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Privacy Policy

Last updated: November 27, 2022
 

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1. Introduction

This Privacy and Data Processing Policy (the “Privacy Policy”) governs your access to and the use of the SPARWK’s services (“SERVICES”), including the SPARWK apps (“APPs”), and website (“WEBSITE”).

 

By using our WEBSITE, APPs, or any of our SERVICES, you are agreeing to this Privacy Policy and entering into a legally binding contractual relationship with SPARWK AS, Enterprise Registration nº 923205985, Kai 9, Pir II 13A, 7010 Trondheim, Norway, (“SPARWK”). You also understand and agree that your continued access to or use of our WEBSITE, APP or SERVICES after any posted modification to the Privacy Policy indicates your acceptance of the modification of its terms.

 

It is important that you read this Privacy Policy carefully so that you can determine on a free and voluntary basis whether you wish to provide your personal data to SPARWK. Please understand that data processing is required for SPARWK to perform its SERVICES; therefore, in case you do not agree with the terms of this Privacy Policy, you should not use SPARWK’s WEBSITE, APPs, or SERVICES.

 

Any references to “You” and “Your” refer to you, as a user of the WEBSITE, APPs, or SERVICES. References to “We”, “Us” and “Our” refer to SPARWK. Any references to “APPs” refer to any of our APPs, regardless of whether you have downloaded or registered to all of them or not.

2. Data we collect and its purpose

We collect, store and process the personal data needed to provide, maintain, and improve our SERVICES, measure our performance, communicate with you, and for our direct marketing purposes. We ensure that the data we use are adequate, relevant and not excessive for the above described purposes.

We will only collect data when we have a legal basis for doing so. In almost all cases, such legal basis will be your consent, which we will ask for, clearly and informedly; and when deemed necessary according to laws applicable, we will ask for you to give it explicitly (ex.: biometric data collection). But alternatively, the legal basis can be: to comply with our legal and regulatory obligations; to establish or defend legal claims; to perform a contract.

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We only request and use the personal data that is necessary for the above described purposes.

Please note that the type of data we request may differ depending on which of our SERVICES you use.

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The information we collect, store and process, as well as the purposes of it, are:

Identity

  • Full name

  • Pseudonyms and alternate names

  • Social media and online ID numbers or usernames

  • Birth date

  • Nationality

  • Biographical information

  • Rights owner category (writer, record producer etc)

  • Identification numbers (Taxpayer, Residence Permit, Work Permit, Passport, Drivers’ License, or Identity Card)

  • Affiliation to collection societies

  • To feed the database of which our SERVICES consist and are based on

  • For identity verification purposes

  • For preventing and combating any eventual frauds regarding your individual registration and access to our services

Proof of identity

  • Copies of identification documents (Taxpayer Identification Number, Birth Certificate, Residence Permit, Work Permit, Passport, Drivers’ License, or Identity Card)

  • Biometric data*

  • For identity verification purposes*

  • For preventing and combating any eventual frauds regarding your individual registration and access to our services

Your contact details

  • Email address

  • Physical address

  • Phone number

  • For communication purposes

Your usage and transaction data

  • SPARWK ID login and password

  • Data about how you use the app

  • Browsing and search history

  • Browsing preferences

  • Shopping history

  • Comments 

  • Passwords saved

 

  • To provide quicker access based on your previous access

  • To make suggestions to you for other sites or products which we believe you will also be interested in

Technical data for access to our WEBSITE, APP, SERVICES and direct marketing

  • IP number

  • Cookies

  • Login data

  • Internet browser

  • Place and time/timezone of access

  • Engagement (clicks, session durations, comments left, likes, savings, shares)  with our emails, posts and overall communications

  • To understand how you use our WEBSITE, APP, SERVICES and marketing communications in order to improve user experience

Communication preferences and data

  • Preferences to receive marketing, notices and overall communication**

  • To ensure we will only provide you with the material and services you agreed upon

Identity and repertoire records

  • ISNI

  • ISRCs

  • ISWCs

  • IPI/CAE numbers

  • Collection societies and distribution offices’ ID numbers

  • To feed the database of which our SERVICES consist and are based on

  • To compile performance metrics about you or our SERVICES

Information disclosed through emails, forms, and comments

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  • To verify and appropriately respond to your communications and requests

