Privacy Policy

Last updated on: July 20, 2021

1. INTRODUCTION

1.1 Acast, along with its direct and indirect subsidiaries, is committed to protecting your privacy and we always aim to achieve a high level of protection for your personal information. Through this policy we aim to explain when Acast collects and processes your personal data, how we go about doing this, what we do with your information and crucially, why. The information is directed to listeners, podcasters, customers and newsletter subscribers of Acast ("you" or "your").

1.2 By using Acast as the host of your podcast (and any Acast tool associated with this) and/or by using the Acast application ("Acast App"), website or by listening to Acast hosted podcasts through any third party site (together the "Services"), you do so with the knowledge that your data will be collected and processed as described in this policy.

1.3 Acast AB (publ), company reg. no. 556946-8498 or another Acast group company, if specifically indicated in this Privacy Policy, (“Acast”, “us”, “we” or “our”) is the data controller responsible for the processing of your personal data according to this Privacy Policy. If you are listening from outside of the EU/EEA, please read our Rest of World Privacy Policy.

1.4 It is important for you to understand that by using the Services, you accept the practices described in our Privacy Policy. Consequently, if you do not agree to the terms of this Privacy Policy, we ask you to not use the Services. We reserve the right to modify or amend the terms of this Privacy Policy at any time. When we make material changes to this Privacy Policy, we’ll notify you via a message on our website and/or Acast App. Any changes to this Privacy Policy will become effective as of the date that appears at the very beginning of this document in the section “Last updated on”. Your continued use of our Services following the posting of changes will be deemed an acceptance of those changes.

2. YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

Certain rights are granted to individuals in relation to their personal data under GDPR. As an individual you have the following rights:

2.1 Right of Access - You have the right, upon request, to be informed of the personal data we collect about you. A copy of which will be provided free of charge. However, we may charge a reasonable fee to comply with requests for further copies of the same information or when a request is manifestly unfounded or excessive, particularly if it is repetitive.

• If you are a listener accessing podcasts through the Acast App, you can submit an ‘access request’ by going to 'Settings' – 'User Privacy' – 'Request my user profile'.
• If you do not listen through the Acast App, please contact us at privacy@acast.com

2.2 Right to rectification - You have the right to request that we rectify your personal data if you have identified that it is inaccurate or provide us with additional data if you have identified that it is incomplete.

• To do this please contact us at privacy@acast.com

2.3 Right to erasure - You have the right to request that we delete your personal data.

• If you are a signed-in user in the Acast App, you can request that we delete your personal data by going to 'Settings' – 'User Privacy' – 'Withdraw consent' (please note that this will result in your account being deleted).
• If you are not a signed-in user in the Acast App, please contact us at privacy@acast.com

2.4 Right to restrict processing - You have the right to request that we restrict the processing of some or all of your personal data.

• To do this please contact us at privacy@acast.com

2.5 Right to data portability - You have the right to request a copy of your personal data in an electronically retrievable form and the right to use that data in other services.

• To do this please contact us at privacy@acast.com

2.6 Right to object to processing - You have a right to object to the processing of your personal data and an absolute right to object to processing your personal data for the purpose of direct marketing.

• To do this please contact us at privacy@acast.com

2.7 Right to withdraw consent - When we process your personal data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall however not affect the lawfulness of processing based on your consent before its withdrawal.

• If you are a signed-in user in the Acast App, please go to 'Settings' – 'User Privacy' – 'Withdraw consent' in the or please contact us at privacy@acast.com (please note that a withdrawal of consent will result in your account being deleted)

2.8 Right to lodge a complaint with the Data Supervisory Authority - If you believe your personal data is not being processed in accordance with applicable legislation, please contact us directly at privacy@acast.com. You also have the right to lodge a complaint with the relevant data supervisory authority in your jurisdiction.

3. PERSONAL DATA WE PROCESS AND WHY – LISTENERS

To understand how our listeners interact with Acast and to provide you the Services, we collect some data that is personal to you. The data we collect and process will depend on Acast’s legal basis for collecting your data and how you interact with Acast. We also process different data depending on what sort of user you are.

