Vobile Privacy Policy

Last updated: August 2025

We are Vobile, Inc., a California company. If you need to contact us about this privacy notice, please use the details set out in the ‘How to contact us’ section at the end of this notice.

This privacy notice tells you about how and why we use personal data in connection with providing our products and services (Services).

What personal data do we collect?

‘Personal data’ is information about individuals or information from which individuals can be identified. We’ve set out below the broad categories of the personal data that we process in connection with the Services.

User account information:

The Services are used by entities, natural persons, rightsholders, representatives of rightsholders, creators, and internet platforms on which audio, visual, and/or audio-visual work (Content) is displayed.

In the course of contracting with these customers and granting them (or employees acting on their behalf) access to the Services, we collect the following personal data:

Where we contract with a company, and you are a user accessing the Services on its behalf, we may either collect this information from you directly or from the company that employs you.

Platform visitor information:

In the course of operating the Services we collect the following personal data in connection with individuals that use our customers’ platforms:

Due diligence information:

As part of our due diligence processes when contracting with new customers we may need to carry out some “Know Your Customer” (KYC) and “Know Your Business” (KYB) checks. We use specialist third-party providers to carry out these checks. Third-party KYC/KYB providers are independently responsible for the processing of any personal data they use or collect in carrying out these checks. We simply receive a notification that you (or the company you work for if you are an employee of one of our customers) has passed or failed these checks. Lastly, if you are an individual rightsholder, the fact that you have or have not passed these checks will constitute your personal data.

Rightsholder information:

The Services facilitate the regulation of Content on online platforms. To do this, we need to collect information on who the rightsholders of that Content are (for example, information on who created, featured in, and owns the Content). The rights landscape in respect of Content is complex and there can be multiple rightsholders in respect of any one piece of Content. Where rightsholders are individuals, this information will constitute personal data.

If our customer is a company that a rightsholder has appointed to represent them and manage their Content and/or associated rights, we collect this information from that company. In some cases, we may collect rightsholder information from other trusted database sources. If you are an individual rightsholder with whom we contract directly, we collect your personal data directly from you.

Platform Content usage information:

The Services process information about the use of Content on internet platforms, which is used to enable rightsholders and platforms to calculate and account for royalties, licensing fees, monitor, identify, or analyze Content in respect of that use. Where this information is linked back to an individual rightsholder, this will constitute personal data.

Similarly, where this information relates to individual users of customer platforms, this will constitute personal data. Please see the ‘What personal data do we collect?’ section above for a description of personal data collected in connection with such Content usage.

Information on Content use is collected by technology incorporated in the Services working in partnership with the internet Platforms on which Content is displayed.

Prospective customers’ data:

As part of our marketing campaigns from time to time we may identify potential customers and process their contact details to inform them of the Services or other services we believe may be of interest to them. If you don’t want to receive marketing from us, you can let us know at any time by contacting us or by unsubscribing using the link in marketing emails we send to you.

Why do we use personal data?

The table below shows the various reasons why we use personal data. Some of our customers are individuals based in the UK and EEA. To comply with data protection laws that apply to our use of their personal data we need to identify the ‘lawful basis’ we rely on for each use of their personal data. We’ve included this in the table, too.

Category of data Purpose Lawful Basis
User account information To set up, administer and manage customer accounts. Where the customer is an individual rightsholder, necessary for the performance of our contract with the customer. Where the customer is a company, our legitimate interests in fulfilling our contract with the company.
To respond to any communications from customers (or employees on their behalf), including customer support queries. Our legitimate interests in maintaining good customer relationships.
To send customers essential service messages about the Services. Our legitimate interests and those of our customers, to keep them informed about important information they need to know about the Service they have signed up for.
To facilitate rights claims. The legitimate interests of Vobile and rightsholders to resolve claims as to rights ownership.
Due diligence Information To undertake “Know Your Customer”/ “Know Your Business” due diligence. Our legitimate interests, to prevent fraudulent behavior.
Rightsholder information and Content usage information To facilitate the regulation of Content on internet platforms. Where the customer is an individual rightsholder, and we process their data, necessary for the performance of our contract with the customer. Where the customer is a company, and we process the data of rightsowners, our legitimate interests in fulfilling our contract with the company.
To inform platforms we partner with or who are our customers of Content ownership so they can regulate Content. The legitimate interests of Vobile, rightsholders and platforms, to prevent copyright infringement and to facilitate regulation.
To inform rightsholders of the use of Content on internet platforms. Where the customer is an individual and we process their data, necessary for the performance of our contract with the customer. Where the customer is a company and we process the data of rightsowners and/or platform users, our legitimate interests in fulfilling our contract with the company.
To facilitate licenses for use of Content.
To identify and report on platform usage of Content.
To build up a database of Content metadata for ongoing internal analysis and marketing purposes. Our legitimate interests in developing our business.
To facilitate rights claims. The legitimate interests of Vobile and rightsholders to resolve claims as to rights ownership.
User account information and prospective customer information To send customers and potential customers marketing relating to our products and services which we believe may be of interest to them. Our legitimate interests, to promote our company’s products and services.
All categories of personal data To share with third party service providers we appoint from time to time. Our legitimate interests, to produce service efficiencies and to get the benefit of specialist products or services.
All categories of personal data To administer a sale or possible sale of the whole of or part of our business or the restructuring of our business. Our legitimate interests in facilitating any such possible or actual transaction or restructuring.

