PRIVACY POLICY

EMP Merchandising Handelsgesellschaft mbH (" EMP "), a Warner Music Group company, is committed to respecting your privacy and wants you to understand its information collection, use and disclosure practices. This Privacy Policy describes our practices with respect to information that we, an EMP company (EMP Merchandising Handelsgesellschaft GmbH, EMP Mail Order UK Ltd, Emp Mailorder Italia Srl, Large Popmerchandising BV and Large Popmerchandising BVBA), or our third party service providers, collect through certain websites we own or control (e.g., our artist websites or artist shops), web applications (e.g., widgets and other applications), and mobile applications (" Mobile Apps ") that link to this Privacy Policy (collectively, the " Application " or " Applications ").

1. PERSONAL INFORMATION

1.1 Type of personal information we collect

Two types of information are collected in connection with the Applications: personal information and other information. " Personal Information " is information that can be used to identify you as an individual. " Other Information " is any information that does not relate to your specific identity. To the extent that we are required by law to treat Other Information as Personal Information, we have the right to use and transfer Other Information in accordance with the terms set out in this Personal Information Privacy Policy. Such Other Information is treated separately below under the heading "OTHER INFORMATION."

We and our third-party service providers may collect, among other things, the following personal information about you:

• name
• Postal address (including billing and shipping addresses)
• phone number
• email address
• birth date
• credit and debit card number
• Details of the purchase
  

1.2 Collection of personal information

We and our third-party service providers collect personal information through the Applications in a variety of ways, including:

1.2.1 About the Applications

We may collect personal information through the Applications, for example when you sign up for newsletters or other communications through the Applications, create an account, make a purchase, or submit an inquiry.

1.2.2 Offline

We may collect personal information offline, for example when you provide information to us in an EMP store or at concerts or events.

1.2.3 From other sources

We may receive your personal information from other sources, such as:

• address databases or
• from our marketing partners who provide us with information in connection with marketing and promotional campaigns related to our business activities.

If you use your social media account - or another account from another provider - to participate in our competitions, prize draws or other promotions or are invited to register for such an account via our applications, you may send us some of your personal information from your account, such as your name, email address, photo, list of contacts, most recently listened to music tracks, favorite music tracks and other information that is made available to us by you or otherwise as part of the connection to the account.

1.2.4

You are not required by law or contract to provide us with personal information. For example, we collect personal information from you when you use the various features of the applications in order to provide you (or us) with the full experience of using the applications.

1.3 Use of personal information

We and our third-party service providers use personal information for the following business purposes, among others:

1.3.1

To provide you with the functionality of the applications and to answer your inquiries

• To provide you with the functionality of the applications, e.g. to grant you access to your account and to provide you with related customer service;
• To answer your questions and respond to your other requests when you contact us via one of our online contact forms or otherwise, for example when you send us questions, suggestions, praise, criticism or when you send us inquiries about our applications;
• To send you administrative information, including information about the Applications and about changes to our terms, conditions and policies;
• To process and carry out your purchase, for example to process your payments, arrange for the shipment of your orders, communicate with you about your purchase and provide you with related customer service;
• To provide international customer service to all EMP companies.

We carry out these activities to manage our contractual relationship with you and/or to comply with legal requirements.

1.3.2

To provide you with our newsletters and/or marketing information and to enable sharing of information via social networks

• To send you regular newsletters with information about our products and services as well as newsletters with information from our affiliated companies within the Warner Music Group. You can sign up for three different newsletters on our website. You have the option of signing up for the EMP newsletter from EMP, the artist newsletter from Warner Music Group Germany Holding GmbH ("WMG") and the artist shop newsletter. EMP and WMG send the artist shop newsletter as joint controllers. You can find more information about data processing in the artist shop newsletter here . You are free to provide us with additional information when registering for the newsletter. When you subscribe to our newsletter, you will receive an email from us. To complete the registration, you must click on the activation link in this email.
• To send you further marketing information which we think may be of interest to you based on your behaviour (including by post and other types of advertising through our third party service providers);
• To send you SMS text messages using your phone number, for example if you have entered a competition using your phone number and you have indicated that you would like to receive such messages. Please note that this may incur message and transmission costs. Please check with your mobile operator to find out the applicable transmission costs.

