Privacy Policy

Last Updated: 15th October 2022

1. General

  1. CLASS CARD (hereinafter “Listen2It”; “We” or “Us” which expression, unless repugnant to the context hereof, shall mean and include its successors, subsidiaries and assigns) is the owner and developer of Listen2It suite of audio content, distribution, marketing and advertising software and services along with the website at (“Listen2It Service” or “Service”). The Listen2It Service is used by Listen2It’s registered users (“User”) on their webpage, website, portal, mobile application, and/or platform (“Property”) enabling the end user (“End User”) of their Properties to listen to audio content and enables the Users to distribute and market audio and advertise via audio to their End Users. Listen2It also allows Users to advertise to their End Users with advertisements (“Advertisements”) provided by  third party advertisers (“Advertisers) integrated with the Listen2It Service.
  2. When we receive personal information, we maintain high ethical standards and take steps to handle such information in a responsible manner that is consistent with data protection laws, our core values and business objectives.
  3. This privacy policy (“Privacy Policy”) governs our privacy and data collection practices with respect to the data we collect from individuals who access and use our website available at ("Visitors"), our Users who use and register for the Listen2It Service and their End Users interacting with Listen2It Service. Each of the Users, End Users and Visitors shall also be referred to herein as “you” or “your”.
  4. This Privacy Policy will explain what information we may collect from our Visitors, Business Partners and their Users, how such information may be used or shared with others, how we safeguard it and how each of the aforementioned individuals may exercise their rights related to their Personal Data (as such term is defined below) in accordance with applicable data protection laws
  5. By using Listen2It Services and agreeing to this policy, You consent to our use of cookies in accordance with the terms of this policy.
  6. We may modify or update this privacy policy at any time at our sole discretion without prior notice. The revised Privacy Policy will go into effect immediately upon its implementation on our website You can check the “Last Updated” date above to see when the policy was last changed. Your continued use of the Listen2It Services constitutes Your consent to the contents of this Privacy Policy

2. Basis for processing data

Subject to applicable law, personal data we hold about you will be processed either because:

  1. The processing is necessary in order for us to perform our contractual obligations with you;
  2. You have consented to the processing for the specific purpose described in this notice;
  3. We (or our Advertisers) may require the use of cookies for advertising purposes, for which subject to applicable law requirements, your consent will be requested by our Users for whose Property you are the End User.
  4. The processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security;

3. Personal Data we collect

If you are a Visitor, User and/or End User of Listen2It Service, we may collect one or both of the following types of data from when you access or use the Listen2It Service, as applicable

  1. Aggregated, non-personal, non-identifiable data (“Non Personal Data”). We are not aware of the identity of the individual from whom the Non Personal data was collected. This may include, but not be limited to aggregated usage information; information about your activity on the Service for example audio listened to, ads shown and clicks; technical information transmitted by your device such as software and hard information for example type of device, browser being used, access times, website from which you accessed etc. collected in order to provide or enhance the functionality of Listen2It Service and for security and functionality purposes.
  2. If we combine Personal and Non Personal Data, the combined data will be treated as Personal Data as long as it is combined.
  3. We act as a Processor of End User's Personal Data that we process on behalf of our Users. We are considered to be the Controller of the Personal Data we collect from our Users and Visitors.
  4. Individual identifiable information that identifies or may identify an individual (“Personal Data”). The Personal Data that we collect and the reasons for processing such data are:
Personal Data Collected from Users and Visitors How is it used?
Service Information:

Information You provide when voluntarily seeking for information about our Services (e.g. through an web chat or online form or via email or on our website). This may include but not limited to Your name, email address, phone number, job title, business name (if any), record and details of any correspondence or communication between you and us or relating to any complaint submitted to us

Solely for the purpose of responding to your inquiry and providing with support or information that you requested. We may retain the records and details of any correspondence with you for as long we find it necessary, as per applicable law
User Registration Information:

Information provided by You when signing up to be a User of our Services (including log-in details and personal contact information like your name, email address, phone number, job title and business information, if applicable) and other information we require in order to provide our services to You.

To provide the Services and designate your account.

Your contact details will be used in order to send you needed information related to our Services and our business engagement and additional occasional communications and updates related to the Services, as well as provide you with tips related to our Services, and promotional and marketing communication.

We may also use the information in order to verify your identity, including by sending you a text message for password verification purposes.

Payment Information:

information provided relating to payment, but please note that this information may be supplied directly to a third party payment processor who will process the data in accordance with their own privacy notices or policies (see below)

To pay for the use of Services or receive any payment from the use of advertising related Services
Marketing Information:

information you provide when you sign-up to our newsletter or ask or agree to receive information relating to our products and services such as your name, phone number, email address, date of birth and service or product preferences.

You can unsubscribe at any time using the unsubscribe option within the body of the applicable email correspondence or by contacting us directly.

For promoting and marketing our products to you.

