PRIVACY POLICY

Last updated: 02-12-2024

1. INTRODUCTION

Tosky Records (“we,” “our,” or “us”), located in Via Amelia, 5 00181 Roma (Italy), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, services, and products.

2. DATA CONTROLLER

The Data Controller for your personal information is:

Giorgio Lovecchio (Data Protection Officer)
Tosky Records
Via Amelia, 5 00181 Roma (Italy)
Email: lovecchio@toskyrecords.com

3. INFORMATION WE COLLECT

3.1 Personal Information:

  • Name and contact details (email address, phone number, postal address)
  • Login credentials
  • Payment information
  • Purchase history
  • Musical submissions and related content
  • Personal preferences
  • Communication preferences
  • Technical information about your device and browsing

3.2 Automatically Collected Information:

  • IP address
  • Browser type and version
  • Operating system
  • Device information
  • Browsing patterns and site usage
  • Referral sources
  • Length of visit and page views

4. HOW WE USE YOUR INFORMATION

  • Processing your orders and payments
  • Managing your account
  • Sending newsletters and marketing communications
  • Evaluating music submissions
  • Improving our services
  • Analyzing website performance
  • Complying with legal obligations
  • Responding to your inquiries
  • Preventing fraud

5. SPECIAL NOTICE FOR MUSIC SUBMISSIONS

By submitting musical content to Tosky Records, you acknowledge and agree that:

  • Your submitted content may be used for machine learning purposes
  • Data will be anonymized and used to improve our automated services and bots
  • This processing is part of our service improvement efforts
  • The machine learning analysis will not affect your rights to the original content
  • Anonymized data patterns may be retained indefinitely for system training

6. DATA SHARING AND THIRD-PARTY SERVICES

We share your information with:

  • Payment processors (PayPal, Apple Pay, Google Pay)
  • Email marketing service (Brevo)
  • Analytics provider (Google Analytics)
  • Cloud service provider (Google Cloud Platform)
  • Social media platforms (when you use social features)

All third-party providers are carefully selected and required to maintain appropriate security measures.

7. DATA STORAGE AND SECURITY

Your data is stored on secure cloud servers located in the European Union through Google Cloud Platform. We implement appropriate technical and organizational measures to protect your personal information.

8. DATA RETENTION

We retain your personal information indefinitely unless you request deletion. You can:

  • Access your data through your account dashboard
  • Modify your profile information at any time
  • Request complete account deletion

9. COOKIES AND TRACKING

We use cookies and similar technologies for:

  • Essential website functionality
  • Analytics (Google Analytics)
  • Marketing purposes
  • User experience improvement

You can manage cookie preferences through your browser settings.

10. YOUR RIGHTS

Under GDPR, you have the right to:

  • Access your personal data
  • Correct inaccurate data
  • Request data deletion
  • Object to processing
  • Data portability
  • Withdraw consent
  • Lodge a complaint with a supervisory authority

Exercise these rights through your account dashboard or by contacting our DPO.

11. INTERNATIONAL TRANSFERS

While our servers are located in the EU, some service providers may be based outside the EEA. Any international transfers are protected by appropriate safeguards, including EU Standard Contractual Clauses.

12. CHILDREN’S PRIVACY

Our services are not intended for users under 16 years of age. We do not knowingly collect information from children. If we discover we have collected children’s personal data, we will delete it immediately.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. Significant changes will be notified via email or website notice. Continued use of our services after changes constitutes acceptance of the updated policy.

14. CONTACT US

For privacy-related questions or to exercise your rights, contact:

Giorgio Lovecchio
Data Protection Officer
Tosky Records
Via Amelia, 5 00181 Roma (Italy)
Email: [insert email]

15. ADDITIONAL INFORMATION

For music submissions and special processing:

  • Submitted materials are reviewed confidentially
  • Storage and usage rights are governed by separate submission agreements
  • Artists retain ownership of submitted content
  • Anonymized data may be used for service improvement and analysis

16. UPDATES AND CHANGES

This Privacy Policy was last updated on [Current Date]. We reserve the right to modify this policy at any time. Changes will be effective immediately upon posting to the website.