Earbug

GDPR Privacy Addendum

This GDPR Privacy Addendum ("Addendum") supplements our Privacy Policy and Terms of Service and applies exclusively to individuals located in the European Union ("EU"), the European Economic Area ("EEA"), and the United Kingdom ("UK") (collectively, "European Users"). In the event of any conflict between this Addendum and the Privacy Policy, this Addendum shall control with respect to European Users.

This Addendum describes how Earbug, Inc. processes your personal data in accordance with Regulation (EU) 2016/679 (the "GDPR") and, with respect to UK residents, the UK GDPR as incorporated into UK law by the European Union (Withdrawal) Act 2018.

Data Controller

Earbug, Inc. is the data controller responsible for your personal data. This means we determine the purposes and means of processing your personal data in connection with your use of the Platform.

You may contact us regarding any data protection matter at:

Earbug, Inc.
3924 Knollwood Drive
Austin, TX 78731
United States
Email: privacy@earbug.com

We do not currently have a formally designated Data Protection Officer ("DPO"). If you have a question or concern about how your personal data is handled, please contact us at the email address above and we will respond promptly.

Personal Data We Collect

We collect and process the following categories of personal data about you:

  • Account and identity data. Your name, email address, password (stored in hashed form), and any profile information you choose to provide.
  • Usage and activity data. Information about how you use the Platform, including content you post, comments you make, artists and tracks you interact with, playlists you create or share, and features you use.
  • Device and technical data. Your IP address, browser type and version, operating system, device identifiers, time zone, and other technical identifiers collected automatically when you access the Platform.
  • Communications data. Records of correspondence if you contact us by email or through the Platform.
  • Cookie and tracking data. Information collected via cookies and similar technologies as described in our Cookies Policy.
  • Payment data. If and when Premium Account subscriptions are offered, payment and billing information will be collected. We will update this Addendum at that time with specifics regarding the processing of payment data.

We process your personal data only where we have a lawful basis to do so under the GDPR. The legal bases we rely on are:

  • Performance of a contract (Article 6(1)(b)). We process your account and identity data, and certain usage data, because it is necessary to provide you with the Platform and perform our obligations under our Terms of Service — for example, creating and managing your account, enabling you to post content, and delivering core features of the Platform.
  • Legitimate interests (Article 6(1)(f)). We process certain technical, usage, and activity data on the basis of our legitimate interests in operating, improving, and securing the Platform, and in understanding how users engage with the service. We have assessed that these interests are not overridden by your rights and interests.
  • Consent (Article 6(1)(a)). Where we rely on your consent — for example, for non-essential cookies or marketing communications — we will ask for your consent separately at the time of collection and will not process your data for those purposes without it. You may withdraw your consent at any time.
  • Compliance with a legal obligation (Article 6(1)(c)). We may process your personal data where necessary to comply with applicable law, such as retaining records required by tax, accounting, or copyright law.

How We Use Your Data

We use your personal data for the following purposes:

  • To create and manage your Earbug account.
  • To provide, maintain, and improve the features and functionality of the Platform.
  • To enable you to interact with other users and share content on the Platform.
  • To respond to your inquiries and support requests.
  • To send you service-related notices (such as account updates or security alerts).
  • To enforce our Terms of Service and protect against fraud, abuse, and unauthorized use.
  • To comply with legal obligations, including responding to lawful requests from public authorities.
  • With your consent, to send you promotional communications about the Platform.
  • To analyze usage patterns and improve the Platform through aggregated, anonymized analytics.

Data Retention

We retain your personal data for as long as your account is active or as needed to provide you with the Platform. If you close your account, we will delete or anonymize your personal data within a reasonable period, except where:

  • We are required by law to retain it for a longer period (for example, for tax or accounting purposes);
  • We need it to establish, exercise, or defend legal claims; or
  • Your content has been created collaboratively with other users, in which case it may be retained until all contributing users have also removed it from the Platform (as described in our Terms of Service).

