Privacy Policy

LEGAL

Last updated: August 2026

Introduction

MANTRA RAY LLC (“Company”, “we”, “our”, or “us”) understands that privacy is important to our users.This Privacy Policy describes our practices regarding the collection, use, sharing, and protection of your personal data for the website located at stereopool.io (the “Website”), the Stereopool app (the “App”), and any other services provided by us or our affiliates which are not covered by a separate privacy policy (the “Services”). This Privacy Policy also tells you about the rights and choices you have with respect to your personal data, how you can assert those rights, and how you can contact us to get answers to your questions. For the purposes of this Privacy Policy, the terms “you,” “user,” “consumer,” “individual,” and “data subject” are used as appropriate for the relevant legal framework and all refer to the person whose personal data is processed.

Please note that our privacy practices are subject to the applicable laws of the regions in which we operate. Accordingly, some additional region-specific terms will only apply to individuals in those locations, or as required by applicable laws.

For more information about how users with disabilities can access this Privacy Policy in an alternative format, please contact us at support@stereopool.io.

BY USING OR ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE

WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE SERVICES OR PROVIDE US

WITH ANY PERSONAL DATA.

This website is operated by Mantra Ray LLC ("we," "us," or "our"). By accessing or using this website, you agree to these Terms of Use. If you do not agree, please do not use the site. These terms apply to the Stereopool marketing website only, not to any future app or platform services, which will be governed by separate terms.

PERSONAL DATA WE COLLECT FROM YOU

This Privacy Policy applies to the personal data that we obtain in various contexts. We use the term “personal data” – also called “personal information” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal data.

The following are the categories and types of personal data that we may collect from or about you, depending on how you interact with the Services:

Identifiers and contact information, such as your name, date of birth (for age verification), email address, username, and device identifiers;
Audio information, such as audio recordings and files you upload, including associated metadata (titles, descriptions, format tags, cover art, and transcripts);

• General geolocation information derived from your IP address;

Social graph and interaction data, including follows, collects, comments, and in-App notifications;
Profile information you optionally provide, such as display name, bio, website URL, and avatar image; and
Any other personal data that you voluntarily provide us.

All content on this site — including text,

graphics, design, audio, and branding — is owned by or licensed to Mantra Ray LLC and protected by applicable intellectual property laws. You may not reproduce, distribute, or use any site content without our prior written permission.

HOW WE COLLECT YOUR PERSONAL DATA

Personal Data You Provide

We collect personal data that you provide to us directly. This may include, but is not limited to:

Information you provide when you contact us via email or through other Internet-enabled communications;
Information you provide when you register to use our Services, create a profile or account, or subscribe to one of our Services;
Content that you post to the Services;
Your responses to surveys that you choose to complete for us;
Information you provide when you enter a contest or other promotion sponsored by us;
Any other information that you provide us on or through the Services.

Personal Data We Collect Automatically

When you use our Services, we or third parties we work with may automatically collect certain

information. The App is a native mobile application and does not operate in a browser context,

therefore the App does not use traditional web cookies. Instead, we use on-device local storage and server-side collection as described below.

Local Device Storage: Because the App is a native mobile application, we do not use browser
cookies. Instead, the App uses on-device local storage, which involves strictly necessary and
functional/caching cookies being stored locally on your device.

Aggregate Analytics: We collect aggregate play counts on a per-track basis (a counter of total plays per audio track, not a per-user listening history). Separately, we record information about your listening activity, such as the tracks you play, in association with your account, and use it to operate, personalize, and improve the Services.

Session Replay Software: We employ session replay software, which is a digital tool that
reconstructs your sessions using data from your device, such as clicks and scrolls. Our session replay software is configured by default to mask all text content and to block media elements such as images and videos, before any data is transmitted to our third-party vendors. We use this information to better understand user behavior, diagnose problems, and make improvements to our Services. We do not use this information to track you for purposes of advertising or marketing. By using our Services, you understand that we or our third-party
vendors may collect session information through session replay software.

Transcription: Audio you publish publicly is transcribed automatically to generate a text transcript. To do this, your audio is transmitted to a third-party speech-to-text provider that operates a zero-retention policy: it does not store your audio after processing and does not use it to train models. Audio you keep private is transcribed on your own device using your device's built-in speech recognition, and is never transmitted to us or to any third party for this purpose. You may write your own transcript instead, in which case no automatic transcription takes place.

From Other Sources: We may use an AI-powered recommendation feature that processes
certain data to generate content suggestions for you. We do not otherwise obtain personal data about you from third-party sources for advertising or marketing purposes.

