˜ PRIVACY POLICY
Tugboat Music, LLC
Last Updated: May 2026
We at Tugboat Music, LLC understand that your privacy is important to you. We are committed to protecting the privacy of your personally-identifiable information as you use this website. This Privacy Policy tells you how we protect and use information that we gather from you. By using this website, you consent to the terms described in the most recent version of this Privacy Policy. You should also read our Terms of Use to understand the general rules about your use of this website, and any additional terms that may apply when you access particular services or materials on certain areas of this website. "We," "our" means "Tugboat Music, LLC" and its affiliates. "You," "your," "visitor," or "user" means the individual accessing this site.
PERSONAL AND NON-PERSONAL INFORMATION
Our Privacy Policy identifies how we treat your personal and non-personal information.
What is Non-Personal Information and How is it Collected and Used?
Non-personal information is information that cannot identify you. If you visit this web site to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer's web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information.
What is Personal Information and How is it Collected?
Personal information is information that identifies you as an individual, such as your name, mailing address, e-mail address, telephone number, and fax number. We may collect personal information from you in a variety of ways:
· When you send us an application or other form
· When you conduct a transaction with us, our affiliates, or others
· When we collect information about you in support of a transaction, such as credit card information
· In some places on this web site you have the opportunity to send us personal information about yourself, to elect to receive particular information, to purchase access to one of our products or services, or to participate in an activity
COOKIES AND TRACKING TECHNOLOGIES
Yes, we may use cookies and related technologies, such as web beacons, to collect information on our web site. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
A web beacon is a small graphic image that allows the party that set the web beacon to monitor and collect certain information about the viewer of the web page, web-based document or e-mail message, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to, and the time the web beacon was viewed. We may use web beacons to count visitors to the web pages on the web site or to monitor how our users navigate the web site, and we may include web beacons in e-mail messages in order to count how many messages sent were actually opened, acted upon or forwarded.
Third party vendors also may use cookies on our web site to track and analyze anonymous usage and volume statistical information from our visitors and members. Such information is shared externally only on an anonymous, aggregated basis.
Cookie Opt-Out
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Tugboat Music, LLC websites you visit.
In addition to browser-level controls, where technically feasible, we will provide a cookie preference tool on this website so that you may opt out of non-essential tracking. Your option to decline tracking will be presented with equal prominence to the option to accept, in accordance with guidance from the New York Office of the Attorney General. Declining non-essential cookies will not affect your ability to access basic site content.
[NY AG Compliance Note: Cookie opt-out options must be as clear and accessible as opt-in options. Review and update your cookie banner or preference tool to ensure parity.]
HOW TUGBOAT MUSIC, LLC USES PERSONAL INFORMATION
Tugboat Music, LLC may keep and use personal information we collect from or about you to:
· Provide you with access to this web site or other products or services
· Respond to your requests
· Bill you for products/services you purchased, and to provide ongoing service and support
· Contact you with information that might be of interest to you, including information about products and services of ours and of others, or ask for your opinion about our products or the products of others
· Record keeping and analytical purposes, and to research, develop and improve programs, products, services and content
· Protect our rights or property, or to protect someone's health, safety or welfare
· Comply with a law or regulation, court order or other legal process
Personal information collected online may be combined with information you provide to us through other sources.
De-Identification of Personal Information
We may remove your personal identifiers (such as your name, email address, etc.) from your data. Once we have de-identified information, it is treated as non-personal information. When we de-identify personal data, we do so using reasonable technical and administrative measures designed to ensure that the information cannot be reasonably re-associated with you, such as aggregation, generalization, or suppression of identifying fields. De-identified data may be used for analytics, product improvement, or shared with third parties in aggregated, non-identifiable form.
[Compliance Note: This de-identification disclosure addresses emerging NY privacy guidance. Consult an attorney if your de-identification practices differ from the above description.]
DOES TUGBOAT MUSIC, LLC SHARE PERSONAL INFORMATION WITH OTHERS?
We will not share your personal information collected from this web site with an unrelated third party without your permission, except as otherwise provided in this Privacy Policy.
In the ordinary course of business, we may share some personal information with companies that we hire to perform services or functions on our behalf. These service providers include, but may not be limited to: email delivery providers, payment processors (such as credit card companies and banks), web analytics providers, and customer support platforms. In all cases in which we share your personal information with a third party for the purpose of providing a service to us, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.
