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Duetti, Inc. (âwe," âus," or âourâ) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and handle your Personal Information through our website, tools, and services, which involve evaluating and monetizing music assets by purchasing masters, publishing rights, and royalties, and providing catalog management and marketing services (collectively, the "Services").
In this policy, "Personal Information" also means "personal data" as defined under applicable laws, including those in the United Kingdom ("UK") and the European Economic Area ("EEA"). For the purposes of data protection laws in the UK and EEA, Duetti, Inc. is the âdata controllerâ of your Personal Information.
COLLECTION OF PERSONAL INFORMATION
We collect Personal Information from you in several ways when you use our Services:
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Information you provide.
Identifiers, including your real name, alias, email address, telephone number, artist social media details (such as a link to your Spotify page), and your relationship to the artist (for example, artist, manager, or another representative). We may also require information for identity verification and payment, such as a government-issued ID, Social Security Number, or other tax ID.
Commercial information, such as royalty statements, audio files, track/album titles, artwork, tax forms (for example, W-9), bank account details for payment, and records of music assets you have offered or sold to us.
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Information collected automatically.
We automatically gather technical information from your devices, such as your IP address, device and ad identifiers, time zone, location, browser details, and operating system. We also log how you interact with our Services, like the pages you visit and the links you click.
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Information from third-party services.
If you choose to create an account or connect to our Services through a third-party platform (such as Google or a social media service), we may collect Personal Information from that platform, such as your name, email address, and profile information, in accordance with your privacy settings on that platform.
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We may be legally or contractually required to collect certain Personal Information from you when you engage our Services. If you fail to provide this information, we may be unable to fulfill our contractual obligations (for example, purchasing your assets) or provide certain Services. This may require us to cancel a service you have with us.
Some information we collect may be considered "sensitive" under the law. We only process this data when we have a legal basis to do so, such as to perform a contract with you, comply with a legal obligation, or with your explicit consent.
We may aggregate or de-identify this information so it can no longer be linked to you. This aggregated or de-identified data is not considered Personal Information and is not subject to this Privacy Policy.
SOURCES OF PERSONAL INFORMATION
We also receive Personal Information from other sources, such as your talent manager or other representatives, our vendors (such as background check providers), music rights organizations, music publishers, and distributors, and other third-party services. We may also collect Personal Information that you make publicly available, such as when you comment or post on our social media pages.
USE OF PERSONAL INFORMATION AND PURPOSE OF DATA PROCESSING
We use and otherwise process each of the categories of Personal Information identified above for the following business purposes:
| Processing activity |
Lawful basis for processing |
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To register and manage your account; provide our Services to evaluate, purchase, and monetize your music assets (including masters, publishing, and other royalties); conduct due diligence; process sales; manage your catalog; administer royalties and payments; and to communicate with you about your account and our Services.
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Performance of a contract with you.
Necessity to comply with a legal obligation.
Necessity for our legitimate interests (for example, to provide our Services, keep our records updated, and ensure the security of our platform).
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To market, personalize, and expand our Services. This includes providing you with marketing services (such as Spotify playlisting, YouTube optimization, and sync opportunities), suggesting or recommending other opportunities we think you'll be interested in, such as personalized offers for your music assets, and informing you about new features or services.
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Necessity for our legitimate interests (for instance, to grow our business).
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To improve our Services, keep them secure, and meet legal rules. This includes analyzing how you use the Services, fixing issues, and using data for research. It also includes keeping our platform safe and complying with the law.
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Necessity for our legitimate interests (for instance, for running and protecting our business, providing IT services, preventing fraud, analyzing, and developing our Services, and informing our business strategy).
Necessity to comply with a legal obligation.
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Where required by law, we will obtain your consent to process your Personal Information (for example, for marketing purposes). You can withdraw your consent at any time by contacting us; however, this will not affect the lawfulness of any processing conducted prior to your withdrawal.
We may use your Personal Information to send you newsletters or other marketing communications. Where required by law, we will obtain your consent to do so. You can unsubscribe from these communications at any time by following the instructions included in the email.
When our service providers in the UK or EEA process your Personal Information for us, we ensure we have the required data processing agreements in place. These providers act as âdata processorsâ on our instruction.
DISCLOSURE OF PERSONAL INFORMATION
We may share your Personal Information for business purposes with the following parties, who may act as "data processors" (processing data on our behalf) or independent "data controllers" (processing data for their own purposes):
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Vendors and service providers.
