or UK, this section applies to you.

    The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
    • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
    • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
    • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • Send users information about special offers and discounts on our products and services
    • Analyse how our Services are used so we can improve them to engage and retain users
    • Support our marketing activities
    • Diagnose problems and/or prevent fraudulent activities
    • Understand how our users use our products and services so we can improve user experience
    • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
    • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
    In legal terms, we are generally the 'data controller' under European data protection laws of the personal information described in this Privacy Notice, since we determine the means and/or purposes of the data processing we perform. This Privacy Notice does not apply to the personal information we process as a 'data processor' on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the 'data controller' responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

    If you are located in Canada, this section applies to you.

    We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

    In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
    • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
    • For investigations and fraud detection and prevention
    • For business transactions provided certain conditions are met
    • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
    • For identifying injured, ill, or deceased persons and communicating with next of kin
    • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
    • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
    • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
    • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
    • If the collection is solely for journalistic, artistic, or literary purposes
    • If the information is publicly available and is specified by the regulations
    • We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

    4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

    In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

    Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

    The categories of third parties we may share personal information with are as follows:
    • Cloud Computing Services
    • Data Analytics Services
    • Data Storage Service Providers
    • Payment Processors
    • Performance Monitoring Tools
    • Sales & Marketing Tools
    • User Account Registration & Authentication Services
    • Website Hosting Service Providers
    • Communication & Collaboration Tools

    We also may need to share your personal information in the following situations:
    • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
    • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
    • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
    • Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

    5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

    In Short: We may use cookies and other tracking technologies to collect and store your information.

    We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

    We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements or to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

    To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'

    Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: http://www.acaply.com/cookies.

    6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

    In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

    As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, 'AI Products'). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

    Use of AI Technologies

    We provide the AI Products through third-party service providers ('AI Service Providers'), including AssemblyAI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in 'WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?' You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

    Our AI Products

    Our AI Products are designed for the following functions:
    • AI applications

    How We Process Your Data Using AI

    All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

    7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

    In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

    Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

    We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

    8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

    In Short: We may transfer, store, and process your information in countries other than your own.

    Our servers are located in the United States and Hong Kong. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), including facilities in the United States, Hong Kong, and other countries.

    If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

    European Commission's Standard Contractual Clauses:

    We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

    9. HOW LONG DO WE KEEP YOUR INFORMATION?

    In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

    We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). If you are located in the EU or UK, see section 'HOW DO WE PROCESS YOUR INFORMATION?' for our retention periods by purpose.

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

    10. HOW DO WE KEEP YOUR INFORMATION SAFE?

    In Short: We aim to protect your personal information through a system of organisational and technical security measures.

    We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

    11. DO WE COLLECT INFORMATION FROM MINORS?

    In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

    We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at hello@acaply.com.

    12. WHAT ARE YOUR PRIVACY RIGHTS?

    In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

    In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

    We will consider and act upon any request in accordance with applicable data protection laws.

    If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

    How to contact us:
    What happens after you complain
    • We will acknowledge your complaint within 30 days of receiving it.

    • We will investigate without unjustifiable or excessive delay.

    • We will keep you informed of progress and explain the outcome.
    If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority.
    • Website: ico.org.uk/make-a-complaint

    • Helpline: 0303 123 1113

    • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
    If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

    If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

    Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or updating your preferences.

    However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

    Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying 'STOP' or 'UNSUBSCRIBE' to the SMS messages that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

    No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

    Account Information

    If you would at any time like to review or change the information in your account or terminate your account, you can:
    • Log in to your account settings and update your user account.
    Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

    Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: http://www.acaply.com/cookies.

    If you have questions or comments about your privacy rights, you may email us at hello@acaply.com.

    13. CONTROLS FOR DO-NOT-TRACK FEATURES

    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

    California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

    14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

    Categories of Personal Information We Collect

    The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section '    WHAT INFORMATION DO WE COLLECT?'

