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PRIVACY POLICY

Libera Publishing cares about your privacy. We are committed to maintaining your trust by protecting your Personal Information (as defined below). This privacy policy (the “Policy”) describes our policies on the collection, use and disclosure of your Personal Information in connection with your use of our websites, social media web pages, online services and emails (individually and collectively, the “Site” or “Sites”). It does not apply to any information collected offline.

Personal Information collected on the Sites may be used in the manner described below by Libera, our affiliates and/or their respective agents and trusted partners (individually and collectively, the “Company”). When used herein, the terms “we”, “us” and “our” refer to the Company.  When this Privacy Policy uses the term “Personal Information,” we mean information that relates to you and can be used to identify you as an individual. Personal Information does not include information or data that has been aggregated or made anonymous such that you can no longer be personally identified using any means reasonably available to us.

1. Collection of Personal Information.

We collect different types of Personal Information in different ways depending on how you use and interact with our Sites.

 

We may collect the following types of Personal information from you:

  • Contact information, including your name, email address, street or mailing address and telephone or mobile phone number;

  • Billing and payment information, including your bank account information, payment preferences, tax ID number, credit card information and billing address;

  • Unique identifiers, including your user name and password;

  • Demographic information, including your age and date of birth; and

  • Internet and other electronic network activity, including your home server domain name and search history.

 

We may collect such Personal Information from you when you visit and/or use the Sites in any of the following ways:

  • When you communicate with the Company via email,

  • When you post messages to the Company’s bulletin boards or chat groups;

  • When you provide information to us in online registration and other forms, surveys, and contest entries;

  • Via the use of Internet cookies and similar Internet technologies; and

  • When you perform a search using our search engine.

 

We may also collect and/or generate anonymized and aggregated information when you visit and/or use our Sites. Anonymized or aggregated information is not Personal Information.

2. Use of Personal Information.

We may use your Personal Information for the following business purposes:

  • To facilitate your requested forms and inform you about your applications;

  • To administer your accounts and respond to your requests, questions and concerns;

  • To send you marketing and promotional communications;

  • To administer promotions and sweepstakes you enter and notify you of the results;

  • To maintain and improve our Sites, content, products and services, including to customize your experience on our Sites and to inform you about Site updates;

  • To conduct research and analysis for product development and content improvement purposes;

  • To maintain the security and effective functioning of our Sites; and

  • To address our compliance and legal obligations and exercise our legal rights.

 

We may use Internet cookies to save information regarding your Site preferences, the pages of the Site viewed by you, and the advertisements viewed or clicked by you. This enables us to recognize you when you revisit the Site and to customize your Site experience. Internet cookies are stored on your hard drive and are not stored, in any form, by the Company. You may decline the Internet cookies by using the appropriate feature of your web browser, if available.

We may also use web beacons and similar technologies to automatically collect and save information as you browse our Sites, such as connection information (including the domain name and Internet Service Provider), browser type and version, mobile device ID, cell phone carrier, operating system and device type, traffic to and from the websites, the Internet Protocol (IP) address you use to connect to the Internet and other standard weblog information. Such information is sometimes referred to as web analytics and/or clickstream data. This information is used to make our Sites easier to use, improve our advertising and to provide you with a more personal and convenient experience.

We do not currently use your Personal Information in such a way that automated decisions are made about you without any human input.

3.  Sharing of Personal Information Collected.

We may disclose your Personal Information to third parties in order to operate, maintain and improve the Site and to provide you with your requested services and process your requested transactions. For example, we partner with Songtrust® to provide certain publishing administration services. If you sign up for our publishing administration service, your Personal Information will be shared with WAMI and Songtrust, and use of such Personal Information by Songtrust will be subject to Songtrust’s privacy policy: https://www.songtrust.com/privacy/. We do not make any representations in regard to, and will not be responsible for, the privacy practices of any third party, including, but not limited to those of Songtrust or any other third party with whom we may share your Personal Information for business purposes.

To help protect you and others, we also use the information we collect, including Personal Information, to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to, or misuse of, the Sites; to ensure compliance with applicable agreements between you and the Company; to investigate violations of, or enforce our agreements; and to otherwise to protect our rights and property. We may disclose your Personal Information if necessary to detect, limit or prevent fraud or security issues, to protect our rights, property and safety or those of our employees or partners, or if required by applicable law or to respond to legal process or a request for cooperation by a government entity or law enforcement.