We use Freshdesk CRM for email marketing services. Please review Freshdesk’s privacy policy at for more information

IP and Technical Data:

When you access or use our website and/or Service we may collect online identifiers (for example IP Address), resources you access, functionality you use, as well as Non-Personal Data (for example browser type, operating system type, access time, approximate geographical location)

We use this data for our legitimate interests of

  1. Administering, operating, providing, testing, troubleshooting, maintaining, protecting, managing, customizing, supporting and improving our Service and the way in which we offer it
  2. Enhancing your experience
  3. Auditing and tracking usage data and traffic flow
  4. Protecting the security of our Services

We obtain consent, as per applicable law, when we use third party cookies on our website (if required)

Personal Data Collected from End Users How is it used?
IP and Technical Data:

When you access or use our Service we may collect online identifiers (for example IP Address, Advertising ID and IDFA), resources you access, functionality you use, as well as Non-Personal Technical Data (for example browser type, operating system type, access time, approximate geographical location). We may also assign a unique ID to your browser.

We use this data for our legitimate interests of

  1. Administering, operating, providing, testing, troubleshooting, maintaining, protecting, managing, customizing, supporting and improving our Service and the way in which we offer it
  2. In some cases to provide End Users with personalised Advertisements.
  3. Enhancing your experience
  4. Auditing and tracking usage data and traffic flow
  5. Calculating payments related to the Services to our Users.

Where required under applicable law, we will require our Business Partner to obtain your consent to collect such data and share it with us

4. How we collect data

  1. Depending on the nature of your access or use of the Service or the website we may collect data 

    i. Voluntarily, when you choose to provide us with information;

    ii. Automatically including via cookies (see below) and other similar tracking technologies.
  2. We may obtain data from third parties from time to time. If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
  3. We will not collect any sensitive personal data without your prior consent. By sensitive personal data we mean data which falls within certain ‘special categories’ which are defined in the EU General Data Protection Regulation - GDPR (e.g. health data) and which require additional protection and consent measures.
  4. You do not have to supply any personal information to us but our services may not be operable without providing data to us.
  5. We will seek consent to collect your Personal Data. You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time as per applicable law but we may need to withhold some personal data for legal or other reasons

5. Cookies

  1. A “cookie” is a small piece of information that a website or service assigns to your device while you access such a website or service. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising).
  2. We or our third-party affiliates (including Advertisers) may use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with the Technology and website, as applicable.
  3. Cookie Opt Out

    i. Once you close your browser, our access to the cookie terminates.

    ii. You can change your cookies settings at any time to control cookie placement through limiting or forbidding the website under which we provide the Services to place cookies on your device and to disable unwanted cookies already stored on your device, by changing your browser’s privacy preferences (please visit the help pages of your web browser). Please note, however, that if you disable cookies or refuse to accept them, you might not be able to use all of the features we offer or some of the features may not function properly. You may not be able to store your preferences and some of our pages might not display properly. We may, at our sole discretion, delete old cookies after a certain time which no activity had occurred from a User or End User. Your web browser allows you to manage the cookies and your choices. Please visit the help pages of your web browser to find out about the same.

    iii. Our affiliates (including our Users and Advertisers) may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to their respective privacy policies. Please note, however, that we are not responsible for their privacy practices and of other third parties.
  4. The third party cookies used in our website and Service are as follows:

Third Party


Privacy Policy

Google Analytics

Analytics and performance measurement

Zoho CRM

Marketing and support

Zoho Chat

Customer Engagement


Analytics and performance measurement


Payment Services


Payment Services


Website Hosting Services


Analytics and performance measurement

Amazon Web Services

Technical Functionality

In addition to the above, our Service may include cookies placed by Advertisers, and will include our cookies required for functionality and operation of our website and Service, which expires every 12 months.

6. Sharing your information

  1. We do not disclose any personal data you provide to any third parties other than as follows:

    i. Payment Processors: we may provide payment information to our payment processing partner. If we take payment through a payment processing partner (as opposed to direct bank transfer), this information will be supplied to our payment processing partner directly, even if you provide the information while on our website or Service. Our payment processing partner will be the data controller for credit and debit card information.

    ii. Third Party service providers – we may disclose your Personal Data to third parties that perform services on our behalf (e.g. tracking, servers, service functionality and support, marketing, etc.). These entities may be located in a different jurisdiction than you and are prohibited from using your Personal Data for any purposes other than providing us with the requested services;

    iii. Hosting Providers: we may host personal data with third party hosting providers

    iv. Research: where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties;

    v. Policy Enforcement – we may share your Personal Data, solely to the extent needed in order to enforce our policies and terms including investigations of potential violations thereof, to establish or exercise our rights to defend against legal claims or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;

    vi. Third Party Rights – we may share your Personal Data, solely to the extent needed to prevent harm to the rights (including intellectual property rights and other legal rights), property or safety of us, our Visitors, Users  and their End Users, yourself or any other third party.