    CategoryExamplesCollected
    A. Identifiers
    Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

    YES

    B. Personal information as defined in the California Customer Records statute
    Name, contact information, education, employment, employment history, and financial information

    YES

    C. Protected classification characteristics under state or federal law
    Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data

    NO

    D. Commercial information
    Transaction information, purchase history, financial details, and payment information

    YES

    E. Biometric information
    Fingerprints and voiceprints

    YES

    F. Internet or other similar network activity
    Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements

    YES

    G. Geolocation data
    Device location

    NO

    H. Audio, electronic, sensory, or similar information
    Images and audio, video or call recordings created in connection with our business activities

    YES

    I. Professional or employment-related information
    Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

    YES

    J. Education Information
    Student records and directory information

    NO

    K. Inferences drawn from collected personal information
    Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

    NO

    L. Sensitive personal Information

    NO


    We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
    • Receiving help through our customer support channels;
    • Participation in customer surveys or contests; and
    • Facilitation in the delivery of our Services and to respond to your inquiries.
    We will use and retain the collected personal information as needed to provide the Services or for:
    • Category A - As long as the user has an account with us
    • Category B - As long as the user has an account with us
    • Category D - As long as the user has an account with us
    • Category E - As long as the user has an account with us
    • Category F - As long as the user has an account with us
    • Category H - As long as the user has an account with us
    • Category I - As long as the user has an account with us

    Sources of Personal Information

    Learn more about the sources of personal information we collect in 'WHAT INFORMATION DO WE COLLECT?'

    How We Use and Share Personal Information

    Learn more about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'

    Will your information be shared with anyone else?

    We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

    We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

    We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

    • Category E. Biometric information

    • Category H. Audio, electronic, visual, and similar information

    The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

    We have sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:

    The categories of third parties to whom we sold personal information are:

    The categories of third parties to whom we shared personal information with are:
    • AI Platforms
    • Affiliate Marketing Programs
    • Retargeting Platforms
    • Social Networks

    Your Rights

    You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
    • Right to know whether or not we are processing your personal data
    • Right to access your personal data
    • Right to correct inaccuracies in your personal data
    • Right to request the deletion of your personal data
    • Right to obtain a copy of the personal data you previously shared with us
    • Right to non-discrimination for exercising your rights
    • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')
    Depending upon the state where you live, you may also have the following rights:
    • Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
    • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
    • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
    • Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
    • Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
    • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
    • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

    How to Exercise Your Rights

    To exercise these rights, you can contact us by visiting http://www.acaply.com/contact, by emailing us at hello@acaply.com, by visiting http://www.acaply.com/contact, or by referring to the contact details at the bottom of this document.

    You can opt out from the selling of your personal information, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings.

    Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

    Request Verification

    Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

    If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

    Appeals

    Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hello@acaply.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

    Financial Incentives

    'Financial incentive' means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, sale, or sharing of personal information.

    The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer’s data. A business must be able to explain how the financial incentive or price or service difference is reasonably related to the value of the consumer’s data. The explanation must include:
    • a good-faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference; and
    • a description of the method the business used to calculate the value of the consumer’s data.
    We may decide to offer a 'bona fide loyalty program' under Colorado law, or a 'financial incentive' under California law (e.g. price or service difference) in exchange for the retention, sale, or sharing of a consumer’s personal information.

    If we decide to offer a financial incentive, we will notify you of such financial incentive and explain the price difference, as well as material terms of the financial incentive or price of service difference, including the categories of personal information that are implicated by the financial incentive or price or service difference.

    Under California law, the value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable program, less the expense related to offering those products, services, and benefits to program participants.

    If you choose to participate in the financial incentive you can withdraw from the financial incentive at any time by emailing us at hello@acaply.com, by visiting http://www.acaply.com/contact, or by referring to the contact details at the bottom of this document.

    California 'Shine The Light' Law

    California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section '    HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'

    15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: You may have additional rights based on the country you reside in.

