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Privacy Notice

Draft — pending legal review. This notice describes accurately how the platform processes data, but the binding wording, the controller's legal identity, and retention periods must be confirmed with a data-protection lawyer before launch. Placeholders are marked [in brackets].

1. Who is responsible (controller)

The controller for the processing described here is [legal entity name, address, country]. See our Impressum. Contact for data-protection matters: [privacy@your-domain].

2. What data we process

  • Account: email address, role, rank and XP.
  • Profile: display name, optional bio, avatar, TikTok / YouTube handles.
  • Connected accounts (optional):if you link your TikTok or YouTube account via their login (up to 3 per platform), we store the platform's account/channel ID, your public handle and avatar, encrypted read-only access tokens, and a cached copy of the account's public stats (follower, like and video counts) and recent public videos — used to verify the account is yours and to show campaign owners your public track record on your platform profile. You can hide any account's stats from campaign owners in your profile at any time; hidden accounts remain pure ownership proof. We never post on your behalf. Disconnecting or deleting your account removes these records; connections unused for 180 days are removed automatically.
  • Date of birth: collected at onboarding. We need it to (a) confirm you meet the minimum age of 13 and (b) determine whether payout details may be held in your own name — under 18 they may not, because a parent or guardian must be the contracting party and the recipient of any payout. We store the date, not a copy of any ID document.
  • Payout & tax (creators, 18+ only): legal name, address, country, payment method and payment details (IBAN / PayPal or Wise email), and tax ID. Provided by you during onboarding so we can pay you. We do not collect or hold these from anyone under 18.
  • Activity: campaign ideas, votes, predictions, claimed slots, uploaded video links, captions/hook text, and performance metrics.
  • Gamification & payments: XP events, rank transitions, badges, and credit notes (Gutschriften) with the amounts paid.
  • Security logs: an audit trail of privileged actions (identifiers and categories only — no sensitive payout details).
  • Fraud-prevention signals: when you submit a video or request access, we record your IP address and browser identifier (user-agent), and we store a one-way cryptographic hash of your payout details. These let us detect duplicate accounts and coordinated abuse. We do not build advertising or behavioural profiles from them.
  • Promoter enquiries:if you use the public “Promote your song” form, we process the name, email address, song link and message you send us — plus the same fraud-prevention signals (IP address, browser identifier) — to reply to your enquiry and scope a campaign with you.

3. Why we process it, and on what legal basis

  • To run campaigns and pay you — performance of our contract with you (Art. 6(1)(b) GDPR).
  • To keep credit notes / tax records — compliance with a legal obligation (Art. 6(1)(c); German §147 AO / §14b UStG retention).
  • To rank submissions, prevent fraud, and secure the service — our legitimate interests in a working, abuse-free platform (Art. 6(1)(f)). This is the basis for the fraud-prevention signals above (IP address, browser identifier, hashed payout details), which are used only to detect duplicate accounts and coordinated abuse.
  • To answer promoter enquiries — steps taken at your request prior to entering into a contract (Art. 6(1)(b)).

4. Where your data is stored, and who processes it for us

  • Hosting & database: Supabase, in the EU region (Frankfurt, eu-central-1). Payout documents (credit-note PDFs and payout exports) are kept in private storage and only ever served through short-lived, signed links.
  • AI content scoring: the text you submit (idea title/description, video caption and hook text) is sent to Anthropic (Claude) to score creative quality and fraud signals. No account, payout or tax data is sent.

These providers act as our processors under a data-processing agreement. Where a transfer leaves the EU/EEA, it relies on [appropriate safeguards — confirm with counsel].

5. How long we keep it

Credit notes and the tax data they contain are retained for about [10] years to meet statutory tax-retention duties. Other personal data is kept while your account is active and then anonymised; pseudonymous business records (e.g. votes, XP) may be retained in anonymised form for platform integrity.

Fraud-prevention signals (IP address and browser identifier) are deleted automatically after at most 24 months — and earlier if your account is erased. Sign-up requests that are rejected or abandoned — and promoter enquiries once handled or abandoned — are anonymised after 90/180 days, including these signals.

6. Your rights

You have the right to access, rectify, erase, restrict, port and object to the processing of your personal data (Art. 15–21 GDPR), and to lodge a complaint with a supervisory authority.

  • Access & portability: export all of your data as JSON from your profile (“Privacy & your data”).
  • Rectification: edit your profile and payout details at any time.
  • Erasure: request deletion at [privacy@your-domain]; we anonymise your account (tax records are retained as required by law).

7. Cookies

We use only strictly-necessary cookies to keep you signed in. There is no advertising or analytics tracking, so no cookie-consent banner is required.

8. Contact

Questions or requests: [privacy@your-domain]. Last updated: [date].