Cookie data is retained in accordance with the periods described in our Cookies Policy.

International Data Transfers

Earbug is based in the United States. When you use the Platform, your personal data is transferred to and processed in the United States, which the European Commission has not recognized as providing an adequate level of data protection equivalent to that in the EU/EEA.

Where we transfer your personal data outside the EU/EEA/UK, we take steps to ensure that appropriate safeguards are in place. These safeguards currently include the use of Standard Contractual Clauses ("SCCs") approved by the European Commission for transfers from the EU/EEA, and their UK equivalent (the International Data Transfer Agreement ("IDTA")) for transfers from the UK, where required.

You may request a copy of the relevant transfer safeguards by contacting us at privacy@earbug.com.

Your Rights

Under the GDPR and UK GDPR, European Users have the following rights with respect to their personal data. To exercise any of these rights, please contact us at privacy@earbug.com. We will respond to all verified requests within one month, and will notify you if we need additional time (up to two further months for complex requests).

  • Right of access. You have the right to request a copy of the personal data we hold about you and information about how we process it.
  • Right to rectification. You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
  • Right to erasure. You have the right to request that we delete your personal data in certain circumstances — for example, where the data is no longer necessary for the purposes for which it was collected, or where you withdraw your consent and we have no other legal basis to continue processing. Note that we may be entitled or obliged to retain certain data even following an erasure request (for example, where retention is required by law or to establish or defend legal claims).
  • Right to restriction of processing. You have the right to request that we restrict the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data, or where you have objected to processing based on legitimate interests pending our verification.
  • Right to data portability. Where we process your personal data on the basis of your consent or because it is necessary to perform a contract with you, and that processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit it directly to another controller where technically feasible.
  • Right to object. You have the right to object to processing of your personal data where we rely on legitimate interests as the legal basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, or where processing is necessary for the establishment, exercise, or defense of legal claims. You also have an unconditional right to object to processing of your personal data for direct marketing purposes at any time.
  • Rights related to automated decision-making and profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects on you. We do not currently make decisions about you using solely automated means that produce such effects.
  • Right to withdraw consent. Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out before withdrawal.

Please note that some of these rights are not absolute, and we may be entitled to refuse requests in whole or in part where exceptions apply under applicable law. We will always explain our reasons if we are unable to fulfill a request.

Children

The Platform is not directed to children under the age of 16 in the EU/EEA/UK. If you are under 16, you may not use the Platform without the verifiable consent of your parent or legal guardian. We do not knowingly collect personal data from children under 16 without such consent. If we become aware that we have inadvertently collected personal data from a child under 16 without verifiable parental consent, we will take steps to delete that data promptly.

Please note that the minimum age of digital consent varies across EU member states (from 13 to 16 years), and the age applicable in your country will apply to you.

Cookies

We use cookies and similar tracking technologies on the Platform. Where we rely on consent for non-essential cookies, we will request your consent before placing such cookies. You may manage or withdraw your cookie consent at any time through your browser settings or by following the instructions in our Cookies Policy.

Right to Lodge a Complaint

If you believe that our processing of your personal data violates applicable data protection law, you have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or place of the alleged infringement.

In the EU, you can find the contact details for your national supervisory authority at www.edpb.europa.eu.

In the UK, the supervisory authority is the Information Commissioner's Office (ICO), which can be contacted at ico.org.uk.

We would, however, appreciate the opportunity to address your concern directly before you approach a supervisory authority, and we encourage you to contact us first at privacy@earbug.com.

Changes to This Addendum

We may update this Addendum from time to time to reflect changes in our practices or in applicable law. Where changes are material, we will notify you by email or by a prominent notice on the Platform prior to the change taking effect. The date of the most recent revision is shown below.

Contact Us

For any questions, concerns, or requests relating to this Addendum or our processing of your personal data, please contact us at:

Earbug, Inc.
3924 Knollwood Drive
Austin, TX 78731
United States
Email: privacy@earbug.com

Last Amended: 11 June 2026