We only carry out these activities if you have given your consent or if we have a legitimate interest in doing so.

1.3.3

To analyze personal information for business reports and to provide personalized services

• To analyze or predict our users' preferences in order to create aggregated trend reports on the use of our digital products in order to improve our applications.
• To personalize your experience using the Applications through the use of your IP address by providing content, products and offers tailored to you.

We will only provide you with personalized services if you have consented or if we have a legitimate interest in doing so.

1.3.4

To enable you to participate in competitions, prize draws or other promotional activities.

• To allow you to participate in sweepstakes, contests and related promotions using your name, address and email address and to administer those activities. Some promotions have additional rules that may require additional information (such as your date of birth) about our use and disclosure of your personal information; for this reason, we encourage you to read those rules carefully; in the event of any conflict between such rules and this Privacy Policy, the rules will prevail;
• To inform you of the results of a competition, EMP will send you an email. If you are the winner, EMP may publish your name

We use this information to regulate our contractual relationship with you.

1.3.5

Aggregated and/or anonymized personal information.

• We may aggregate and/or anonymize Personal Information in a form that no longer constitutes Personal Information. We do this to create Other Information for us, which we may use and transfer for any purpose.

We carry out these activities if we have a legitimate interest in doing so.

1.3.6

To achieve our business goals.

• For data analysis, for example to increase the efficiency of applications;
• For controls to ensure that our internal processes function as intended and comply with legal, regulatory and contractual requirements;
• For fraud and security monitoring, such as cyber-attacks or identity theft;
• To develop new products and services;
• To further develop, improve or modify our existing products and services
• To identify usage trends, for example to understand which areas of our applications are most interesting to users;
• To determine the effectiveness of promotional campaigns so that we can tailor our campaigns to the needs and interests of our users;
• To carry out and expand our business activities; for example, by understanding which areas of our applications are most interesting to users so that we can focus on meeting our users' needs.

We carry out these activities to manage our contractual relationship with you, to comply with legal requirements and/or where we have a legitimate interest in doing so.

1.4 Transmission of personal information

We transfer personal information:

1.4.1

To Warner Music Group and its affiliates for marketing purposes. You can view the Warner Music Group list and locations here: https://wminewmedia.com/affiliates/ .

For further information on data protection within the Warner Music Group, please see the privacy policy at https://wminewmedia.com/privacy/ .

1.4.2

To our third-party service providers (and in some cases, our affiliates) so that they can provide their services to us

• The services may include: hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery, credit card processing, auditing and other related services;
• If you choose to pay by invoice, we collect personal data that is required to process a purchase with payment by invoice and to carry out an identity and credit check and forward it to the payment service provider. The service provider needs this information to obtain information about the buyer's identity and creditworthiness from the relevant credit agencies.

1.4.3

To third parties so that they can send you marketing information, if you have expressed a wish to do so.

• Other third parties and their vendors so that they can send or have sent you digital and/or other marketing information.
• Our artists (including the artists' band members, where applicable) and their representatives, so that the artists and their representatives may use the information to send you communications (including marketing communications) which they believe may be of interest to you, including, for example, if you (a) have subscribed to the relevant artist's mailing list and/or newsletters, (b) have subscribed to the relevant artist's website, or (c) have otherwise indicated that you would like to receive information and/or marketing communications from the relevant artist to the extent that you have indicated that you would like to receive such communications. We do not control the use of personal information by the artists and their representatives and we assume no responsibility in relation to this.

1.4.4

To an artist not affiliated with us if you have expressed an interest in such artist (for example, by registering on their website);

1.4.5

to third parties who act as sponsors of competitions, prize draws and similar promotions so that these third parties can conduct and administer the competitions, prize draws and similar promotions.

1.4.6

You may provide us with personal information through your use of the Applications.

• Through message boards, chats, profile pages and blogs and other services that allow you to post information and materials. Please note that any information or materials you post or disclose through an Application will become public information and will be available to visitors to the Application and the general public, and may be further distributed through the Internet and other media channels to reach an even wider audience. We strongly recommend that you exercise caution when posting your personal or other information through the Applications.

1.5 Further uses and transfers

We use and transfer your personal information where necessary or appropriate, in particular where we are subject to a legal obligation or where we have a legitimate interest in doing so.

1.5.1

To comply with applicable laws.

• This may include laws outside your country.

1.5.2

To answer questions from authorities or other government bodies.

• This may include positions outside your country.

1.5.3

To cooperate with law enforcement authorities..

• For example, when we respond to questions from law enforcement authorities.

1.5.4

For other legal reasons.

• To enforce our terms and conditions;
• To protect our business or the business of our affiliates or artists; To protect our rights, privacy, safety or property or that of our affiliates, our artists or others
• To exercise legal remedies available to us or to limit the damages we may incur.

1.5.5

In connection with a sale or business transaction

• We have a legitimate legal interest in transferring your personal information to third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or a portion of our business, assets or securities (including in connection with any bankruptcy or related proceedings). Third parties may also be, for example, purchasers or their advisors.

1.6 Data retention period

We will retain your personal information for as long as necessary for the purposes for which the personal information was collected and as permitted by law.

The criteria we use to determine the data retention period include:

• The period for which we have an existing contractual relationship with you and for which we provide the Applications to you (e.g. the period during which you have an account with us and use the Applications);
• Whether we are subject to a legal obligation (e.g. legal obligations to retain sales transactions for a certain period of time before we can delete them); or
• Whether deletion is appropriate in light of our legal position (e.g. in view of applicable limitations of liability, litigation or government investigations).

1.7 Sensitive information

We ask that you do not send or disclose any sensitive personal information (e.g., social security number, information about your ethnic origin, political opinions, religious affiliations or other beliefs, health-related data, information about a criminal background or trade union membership) to us through the Applications or otherwise.

2. OTHER INFORMATION

We and our third-party service providers may collect Other Information (as defined above), such as:

• browser and device information
• mobile app usage data
• server log files
• Information collected through cookies, pixel tags and other technologies. For more details about our use of cookies, see our Cookie Policy .
• Geographical location information
• demographic information you provide and other non-personally identifiable information
• Information about how you use the applications
• summarized information

2.1 Collection of other information

We and our third-party service providers may collect other information in a variety of ways, including:

2.1.1

Through your browser or device:

Most browsers collect certain information, such as your Media Access Control (MAC) address, your device type (Windows or Mac OS), your screen resolution, operating system version, your Internet browser type and version, and the type and version of an application you use. We and our third-party service providers may also collect a unique device identifier that we or our third-party service providers have assigned to the device from which you access an application, as well as other transaction-related information for the device that we and our third-party service providers may use to deliver content and advertisements.

2.1.2

About your use of mobile apps:

When you download and use a Mobile App, we and our service providers may track and collect Mobile App usage data, such as the date and time the Mobile App on your device accesses our servers and the types of information and files downloaded to the Mobile App based on your device number.

2.1.3

About server log files:

An Internet Protocol (IP) address is a number that your Internet Service Provider (ISP) automatically assigns to the device from which you access the Application; this number, along with the time of your visit and activity on an Application, is automatically identified and entered into our server log files when you use the Application. We and our service providers use IP addresses for purposes such as calculating the load on the Application, helping diagnose server problems, administering the Applications, and determining your approximate geographic location.

2.1.4

When you visit our webshop website, we ask, as part of a so-called cookie banner, whether we may use cookies and other technologies in order to be able to use the data obtained for the purposes of website optimization. In this context, we would like to expressly draw your attention to the following circumstances:

 As already stated in the cookie banner, the consent, if you can give us this, applies not only to EMP Merchandising Handelsgesellschaft mbH as the operator of the website, but also to Warner Music Group Germany Holding GmbH . If you revoke your consent, this revocation naturally applies to all of the data processed by EMP Merchandising Handelsgesellschaft mbH as well as to Warner Music Group Germany Holding GmbH. without any further action on your part being necessary.