3.1 Acast App Users - Using the App with a ‘signed in’ user account.

• Explanation - We process your data in order to understand you as a listener and to give you a customized user experience when you access podcasts via a signed-in account in the Acast App. With the information you provide, we create a unique profile which enables us to tailor your experience by providing recommendations to podcast content, information, advertising that is specific to your interests and where applicable, relevant marketing.
  
  
• Legal basis - The processing of your personal data is based on your consent.
  
  
• Categories - We may process the following categories of personal data when you sign-in to the Acast App to listen to podcasts:
  - IP address.
  - User Agent.
  - User ID.
  - Password.
  - Advertising ID (only for Android users).
  - Name or nickname.
  - Gender.
  - Age.
  - E-mail address.
  - Facebook ID/Google Plus ID/Apple ID (only for users that sign-in through their Facebook, Google or Apple account)
  - Profile picture (only for users that sign-in through their Facebook, Google or Apple account account)
  - Settings preferences.
  - Payment details and history (if applicable).
  - Listening history.
  - Podcasts shows you subscribe to.
  - Podcast categories you have marked as being of interest to you.
  
  
• Why? - We process this data in order to:
  - Validate you as a listener.
  - Confirm your identity and age.
  - Identify the device you are using and to deliver content to your podcast player.
  - Give you access to your account with login and password information and enable you to update your profile.
  - Provide targeted advertising and general (direct) marketing based on the information you provide alongside geographic and demographic profiling.
  - Customize frequency and language of marketing messages.
  - Obtain an overview of your listening history and to make suggestions on podcasts you may like based on this.
  - Provide anonymised listening reports to our podcasters/podcast representative and/or advertising partners/media house partners.
  - Test and develop new products and services by sharing your data with certain third-parties.
  - Compile statistics, anonymised or aggregated data reports for analytical purposes for Acast and/or third-parties, including working with "ad measurement" and "ad effectiveness" service providers.
  - Prevent, detect or block misuse or fraudulent behaviour.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your personal data is retained for as long as you don't delete your user account in the Acast App. However, we may retain anonymised data for analysis and information purposes.

3.2 Acast App Users - Using the App without creating an account.

• Explanation - We process your data when you choose to listen to podcasts through the Acast App without creating a user account.
  
  
• Legal basis - The processing of your personal data is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to continue to provide you with audio podcast content.
  
  
• Categories - We may process the following categories of personal data when you listen to podcasts on the Acast App (without creating a user account / without signing in):
  - IP address.
  - User Agent.
  - User ID.
  - Payment details and history (if applicable).
  
  
• Why? - We process this data in order to:
  - Validate you as a listener.
  - Identify the device you are using and to deliver content to your podcast player.
  - Test and develop new products and services by working and sharing your data with certain third-parties.
  - Provide anonymised listening reports to our podcasters/podcast representative and/or advertising partners /media house partners.
  - Compile statistics, anonymised or aggregated data reports for analytical purposes for Acast and/or third-parties, including working with "ad measurement" and "ad effectiveness" service providers.
  - Work with our third-party advertisers to place adverts based on your location.
  - Prevent, detect or block misuse or fraudulent behaviour.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your hashed IP address and all anonymised data collected about you will be retained for analysis and information purposes. In addition, Acast retains your clear text (identifiable) IP address for 30 days, after which time this is deleted.

3.3 Users accessing Acast hosted content via the Acast Embed player and through play.acast.com

• Explanation - We process your data when you access Acast hosted podcasts through an Acast Embed player placed on a third-party website/app or if you access Acast hosted podcasts on play.acast.com.
  
  
• Legal basis - The processing of your personal data is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to continue to provide you with audio podcast content.
  
  
• Categories - We may process the following categories of personal data when you access to podcasts through use of these platforms:
  - IP address.
  - User Agent.
  - Session ID.
  
  
• Why? - We process this data in order to:
  - Validate you as a listener.
  - Identify the device you are using and to deliver content to your podcast player.
  - To provide anonymised listening reports to our podcasters/podcast representative and/or advertising partners/media house partners.
  - Test and develop new products and services by working and sharing your data with certain third-parties.
  - Compile statistics, anonymised or aggregated data reports for analytical purposes for Acast and/or third-parties, including working with "ad measurement" and "ad effectiveness" service providers.
  - Work with our third-party advertisers to place adverts you based on your location.
  - Prevent, detect or block misuse or fraudulent behaviour.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your hashed IP address and all anonymised data collected about you will be retained for analysis and information purposes. In addition, Acast retains your clear text (identifiable) IP address for 30 days, after which time this is deleted.
  

