1. Introduction
Welcome to the Tunearo Privacy Policy. Tunearo ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website or use our services (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please read this Privacy Policy carefully so that you are fully aware of how and why we are using your data. This policy supplements other notices and policies and is not intended to override them.
2. Who We Are
Tunearo is the controller and responsible for your personal data. We are a music distribution platform facilitating the delivery of digital music to Digital Service Providers (DSPs) worldwide.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out in Section 18.
3. Information We Collect
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: First name, last name, artist name, username or similar identifier, marital status, title, date of birth, and gender. Contact Data: Billing address, email address, and telephone numbers. Financial Data: Bank account details, payment card details, and tax identification numbers required for payouts. Transaction Data: Details about payments to and from you, royalty statements, and other details of services you have purchased from or through us. Technical Data: Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Content Data: Audio files, artwork, lyrics, and metadata associated with your music releases. Usage Data: Information about how you use our website, products, and services. Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.
4. How We Use Your Information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Service Delivery: To register you as a new customer, manage your account, and deliver your music to DSPs (like Spotify, Apple Music, TikTok). Financial Processing: To manage payments, fees, charges, and process your royalty payouts efficiently. Relationship Management: To notify you about changes to our terms or privacy policy, and to ask you to leave a review or take a survey. Security & Maintenance: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). Platform Improvement: To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.
5. Legal Basis for Processing
We process your personal data under the following lawful bases:
Performance of a Contract: Processing your data where it is necessary for the performance of a contract to which you are a party (e.g., our Terms of Service) or to take steps at your request before entering into such a contract. Legitimate Interests: The interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. Compliance with Legal Obligation: Processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to (e.g., tax reporting, anti-money laundering). Consent: Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time.
6. How We Share Information
We may have to share your personal data with the parties set out below for the purposes set out in Section 4:
Digital Service Providers (DSPs): We share your Content Data, Identity Data (Artist Name), and necessary metadata with external platforms to fulfill our core music distribution service. Internal Third Parties: Other companies within the Tunearo group acting as joint controllers or processors. Professional Advisers: Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services. Regulators and Authorities: Tax authorities, customs, and other regulators who require reporting of processing activities in certain circumstances. Business Transfers: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
7. Third Party Processors
We use carefully selected third-party service providers (data processors) to assist us in delivering our services. These include:
Cloud Hosting Providers: To securely store your data and content (e.g., AWS, Supabase, Google Cloud). Payment Gateways: To securely process your payments and manage your royalty payouts (e.g., Stripe, PayPal, Wise). Identity Verification Services: To securely perform KYC checks to prevent fraud and comply with Anti-Money Laundering regulations. Analytics & Support: To track platform usage and provide customer support tools. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes.
8. International Data Transfers
We operate globally, and your data may be transferred to, stored, and processed in countries other than your own. Whenever we transfer your personal data out of the UK or the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. Where we use certain service providers, we may use specific contracts approved for use in the UK/EEA (Standard Contractual Clauses) which give personal data the same protection it has in the UK/EEA.
9. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.
Financial and Transaction Data: By law we have to keep basic information about our customers for tax and legal purposes for at least seven (7) years after they cease being customers.
Content Data: We will retain your audio files and metadata for as long as you maintain an active account or have active releases distributed through our platform. Upon account deletion or takedown, content may be kept in secure archives for a limited time for dispute resolution and legal compliance.
10. Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:
Request access to your personal data (commonly known as a "data subject access request"). Request correction of the personal data that we hold about you. Request erasure of your personal data. Object to processing of your personal data where we are relying on a legitimate interest. Request restriction of processing of your personal data. Request the transfer of your personal data to you or to a third party (Data Portability). Withdraw consent at any time where we are relying on consent to process your personal data. To exercise any of these rights, please contact us. You will not have to pay a fee to access your personal data; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.
11. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12. AI & Your Content
We utilize Artificial Intelligence and Machine Learning tools primarily to ensure compliance and improve service quality:
Content Moderation: To scan audio uploads for copyright infringement, duplicates, or malicious content before delivery to DSPs. Fraud Detection: To analyze streaming patterns and transaction data to prevent artificial streaming, bot activity, and financial fraud. Metadata Enhancement: To assist in categorizing genres and optimizing release metadata. Your personal identity data is generally pseudonymized or anonymized when used within these internal analytical systems. We do not use your Content Data to train public-facing generative AI models without explicit, separate consent.
13. KYC Verification
To comply with Anti-Money Laundering (AML) laws and prevent financial fraud, you may be required to complete a Know Your Customer (KYC) process before withdrawing royalties.
This process involves collecting government-issued identification, proof of address, and occasionally a biometric "selfie." This highly sensitive Identity Data is processed securely by our certified third-party verification partners and is strictly used only for compliance and fraud prevention. It is not used for marketing or profiling.
14. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. We use cookies for:
Essential Functionality: Maintaining user sessions and securing the platform. Analytics: Understanding how users navigate our site to improve UX. Preferences: Remembering your UI choices (like dark mode).
15. Children's Privacy
Our Services are explicitly not intended for children under the age of 18 (or the applicable age of majority in your jurisdiction) without the direct consent and supervision of a legal guardian.
We do not knowingly collect personal data from children under 13. If you are a parent or guardian and you become aware that your child has provided us with personal data, please contact us immediately so we can take steps to remove such information and terminate the child's account.
16. Third-Party Links
Our website may include links to third-party websites, plug-ins, and applications (e.g., links to your artist profiles on Spotify or Apple Music). Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
17. Changes to This Policy
We keep our privacy policy under regular review. This version was last updated on the Effective Date shown at the top of this document.
If we make material changes to how we treat your personal data, we will notify you by email to the primary email address specified in your account or through a prominent notice on the platform. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
18. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Privacy Officer (DPO) in the following ways:
Full name of legal entity: Tunearo
Email address: privacy@tunearo.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
19. Definitions
"Personal Data" means any information relating to an identified or identifiable natural person. "Processing" means any operation or set of operations which is performed on personal data, such as collection, recording, storage, alteration, retrieval, use, disclosure, or destruction. "Data Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. "Data Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller. "DSP" means Digital Service Provider, referring to digital music streaming and download platforms like Spotify, Apple Music, Deezer, etc.