Legal
Privacy Policy
Universal Music Group International Limited operates Sollos, an audio-wellness service designed to support focus, relaxation and sleep. This Privacy Policy explains how Sollos collects, uses, shares and protects personal data when you use the Sollos app, visit a Sollos website, communicate with us, or choose to connect supported third-party services.
This Policy applies to the ordinary operation of Sollos. Where Sollos is used as part of a formal research study, additional participant information and consent materials may apply and will explain the study-specific processing.
1. Who we are
Sollos is operated by Universal Music Group International Limited, 4 Pancras Square, London N1C 4AG, United Kingdom ("UMGI", "Sollos", "we", "us" or "our"). UMGI is the controller of personal data processed through Sollos unless we tell you otherwise.
Other Universal Music Group companies may support Sollos by providing technology, security, analytics, legal, privacy, customer-support or other internal services. Where another UMG entity acts as a separate controller for a specific activity, we will provide any additional information required by law.
2. How to contact us
You can submit privacy questions and requests through UMG's Privacy Request Form. You may also contact UMG's Data Protection Officer by writing to: Universal Music Group, Attn: Data Protection Officer, 2220 Colorado Avenue, Santa Monica, CA 90404, USA.
For non-privacy questions about Sollos, please use the customer support or FAQ contact channel made available in the app or on the Sollos website.
3. Personal data we collect
Depending on how you use Sollos and the features you enable, we may collect the following categories of personal data:
| Category | Examples | How we obtain it |
|---|---|---|
| Account and contact information | Nickname; email address; account or user ID; country or billing country; support correspondence. | Directly from you when you create or manage an account, contact us, or request support. |
| App and device information | Network information; device identifiers; device and hardware information; app and operating-system version; language and time zone; derived or approximate country/location; error, performance and diagnostic information. | Automatically from your device and through the technologies used to operate and secure Sollos. |
| Usage and listening information | Content selections; listening time and duration; in-app behavioural events; feature interactions; session and usage statistics. | Automatically when you use the Sollos app. |
| Wellbeing and feedback information | Responses you choose to provide about focus, relaxation, sleep, mood or other wellbeing experiences, including responses provided before or after listening and periodic responses collected over time to help assess changes or trends in wellbeing; feedback about the perceived impact of a listening session; app experience or feature feedback. | Directly from you through optional in-app prompts, check-ins, questionnaires or feedback features. You can use Sollos without providing this information, although some features may not be available. |
| Apple Music information, if you enable the integration | Information from your Apple Music library and listening activity that Sollos uses to provide music features and recommendations, such as music in your library, recently played or frequently played content, and information needed to add or manage music in your library. | From Apple through MusicKit only after you choose to connect Apple Music and grant the requested permission. |
| Apple Health information, if a Health feature is enabled | Health or wellness information specifically identified in the permission request, which may include heart rate, resting heart rate, heart-rate variability, respiratory rate, or sleep-related information. | From Apple Health only after you separately enable the feature and grant the requested permission through Apple's Health permissions interface. Sollos does not currently retain Apple Health data after it is used to provide the enabled feature. |
| Marketing and attribution information | Advertising or device identifiers and limited campaign or attribution information used to understand how users discover or engage with Sollos. | From the app, attribution providers and advertising platforms, subject to applicable consent requirements and the configuration of the relevant service. |
We do not ask you to provide medical records or a clinical diagnosis through the ordinary Sollos service. However, depending on the questions asked and how you respond, some wellbeing information may reveal information about health and may therefore receive additional protection under applicable data-protection law.
4. How we use personal data
- Provide and administer Sollos: Create and manage accounts; deliver content and features; manage access; respond to support requests; send service notices; and maintain the service.
- Personalise and improve the service: Understand use of Sollos, improve content and product features, develop recommendations or personalised experiences, conduct testing, analytics and product research, and measure performance.
- Support wellbeing features: Process wellbeing or feedback information you choose to provide so that the relevant feature can operate and, where appropriate, tailor the Sollos experience.
- Communicate with you: Send requested or permitted service, support, product and marketing communications. You can opt out of direct marketing at any time.
- Measure marketing and acquisition: Understand which campaigns or channels lead users to Sollos, measure advertising effectiveness and improve marketing efficiency, where permitted by law and subject to applicable consent requirements.
- Security and integrity: Protect Sollos, UMG systems and users; detect, investigate and prevent fraud, misuse, security incidents and other unlawful activity.
- Legal and business purposes: Comply with legal obligations, enforce our terms, resolve disputes, protect rights and safety, and support corporate transactions where permitted by law.
- Create anonymous or aggregate information: Create data that no longer identifies individuals for analytics, product development, research, reporting and other lawful business purposes.
- We do not use personal data collected through Sollos to train artificial-intelligence or machine-learning models for predicting sales, marketing or advertising outcomes unless we separately tell you and have a lawful basis to do so.
5. Research
Sollos may be used in research studies conducted or supported by UMG or academic collaborators. Formal research may involve different data, purposes, retention periods, access arrangements and legal bases from the ordinary Sollos service. Where you are invited to take part in a study, the relevant participant information and consent materials will explain those study-specific details.