3.4 Users listening via third-party distribution channels

• Explanation - We process your data when you access Acast hosted podcasts through any third-party distribution channel in order to offer you more relevant podcast content, information and marketing choices and to serve advertisements.
  
  
• Legal basis - The processing of your personal data is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to continue to provide you with audio podcast content.
  
  
• Categories - We may process the following categories of personal data when you access Acast hosted podcasts from a third-party distribution channel:
  - IP address.
  - x-Session-Header-ID (iOS applications).
  - Browser ID.
  - Information stored on browser cookies.
  - User Agent.
  - User ID.
  
  
• Why? - We process this data in order to:
  - Validate you as a listener.
  - Identify the device you are using and to deliver content to your podcast player.
  - Compile statistics, anonymised or aggregated data reports for analytical purposes for Acast and third-parties, including working with "ad measurement" and "ad effectiveness" service providers.
  - Provide anonymised listening reports to our podcasters/podcast representative and/or advertising partners /media house partners.
  - Test and develop new products and services by working and sharing your data with certain third-parties.
  - Work with our third-party advertisers to place adverts you based on your location.
  - Prevent, detect or block misuse or fraudulent behaviour.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your hashed IP address and all anonymised data collected about you will be retained for analysis and information purposes. In addition, Acast retains your clear text (identifiable) IP address for 30 days, after which time this is deleted.

3.5 Users accessing our user support

• Explanation - We process your data when you access our user support system on the Acast website or e-mail our support team in order to provide you with podcast related assistance.
  
  
• Legal basis - The processing of your personal data is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to continue to provide you with the support you may require.
  
  
• Categories - We may process the following categories of personal data when you access or e-mail the Acast support system:
  - Name.
  - Email address.
  - User ID.
  - Your communication with us, including necessary information regarding the matter at hand.
  
  
• Why? - We process this data in order to:
  - Confirm your identity as an Acast podcast user.
  - Communicate with you.
  - Answer your questions and find a solution to the issue.
  - Develop new services.
  - Compile statistics for analytical purposes.
  - Understand, diagnose, troubleshoot and fix issues with the Services.
  - Prevent, detect or block misuse or fraudulent behaviour.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your personal data is retained for as long as necessary to fulfil your support request and will be kept for a reasonable period of time thereafter. However, we may retain the email and other communication between you and Acast for internal monitoring purposes.

4. PERSONAL DATA WE PROCESS AND WHY – PODCASTERS

4.1 To give podcasters access to our hosting and distribution services

• Explanation - Regardless whether you are a natural person or a representative of a podcaster who is a legal person, we process your data in order to provide you/the podcaster with our services in connection with podcasts owned or controlled by you (including but not limited to hosting and distribution services and / or sale of advertisements and sponsorships).
  
  
• Legal basis - The processing of your personal data is necessary for the performance of our contract with you in case you are a natural person. In case you are a representative of a legal person, the processing is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to fulfil the contract with the podcaster you represent.
  
  
• Categories - We may process the following categories of personal data when you (or in your capacity as a representative of the podcaster) enter into an agreement with Acast:
  - Name.
  - Email address.
  - Telephone number.
  - Username and password.
  - Invoicing and payment details.
  - Purchase orders.
  - IP address.
  - Personal data contained in the podcasts.
  
  
• Why? - We process this data in order to:
  - Give you/the podcaster access to Acast’s services for uploading, managing, distributing and monetising podcasts.
  - Give you/the podcaster access to Acast’s tool for sale and management of advertisements and sponsorships (if applicable).
  - Make payments to you/the podcaster in relation to advertisements and sponsorships sold (if applicable) and provide information related to such payments.
  - Give you/the podcaster access to anonymized statistics related to the podcasts, such as number of listens and demographic data.
  - Give you/the podcaster access to statistics related to the sale of advertisements inserted into the podcasts.
  - Communicate with you/the podcaster and provide support in the event of technical, financial or other issues.
  - Compile statistics for analytical purposes.
  - Prevent, detect or block misuse or fraudulent behaviour.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your personal data is retained for the duration of the agreement and will be kept for a reasonable period of time thereafter in order to comply with any legal obligation Acast may have.

