PRIVACY POLICY

Effective starting: January 1, 2020

Who we are: Alfred Publishing, LLC (“Alfred Music,” “we,” or “us”) provides a variety of services, including provides the ability for users to browse and search through our catalog, place orders of our products or courses, create and view your account information, submit feedback and other customer service inquiries, and engage with our marketing content (the “Services”). Alfred Music is committed to protecting your privacy and utilizing technology that gives you a powerful and safe online experience. The websites www.alfred.com.com, www.totalsheetmusic.com.com, www.alfred-music.com, www.emtontheweb.com, sionline.alfred.com, and media.alfred.com (hereinafter "the Site") is owned and operated by Alfred Music and Alfred Musicis the controller of the Personal Data.

Please read carefully through all sections of this Privacy Policy. This Privacy Policy covers our treatment of Personal Data that we collect through your registration, access and use of the Sites and the Services provided on the Sites. This policy does not apply to the practices of companies that we do not own and/or control or to people that we do not employ or manage.

This Privacy Policy may be changed by us from time to time and the governing version will be posted on the Site. We will notify you if we make material changes to the Privacy Policy or we will provide notice to you of our changes on our website landing page. Please review this Privacy Policy on a regular basis as your use of the Site will be governed by the then-current Privacy Policy.

Alfred Musicrecognizes the importance of protecting the privacy of our customers and the users of the Site. As such, we will always ensure that we have a lawful basis for processing your Personal Data.

Why We Collect and How We Use Personal Data. We collect and share data from the users of our Sites and Services to manage our contractual obligations to you, comply with legal obligations and/or because we have a legitimate business interest to do so. We collect and share information to: (a) provide our Sites and Services; (b) provide information about our products and Services; (c) provide information about data security and privacy; (d) learn more about our customer’s preferences; (e) enhance, personalize and support your experience on our Sites; (f) enhance and develop our products and Services based on your direct comments and/or on the pages or information you view on our Sites; and (g) analyze the traffic to our Sites.

Personal Data Collection and Use

We do not collect any more Personal Data from you than what we have determined is needed for us to provide the Services and comply with applicable laws.

What Happens If You Don’t Provide Your Personal Information?

Please be aware that, if you choose to limit the personal information you provide to us (or, in some circumstances, provide no personal information at all), then we may be unable to provide you with the products and services you have expressed an interest in, or which we have a contract to provide to you. We may also be unable to provide you with access to some or all our Site (or its functionality).

We may also collect and use Non-Personally Identifiable User Information for several purposes, including (without limitation):

• To calculate necessary royalty payments to third party content providers, which are often based on the number of times a work is opened or accessed by our users.

• To prepare reports and other materials that we may share with others in an anonymous format.

• For analytics purposes.

In some instances, we use third-party vendors to collect, monitor and/or maintain Non-PII; for example,we may use Google and Google Analytics to analyze application, feature and content usage.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

Electronic Marketing

We provide you the opportunity to consent to receive commercial email from us related to the Services or information that we deem you may be interested in when you seek more information from us. We will give you the opportunity to "opt out" of receiving any unsolicited information from us or to limit the unsolicited information you receive from us to information regarding the Services or information you specifically request or information we determine you may find useful as a result of your use of the Site.

Information Sharing and Disclosure

Except as otherwise described in this Privacy Policy, we will not share your Personal Data with any other person or company. We will share your Personal Data to other companies or people when:

• We need to share your information to provide a product or service you have requested;

• We may provide affiliates access to your Personal Data in order to for us and our affiliates to review common customers and/or identify where you may benefit from other services we may provide or the services of our affiliates.

• We need to send the information to companies who work on behalf of Alfred Music to provide a product or service to you. Unless we tell you differently, we only provide these companies the minimum amount of information that is necessary for them to assist us and these companies do not have any right to use the Personal Data we provide to them beyond what is necessary to assist us;

• We find that your actions on our website violate the Terms and Conditions of Use, any of our usage guidelines for specific services or any agreement; and

• As required to respond to or initiate subpoenas, court orders, or legal process.

Third Party Processors

To ensure that your Personal Data receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your Personal Data with to ensure that your Personal Data is treated by those third parties in a way that is consistent with and which respects the applicable laws on data security and privacy. For example, we use third-party cloud data storage, error logging, accounting software, payment processors and marketing service providers.

How long do we keep your information?

We will store your information for as long as you have an account with Alfred Music. We may keep records of transactions with you for a period of up to seven (7) years to comply with the IRS requirements.

Use of Cookies

We use “cookies,” a small text file transferred to your device, along with similar technologies (e.g., internet tag technologies, web beacons, embedded scripts) to help provide you a better, more personalized user experience. For a detailed description of the cookies we use and your ability to control the use of cookies while you navigate the internet, please see our Cookies Policy.

Interest-Based Ads

Unaffiliated third parties may use cookies and other technologies on our website to collect information about your online activities over time and across different websites you visit in order to provide you with interest-based advertising. You can generally opt-out of receiving interest-based advertisements from members of the Network Advertising Initiative or the Digital Advertising Alliance by visiting their opt-out pages: (http://www.networkadvertising.org/choices/) and (http://www.aboutads.info/choices/). When you opt-out using these links, please note that you may still receive advertisements. They just will not be personalized based on your interests.

