Copyright

Smulie Co. Ltd. (“us”, “we”, or “our”) operates the amanotes.com website and the Smulie’ applications mobile application including Simpia, Beat Battle Duel, Music Night Battle, HDPiano (hereinafter referred to as the “Service”).

​

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

​

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

We can change or modify this Privacy statement. We therefore recommend that you regularly read this privacy statement for changes.

1. Information Collection and Use

​

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

• Personal data: 

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

​

• First and last name

• Email address

• Profile information (shared by yourself in the community) including profile picture, gender, favourite genres of music. 

• Cookies and Usage Data

​

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

• Usage data:

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

​

This Usage Data may include information such as user ID and customer number, your computer’s Internet Protocol address (e.g. IP address), device data and ID, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, mobile advertising ID, unique device identifiers and other diagnostic data.

​

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

• Location data: 

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service. You can enable or disable location services when you use our Service at any time by way of your device settings.

• Tracking & Cookies Data​

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

​

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

​

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

​

Examples of Cookies we use:

​

• Session Cookies: We use Session Cookies to operate our Service.

• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

• Security Cookies: We use Security Cookies for security purposes.

• Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Why we collect data

We process personal data for the following purposes:

• Legal obligations

Some of our data processing is mandated by law. This primarily involves information essential for our (financial) administration and ensuring compliance with tax and accounting obligations. By collecting your personal data we can fulfil our contractual obligations to you, ensuring you comply with our legal obligations.

• Membership administration and services

We keep track of our membership records of people who are Chordify members. We keep various personal details of contacts to run our services as best we can. For instance, we keep contact information in order to reach your areas of interest so we can provide you with the best possible information and appealing content, and we process personal data for our market research and promotions. You can reach us through many different channels, like mail, email, Twitter, LinkedIn, Instagram and Facebook. To make this possible, we also process personal data.

We maintain a record of individuals who are Smulie members in our membership records. We retain diverse personal details of contacts to effectively manage our services and sometimes to notify about our changes in Services. This includes keeping contact information to facilitate communication with you, noting areas of interest for personalised information and engaging content, and processing personal data for market research and promotional purposes. We can also use your personal information for customer support. You can connect with us through various channels such as mail, email, Twitter, LinkedIn, Instagram, and Facebook. To enable this, we also engage in the processing of personal data.

• Newsletters and mailings

You can sign up for different types of newsletters from us. Sometimes personalised, and sometimes not. If you no longer wish to receive newsletters, you can unsubscribe in every email, and in your account settings, and you can indicate your preferences of the type of newsletters that you wish to receive in your account settings.

You have the option to subscribe to various newsletters from us, some personalised and others not. If you no longer wish to receive newsletters, you can unsubscribe from our email, following the instructions within each newsletter.

• Marketing

For development purposes, Smulie needs to expand our range of customers, in other words, we therefore constantly recruit new members, (industrial) partners, musicians, music teachers. Therefore in order to maintain communication with everyone, we process their contact details and areas of interest. Additionally, we process personal data for Smulie campaigns especially for marketing purposes,  including IP address, cookie ID, social ID, and/or surfing habits. This enables us to display the most relevant ads in the appropriate locations. We utilise 'custom target groups' on social media platforms for Chordify (and related campaigns) through Google ads, Youtube, Tiktok targeting, allowing these platforms to display personalised ads. If you prefer not to receive ads through these platforms, you can unsubscribe directly on the respective platforms. Please note that opting out does not guarantee that you will never see Chordify ads again, as we also target ads to general audience groups, of which you may be a part.

• Improved our services

We also keep personal data for the improvement of our services. For example, we ‘log’ clicking behaviour on the website to analyse which numbers are most played along with, which articles are read the most, and open rates to see if our newsletters are relevant.

2. Your rights:

For suggestions or comments or being objected to about processing personal data, please contact us at hello@smulie.io. To exercise your rights, send us an email with specific details about the personal data. Regarding  deletion requests, we will swiftly eliminate pertinent personal data unless legal obligations or urgent reasons hinder us. You will receive confirmation after deletion. In case not all data is removed, we will provide an explanation. Further specify your request if necessary. 