We may also process your personal data (a) to comply with a legal obligation we are under; and (b) for additional purposes in the future, but only if such purposes are compatible with those listed above.

In certain circumstances, you may be obliged to provide us with your personal data under a statutory requirement. This might include, but is not limited to, for tax and accounting purposes; and to enable us to fulfil our compliance and other obligations under relevant legislation or regulation. Failure to provide us with personal data required under a statutory requirement, or where we’ve indicated in the table above that it is necessary for our contract with you or your company, may prevent us from entering into or performing our obligations under a contract with you or your company.

Who do we disclose personal data to?

Our customers and platform partners:

Where necessary, we disclose:

Service providers:

We may disclose personal data to our service providers who need to process personal data to provide those services to us. Currently, we use a third-party data hosting provider, Microsoft Azure, to store data on our behalf. Azure’s servers are based in the USA and overseas, and we rely on Microsoft’s security arrangements for the security of data transfers.

We may from time to time engage other third-party service providers to act on our behalf. Where we do, and they will have access to personal data, we will include any contractual protections and undertake any due diligence that we deem necessary before disclosing any personal data to them in accordance with the data protection laws that apply to us.

Sale/restructuring:

We may disclose personal data that we process to third parties internationally in the context of a sale or possible sale of the whole of or part of our business or the restructuring of our business.

Other data sharing:

We may also disclose personal data to law enforcement agencies to assist with any investigations, when we bring a claim or defend ourselves against a claim that requires the disclosure of the personal data, and when we engage professional advisors.

International transfers:

We take steps to ensure personal data is protected irrespective of where in the world it is processed or transferred.

Where we process personal data of individuals based in the UK and EEA, by law we are required to ensure that they are afforded equivalent protection in respect of their personal data as they have in the country in which they are based. On a practical level this means that when we transfer personal data outside a country which is deemed to have an “adequate” data protection regime by the European Commission or UK government, we will put in place appropriate safeguards to protect personal data, such as contractual and other supplementary measures.

Data protection law also allows us to make transfers of personal data internationally without putting in place additional safeguards in certain, specific, limited situations, such as where the transfer is necessary for a contract with the individual concerned or a contract which is in the individual’s interests. The sharing of rightsholder information and platform Content usage information with customers and platforms which is necessary to facilitate licensing falls within that scope.

How long do we keep your personal data for?

We will retain your personal data for the period necessary to fulfil the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law.

Cookies:

We make minimal use of cookies – only using those that are necessary to ensure the security and functionality of your visit to our platform. Additionally, we use cookies to provide you, our users, with important notifications that confirm your choices and activity as to the management of your Assets. While we recommend keeping these notifications turned on to ensure a seamless experience, cookies controlling the delivery of these notifications can be disabled when you visit our platform.

UK and EEA citizens’ rights

If you are an individual rightsholder based in the UK or EEA, you have the following rights under data protection legislation.

If you have any questions about your rights, or you wish to exercise any of these rights, please email data.protection@vobileinc.com. We may require you to provide forms of identity should you wish to exercise one of your rights below.

How to contact us

No matter which country you are based in, if you have any questions about this privacy notice, how we use personal data or your rights in respect of your personal data, in the first instance, please contact us at data.protection@vobileinc.com.

We have representatives in the UK and EEA for data protection purposes. If you are based in the UK, or EEA you should contact our representatives. Their contact details are below.

Changes to this privacy notice

We may update this privacy notice from time to time to make sure it is up to date. When we do, we will revise the “last updated” date at the top of the privacy notice. We'll endeavor to make you aware of material changes, but we suggest you also check this page from time to time to ensure you are up to date with our latest privacy practices.