Insofar as consent within the meaning of Art. 6 Para. 1 GDPR is mentioned as the legal basis for the processing listed in this data protection declaration, this also constitutes consent within the meaning of Section 25 Para. 1 TDDDG. If no consent is required for the processing of the information, for example because access to information already stored in the end user's terminal equipment is absolutely necessary so that the controller can provide you with a digital service such as the website, Art. 25 Para. 2 TDDDG is also applicable as the legal basis.

We and our service providers may use cookies, pixel tags, web beacons, Adobe Flash technology (including Flash Local Stored Objects (" Flash LSOs "), and other similar technologies to, among other things, provide you with more tailored information about our and third parties' products and services, to facilitate your continued access to and use of the Applications, and to collect and store information about your use of the Applications. For example, pixel tags and web beacons may be used in connection with an Application to, among other things, track the steps taken by users of the Application, evaluate the success of marketing campaigns, and compile statistics about Application usage and response rates.

• If you do not want information to be collected through cookies, most devices used to access the Applications provide an easy way to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. If you choose not to accept cookies, some or all of the features, functionality and advertising offered by the Application may not be available to you.
• If your device stores Flash LSOs but you do not want that storage on the device from which you access the Applications, you can change your Flash Player settings to block Flash LSO storage using the tools available to you in the Website Storage Settings Panel. You can also control Flash LSOs by accessing the Global Storage Settings Panel and following the instructions there (which may include instructions explaining, for example, how to delete existing Flash LSOs (called "Information" on the Macormedia Site), how to prevent Flash LSOs from being placed on your device without prompting, and (for Flash Player 8 and later versions) how to delete Flash LSOs provided by a carrier other than the carrier of the site you are currently on). In the event that you configure the Flash Player to reduce or limit acceptance of Flash LSOs, please note that the functionality of some Flash applications, including those used in connection with the applications or our content, may be limited or hindered. We expect our service providers and technology suppliers to honor any decisions you make to limit or restrict Flash LSOs, but we make no guarantees that they will do so.
• The use of these technologies enables our vendors, as well as third parties and their vendors, to deliver advertisements about our products and services and those of other parties when you use the Applications or other applications or visit websites or web applications over the Internet using your device. These third parties may place so-called "pixel tags", "web beacons", "clear GIFs" or similar technologies on the device through which you access the Applications and other applications or websites over the Internet; they may also place or accept third-party cookies when you use the Applications or other applications, websites or web applications. The vendors/third parties may use these technologies, as well as the information they collect about your online use, to recognize you across all devices you use, such as mobile devices or laptops. The vendors/third parties may use information about your visit to - and the device used to visit - the Applications and other applications, websites or web applications (excluding your name, address and telephone number) and information from other third parties to send you advertisements about our and other third parties' goods and services that may be of interest to you. If you would like more information about these technologies, please visit the Network Advertising Initiative at www.networkadvertising.org or the Digital Advertising Alliance at www.aboutads.info. You can also visit these sites to opt out of these marketing practices in your desktop or mobile browser on the device you are using to access this Privacy Policy.
• Our applications do not respond to browser-based “do-not-track” notices.

2.1.5

Site-specific information

When you use location-based products or services, you may send us location information. To the extent you use a location-based service, we may collect and process information about your precise geographic location, such as GPS signals sent by a mobile device. We and our third-party service providers and partners may use the physical location of your device to provide you with personalized location-based services, content and advertisements. In some cases, you will be able to allow or decline such use of your device's location, although if you decline, we will no longer be able to provide you with those personalized services and content.

2.1.6

Through you:

We may collect demographic information, such as your zip code or gender, or other information, such as your preferred method of communication, when you voluntarily provide it to us. This information does not necessarily identify you or other users of the Application, but only when combined with other information that allows identification, in which case this information is treated as personal information.