If there is inaccurate or outdated information about you, feel free to modify it in your settings inside the application. Alternatively, inform us of the necessary changes, and we'll be happy to assist you.

You can Revoke your permission, for example, to receive emails (you do that in settings, or via the link in a mailing sent by Smulie) or through Google security settings page at https://security.google.com/settings/security/permissions. If you want to withdraw your permission for any other processing, please contact us.

Deletion: You can easily remove the personally identifiable information we have stored of you yourself by checking the box [delete all data stored about me] while deleting your Smulie Account. [Settings] > [My Account] > [delete account].

Fulfilling this deletion request may require up to 7 days due to the following reasons:

• Administrative needs, such as managing payments or processing refunds, including de-duplication processes.

• We retain your account for 7 days post-deletion, considering that parting ways may be more significant than anticipated. Although deleted accounts become immediately invisible and inactive, this grace period allows users to reactivate their accounts if necessary.

Marketing Communications 

You can restrict the use of your personal data for marketing purposes in the following ways: 

• Manage notification settings 

You can deactivate push notifications or change your notification preferences at any time within the app or in your device settings. 

• Opt out of interest-based ads 

To opt out of interest-based ads, please visit the Network Advertising Initiative (https://www.networkadvertising.org/choices) or the Digital Advertising Alliance (https://www.aboutads.info/choices). Opting out of interest-based ads does not mean you will no longer see ads online. It means that we will not use your personal data to select which ads you see. 

Do Not Track and Other Browser Settings 

We do not respond to "do not track" signals.   

Specific Jurisdictional Privacy Rights 

You may have certain rights regarding the personal data we hold about you, subject to local law. In some cases requests to access rights may be subject to verification. For example: residents of California or the European Union may have additional rights and choices. Please refer to Section 7 (California Privacy Rights) and Section 8 (European Union Privacy Rights) below. 

Third-parties receivers:

We assign external service providers to carry out our own services. For the purpose of personalised advertising and partnering, with other companies that send you promotions and special offers relevant to your interests We may share your personal data with the following third parties for the purposes described below: 

 
• Software development kits (SDKs) or advertising and analytics platforms
We use SDKs to support certain functionality for our apps, including advertising and analytics. Each platform has its own privacy policy and data protection practices.
 
• AdColony
https://www.adcolony.com/privacy-policy/  

• Apple Search Ads
https://www.apple.com/legal/privacy/  

• Facebook Ads Manager
https://www.facebook.com/privacy/explanation
 
• Facebook Business Suite
https://www.facebook.com/privacy/explanation
 
• Google Ad Manager
https://policies.google.com/privacy
 
• Google AdMob
https://policies.google.com/privacy
 
• Google Analytics
https://policies.google.com/privacy
 
• Google Firebase
https://policies.google.com/privacy
 
• InMobi
https://www.inmobi.com/privacy-policy/
 
• IronSource
https://www.is.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf
 
• Kidoz
https://kidoz.net/website-and-kidoz-sdk-privacy-policy/
 
• Liftoff
https://liftoff.io/privacy-policy  

• Mintegral
https://www.mintegral.com/en/privacy/
 
• Tapjoy
https://www.tapjoy.com/legal/players/privacy-policy/
 
• TikTok Ads
https://ads.tiktok.com/i18n/official/policy/privacy
 
• Twitter Ads
https://twitter.com/en/privacy
 
• Unity Ads
https://unity3d.com/legal/privacy-policy
 
• Vungle
https://vungle.com/privacy/
 
• Fyber
https://www.digitalturbine.com/fyber-services-privacy-statement/

• BrightSDK
https://bright-sdk.com/privacy-policy

In return for some of the premium features of Smulie Co. Ltd, you may choose to be a peer on the Bright Data network. By doing so you agree to have read and accepted the Terms of Service of the Bright SDK EULA: https://brightdata.com/legal/sdk-eula. You may opt out of the Bright Data network by clicking Settings -> Web Indexing button
You will get free character or free song in exchange for safely using some of your device’s resources, and only in a manner that will not substantially affect the device's operation. You may turn this off from the settings menu. Please see our Privacy Policy at https://www.smulie.io/privacy-policy and the SDK Privacy Policy at https://brightdata.com/legal/sdk-privacy for further information.