Do Not Track

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Security

We will take reasonable and appropriate measures to protect your Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data. However, no electronic storage method or data transmission over the Internet can be guaranteed to be 100% secure.

Commitment to Children’s Privacy

In compliance with the Children's Online Privacy Protection Act, 15 U.S.C., §§ 6501-06 and 16 C.F.R., §§ 312.1-312.12, the Site does not collect information from children under 13 years of age, and we do not intentionally collect information from persons under sixteen (16) years of age. Use of the Site is limited to users that are sixteen (16) years of age and older. By using the Site, you represent that you are sixteen (16) years of age or older.

Policies of Other Websites

The Site may contain links to third-party websites not owned or controlled by Alfred Music. Alfred Music is not responsible for the privacy policies of any third-party websites which user may access through a third-party link. Further, these third-party websites may have privacy policies that differ from this Privacy Policy. Alfred Music disclaims all responsibility for the privacy practices of such other third-party websites. You should read the privacy policies of each third-party website you visit to determine what information each third-party website may be collecting about you and how they intend to use such information.

Notice to Utah Residents

Except as expressly identified below, we do not disclose a user’s personal data to any third-party for such third-party’s direct marketing purposes.

Notice to Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to customerservice@alfred.com.

Notice to California Residents

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is publicly available, deidentified or aggregate information. For purposes of this

“Notice to California Residents” section we will refer to this information as “Personal Information.”

Right to Know About Personal Information Collected, Disclosed, or Sold

Your Right

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

1. Specific pieces of Personal Information that we have collected about you;

2. Categories of Personal Information we have collected about you;

3. Categories of sources from which the Personal Information was collected;

4. Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;

5. Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and

6. The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Know

You may submit a request to know through our interactive webform available here or by calling us at (800) 628-1528. You also may submit a request to know by emailing customerservice@alfred.com.

Our Process for Verifying a Request to Know

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

We will verify your identity as follows:

Request to Know Categories of Personal Information: We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

Request to Know Specific Pieces of Personal Information: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Collection of Personal Information

The following table presents the categories of Personal Information that we have collected, the categories of sources from which that information was collected, and the categories of third parties with whom we shared that Personal Information for the 12 months preceding the Effective Date of this Privacy Policy.

Disclosure or Sale of Personal Information

The following is a list of categories of Personal Information that we have sold to third parties in the 12 months preceding the Effective Date of this Privacy Policy and solely for remarketing advertising purposes:

• IP address

• Cookie information

The following is a list of categories of Personal Information that we have disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy:

• Name

• Postal address

• Email address

• Telephone #

• Records of products or services purchased, obtained or considered

• Purchasing or consuming histories or tendencies

• Professional or employment-related information

• IP Address

• Cookie information

We do not knowingly sell the Personal Information of minors under 16 years of age without affirmative authorization.

Right to Request Deletion of Personal Information

Your Right

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected or maintain. However, a business is not required to comply with a request to delete if it is necessary for the business to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

How to Submit a Request to Delete

You may submit a request to delete through our interactive webform available here or by calling us at (800) 628-1528. You also may submit a request to know by emailing customerservice@alfred.com.

If you submit a request to delete online, you will be asked to confirm separately that you want your Personal Information deleted.

Our Process for Verifying a Request

If we determine that your request is subject to an exemption, we will notify you of our determination. If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized deletion.

We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

If we are unable to verify your identity to the applicable standard, we will treat your request to delete as a request to opt-out of the sale of the personal information that you provided as part of processing the request to delete. See the following section for a description of the right to opt-out of the sale of personal information.

Notice of Right to Opt-Out of Sale of Personal Information

Your Right

If you are a California resident, you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Opt-Out

You may submit a request to opt-out of sales through our interactive webform available here or by clicking on this link: “Do Not Sell My Personal Information.” You also may submit a request by calling us at (800) 628-1528 or emailing us at customerservice@alfred.com.

How We Process a Request to Opt-Out

We will act upon your request to opt-out within 15 days from the date that you submit the request. The CCPA does not require that we verify the identity of individuals who submit requests to opt-out of sales. However, we may deny the request if we have a good-faith, reasonable, and documented belief that the request is fraudulent. If we deny the request on this basis, we will notify the requesting party and provide an explanation why we believe the request is fraudulent.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents

California residents may use an authorized agent to submit a request to know, delete, or opt-out of sales on your behalf.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission and (2) you verify your identity directly with us. These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465.

If you use an authorized agent to submit a request to opt-out of sales, you will need to provide that authorized agent with written permission to do so and submit written proof to us that the agent has been authorized to act on your behalf.

Shine the Light Law

We do not disclose personal information obtained through our Site or Services to third-parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

Notice to Residents of Europe and the United Kingdom

Under the GDPR, you have the following rights related to Alfred Music’s use of your Personal Data.

If you choose to exercise any of your rights listed above, it may affect your ability to use the Site, as the operation and functionalities provided on the Site may require the use of your Personal Data.

Notice to Residents of the U.S. (Other than California) and Canada:

You may access Personal Data held by us about you, as well as information about how we are using your data and you can request that we rectify any inaccurate personal data held by us about you.

Contact Us

To contact us or exercise any of your rights above, please contact Alfred Music at:
customerservice@alfred.com

and/or

Alfred Music
Attn: Privacy
PO Box 10003
Van Nuys, CA 91410