    Australia and New Zealand
    We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

    This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

    If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services, in particular:
    • offer you the products or services that you want
    • respond to or help with your requests
    • manage your account with us
    • confirm your identity and protect your account
    At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'

    If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

    Republic of South Africa

    At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section '    HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'

    If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

    General enquiries: enquiries@inforegulator.org.za

    16. PROHIBITION ON USE OF VOCAL CONTENT FOR AI TRAINING

     Content downloaded from our platform, including acapella recordings, may not be used by subscribers to train, develop, fine-tune, or improve artificial intelligence or machine learning models of any kind, including but not limited to voice cloning or voice synthesis systems. This prohibition applies to all users and any third parties to whom downloaded content is shared. Any account found to be in breach of this prohibition will be permanently suspended without refund. This prohibition governs how subscribers may use content obtained from the platform and does not describe how our authorised third-party service providers process content on our behalf under their own terms of service.

    17. PROCESSING OF VOCAL AUDIO AND BIOMETRIC DATA

     In operating our platform, we process vocal audio recordings uploaded by vocalists. This processing includes transcription and metadata generation, where audio content is submitted to AssemblyAI for the purpose of generating searchable subject matter tags used solely to improve content discovery on the platform, and audio fingerprinting, where audio content is submitted to ACRCloud for the purpose of creating a unique audio fingerprint used to monitor major streaming platforms for unauthorised distribution of vocal content. These third-party providers process submitted content in accordance with their own terms of service and data processing agreements, which govern their respective use of that content independently of this policy. Vocal audio recordings may constitute biometric data under applicable privacy laws. By uploading content to the platform, vocalists consent to our processing for the purposes described above. Users who wish to withdraw this consent should contact us at hello@acaply.com. Withdrawal of consent will result in the removal of their content from the platform, as continued availability of that content depends on this processing.

    18. PLATFORM COMMUNICATIONS AND COMMISSION MONITORING

     Acaply administrators have access to review communications conducted through the platform's messaging features for the purposes of protecting our commission rights, ensuring compliance with our Terms and Conditions, and supporting dispute resolution between users. We may in future deploy automated tools, including artificial intelligence, to assist with this review, subject to further legal assessment and an update to this policy before any such tools are introduced. By using the platform's messaging features, users consent to this administrative access. Communication content will not be used for any purpose other than those described above and will not be shared with third parties except where required by law.

    19. DO WE MAKE UPDATES TO THIS NOTICE?

    In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

    We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

    20. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

    If you have questions or comments about this notice, you may email us at hello@acaply.com or contact us by post at:

    ACAPLY LTD
    128 City Road
    London EC1V 2NX
    England

    If you are a resident in the European Economic Area, we are the 'data controller' of your personal information. We have appointed __________ to be our representative in the EEA. You can contact them directly regarding our processing of your information, or by post to:

    If you are a resident in the United Kingdom, we are the 'data controller' of your personal information. We have appointed Isaac Green to be our representative in the UK. You can contact them directly regarding our processing of your information, by email at isaac@acaply.com, by visiting http://www.acaply.com/contact, or by post to:

    128 City Road
    London EC1V 2NX
    England

    21. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

    Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: http://www.acaply.com/contact.

    Right to erasure

    Under UK GDPR Article 17 you can erase the personal data we hold about you. Signed-in users can do this instantly from Settings → Account & security → Delete account. Type DELETE to confirm. We remove your login, profile, and subscription, and anonymise download events and submission records we keep for commission tracking. We complete self-serve requests immediately, which is faster than the 30-day statutory window. You can also email support@acaply.com.

    Personal data breaches

    We maintain an internal personal data breach response procedure. Where a breach is likely to result in a risk to your rights and freedoms, we notify the Information Commissioner’s Office without undue delay and, where feasible, within 72 hours of becoming aware of it. Where a breach is likely to result in a high risk to those rights and freedoms, we also inform affected people without undue delay. If you think your data has been affected, email support@acaply.com. You can also complain to the ICO.