We may also create anonymised or aggregated information from Sollos data for research, analysis and publication. We will not publicly disclose participant-level personal data as part of a research publication.
6. Our legal bases for processing
If UK or European data-protection law applies, we rely on one or more of the following legal bases, depending on the activity:
| Legal basis | When we may rely on it |
|---|---|
| Contract | Where processing is necessary to provide the Sollos service or a feature you request, including account management and core service delivery. |
| Legitimate interests | Where necessary for interests such as product analytics and improvement, service security, fraud prevention, support, business administration and limited marketing measurement, provided those interests are not overridden by your rights and interests. |
| Consent | Where we ask for permission, including for optional integrations, certain marketing or advertising technologies, and other activities where consent is required. You may withdraw consent at any time. |
| Legal obligation | Where processing is necessary to comply with law, regulation, court orders or other binding legal requirements. |
Special-category data: if information you provide through ordinary Sollos features constitutes health data or another category of special-category personal data under UK/EU law, we will process it only where an applicable Article 9 condition is satisfied. Where required, we will obtain your explicit consent before that processing and you may withdraw that consent at any time.
7. How we share personal data
We may share personal data only as reasonably necessary for the purposes described above, including with:
- UMG companies that provide technology, infrastructure, security, privacy, legal, analytics, finance, operational or other support to Sollos;
- service providers that host or support the app and backend systems, customer communications, analytics, diagnostics, customer support, attribution, security and related functions;
- Apple or other third-party services that you choose to connect, where needed to enable the integration;
- advertising and attribution partners, but only to the extent Sollos actually uses those services and subject to applicable consent, platform and legal requirements;
- professional advisers, regulators, law-enforcement authorities, courts or other parties where disclosure is required or permitted by law; and
- a purchaser, investor, successor or other relevant party in connection with a proposed or completed merger, acquisition, financing, reorganization or sale of all or part of a business.
We do not sell personal data for money. If an activity is treated as a "sale," "sharing" or targeted advertising under an applicable U.S. state privacy law, we will provide the choices required by that law.
8. Analytics, advertising and attribution
Sollos uses analytics and attribution tools to understand how the service is used and how users discover Sollos. These tools may process device, user, usage, campaign and advertising identifiers. Where required by law, we will obtain consent before using non-essential tracking or advertising technologies.
Sollos may work with advertising platforms such as Google, Meta or TikTok for campaign measurement or audience-related activities only where the relevant implementation has been approved and is operated in accordance with applicable law, consent requirements and platform rules. The exact data made available to an advertising platform depends on the feature in use.
9. Optional third-party integrations
If you choose to connect Sollos with a third-party service, such as Apple Music or Apple Health, we will receive only the information that the relevant integration makes available and that you authorise. You can manage or revoke those permissions through the relevant third-party service or your device settings. The third party's own terms and privacy practices also apply to its processing.
10. Retention
We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, including to provide Sollos, maintain appropriate business and security records, resolve disputes, enforce agreements and comply with legal obligations. Retention periods may vary by data type and system. When personal data is no longer needed, we will delete it or take steps to de-identify it, subject to lawful retention requirements.
If you close your Sollos account, we will begin the account-deletion process in accordance with our applicable procedures, but some information may remain for a limited period where required for security, legal, financial, backup or dispute-resolution purposes.
11. International transfers
Sollos is operated from the United Kingdom and may use UMG companies and service providers in other countries. As a result, personal data may be accessed from or transferred to countries outside the United Kingdom or European Economic Area.
Where UK or European transfer restrictions apply, we use an approved transfer mechanism or another lawful safeguard, such as an adequacy decision, the UK International Data Transfer Agreement or Addendum, or the European Commission's Standard Contractual Clauses, as applicable. We also assess and apply supplementary measures where required.
12. Security
We use technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. No system can be guaranteed to be completely secure, but we regularly review appropriate safeguards for the nature of the service and the information processed.
13. Age restrictions
Sollos is intended for users aged 16 and over. We do not knowingly permit children under 16 to create an ordinary Sollos account. If we learn that personal data has been collected from a child contrary to this requirement, we will take appropriate steps to address it.
14. Your privacy rights
Depending on where you live, you may have rights in relation to your personal data. These may include rights to access, correct, delete, restrict or object to processing, receive a portable copy of certain data, withdraw consent, and opt out of certain marketing, targeted advertising, sale or sharing activities.
You may exercise applicable rights through UMG's Privacy Request Form. We may need to verify your identity before completing a request. You also have the right, where applicable, to complain to a data-protection authority. In the United Kingdom, this is the Information Commissioner's Office.
If we rely on legitimate interests, you may have the right to object to that processing. You always have the right to opt out of direct marketing communications.
15. Automated decision-making
We do not currently make decisions about you based solely on automated processing that produce legal effects or similarly significant effects on you through the ordinary Sollos service.
16. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. If we make a material change, we will provide notice in a manner appropriate to the change and required by applicable law, for example through the app, our website or by email. The effective date at the top of the Policy indicates when the current version takes effect.