In the event that we purchase, sell, transfer or acquire all or a substantial portion of a business or its assets, such as in connection with a merger, acquisition or in the event of a bankruptcy reorganization or liquidation, then we may also disclose or share your Personal Information in connection with such transaction. Any recipient of information in connection with any such transaction will be required to comply with reasonable confidentiality restrictions with respect to your Personal Information.

We will not rent or sell share your Personal Information to third parties for marketing or advertising purposes without your prior consent.

4.  Links to Third-Party Websites.

We may display links to third party websites, including social media sites that we do not own or operate. We provide links to these third-party sites as a convenience to you. They are not intended as an endorsement of or referral to the linked sites or services. The linked sites and services are subject to their separate and independent privacy statements, notices, and terms.  Please read their privacy policies carefully to find out how they collect and process your Personal Information prior to submitting any Personal Information via those third-party websites. The collection, use, and disclosure of your Personal Information will be subject to the privacy policies of the third party and not this Policy. We cannot control or be held responsible for the data collection, privacy, and information sharing policies and procedures or content of third-parties.

5.  Data Retention, Transfer and Security.

We will retain your Personal Information for as long as your account with us is active and as needed to provide you services.  We will also retain your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

The Company is headquartered in Jakarta, Indonesia. The Personal Information we collect from you will be transferred to and stored and processed in the Indonesia. It may be transferred to and/or stored in other countries where our service providers maintain facilities as well. By using our Sites, or providing us with any Personal Information, you fully understand and consent to this transfer, processing and storage of your information. If you are located in the European Union or other regions with laws governing data collection and use, please note that we will not transfer your Personal Information across international borders except in accordance with applicable law.

The security of all Personal Information provided to the Company is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and after receipt, including against unauthorized or unlawful access and accidental loss, destruction or damage. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk.

6.  Opt-Out & Security Breach Notices.

You have the right to opt-out of having your Personal Information collected by the Company, used by Company for secondary purposes, disclosed to third parties, and/or used by the Company or third parties to send promotional correspondences to you, by contacting Company via e-mail at legal@liberapublishing.com or to the extent applicable, by checking the appropriate box on the online form or clicking the unsubscribe link in the email. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us via e-mail at legal@liberapublishing.com.

Please note, however, that we may still need to send you certain communications regarding the operation and administration of our Site, and you will not be able to opt-out of those communications, for example, communications regarding updates to this Policy and any data security breaches.

In the event that your Personal Information is compromised due to a breach of our security, the Company will promptly notify you in compliance with all applicable laws. Subject to applicable law, we reserve the right to determine the form and means of providing such notifications to you.

7. Access to and Ability to Correct Personal Data.

We value your rights to your Personal Information. In addition to your other rights hereunder, and in accordance with applicable law, you may have the right to (i) request confirmation of whether we store, use or share any of your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of the Personal Information that you have provided to us, or ask us to send that information to another company; (iv) restrict our uses of your Personal Information or object to those uses; (v) seek correction of inaccurate, untrue or incomplete Personal Information; and (vi) request erasure of Personal Information held about you by us, subject to certain exceptions. If you would like to exercise any of these rights, please contact us via email to legal@liberapublishing.com. We will process such requests within a reasonable time period and in accordance with applicable laws.

8. Children’s Privacy.

 

We do not knowingly collect or attempt to collect any Personal Information from children under the age of 17 (“Children”).  If you feel that we have unknowingly collected information from a Child, please contact us immediately via email to legal@liberapublishing.com and this information will be removed. For more information on how to protect your Children online, visit www.unicef.org/indonesia/child-protection/how-to-be-safe-online.

9.  Changes to this Policy.

By using our Site, you agree to the terms of this Policy.  We may amend this Policy at any time and, as such, we encourage you to periodically review this page for the latest information on our privacy practices.  If we make a material change to this Policy, we will send an email to users who have provided an email address or post a notice on our Site prior to the change becoming effective.  Changes to this Policy are effective when they are posted on our Site. Your continued relationship with us after the posting of any amended version of this Policy shall constitute your agreement to be bound by any such changes.  We encourage you to review this Policy periodically to remain informed of how we use and protect your Personal Information, and to be aware of any Policy changes.

 

10.  Additional Terms.

If you have any questions or comments regarding this Policy, please email us at legal@liberapublishing.com.

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