4.2 Podcast guests

• Explanation - If you participate in a podcast which is made available to the public by Acast, Acast will process certain personal information.
  
  
• Legal basis - The processing of your personal data is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to successfully host the podcast show you are participating in.
  
  
• Categories - We may process the following categories of personal data when you participate in an Acast hosted podcast:
  - Name.
  - Any corresponding information you choose to give.
  Please be aware that you personally determine what personal data you include in the podcast and should therefore always use care when deciding what (if any) personal data to disclose.
  
  
• Why? - We process this data in order to:
  - Enable Acast to host, distribute and make available to the public the podcast in which you participate.
  
  
• Retention period - Your personal data is retained for as long as Acast hosts, distribute and make available to the public the podcast in which you participate.

4.3 For podcasters to receive newsletters, information and offers about Acast, its products/services and any other (direct) marketing message

• Explanation - We process your data in order to send you newsletters, relevant information and any other (direct) marketing messages regarding Acast, its products/services and/or your podcaster account.
  
  
• Legal basis - We process your personal data based on our legitimate interest. We have performed a balancing test and have concludes that the processing of your data will have minimal impact to your privacy and the processing is necessary to provide you with new offers/information.
  
  
• Categories - We may process the following categories of personal data when you sign up a podcaster account:
  - Name.
  - Email address.
  
  
• Why? - We process this data in order to:
  - Send you newsletters, information, e-mail notifications, offers, updates, tips, system improvements and any other (direct) marketing messages regarding Acast, its products/services and/or your podcaster account.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your personal data is retained until you choose to unsubscribe by using the opt-out feature provided in the e-mail.

4.4 For podcasters to access user support

• Explanation - We process your data when you access our user support system or e-mail out support team in order to provide you with podcast related assistance.
  
  
• Legal basis - The processing of your personal data is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to continue to provide you with the support you may require.
  
  
• Categories - We may process the following categories of personal data when you access or e-mail the Acast support system:
  - Name.
  - Email address.
  - User ID.
  - Your communication with us.
  
  
• Why? - We process this data in order to:
  - Confirm your identity as a podcaster.
  - Communicate with you.
  - Answer your questions and find a solution to the issue.
  - To develop new services.
  - To compile statistics for analytical purposes.
  - Understand, diagnose, troubleshoot and fix issues with the Services.
  - To prevent, detect or block misuse or fraudulent behaviour.
  - To comply with any legal obligation Acast may have.
  
  
• Retention period - Any information (in addition to the personal information required under contract) which is provided whilst Podcaster is accessing user support will be retained for as long as necessary to fulfil your support request and will be kept for a reasonable period of time thereafter. However, we may retain email and other communication between you and Acast for internal monitoring purposes.

5. PERSONAL DATA WE PROCESS AND WHY – CUSTOMERS

5.1 Existing customer - To sell ads and campaigns and administer the contractual relationship

• Explanation - Regardless of whether you are a natural person or a representative of a customer who is a legal person, we process your data in order to offer you/the customer to purchase ads/campaigns and administer the contractual relationship with you/the customer to the extent an ad/campaign has been purchased. The Acast group company that enters into the agreement with you/the customer is the data controller for the processing of personal data related to you/the customer.
  
  
• Legal basis - The processing of your personal data is necessary for the performance of our contract with you in case you are a natural person. In case you are a representative of a legal person, the processing is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to fulfil the contract with the customer you represent.
  
  
• Categories - We may process the following categories of personal data when you (or in your capacity as a representative of the customer) enter into an agreement with Acast:
  - Name.
  - Email address.
  - Telephone number.
  - Invoicing and payment details.
  - Purchase orders.
  