This site includes an open call page where users may submit audio recordings for potential use in Stereopool's marketing. By submitting a recording, you agree to the terms presented at the point of submission, which include the following:

You grant Mantra Ray LLC a free, non-exclusive, irrevocable, royalty-free license to use, share, edit, modify, adapt, and publish your submission

across social media channels and all other channels, media, formats, and platforms for marketing purposes.

You confirm that you own or have the right to submit your audio and grant these rights. You retain ownership

of your recording. You confirm you are 18 years of age or older.

We reserve the right to reject, remove, or decline to use any submission at our sole discretion.

HOW WE USE YOUR PERSONAL

We collect and use personal data for the following purposes:

To communicate with you, which may include:
- Contacting you about and providing you with our Services;
- Responding to your direct inquiries, requests, issues or feedback, and providing customer service;
- Adding you to our mailing lists and sending you emails from time to time;

To provide our products and services, which may include:
- Operating the Services, and providing you with any specific services that you have requested;
- Creating, maintaining, and otherwise managing your account, profile, or subscription;
- Delivering content and audio recommendations relevant to your interests;
- Enabling users to upload and share audio content, post comments, and interact with other users’ content;

For analytics and personalization, which may include:
- Identifying trends and understanding how users interact with the Services;
- Conducting research and analytics to improve our services and product offerings;
- Understanding how you interact with our Services to determine which features are most
  popular and to improve the App;
- Personalizing your experience, including generating AI-powered content recommendations;
- Providing personalized audio content recommendations;

For security and fraud prevention, which may include:
- Helping maintain the safety, security, and integrity of our Services, databases and other technology assets, and business;
- Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity;
- Investigating suspected fraud, harassment, or other violations of any law, rule, or regulation,or the policies for our Services;

To comply with legal obligations, which may include:
- Establishing or exercising our rights and defending against legal claims;
- Responding to law enforcement requests and as required by applicable law, court order,
  legal process, or governmental regulation;
- Acting in connection with a bankruptcy proceeding or the sale, merger, or change of control of the Company or the division responsible for the services with which your information is associated;

• For any additional purposes that you specifically consent to.

We may collect information that is not personal data (“non-personal data”), including anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal data does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal data with personal data. If we combine any non-personal data with personal data, the combined information will be treated by us as personal data to the extent that it is capable of personally identifying you.

When using this site you agree not to: submit content you do not own or have rights to; submit content that is unlawful, defamatory, obscene, or harmful to others; attempt to disrupt or interfere with the site's functionality; or use the site for any commercial purpose without our written consent.

HOW WE DISCLOSE OR SHARE YOUR PERSONAL DATA

In addition to using your personal data ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal data to other affiliates and entities in the following instances:

Service Providers: We may share your personal data with third-party service providers who may use your information to provide us with services including, but not limited to: app hosting providers, data analytics services, infrastructure provision, information technology services (including third party AI-platforms), email delivery services, auditing, and anti-fraud monitoring. These service providers may have access to personal data that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

Legal Compliance and to Defend Our Rights: We may disclose personal data and other information as we believe necessary or appropriate: (a) under applicable law, including laws
outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Business Transfers: We may share your personal data and other information with third parties
in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Services.

Non-Personal Data: We may share non-personal data, such as aggregate play counts and usage
statistics, with unaffiliated third parties to improve and enhance your experience using the
Services and for our own research activities. We publicly commit to maintain and use the
information in deidentified or aggregate form, and not to attempt to re-identify the information.

Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.

Your use of this site is also governed by our Privacy Policy, which describes how we collect and handle data including analytics and cookies. By using this site you consent to those practices.

THIRD PARTY LINKS

We may create links to other websites that we think may be of interest to you. We do not endorse any other websites, providers, or services by providing such links, and this Privacy Policy applies only to your use of our Services. We are not responsible for the privacy policies of any websites and services we link to on our Services, and you should read the privacy policies of each site you visit to determine what data that site may collect about you. You should be aware that any personal data which you voluntarily include and transmit online in a publicly accessible blog, forum, social network, or otherwise may be viewed and used by others. By using such features, you assume the risk that the personal data provided by you may be viewed and used by third parties.

This site may contain links to third-party websites. We are not responsible for the content, privacy practices, or terms of any third-party sites and linking does not imply endorsement.

HOW WE PROTECT YOUR PERSONAL DATA

Personal data is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this Privacy Policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by using the information in the section below titled Contacting Us.

