Privacy

1. Introduction

This privacy policy (“Privacy Policy”) is created in order to be transparent about how Eccho Rights AB, situated at Kungsgatan 48, 111 35 Stockholm, Sweden (“Eccho Rights”, “we”, “us”, “our”) collects, uses and protects personal information about their clients and others who in some way have been in contact with Eccho Rights.

We will in this Privacy Policy outline the different ways that Eccho Rights process the personal information that is supplied or gathered by Eccho Rights, how we use and protect said information and what your rights are when it comes to controlling or limiting such use.

After you have read through this Privacy Policy, we are confident that you should be more aware of what your rights are in relation to Eccho Rights when it comes to your personal information.

In general, Eccho Rights is required to process personal information in order to fulfil requirements in agreements and other obligations towards our clients. For instance, this may include, but is not limited to, the contact details of a person working for the client. The personal information gathered about this person may be required for example; in order to send inquiries to the company; issuing invoices; or sending them program materials. Eccho Rights also collects so called “cookies” from our websites, which will be explained in greater detail below, allowing us to reach more relevant recipients of the advertisement that we have to offer. There are many examples of where it is necessary for Eccho Rights to process personal information, but for every piece of personal information that Eccho Rights collect, store and use, we want to ensure you that we do so thoughtfully and with your best interest in mind.

There is, however, a distinction to be made here. Information in one category is information you must provide in order for Eccho Rights to perform its obligations towards you and/or your company. When you agree to our Privacy Policy, you give us the right to collect this information and use it for the purposes described. Then there is information in another category which we may only collect if you explicitly give us permission to do so in the future. For this second category of information, we will ask for your permission before first accessing it, we will describe how we will use it if you give us permission, we will only use the information for the purpose we described, and you will always have the ability to change your mind and revoke that permission.

Acceptance of our Privacy Policy does not automatically mean you have granted us permission to access or use information in the secondary category. This is, as just described, something that we will have to ask for.

We will be clear with you about how and when we might share information.

In some contexts, we will share certain information. For example, like most services, if you interact with Eccho Rights through a third party like Facebook or a mobile provider, we share some information with them and they share some information with us in order to enable your interaction. And we also share and receive de-identified information with third-party analytics companies to help us understand how the content we license is performing, with marketing partners who help us with promotional efforts, and with advertisement aggregators who allow us to advertise our programs. There also may be times when we want to share information with you. For example, newsletters are a great way to keep our clients updated on the latest news regarding the programs that we offer. Similarly, you can ask us to share information to you, like the contact information to our sales agents, who may want to directly send you news or promotional offers, but you can also revoke that permission at any time.

With this Privacy Policy we hope that you will get a better understanding of our privacy commitments to you.

Should you have any questions or concerns, please do not hesitate to contact us at privacy@ecchorights.com.

2. Your Consent

By being a client or partner of Eccho Rights’ and/or by visiting, using or interacting with Eccho Rights’ websites and/or social media you are consenting to:

the use of cookies and similar technology;

the transfer of your information abroad from where you live;

the collection, use, sharing, and other processing of your information,including for advertising-related purposes; and,

the public availability of your information and the controls over such information.

3. The Information We Collect

3.1 Client’s Contact Information

When a company becomes a client of Eccho Rights, we may ask that company for information such as a contact person for further correspondence, which could include name, email address, phone number, office address, postal code, and country.

Eccho Rights may also access personal information that is publically available on a company’s website and store this information for the purpose of contacting the company regarding relevant content.

3.2 Cookies

A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognise your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them).

When you use or interact with Eccho Rights’ website and/or social media (collectively the “Websites”), we may use a variety of technologies that collect information about how the Websites is accessed and used. This information may include:

what pages you have visited, your interactions with content that is uploaded, advertising, products, and services which are offered, linked to, or made available on or through the Websites;

the details of the queries you make and the date and time of your request; and,

technical data, which may include URL information, cookie data, your IP address, device attributes, network connection type (e.g., WiFi, 3G, LTE) and provider, network and device performance, browser type and language.

Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage similar technologies in the same way that you manage cookies using your browser’s preferences.

You hereby consent to the use of the cookies and other technologies described above.

3.2 Third-Party Applications

If you interact with, and sign up to applications provided by, Eccho Rights using credentials from a third-party application (e.g., Facebook), you authorise us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available on or through your third- party application account, including, for example, your name, profile picture, country, hometown, email address, date of birth, gender, friends’ names and profile pictures, and networks.