2.1.7

Information about the nature of your interactions on the applications:

We may collect information about how you interact with the Applications. For example, some Applications use analytical tools to help us better serve you with improved products, services, and Application updates. The information we collect may help us understand which services and features you use most often within an Application, what type of device and hardware features you use, what country and language you download from, etc.

2.1.8

By compiling information:

We may compile Personal Information in a way that does not identify you or other users of the Applications in the final product, for example, by using Personal Information to calculate the percentage of users who like a particular artist.

2.1.9

We collect personal information when you register for a customer account using single sign-on (“SSO”). If you already have an account with an SSO provider, you can register a customer account without going through the registration and login process. To do this, you must confirm the SSO registration using an SSO button and authenticate yourself with the SSO provider or be already logged in with them. When you register for the first time using SSO, you will send us some of your personal information from your SSO account, depending on the respective SSO provider; this is usually your name and email address. We use this information to create your customer account and link it to the SSO account. We carry out these activities to regulate our customer account contractual relationship with you (Art. 6 Para. 1 lit. b GDPR).

SSO services currently used in our applications:

2.1.9.1

Social Plugins:

Our plugins are not fully integrated into our website, but are simply integrated via an HTML link (so-called "shariff plugin"). This type of integration ensures that using our website does not establish a connection to the provider of the social network. If you click on a button of a social network, a new window opens and you are taken to the provider's website. For the purpose and scope of data collection and further processing and use of the data by the provider of the social network on their respective websites, as well as for your associated rights and setting options to protect your privacy, we refer to the data protection declarations of the providers.

2.1.9.2

Sign in with Apple:

This SSO service is offered by Apple Inc., One Apple Park Way; Cupertino, CA 95014, USA, and its affiliates (together "Apple"). Apple provides more information about the SSO service "Sign in with Apple" at https://support.apple.com/de-de/HT210318. We have no influence on the data collected by Apple through the use of the "Sign in with Apple" service and on its further processing. For information on data processing by Apple, please refer to Apple's privacy policy at https://www.apple.com/legal/privacy/de-ww/.

2.1.9.3

Log in via Google (SSO button "Login with Google"):

This SSO service is offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and its affiliated companies (together "Google"). Google provides more information about the SSO service "Sign in with Google" at https://support.google.com/accounts/answer/112802. We have no influence on the data collected by Google through the use of the "Sign in with Google" service and on its further processing. For information on data processing by Google, please see Google's privacy policy at https://policies.google.com/privacy.

2.2 Use and transmission of other information

Please note that we may use and disclose Other Information for any purpose, unless applicable law requires us to do otherwise. If applicable law requires us to treat Other Information as personal information, we may treat that Other Information as described in the section entitled "Collection of Other Information" above and use it for any of the purposes for which we use and disclose personal information. In some cases, we may combine Other Information with personal information (for example, your name with your geographic location). If we combine Other Information with personal information, we will treat the combined information as personal information for as long as the information is combined.

3. SAFETY

We will take reasonable physical, technical and administrative measures to protect the personal information under our control. If you have reason to believe that your communications with us are no longer secure, please notify us immediately using our contact details (see below).

4. YOUR RIGHTS

4.1 Your choices regarding our use and disclosure of your personal information

We provide you with a number of choices regarding our use and disclosure of your personal information for marketing purposes.

You have the option to withdraw your consent with regard to:

4.1.1

Receiving marketing emails from us and our affiliates

If at any time you do not wish to receive marketing emails from us and our affiliates, you can stop receiving such emails by using the unsubscribe mechanism in the email or by sending us an email to datenschutz@emp.de;

4.1.2

receiving marketing SMS text messages from us and our affiliates:

If you do not wish to receive marketing SMS text messages from us and our affiliates at a certain point in time, you can stop receiving such messages by sending the text “STOP” back via SMS or by sending us an email to datenschutz@emp.de;

4.1.3

Our sharing of your personal information with artists or unaffiliated third parties for their marketing purposes:

If you prefer that we no longer share your personal information with artists or unaffiliated third parties for marketing purposes, you can opt out of this sharing by sending us an email to datenschutz@emp.de.