DATA RETENTION

We will retain your personal data for as long as your account is active or as needed to provide you with the Services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. You may delete your account at any time through a self-serve "Delete Account" flow available in Settings and on your profile screen. When you do, we delete your profile, audio content and cover images, comments, collects, follows, mixtapes, listening history, and push notification tokens. Content reports you submitted are retained for safety and moderation purposes with your identity removed, and a released username may be held briefly before it becomes available to others again. We may continue to retain and use anonymous or aggregate data that does not identify you. Certain third-party services

(such as Sentry error logs and email-provider logs) may retain residual data for a limited time after account deletion in accordance with their own retention policies.

To the fullest extent permitted by law, Mantra Ray LLC shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from your use of — or inability to use — this site or any content on it.

YOUR CHOICES

Consistent with applicable law, you may exercise the choices described in this section regarding your personal data and communications from us. You may also have certain additional rights available depending on laws in your state or country of residence, as described further below in the Privacy Policy.

Opting Out of Messages: We may send you marketing messages via email. If you receive a marketing message from us, you may unsubscribe from future messages in accordance with our
standard unsubscribe process (such as by using the unsubscribe link included in an email), or by sending an unsubscribe request to us at support@stereopool.io. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our services may no longer be available to you.

Notification Controls: You may control which notifications you receive through in-app settings, including a master toggle and per-type toggles (for collects, comments, and followers). Your notification preferences are stored both on-device and server-side. Disabling push notifications will also remove your push token from our servers.

Content Visibility: You can control the visibility of your profile (public or private) and set individual audio tracks to public or private. Profiles are public by default with a private option; content is public by default with a per-track private option.If you set your profile to private, other users must request to follow you and you decide whether to approve each request. You may also grant specific individuals access to an individual private track. Access can only be granted to users with whom you have a mutual follow relationship, and you separately control whether those users may collect a copy of that track; collecting is off by default.Turning off collects prevents new collects but does not remove previous collects.

Account Deletion: You may delete your account at any time using the self-serve “Delete
Account” option available in Settings and on your profile screen. Deleting your account will
permanently remove your profile, uploaded audio content, collects, comments, follows, reposts, and push tokens from our systems.

Access and Correction: You can access and edit your profile information at any time through the App. Profile fields including display name, background, bio, website URL, and avatar image are user-editable.

EUROPEAN PRIVACY RIGHTS

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM,

THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND

ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

References to the “GDPR” throughout this section include, as applicable: the EU General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and the GDPR as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018; and the Swiss revised Federal Act on Data Protection, SR 235.1, effective September 1, 2023.

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM,THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND

ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Legal Basis

We will only use your personal data, as that term is defined under the GDPR, when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where you have consented to a certain use of your personal data.
Where we need to comply with a legal or regulatory obligation.

Data Controller

MANTRA RAY LLC is the data controller of all personal data collected through our Services. To contact us, please see the section of the Privacy Policy titled Contacting Us.

We may update these Terms from time to time. When we do, we'll update the "Last updated" date at the top of this page. Continued use of the site after changes constitutes your acceptance of the revised Terms.

Provision of personal data and failure to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Withdrawing your consent

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at support@stereopool.io.

Data Transfer

We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Where we use certain vendors, we may use specific contracts approved by the European Commission or the UK Secretary of State which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at support@stereopool.io.

Use of your personal data for marketing purposes

We may use your personal data for marketing purposes, including to form a view on what we think may be of interest to you, and to decide which products, services, and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or used our services and, in each case, if you have consented to our use of your personal data for marketing purposes.

Automatic Decision-Making and Profiling

We do not currently make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects concerning you.

Data Subject Rights

If you are situated in the EEA, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the
accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below); where we may have processed your information unlawfully; or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Lodge a complaint with a supervisory authority. If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance.

To exercise your rights under the GDPR or to submit a complaint regarding our privacy practices, please contact us at support@stereopool.io. Please note that in order for you to assert your data subject rights, we may need to verify your identity. This is a security measure to ensure that your personal data is not wrongfully modified or deleted, or disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

CROSS-BORDER DATA TRANSFERS

If you submit personal data to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal data to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Where applicable, we may use model clauses approved by the laws of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for cross-border data transfers.

CHILDREN'S PRIVACY

Our Services are intended for users ages 16 and over, and we do not knowingly collect personal data from children under the age of 16. When we become aware that personal data (or other information that is protected under applicable law) from a child under 16 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal data from or about a child under 16, please contact us by using the information in the section below titled Contacting Us.

CHANGES TO THIS POLICY

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the Website for the latest information on our privacy practices. Your continued use of the Services following the posting of any changes to this Privacy Policy means you accept such changes.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

MANTRA RAY LLC

support@stereopool.io

stereopool

stereopool