Our websites and apps may contain links to third-party sites, products, or services. Links to third parties are not an endorsement by Smulie Co. Ltd. Further, this Privacy Policy for Simpia, Beat Battle Duel, Music Nighy Battle, HDPiano does not govern or protect information that you provide to third parties. With that in mind, it is important that you review the privacy policy of any third-party site or service that you visit or use. 

3. Links

By using YouTube links (embedded videos) on the Simpia platforms, you trust, not only Simpia, but also YouTube with your information. Please read the YouTube Privacy Policy if you need help understanding what information they collect, why they collect it, and how you can update, manage, export, and delete your information.

4. Retention of data

Smulie Co. Ltd. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

​

Smulie Co. Ltd. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

5. Security of Your Personal Data
    
   We are committed to protecting the information we hold. We use a variety of methods to secure your personal data, including the following measures:
     

6. Hypertext Transfer Protocol Secure (HTTPS) connections 

7. Secure Sockets Layer (SSL) encryption 

8. Transport Layer Security (TLS) encryption 

  
Unfortunately, no data transmission or storage method is 100% secure. While we cannot reduce the risk to zero, we work hard to keep your personal data safe.

6. Information from Third-Party Sources
   
   In some cases, we may get information about you from third-party sources, including commercially available sources, such as social media sites and public databases (where permitted by law). 

7. Third-party source: Facebook Login 

8. Collection purpose: For users to have social interaction within product 

7. Cookies and Other Tracking Technologies
    
   We use the following tools: 

8. Firebase Analytics
   We use cookies and other tracking tools (such as web beacons or pixels) to personalize your experience. They help us remember your settings and preferences, log you into your account, and secure our services. 

8. CALIFORNIA PRIVACY RIGHTS
 
The California Consumer Privacy Act (CCPA) requires us to disclose certain information to California residents. This includes a description of our data practices using specific categories.
 
The CCPA also provides the right to access, delete, or opt out of the sale of your personal data. You can find instructions on how to exercise these rights below.
 
If you or an authorized representative would like to discuss or exercise rights under CCPA, please contact us at hello@smulie.io. We may ask you to supply additional information to process your request.
 
Categories of Personal Data
 
If you are a California resident, the data we collect about you may fall within the following categories of "personal information," as defined by the CCPA:
 
• Identifiers
This includes personal identifiers, such as your name and contact information, as well as unique identifiers related to your browser or device.
 
• Commercial information
This includes your payment information and purchase history with Smulie Co. Ltd.
 
• Demographic information
This includes your age, gender identity, marital status, sexual orientation, race, ancestry, national origin, language, religion, and medical conditions.
 
• Biometric information
This includes your fingerprint, if you use it to verify your identity in our services.
 
• Internet or network activity information
This includes your browsing history and interactions with our ads, websites, and apps, as well as the interactions of your device, browser, and apps with our services.
 
• Geolocation data
This includes device location, as determined by GPS, IP address, or sensors on your device.
 
• Audio, electronic, visual and similar information
This includes photos, videos, and other content or files that you create, upload, or receive using our services.
 
• Professional, employment or education information
This includes your work history and educational background.
 
• Inferences drawn from any of the above
This includes any profiles or summaries about you based on information collected.
 
This Privacy Policy describes how we use this personal information and how it may be shared. Please refer to Section 3 (How Personal Data is Used) and Section 4 (How Personal Data is Shared).
 
How to access your data
 
You can request a copy of your personal data by contacting us at Smulie Co. Ltd or within your account settings: Users can contact developer's email to delete their personal data
 
If we sell your personal data, you also have the right to know what personal data was sold and what categories of third parties bought it.
 