  
• Why? - We process this data in order to:
  - Provide you/the customer with offers, information and marketing (e.g. provide offers on future campaigns).
  - Manage/administer current/ongoing customer relationship (to the extent an ad/campaign has been purchased).
  - Provide assistance and support in connection with follow-up questions/matters related to an ongoing or completed campaign.
  - Receive and administer invoicing and payments in relation to advertisements sold (if applicable) and provide information related to such payments.
  - Give you/the customer access to anonymized statistics related to the ads/campaigns.
  - Communicate with you/the customer and provide support in the event of technical, financial or other issues.
  - Compile statistics for analytical purposes.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your personal data is retained for the duration of the agreement and will be kept for a reasonable period of time thereafter in order to provide new offers/information and/or comply with any legal obligation Acast may have.

5.2 Potential customer - To evaluate possible business opportunities

• Explanation - Regardless of whether you are a natural person or a representative of a potential customer who is a legal person, we process your data in order to evaluate business opportunities with you/the potential customer to purchase ads/campaigns and enter into a contractual relationship with Acast.
  
  
• Legal basis - The processing of your personal data is based on our legitimate interest. We have performed a balancing test and have concluded that the processing of your data will have minimal impact to your privacy and the processing is necessary to evaluate possible business opportunities between you/the potential customer and Acast.
  
  
• Categories - We may process the following categories of personal data when you (or in your capacity as a representative of the customer) engage in business discussions with Acast:
  - Name.
  - Email address.
  - Telephone number.
  
  
• Why? - We process this data in order to:
  - Evaluate possible business opportunities with you/the potential customer to purchase ads/campaigns and enter into a contractual relationship with Acast.
  - Communicate with you/the potential customer and provide assistance in connection with a future/potential campaign.
  - Comply with any legal obligation Acast may have.
  
  
• Retention period - Your personal data is retained for as long as we are evaluating possible business opportunities with you/the customer and will be kept for a reasonable period of time thereafter in order to provide new offers/information.

6. WHO DOES ACAST SHARE YOUR DATA WITH?

6.1 In order for Acast to provide a service to you, we share your personal data with certain third-parties. Such third-parties are only allowed to use your personal data in line with our instructions and may not use your personal data for their own purposes. They are also obliged to protect your personal data. For example, we share your personal data with the following companies:

- Amazon who provides hosting services through AWS.

- AdsWizz who provides a service for advertising.

- ID5 who provides advertising profiling for test purposes.

- Intercom who provides a support tool.

- Google who provides a mail server for support.

-  Netsuite who provides a service to process podcasters/customer purchase orders.

-  Salesforce who provides a customer relationship manager system.

- Mailchimp who provides a service for sending newsletters.

- Hubspot who provides a service to empower our blog.

- Certain media house partners.

6.2 We may also share your personal data with other companies in the Acast group (including our subsidiaries) and our partners within the marketing analysis field. Personal data processed by other Acast group companies will not be used for any purpose not outlined in this Privacy Policy.

6.3 We may be obliged to share your data with public authorities at their request in accordance with applicable legislation or a decision by a competent authority or if we have a legitimate interest in disclosing the data.

7. WHERE WE PROCESS YOUR PERSONAL DATA

7.1 Certain recipients (our suppliers and other third parties) who process your personal data may be located in a country outside of the EU/EEA. Where such data transfer occurs, we will make sure that an appropriate data transfer mechanism is put in place to protect your personal data. This includes entering into a contract with the recipient in which the EU Commission's standard contractual clauses (available at the EU Commission’s website) have been incorporated. Consequently, transfers of personal data to such recipients are based on a decision by the European Commission that an adequate level of protection of the personal data is ensured in accordance with GDPR articles 45.1 and 46.

7.2 For transfers of your personal data to other Acast group companies based outside of the EU/EEA, we will rely on the data transfer agreement entered between all Acast group companies in which the EU Commission’s standard contractual clauses (available at the EU Commission’s website) have been incorporated.  

8. CHILDREN

Our Services are not directed at children under the age of 16 and we therefore do not knowingly collect personal data from children under 16 years. If you become aware that Acast has unknowingly collected personal information from a child under the age of 16, we will make reasonable efforts to delete this information from our database as soon as practically possible.

9. HOW TO CONTACT US

If you want to request information about our Privacy Policy or use your rights as expressed above, you can contact us at:

Acast AB (publ)

Company reg. no. 556946-8498

Kungsgatan 28

Stockholm 111 35

Sweden

Email: privacy@acast.com