We share your Personal Information with vendors and service providers who help us with our business operations, such as for payment processing, royalty administration, data hosting and infrastructure, customer service, security, due diligence, background checks, performance monitoring, marketing, and advertising, and auditing.
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Corporate affiliates.
We may share your Personal Information with other companies in our corporate group.
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Business transfers.
We may share your Personal Information in connection with a major corporate transaction, such as a merger, asset sale, or bankruptcy.
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Legal purposes.
We may share your Personal Information to respond to legal requests such as subpoenas and to protect the rights and safety of us, our users, or the public.
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Music industry partners.
We may share your Personal Information with music industry partners, such as performance rights organizations, music publishers, and distributors, as necessary to manage and administer the music assets we acquire.
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Marketing and advertising partners.
We may share your Personal Information with partners such as social media platforms, streaming services, and advertising networks to market your music assets and our Services, in accordance with your preferences and with your consent where required.
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With your consent.
We may share your Personal Information for any other purpose we disclose to you when we collect it, or with your permission.
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THIRD-PARTY WEBSITES AND SERVICES
Our Services may allow you to access third-party services, such as social media platforms, which may collect information about you in accordance with their own privacy policies. Additionally, if you share information in public areas on the Services, other users may read, collect, or use it. We are not responsible for the information you choose to submit to these public areas and urge you to use caution when doing so.
We do not sell your Personal Information for money. However, some US privacy laws define "selling" or "sharing" to include using cookies for targeted ads. You have the right to opt out of this, as described in the 'YOUR RIGHTS AND CHOICES: UNITED STATES RESIDENTS' section below.
ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES
We and our partners use cookies and similar technologies to collect information when you use our Services. We will obtain your consent before using non-essential cookies where required by applicable law. In other jurisdictions, your continued use of the Services signifies your consent to our use of these technologies.
The following types of cookies are used on our Services:
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Essential cookies.
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These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies also help keep our Services safe and secure.
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Preference cookies.
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These cookies store information such as your language preference and login data. Without them, our Services might not remember choices you have made or personalize your experience. They also help recognize your device, so you do not have to enter the same information repeatedly.
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Performance cookies.
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These cookies collect information about how you use our Services, such as which pages you visit most often. We use this data to improve your experience by tracking things such as page load times and error messages.
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Advertising cookies.
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These cookies gather information about how you use our Services to show you more relevant content and ads. Some of these cookies are from third parties that provide "interest-based advertising" based on your online activities. We do not control the privacy practices of these third parties.
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While we do not currently respond to "do-not-track" signals due to the lack of a uniform standard, we honor legally recognized browser-based opt-out signals such as the Global Privacy Control (GPC), as described in more detail below.
AUTOMATED DECISION-MAKING
We may use automated processes and profiling to support our business, for example, to help determine pricing for music assets and to personalize our Services. Where a decision is based solely on automated processing and has a legal or similarly significant effect on you, you have the right not to be subject to that decision, unless it is necessary for entering into or performing a contract with you, is authorized by law, or is based on your explicit consent. In such cases, you are entitled to obtain human intervention, express your point of view, and contest the decision. For more information about your rights, including your right to opt out of certain profiling, please see the 'YOUR RIGHTS AND CHOICES' sections below.
YOUR RIGHTS AND CHOICES: UNITED STATES RESIDENTS
This section supplements our Privacy Policy and provides additional information for residents of U.S. states with comprehensive consumer privacy laws, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. Depending on where you live, you may have some or all of the following rights regarding your Personal Information, subject to certain exceptions:
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Right to know and access.
Request access to the categories and specific pieces of Personal Information we have collected about you. Residents of Delaware, Maryland, Minnesota, and Oregon may also request a list of the categories of third parties to whom we have disclosed their Personal Information, as described in Section 4 of this Privacy Policy.
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Right to correct.
Request the correction of inaccurate Personal Information. This right applies to residents of California, Colorado, Connecticut, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.
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Right to delete.
Request the deletion of your Personal Information.
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Right to revoke consent.
Consumers who are residents of Maryland who have consented to additional processing purposes may revoke that consent at any time.
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Right to data portability.
Receive your Personal Information in a portable and, to the extent technically feasible, readily usable format.
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Right to opt out of sale, sharing, or targeted advertising.
Opt out of the "sale" or "sharing" of your Personal Information for cross-contextual advertising purposes, or the processing of your Personal Information for targeted advertising. You can exercise this right by clicking the "Your Privacy Choices" link in our website footer.