We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition.
We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting web site visitors who violate our rules or engage in behavior which is harmful to other visitors or illegal.
If you submit a review for a third party (person or business) using our Facebook Fan Review Application, during the submission process we ask your permission to gather your basic information (such as name and email address) which we then share with the third party for whom you are submitting the review.
DATA SECURITY AND WRITTEN INFORMATION SECURITY PROGRAM
We have implemented a Written Information Security Program (WISP) consistent with the requirements of the New York SHIELD Act. Our security program incorporates administrative, technical, and physical safeguards appropriate to the size and complexity of our business and the nature of the personal information we handle. These safeguards include:
· Designation of an employee or employees responsible for coordinating our data security program
· Identification of internal and external risks to the security of personal information
· Assessment and improvement of safeguards to control identified risks
· Employee training on data security procedures and awareness
· Oversight of third-party service providers to ensure they maintain appropriate safeguards
· Secure disposal of personal information when no longer needed
· Regular review and updating of security practices as our business changes
Only authorized personnel and third-party vendors have access to your personal information, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.
[SHIELD Act Compliance Note: Ensure your actual internal WISP document reflects these practices. Small businesses (under 50 employees, under $3M revenue, or under $5M in assets) may implement a simplified reasonable security program.]
DATA BREACH NOTIFICATION
In the event of a breach of the security of our computerized data that includes your private information, we will notify affected individuals in accordance with applicable New York State law, including the New York SHIELD Act and any subsequent amendments. Specifically:
· We will notify affected New York residents within 30 days of discovering a breach, as required by New York law (amended effective 2025).
· We will also notify the New York State Attorney General's office, the New York Department of State, and the New York State Police as required by law.
· Notification will be provided in the most expedient manner possible and will include, to the extent known, a description of the breach, the type of information involved, and steps you can take to protect yourself.
· We may delay notification if a law enforcement agency determines that notification would impede a criminal investigation.
[SHIELD Act / 2024 Amendment Compliance Note: The 30-day notification window was mandated by legislation signed December 2024 and effective in 2025. Verify current requirements with legal counsel.]
HOW IS PERSONAL INFORMATION USED FOR COMMUNICATIONS?
We may contact you periodically by e-mail, mail or telephone to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this web site allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.
LINKS TO THIRD-PARTY SITES
This site contains links to other sites that provide information that we consider to be interesting. Tugboat Music, LLC is not responsible for the privacy practices or the content of such web sites. We encourage you to review the privacy policies of any third-party sites you visit.
PUBLIC DISCUSSIONS
This site may provide public discussions on various topics. Please note that any information you post in these discussions will become public, so please do not post sensitive information in the public discussions. Whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that users disclose in any such forums on the web site. Tugboat Music, LLC does not endorse anything posted on the discussion board. You must also comply with our other published policies regarding postings on our public forums.
HOW CAN A USER ACCESS, CHANGE, AND/OR DELETE PERSONAL INFORMATION?
You may access, correct, update, and/or delete any personally identifiable finformation that you submit to the web site. You may also unsubscribe from mailing lists or any registrations on the web site. To do so, please either follow instructions on the page of the web site on which you have provided such information or subscribed or registered, or contact us at:
Email: [email protected]
We will respond to verifiable requests within a reasonable time. We may need to verify your identity before processing certain requests.
CHILDREN'S PRIVACY
Tugboat Music, LLC will not intentionally collect any personal information (such as a child's name or email address) from children under the age of 13. Our web site is not directed at children under 13. If you believe that we have inadvertently collected personal information from a child under the age of 13, please contact us immediately at [email protected] so that we may delete such information.
CHANGES TO THIS PRIVACY POLICY
Tugboat Music, LLC reserves the right to modify this statement at any time. Any changes to this Privacy Policy will be listed in this section, and if such changes are material, a notice will be included on the homepage of the web site for a period of time. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
CONTACT US
If you have any questions about privacy at any websites operated by Tugboat Music, LLC, or about our website practices, please contact us at:
Email: [email protected]
Alternate Email: [email protected]
DISCLAIMER: This privacy policy has been revised for informational purposes to address compliance considerations under New York State law, including the NY SHIELD Act and related guidance. It does not constitute legal advice. Tugboat Music, LLC should consult a licensed New York attorney to confirm compliance before publishing.