If we share your personal data, you have the right to know what categories of personal data were disclosed.
 
How to request deletion of your data
 
You can request deletion of your personal data by following these instructions: 

• Contact us by email, phone or postal mail 

• Users can contact developer's email to delete their personal data 

  
If we are able to verify your request, we will delete your personal data from our records. In order to verify a request we may ask for identifying information provided by you to match the personal data the app already maintains. We will direct any service providers to do the same. Please note that there are exceptions, such as when the data needs to be saved for legal reasons or to protect the security of Simpia, Beat Battle Duel, Music Nighy Battle, HDPiano.
 
We also may not be able to delete your personal data if it is needed to:
  

• Perform our contractual obligations to you, such as completing a transaction, fulfilling the terms of a warranty or recall, or providing a good or service requested by you; 

• Maintain and protect our business, our websites, and our apps, including detecting and preventing security incidents, or prosecuting those responsible for illegal activity; 

• Identify and fix errors that impact the intended user experience or functionality; 

• Exercise our legal rights, or ensure that others can exercise their legal rights, including the right to free speech; 

• Comply with the California Electronic Communications Privacy Act; 

• Engage in public or peer-reviewed research in the public interest, as long as we received your informed consent; 

• Comply with an existing legal obligation; or 

• Use your personal data internally, in a lawful and reasonable manner, in the context that you provided it. 

  
How to Opt Out of a Sale
 
You have the right to tell us not to sell your personal data. If you exercise this right, we will refrain from selling your personal data, unless you later directly authorize us to do so.
 
To opt out of the sale of your personal data, please contact us at hello@smulie.io.
 
Third-Party Direct Marketing
 
California's "Shine the Light" law allows you to opt out of the disclosure of your personal data to third parties for direct marketing once per calendar year.
 
To opt out of such disclosure, please contact us at hello@smulie.io.
 
9.  EUROPEAN UNION PRIVACY RIGHTS
 
The General Data Protection Regulation (GDPR) provides users in the European Union with certain privacy rights. We work to afford all users and customers the following rights, subject to any legal exceptions:
 
• The right to be informed
You have the right to know about the collection and usage of your personal data
 
• The right of access
You have the right to request and receive a copy of your personal data
 
• The right of rectification
You have the right to ask that we correct inaccurate personal data
 
• The right to erasure
In some cases, you have the right to delete your personal data
 
• The right to restrict processing
In some cases, you have the right to restrict or limit the ways that we use your personal data
 
• The right to data portability
In some cases, you have the right to obtain your personal data in a format that you can move to another provider
 
• The right to object
In some cases, you have the right to ask us to stop any or all processing of your personal data, but there are exceptions, such as when we have a lawful reason to continue doing so
 
We process your data based on your consent, legitimate interest, as necessary to perform our contract with you, and any other lawful bases of processing. Where we rely on your consent to process personal data, you may withdraw your consent at any time by contacting us at the contact details below.
 
If you have questions or concerns about or wish to exercise these rights, please contact us at thuanttqq@smulie.io.Your request will be handled in accordance with GDPR requirements. We will let you know if we need additional information from you in order to fulfill your request.
 
You also have a right to lodge a complaint with a competent European supervisory authority.
 
10. CHILDREN'S PRIVACY
 
Protecting children's privacy online is very important to us. To that end, we do not knowingly collect personal information from children under the age of [13].
 
If we discover that we have collected a child's personal data without parental consent, we will delete it as soon as possible, unless we have a legal obligation to keep it.
 
If you are a parent or guardian, who wishes to review or delete any data collected from your child, please contact us at hello@smulie.io.

11. Contact us

 We welcome your questions or comments regarding this Privacy Policy. Please contact us with any concerns. 

Should you have any concerns or questions, please feel free to contact us via:

• By email: 

Customer Support Email: hello@smulie.io 

• By phone: 

+84 903982259

• Or address: Smulie Co. Ltd 

L12-17, Richmond city, 207a Nguyen Xi, ward 26, Binh Thanh District, Ho Chi Minh city, Vietnam