    vii. Online Identifiers - we may share Online Identifiers with our Users and Advertisers for the purpose of the Services, as well as to detect fraud and calculate payments

    viii. Legal Obligations: if we are under a duty to disclose or share your personal data in order to comply with any applicable law, regular, legal obligation, legal process or governmental request.

    ix. Affiliated Companies and Corporate Transaction– we may share your Personal Data with a parent company, subsidiaries, joint ventures, or other companies under common control with the Company ("Affiliated Companies") solely if and when applicable or necessary. In addition, we may share information, in the event of a corporate transaction (e.g. sale, merger, consolidation, etc.), provided however, that our Affiliated Companies or acquiring company will be subject to the obligations detailed herein with respect to your Personal Data.
  2. Our payment processing partner and other third parties to whom we provide your personal data will have their own privacy policies and notices, but we will take steps to ensure that they are compliant with applicable data protection legislation and we will consult with them in relation to maintaining the security of payment information.
  3. Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

7. Third Party Collection of Data

Our Privacy Policy only addresses the use and disclosure of Personal Data that we collect from you. To the extent that you disclose your Personal Data to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other websites throughout the internet, different rules may apply to their use or disclosure of the Personal Data you disclose to them and your Personal Data will be subject to that third-party's privacy policy.

You acknowledge that we are not responsible for third party’s privacy practice related to or integrated with our Service, including Users and Advertisers, and that this Privacy Policy does not apply to any such third-parties’ privacy practices. We strongly advise you to learn about the privacy practices of each website that you may visit before providing any Personal Data to such website

8. Your Privacy Rights

Data protection and privacy laws may provide you with some of the following rights (depending on your jurisdiction) with respect to your Personal Data, which you may be able to exercise:

  1. The right to access your Personal Data;
  2. The right to ensure your Personal Data is accurate, complete and up to date;
  3. The right to have your Personal Data amended (by correcting, deleting or adding information);
  4. The right to object to the processing of your Personal Data;
  5. The right to send or “port” your Personal Data;
  6. The right to file a complaint with a supervisory authority in your jurisdiction; and
  7. The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;

In the event that you contact us and request to exercise any of the rights included above, we may request that you provide us with certain information in order to verify your identity and locate your data. This may take some time, subject to applicable privacy laws.

Please note that you may have different rights than those which we listed above depending on the applicable privacy protection laws in your jurisdiction.

If you wish to exercise any or all of the above rights, please reach out to us in writing at Please feel free to contact us as well if you wish to receive more information or you would like to raise a complaint with respect to how we may have handled your Personal Data. If you are not satisfied with our response or believe we are collecting or processing your Personal Data not in accordance with the applicable data protection laws in your jurisdiction, you may also have the right to submit a complaint with the applicable data protection authority in your jurisdiction

9. Data Retention

We retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless you instruct us otherwise). We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

10. Email and other marketing communication

  1. We may send our newsletter, information about our goods and services or information about similar goods and services to our Users who have registered to receive it and others who have expressly consented to receive such communication (for example by signing up for our newsletter). We will identify the nature of the message and the sender clearly.
  2. You can remove your Personal Data from our mailing list and stop receiving promotional communications from us by following the unsubscribe link located at the bottom of each communication.
  3. As a User, please note that we will still reserve the right to send you service-related communications, including service announcements and administrative messages that relate either to your account or to your transactions with the Services, even after you have chosen to unsubscribe from receiving our newsletter. You will only be able to opt out of receiving such messages by terminating and deleting your account with us. If you wish to delete your account, please contact us at It is important that you are also aware, that we will still need to retain some of your Personal Data as required under applicable law or for the legitimate purpose of our business, even after you have chosen to delete your account

11. Data Protection

We take great care in implementing and maintaining the security of the Services and your data. We employ physical, technical and administrative security measures that we believe comply with applicable laws and are in line with industry standards. We have instituted a variety of procedures and policies to ensure the safety of your data, and prevent unauthorized use of any such data. 

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

If you feel that your privacy was not treated in accordance with our Privacy Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at Additionally, we will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data

12. Data Storage

We currently use Amazon Web Services (AWS) as a cloud and storage service provider. AWS's terms of service are available here: and its privacy policy is available here:

13. International Transfer

We provide Services worldwide and therefore, it may be necessary for us to transfer data, including Personal Data, to countries outside of your jurisdiction, including outside European Economic Area ("EEA"), where applicable. In these instances, we will take steps to ensure that a similar level of protection is given to your Personal Data, including through adequate contractual measures, as shall be required under applicable laws.

14. Do not track

Our website does not respond to Do Not Track signals.

15. Children

The website and Services are not directed or meant to be used by children (the phrase "child" shall mean as such term is defined under applicable law or an individual that is less than 18 years old). If you are under 18 years old, you should not access the website, use the Services, or provide any Personal Data to us.

We will immediately discard any Personal Data that we discover has been shared with us by a child. Please contact us immediately at: if you have any reason to believe that a child has shared any Personal Data with us.

16. Contact Us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: