March 2020

Privacy Policy

We value your (“User,” “You,” or “Your”) privacy and recognize the sensitivity of your personal information (personal data). We are committed to protecting your personal information and using it only as appropriate to provide you with the best possible service, products, and opportunities, as described in this Privacy Policy.

This Privacy Policy explains the online information practices of 1action (collectively, “Company,” “we,” “us,” or “our”) which hosts the website of We think it is important to explain what information We collect, what We do with it and to describe the rights you will have with respect to your personal information processed by us.

Please note that when using our Applications, this Privacy Policy should be read in conjunction with our Terms of Use. By accessing our Applications, you acknowledge that the Privacy Policy and the Terms of Use govern your use of the Applications.

Privacy and personal data protection principles vary from one country to another. When you access or visit a third-party website or application, you are subject to the privacy policy of that website or application. Please read the third party’s privacy policy to determine the privacy practices that apply to information or data maintained by the website or application.


When you visit our Platform, you may provide us with the following types of personal data, and we may collect and process such personal data in accordance with his Privacy Policy, as follows:

Contact Data This may include your name and your email address. This information will be collected by us if you communicate with us, for example if you use the links on our Platform to communicate with us via email. Account Data If you create an account on our Platform to benefit from our services, you may need to provide your name, email address, phone number and your photograph. If you use Facebook or Google to login to our Platform, Facebook [or Google] will share data with us including but not limited to your profile data, language, location and publicly available information about you and your friends. Correspondence Data This includes the information you provide when you request support through our Platform, contact us via the email address provided in this Privacy Policy and elsewhere on our website and your views, opinions and feedback which you choose to provide in relation to the Platform and our services, including any comment facilities and message boards. User Content When you use our Karaoke app, this includes the videos you create (e.g. of you performing songs) and upload to our Platform. When you use our Drum Pad app, this includes audio recordings you upload to the Platform. By providingsuch User Content you acknowledge that we may make it available to other users of the Platform until you delete your account on our Platform. Session Data This includes your IP address, your device's unique identifier details, browser details including version, device operating system, geo-location, time zone setting and time/date of access requests, the amount of data transmitted and the requesting provider. We may also capture other information about visits to our Platform such as pages viewed and traffic patterns. Cookie Data Cookies are small files which are downloaded to your device when accessing our platform. Most web browsers automatically accept cookies. Please refer to paragraph 5 below for further details about our use of cookies. Preference data This includes any information you choose to provide us, such as your musical preferences relating to genres and artists. Payment data When you purchase a subscription or any in-app content, you provide our payment processor with your payment information. We do not store such information on our servers.


We use your personal data in the following ways:

Data we use: Purpose: Lawful Basis: Contact Data To respond to communications that you send to us Necessary for the performance of a contract where such communication relates specifically to our Services, otherwise legitimate interests so that we can respond to your query To market products and services to you only where you have requested that we do so, or otherwise provided your explicit consent (either via our website, by emailing us or by accepting push notifications on your device) Consent Customer relationship management ("CRM") purposes Necessary for the performance of a contract To enable social functionality, such as giving you the option to follow your contacts on the Platform. Consent Account Data To enable you to personalize your use of our services;To enable you to save and maintain your profile and administer your account with us; andTo enable us to identify you. Necessary for the performance of a contract Correspondence Data To help address issues you raise with us and to improve the Platform and our services. Legitimate interests User Content To enable you to use our Platform and services Necessary for the performance of a contract To share the User Content with other users of the Platform by making it available on the Platform. Legitimate interests Session Data To administer, maintain and improve the Platform and our services, including identifying you or your device across our Platform and apps.To identify and respond to potential risks to the security of our Platform (for example spammers, phishing attempts, screen scraping and other actions which may violate our Terms of Use). Legitimate interests Preference Data To infer your interests, including serving and suggesting content that you might like, and tailoring advertising to you based on such preferences. Legitimate interests.


1. By using our Platform, you consent for us to store your personal data in line with legal, regulatory, financial and good-practice requirements.

2. The period for which we may retain your personal data will depend on the type of personal data collected, the purposes for which it was collected, applicable limitation periods for the exercise of legal rights and whether any legal or regulatory obligations require the retention of the personal data.


1. We use cookies and other software development kits ("SDKs") and third-party libraries. Our Platform uses the following categories of cookies:

Strictly necessary cookies These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to load webpages. Analytical/performance cookies These cookies allow us to recognize and count the number of visitors to our Platform and to see how visitors move around our Platform. This helps us to improve the way our Platform works, for example, by ensuring that visitors arefinding what they are looking for easily. Functionality cookies These are used to recognize you when you return to our Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Tracking ID Every iOS and Google Android device has a unique Tracking ID, for iOS devices, called an Identifier for Advertising (IDFA) and for Android devices, called a Google Advertising ID (AAID). These Tracking IDs enable app providers andadvertisers to track user activity and target ads at those users. 2. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

3. You may block cookies by updating the relevant settings on your device or browser to allow you to refuse the setting of some or all types of cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site.


We may need to share your personal data with selected third parties in the following circumstances:

Group companies We are an international organisation, with businesses both inside and outside of the European Union ("EU"). When you create User Content you will be asked if you'd like to share such User Content with other users of our Platform who could be based both inside and outside of the EU. Third party service providers This may include providers of certain systems and services that we use to host, administer and maintain our Platform, including for example the servers used to host our Platform. Third party service providers for marketing purposes If you explicitly consent to any marketing from us, certain personal data may be shared with third party service providers we use to help us carry out marketing including, for example, third party marketing automation platforms. To comply with legal or regulatory requests If we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency. Prospective buyers or sellers If Drum Pad, or its owners, buys or sells any business or assets, we may disclose your personal data to the prospective buyer or seller of such business or assets. If Drum Pad (or substantially all of its assets) is acquired by a third party, your personal data held by Drum Pad, or within such assets, may be transferred to such third party.


1. We will not transfer your personal data outside of the EU, except as set out in paragraph 6 above, for example if we utilise cloud-based platforms to store personal data, which may involve use of geographically distributed data centres.

2. In the case of these extra-EU transfers, where the transfers are not to countries that provide an adequate level of protection, we will put in place appropriate safeguards to cover transfers of personal data including, for example, signing standard contractual clauses, relying on a Privacy Shield certification and/or data protection clauses adopted by the European Commission.

3. If there are any other circumstances which would require us to transfer personal data outside of the UK, we will seek your consent to transfer your personal data outside of the UK.


Our Platform may contain links to third party websites. If you follow a link to a third-party website, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.


1. We take data security seriously. We implement and maintain appropriate technical and organisational measures including resilient security systems and protocols to protect the personal data we store.

2. We have put procedures in place to deal with any suspected data security breach and will notify you and applicable regulator of a suspected breach where the breach may cause a risk to you.

3. Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal data to you.


As a result of us collecting and processing your personal data, you have the following legal rights:

a. To access personal data we hold on you; b. To request us to make any changes to your personal data if it is inaccurate or incomplete; c. To request your personal data is erased where we do not have a compelling reason to continue to process suchpersonal data in certain circumstances; d. To receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the personal data is based on:(i) your consent;(ii) our necessity for performance of a contract to which you are a party to; or(iii) steps taken at your request prior to entering into a contract with us and the processing is carried out byautomated means; e. To object to, or restrict, our processing of your personal data in certain circumstances; f. If we use your personal data for direct marketing, you can ask us to stop and we will comply with your request; g. If we use your personal data on the basis of having a legitimate interest, you can object to our use of it forthose purposes, giving an explanation of your particular situation, and we will consider your objection; h. To object to, and not be subject to a decision which is based solely on, automated processing (includingprofiling), which produces legal effects or could significantly affect you; i. If we are processing your personal data with your consent , you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to yourwithdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processinggrounds other than consent. You may do so by contacting us; j. To lodge a complaint with a data protection supervisory body, which at present, is the Information Commissioner's Office.


Our Platform is not intended for children (under the age of 13 or such higher age as required by applicable law). We do not knowingly collect or solicit any personal data or target interest based advertising to children and we do not knowingly allow children to register for or use the Platform. Children should not use our Platform or send us any personal data about themselves at any time. In the event that we learn that we have inadvertently gathered personal data from children, we will take reasonable measures to promptly erase such information from our records. If youbelieve that we might have information from or about a child, please contact us


Please review our Privacy Notice at


If you have any questions or comments about this Privacy Policy or your personal data, or if you want to exercise any of your rights, including as set out in paragraph 9 above, or you wish to withdraw your consent where we have stated we are processing your personal data based on your consent, then please contact our Data Protection Officer:

a. via e-mail at:;


1. Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

2. This Privacy Policy was last updated in March 2020.