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Right to opt out of profiling.
Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. This right applies to residents of California, Colorado, Connecticut, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.
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Rights regarding sensitive Personal Information.
You may have the right to limit the use and disclosure of your sensitive Personal Information to certain purposes, such as providing the Services you requested. We only process sensitive Personal Information for legally permitted purposes that do not require an opt-out right under most state laws.
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To submit a request to exercise these rights, please contact us using the information in the "CONTACT INFORMATION" section below. We will verify your identity by matching the information you provide with what we have on file. You may also authorize an agent to make a request on your behalf.
If we deny your request, you may have the right to appeal our decision. This right is available to residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. To appeal, please contact us with the details of your original request and the reason for your appeal. We will inform you in writing of our response. If your appeal is denied, you may have the right to contact your state Attorney General.
We will not discriminate against you for exercising your privacy rights, though some features of the Services may change or become unavailable as a result.
California's "Shine the Light" law permits California residents to request, once a year and free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for direct marketing purposes in the preceding calendar year, as well as the type of Personal Information disclosed. To submit a Shine the Light inquiry, please contact us using the information in the "CONTACT INFORMATION" section below and include âShine the Light Inquiryâ in the subject heading.
Although we do not "sell" "covered information" of Nevada "consumers" as those terms are defined by Chapter 603A of the Nevada Revised Statutes, Nevada law requires us to provide a method for consumers to submit a request to opt out of a future sale. You can submit such a request by contacting us using the information in the "CONTACT INFORMATION" section below.
YOUR RIGHTS AND CHOICES: UK AND EEA RESIDENTS
If you are in the UK or EEA, you have certain data protection rights under local laws. Subject to some exceptions, you may have the right to:
| Request access to and receive a copy of your Personal Information. |
| Request correction of any inaccurate Personal Information. |
| Request erasure of your Personal Information. |
| Object to the processing of your Personal Information. |
| Request the restriction of processing of your Personal Information. |
| Request the portability of your Personal Information. |
| Lodge a complaint with a supervisory authority. |
You may exercise these rights by contacting us as detailed in the âCONTACT INFORMATIONâ section below.
INTERNATIONAL TRANSFERS
We are based in the United States, where we process Personal Information under data protection laws that may differ from those in your home country.
When we transfer Personal Information from the UK or EEA to countries that are not considered to have adequate data protection, we do so in compliance
with the law. We use appropriate safeguards, such as the European Commission's standard contractual clauses and/or the UK's International Data Transfer
Addendum to the European Commission Standard Contractual Clauses, to ensure your information remains protected. For more details on these safeguards,
please contact us.
CHILDREN
Our Services are not directed to children, and we do not knowingly collect Personal Information from children under the age of 16
(or any other age stipulated by applicable law in a particular jurisdiction). If we learn that we have collected Personal Information from a child
under this age, we will take steps to delete that information as soon as possible.
DATA RETENTION, SECURITY, AND INTEGRITY
We retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected, provide our Services, serve our
legitimate business interests, and comply with legal obligations. We generally apply the following retention periods:
| Category |
Retention period |
| Account information. |
We retain your account information for as long as your account is active and for a reasonable period thereafter in case you decide to re-activate
the Services.
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| Transaction and music asset information. |
We retain records of transactions and music assets we have acquired for as long as required by law for tax and accounting purposes, which is
typically 7 years after the transaction.
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| Correspondence. |
We keep correspondence for as long as necessary to resolve an inquiry and for a reasonable period for our records.
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| Marketing information. |
We retain information used for marketing purposes until you unsubscribe or opt out.
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We may retain some information in a de-identified or aggregated form. We may also retain your information for a longer period if necessary to comply
with our legal obligations, resolve disputes, or prevent fraud.
We use reasonable security measures to protect your Personal Information. However, no system is completely secure, and we cannot guarantee the
absolute security of your Personal Information.
CHANGES TO THE PRIVACY POLICY
We may update this Privacy Policy from time to time. When we do, we will change the "Last updated" date at the top of this policy. If we make
material changes, we will notify you as required by law (for example, by email or with a prominent notice on our Services) before the change becomes
effective. We encourage you to review this policy periodically to stay informed.
CONTACT INFORMATION
If you have any questions about this Privacy Policy or wish to exercise your legal rights, please email us at
contact@duetti.co.
Address: 250 Lafayette Street, New York, NY 10012, United States.
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© Duetti, Inc.
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