4.1.4

Please specify in your email which activity you are unsubscribing from. We will comply with your request(s) as quickly as reasonably possible and in any case within the time limits required by law. Please note that if you withdraw your consent to receive marketing information from us, we may still send you administrative communications.

4.2 Options for accessing, modifying and deleting your personal information

If you would like to access, review, correct, update, suppress, restrict or delete your personal information, or object to our use of it, or if you would like to receive an electronic copy of your personal information in order to transmit it to another company (only if you have a legal right to data portability), please contact us by email at datenschutz@emp.de. We will respond to you in accordance with the legal requirements.

You can also complain to the responsible data protection authority: The State Commissioner for Data Protection of Lower Saxony, Prinzenstraße 5, 30159 Hanover; Telephone: 0511 120 – 4500; Fax: 0511 120 – 4599; Email: poststelle@lfd.niedersachsen.de, Internet: htttp://www.lfd.niedersachsen.de.

Please specify in your notice what personal information you would like to change, whether you would like us to block your personal information from our databases, or any other restrictions you would like to place on our use of your personal information. For your security, we will only implement requests for personal information associated with the specific email address you used to send us the notice, and we may need to verify your identity before implementing your notice. We will try to respond to your request as quickly as reasonably possible.

Please note that we may need to retain some information for legal purposes and/or to complete a transaction you began before you submitted your change or deletion request (for example, if you made a purchase or entered a contest, you may not be able to change or delete your personal information until you complete the purchase or contest).

If our collection and use of personal data is based on your consent, you can withdraw this consent at any time by sending an email to datenschutz@emp.de. Such a withdrawal will not affect the legality of the processing based on the consent before your withdrawal.

5. CROSS-BORDER DATA TRAFFIC

The Applications are controlled and operated from Germany; accordingly, to the extent permitted by law, this Privacy Policy and our collection, use and transfer of your personal information are governed by German law. Your personal information may be stored and processed in any country in which we maintain facilities or have engaged service providers. By using the Applications, you accept that your information will be transferred to countries outside the European Economic Area (EEA), which may have different data protection laws than your country.
In case you are located in a contracting state to the Agreement on the European Economic Area (EEA): Some countries outside the EEA are considered by the EU Commission to have an adequate level of data protection in accordance with EEA standards. A list of these countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection_de . For transfers of personal information from the EEA to countries that are considered by the EU Commission to not provide an adequate level of data protection, we have taken appropriate measures, such as the EU Commission's EU standard contractual clauses regarding personal information. You can request a copy of the measures by contacting us at datenschutz@emp.de.

6. UPDATES TO THIS PRIVACY POLICY

We have the right to change this Privacy Policy at any time. The date this Privacy Policy was last revised will be indicated by the "LAST UPDATED" notice at the top of the page. Changes to this Privacy Policy will become effective when we make an updated version available on the Application.

7. OUR CONTACT DETAILS

The responsible party for the collection, use and transfer of your personal information under this privacy policy is EMP Merchandising Handelsgesellschaft mbH.

If you have any questions or concerns about this privacy policy or our data processing methods, please contact us by email at datenschutz@emp.de contact us.

We have our registered office at the following address:
EMP Merchandising Handelsgesellschaft mbH
Darmer Esch 70a
49811 Lingen
Data Protection Officer:
André Bosse
Darmer Esch 70a
49811 Lingen
Germany
Telephone: 0049 591 - 9 14 310
E-mail: datenschutz@emp.de

The data protection officer is a "DEKRA certified data protection specialist". As part of the certification of the data protection officer as a "data protection specialist", the data protection officer must prove his or her expertise in a written examination. This time-limited certification can be extended either through regular follow-up examinations or by providing evidence of further training. This certification is issued by DEKRA Certification GmbH, Handwerkstr. 15, 70565 Stuttgart.

The required specialist knowledge includes, but is not limited to, the following:

These requirements are met by the data protection officer we employ. The validity of the certification can be seen on the Dekra seal. This is currently valid until January 2026.

Please note that email communications are not always secure and your emails to us should not contain credit card information or other sensitive information.