Effective Date as of 25th May, 2018
If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business. By using our Services You agree that Dubzoo is not responsible for personal data that you have elected to process through Third Party Services or outside of the Services, including the systems of any other third-party cloud services, offline or on-premises storage.
the terms “controller”, “data subject”, “personal data”, “process,” “processing” and “processor” have the meanings given to these terms in GDPR.
“Breach” means a breach of security resulting in access to Dubzoo or Dubzoo’s partner infrastructure storing your data and the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your data
“Content” means your content and any content provided to us from you including without limitation text, photos, images, audio, video, code, and any other materials.
“GDPR” means the EU General Data Protection Regulation
“Data” means the personal data Dubzoo may process on your behalf and instructions as part of the Services, but only to the extent that you are subject to EU Data Protection Law in respect of such personal data. Your data does not include personal data when controlled by us, including without limitation data we collect (including IP address, device/browser details)
Data Controller and Processor
Dubzoo Ltd is the Data Controller of your personal data provided to, or collected by or for, or processed in connection with, our Platform
Dubzoo can also be the processor of your data. We will process your data for the purpose of providing you with the Services, as may be used, configured or modified from within your Account. E.g. depending on how you use the Services, we may process your data in order for you to get the insights you need to make decisions on how to grow or monetise your audience as an artist.
What information do we collect about you?
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
We collect information about you when you input it into the Services or otherwise provide it directly to us, such as Account and Profile Information. This includes:
Your email address
Your real name
Your artist name
The city and country you live in
Information about how you categorize yourself with respect to your content (e.g. Singer, Rapper, DJ etc.)
This information is necessary for the adequate performance of the Services and to allow us to comply with our legal obligations.
We process this information in light of our legitimate interest in improving the Platform and giving our users the best experience. Without it, we may not be able to provide you with all the requested services and features of the Platform.
We also collect information when you decide to connect to a service that provided an API. It is central to our service so you can track your online fan base as artists and take the appropriate action. E.g. The number of Facebook ‘Likes’ your artist page has, or Soundcloud ‘Plays’ your content on Soundcloud has amassed.
We only process the data from API’s (Facebook, Soundcloud, Instagram, Twitter, etc.) with your express permission by you deciding to connect these services on the Platform. You can disconnect from these services at any time via the Dashboard. Once you disconnect from the services, we stop collecting the data via the API. You can also reconnect your service at any time but you will be starting from scratch.
The benefit to you as a user of collecting this data over time allows us to give you the best suggestions as personalised as possible on how to grow and monetise your audience.
We also in future may collect your:
The emails and other communications that you send us or otherwise contribute, such as customer support, feedback or posts to our social media channels. Please be aware that information on public parts of our sites is available to others.
Information you share with us in connection with surveys, contests or promotions.
Information from your use of the Services. This includes: IP addresses, preferences, web pages you visited prior to coming to our site (Cookies), information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).
Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
Other information you submit to us directly or through Third Party Services if you use a Third Party Service to create an Account
Like many website owners and operators, we use automated data collection tools such as “Cookies”.
How do we use your personal information?
We use the personal information we obtain about you to:
Provision of Services. Create and manage your Account, provide and personalize our Services, and in future process payments
Communicating with you. Communicate with you, including by sending you emails about your activity and provide you with Services related information
Surveys and contests. Administer surveys, contests and other promotions.
Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Dubzoo and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your subscription plan or what we think may interest you based on other information we hold about you. You can opt out of these messages at any time.
Advertising. Analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for Paid Services or we may choose to serve you a particular advertisement based on your subscription plan or what we think may interest you based on other information we hold about you.
Improving our Services. Analyse and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most Users of Paid Services use a particular integration or feature, we might wish to expand on that integration or feature.
Security. Ensure the security and integrity of our Services.
Third party relationships. Manage our vendor and partner relationships.
Enforcement. Enforce our Terms of Service and other legal terms and policies.
Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and legal requests.
We process your personal information for the above purposes when:
Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign in to your Dubzoo account.
Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
To operate and improve the Dubzoo business and provide you with as many tailored and personalised suggestions based on your data on how to reach your goals as an artist
To analyse and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring Dubzoo is secure.
To anonymise and subsequently use anonymised information.
Protecting you and others. To protect your vital interests, or those of others.
Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness
How we share your personal information
We share personal information in the following ways:
Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support or assist with data storage.
Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests or prevent fraud or abuse. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
Advertising. We may share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness.
Your rights and choices
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.
You can access, update, change or delete personal information by contacting us at email@example.com or firstname.lastname@example.org to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email addresses.
You can also elect not to receive marketing communications by emailing us on email@example.com or firstname.lastname@example.org or by following the unsubscribe instruction in such communications.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it but we will alert you as soon as possible when this is done. We also will only retain personal information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
If you are subject to EU data protection laws, we suggest you lodge any such complaints with a supervisory authority:
Irish Data Protection Commissioner
Office of the Data Protection Commissioner
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland
Phone +353 57 868 4757
Fax: +353 57 868 4757
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
Upon your reasonable requests to us for information regarding our compliance and where such information is not otherwise available to you, we may provide you with written responses to comply with EU Data Protection Law.
How we protect your personal information
We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorised alteration, unauthorised disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We carefully choose our partners such as Digitalocean who have robust security measures in place.
How we retain your personal information
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active.
How to contact us
The Tea Building Unit 2.01