User-generated content

  • Content you create, upload, or receive from others when using our SERVICES

  • Resulting information from your data

  • Algorithmic findings based on the data you provide

  • To make suggestions to you for people you may want to connect with or content, sites and products you may be interested in

  • To deliver statistics about your repertoire and performance, for your information or for the improvement of our SERVICES

  • To feed the database of which our SERVICES consist and are based on

*Please note that your biometric data will never be collected or processed unless you give us your explicit consent for the purposes above described. You will be duly asked and informed before we collect biometry and you will have the opportunity to express your consent.

 

**You have the right to object to the processing of our data for our direct marketing purposes at any time and free of charge. Additionally, we may also obtain information about you from third parties (see point 3 below) and when you use our WEBSITE and Social media (please see point 7 below).

3. Information collected from other sources

For what it is relevant or required to the services we provide to you, or where it is relevant to our compliance and enforcement activities, we receive information from third parties such as:

  • Performing Rights Organizations (PROs), Collective Management Organizations (CMOs), Mechanical Rights Organizations (MROs), and other collecting societies and agencies, regarding your repertoire, licensing and overall and use of your work;

  • Our partners handling the identity verification process (regarding your consent for collecting the necessary data for identity verification, please refer to point 2*);

  • International Standard Name Identifier (ISNI) and other credit reference agencies, regarding your repertoire;

  • Digital Service Providers (DSPs), regarding your repertoire and overall use of your work;

  • Your authorized representatives, regarding your repertoire, licensing and overall and use of your work;

  • Industry stakeholders, regarding the use of your work (charts, number of streams, playlist featuring);

  • Business partners and subcontractors who assist us in delivering our services (payment, authentication partners, technical assistance) and who may share your information with us (your contact details, browsing history and information, and payment details).

 

By subscribing to our SERVICES, you understand and acknowledge that your data is obtained from these parties. You can request information about these parties at any time by emailing us at submissions@sparwk.com. 

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Our WEBSITE, APP or social media pages contain links to other websites. Please note that our Privacy Policy does not apply to these. If you click on a link that leads you to another website, you are subject to their Privacy Policy which may be different from ours. You should read their Privacy Policy to ensure we agree with having your data processed by them.

4. Which parties do we share your data with?

We work with partners or collaborators who take part in managing and delivering our services. They are only allowed to use your data to provide their corresponding services. They are not allowed to sell your data to any other party nor use it in any way beyond what is required for their service. The processing that these partners or collaborators conduct of the personal data is not known by SPARWK, since they are also subjected to security measures and data protection laws (please refer to item 10 for more information on security and confidentiality measures taken by our partners and collaborators).

 

When your information is transferred to a country that is subject to a different law regarding data protection or that is not deemed to adequately protect personal data under applicable data protection law, we take steps to ensure your information is protected in the same terms of this Privacy Policy.

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Shall SPARWK AS or its assets ever be acquired by another company, partially or fully, the data we store will be among the assets that shall be transferred. You understand and acknowledge that the new owners will be entitled to use your data in the same terms of this Privacy Policy. However, you will be duly and previously informed before any data transfer happens, and you will have the option to express your consent or refusal. Other than these cases, we will never sell or transfer your data to third parties unless you expressly authorize us to do so, or a law or court authority obligates us to do so.

5. When do you provide us with personal data?

You provide us your personal data when:

  • When you use our WEBSITE, APP, and social networks;

  • When you join and every time you use our SPARWK Passport, Metaverse, and overall SERVICES;

  • When you fill contact forms;

  • When you contact us directly, through email, telephone, SMS, messaging apps (including those provided by social network platforms), or personally;

  • When you subscribe to receive communications from us;

  • When you take part in a promotion or event conducted by us;

  • When you submit your CV, in paper format or by electronic means;

  • When we engage in any contractual relationship.

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Please note that we do not fully know nor can control which and how data is processed through social media platforms, messaging apps, phone and network operators and any other third parties’ platforms through which you can contact us. If you wish to control this information, you can use your profile options in each of these platforms or contact the platform owners’ or operators’ through the means made available by them.