3.3 Payments

Since Eccho Rights sends and receives payments through international banks, it is essential for us to collect and store additional information, like your name, date of birth, and phone number, and provide it to payment processors we work with to issue invoices, to enable credit checks and to send you invoices.

BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORISE ECCHO RIGHTS TO USE AND SHARE WITH OTHER COMPANIES IN THE ECCHO RIGHTS CORPORATE GROUP, AS WELL AS CERTAIN TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE OF THE COUNTRY OF YOUR RESIDENCE (INCLUDING COUNTRIES WHICH DO NOT PROVIDE THE SAME LEVEL OF PROTECTION FOR THE PROCESSING OF PERSONAL DATA AS THE COUNTRY OF YOUR RESIDENCE), THE INFORMATION PROVIDED BY YOU TO ECCHO RIGHTS, EVEN IF SUCH INFORMATION IS COVERED BY LOCAL BANKING SECRECY LAWS. YOU ACKNOWLEDGE AND AGREE TO THE IMPORTANCE OF SHARING SUCH INFORMATION TO ECCHO RIGHTS AND ALSO AGREE THAT, BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU EXPRESSLY WAIVE YOUR RIGHTS UNDER SUCH BANK SECRECY LAWS WITH REGARD TO ECCHO RIGHTS, ANY COMPANY IN THE ECCHO RIGHTS CORPORATE GROUP, AND ANY TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE YOUR COUNTRY OF RESIDENCE. THIS CONSENT IS GIVEN FOR THE DURATION OF YOUR RELATIONSHIP WITH ECCHO RIGHTS.

4. Our Use of Information

Consistent with the permissions you give us to collect the information, we may use the information we collect, including your personal information:

to ensure that materials, such as program video files, are sent to Eccho Rights’ clients;

to analyse your use of the Websites, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Websites;

to communicate with you for service-related purposes including via emails, notifications, text messages, or other messages, which are relevant to the relationship with Eccho Rights its services;

to communicate with you, either directly or through one of our partners, for marketing and promotional purposes via emails, notifications, or other messages, consistent with any permissions you may have communicated to us;

to process payments;

to enforce this Privacy Policy and any other terms that you have agreed to, including to protect the rights, property, or safety of Eccho Rights, its users, or any other person, or the copyright-protected content of Eccho Rights’ catalogue which we represent;

to provide you with information, advertising, or other content which is influenced by your location and your location in relation to other clients; and

as otherwise stated in this Privacy Policy.

5. Transfer to Other Countries

Eccho Rights transfers, processes and stores information about our clients on servers located in a number of countries. Accordingly, Eccho Rights may share your information with other companies in the Eccho Rights corporate group in order to carry out the activities specified in this Privacy Policy. Eccho Rights may also subcontract processing to, or share your information with, third parties located in countries other than your home country. Your personal information may therefore be subject to privacy laws that are different from those in your country of residence. Information collected within the European Economic Area (“EEA”) and Switzerland may, for example, be transferred to and processed by third parties identified above, located in a country outside of the EEA and Switzerland, where you may have fewer egal rights in relation to your information. The Eccho Rights corporate group will process your information as described in this Privacy Policy.

6. Security

We are committed to protecting our clients’ information. However, while we take data protection precautions, no security measures are completely secure, and we do not guarantee the security of the information that we store.

7. Accessing and Updating User Information

If you want to review and amend the information that we have stored about you, or if you have questions about your privacy in relation to Eccho Rights, this privacy policy, please contact us at legal@ecchorights.com. You can also contact us by sending a letter to Eccho Rights, Attn: Legal Department, Kungsgatan 48, 111 35 Stockholm, Sweden. We will respond to your request within a reasonable period of time upon verification of your identity in accordance with local laws. We recommend you include documents that prove your identity and a clear and precise description of the information which you request access to.

8. Changes to the Privacy Policy

Occasionally we may, in our discretion, make changes to this Privacy Policy. When we make material changes to this Privacy Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Websites, for example www.ecchorights.com/privacy, or by sending you an email. In some cases, we will notify you in advance, and your continued use of the Websites, or business relationship with Eccho Rights after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Websites, or your business relationship with Eccho Rights under the new version of the Privacy Policy, you may terminate such use or relationship by contacting us through legal@ecchorights.com.

Thank you for taking the time to read through our Privacy Policy.

Data Controller:

Eccho Rights AB

Kungsgatan 48

111 35 Stockholm

Sweden