6. How long do we store your data?

Please understand that if you unsubscribe from the SPARWK’s SERVICES, we can still share your personal data linked to your SPARWK ID number and your songs to PROs, CMOs, MROs, and other collecting societies and agencies, credit reference agencies, publishers, labels, your authorized representatives, for the purposes of their services related to your repertoire and rights associated with it. You understand and acknowledge that SPARWK’s SERVICES include the development and maintenance of a database of musical works and their respective rights holders, and therefore, some information provided or generated during your use of our SERVICES will remain stored even if you decide that you will no longer use our SERVICES.

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Other than the exceptions above described, your data will only be stored during the period necessary for fulfilling each purpose described in item 2, for legal provisions that may be applicable, for contractual obligations, or until you revoke your consent.

7. Legitimate basis

The legal basis for the processing of your personal data is the consent you grant us by using our WEBSITE, APP, SERVICES, or engaging with us in any of the forms described in item 5.

 

Your consent may be revoked at any time by sending a request to: submissions@sparwk.com

 

When creating your login for access to our SERVICES and/or subscribing to receiving communications from us, your express consent regarding specific activities will be asked, therefore becoming the legal basis for the activities we will perform and the communications we will send you from then on.

8. Your rights

You can request access, rectification, or removal of your data at any time. You can also request  restrictions to the processing of your data.
 

You understand that rectifications, removals or restrictions may affect or even hinder the delivery of our SERVICES, since they require your data. 


We can keep your data stored for the necessary duration of time required to analyse and grant your request.

You have the right to data portability so your data can  be transferred directly from one controller to another, where technically feasible.

9. Where is your data stored?

Your data is stored within the European Union, and within the United States by our partners handling your identity verification process. We use different applications to process data which are all subject to strict data protection rules.

10. Security, confidentiality, and integrity of your data

We commit to the security, confidentiality, accessibility, and integrity of the information and data you provide, as well as of the systems, applications and processes used for its processing, and to comply with the legal requirements applicable to us. However, we may modify or delete information when it is confirmed that it is false or inaccurate. 

 

We conduct periodic assessments of our data protection compliance policies and procedures, the risks associated with data processing, and the laws applicable to us. We orientate our staff members and contractors on the best and necessary practices to ensure the security and integrity of the data we process.

 

Our partners that collect and store your data hold certifications in information security, confidentiality and systems availability such as SOC 2 Type II and ISO 27001. For more information, please refer to this link: https://onfido.com/security/ 


Should you detect a security incident or breach in our WEBSITE, APP or SERVICES, or should you come across any event in which you consider necessary to improve security, either as a user or a data subject, you can contact us through the following email address: submissions@sparwk.com.

11. Children and underage individuals’ data

We do not knowingly collect, use or disclose information relating to children under 13 or equivalent minimum age in the relevant jurisdiction unless they are shared on their behalf.

12. Modifications of our privacy policy

This Privacy Policy was last updated on November 27st, 2022.

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If our Privacy Policy must go through adjustments or modifications due to changes in regulations or criteria issued by data protection laws or authorities, or due to operational changes in SPARWK’s WEBSITE, APP or SERVICES for the purposes of their improvement, this Privacy Policy will be updated accordingly and immediately.

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By having agreed to this Privacy Policy, you understand and agree that your continued access to or use of our SERVICES after any posted modification to the Privacy Policy indicates your acceptance of the modification of its terms.

Shall any additional data be collected, you will be appropriately notified before we require it and/or collect it.

 

If you have any questions or requests, we can be reached at: submissions@sparwk.com

We collect, store and process the personal data needed to provide, maintain, and improve our SERVICES, measure our performance, communicate with you, and for our direct marketing purposes. We ensure that the data we use are adequate, relevant and not excessive for the above described purposes.

We will only collect data when we have a legal basis for doing so. In almost all cases, such legal basis will be your consent, which we will ask for, clearly and informedly; and when deemed necessary according to laws applicable, we will ask for you to give it explicitly (ex.: biometric data collection). But alternatively, the legal basis can be: to comply with our legal and regulatory obligations; to establish or defend legal claims; to perform a contract.

​

We only request and use the personal data that is necessary for the above described purposes.

The information we collect, store and process, as well as the purposes of it, are:

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