Privacy Policy

Last updated: [insert date]

1. Introduction

This Privacy Policy explains how SAP Music Group and its affiliated companies collect, use, share and protect information about you when you visit our websites, use our portals or interact with our services.

We are committed to handling your personal data in a transparent and responsible way and in accordance with applicable data protection laws, including (where applicable) the UK GDPR, EU GDPR and other local laws.

2. Who we are

When we say “SAP Music Group”, “we” or “us” in this Privacy Policy, we mean one or more of the following entities, depending on your location and the service you use:

SAP Media Publishing Ltd, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom;
SAP Media Publishing LLC, 5830 E 2nd St, Ste 7000 #29084, Casper, WY 82609, United States; and
other group companies and affiliates involved in providing our services.

For some activities, one group company may act as the primary “data controller” and others may act as joint controllers or processors. If you have questions about which entity is responsible for your data, you can contact us using the details in Section 13.

3. What information we collect

We may collect and process the following categories of information:

(a) Contact and account information

name, stage name, company or label name;
email address, phone number, postal address, country;
login details for our client and publishing portals;
preferences, communication settings and support history.

(b) Professional and rights information

songwriter, artist, producer and composer details;
PRO/CMO membership numbers, IPI/CAE, ISWC, ISRC and related identifiers;
split sheets, ownership shares and contractual information;
catalogue and release data (titles, contributors, metadata).

(c) Usage and technical data

IP address, device identifiers and browser type;
log information (pages visited, time and date, referring URLs);
portal usage data (how you interact with dashboards, reports and tools);
basic cookie and similar tracking data; see Section 9 for more.

(d) Financial and payment data

bank account or payment details you provide to receive royalties or other payments;
tax information where required (for example TIN, VAT, W-8/W-9 forms);
transaction and royalty data associated with your account.

(e) Marketing and communications data

your subscriptions and opt-in/opt-out choices;
responses to campaigns, events, surveys or educational content.

4. How we collect information

We collect information in a few main ways:

Directly from you – when you fill in forms, sign agreements, create a portal account, submit music, email us or otherwise communicate with us.
From your use of the Services – through cookies, log files and similar technologies when you browse our websites or use our portals.
From partners and public sources – for example DSPs, PROs, CMOs, collection societies, sub-publishers, distributors, co-writers, labels and publicly available databases.

5. How we use your information

We use your information for the following purposes (and, where required by law, on the legal bases indicated in brackets):

To provide and operate our Services – including distribution, publishing administration, royalty processing, portal access and client support (performance of a contract; legitimate interests).
To administer rights and royalties – including registering works, delivering metadata, collecting and allocating income, and reporting to you (performance of a contract; legal obligations; legitimate interests).
To communicate with you – about your account, statements, service updates, opportunities or changes to our terms (performance of a contract; legitimate interests; consent where required).
To improve our services and technology – including analytics, troubleshooting, testing and developing new tools (legitimate interests).
For marketing – sending you news, educational content, opportunities and event information related to SAP Music Group and SAP Music Group Publishing (consent where required; legitimate interests).
To comply with legal and regulatory obligations – such as anti-money laundering, tax reporting, accounting and responding to lawful requests from authorities (legal obligations; legitimate interests).

6. Legal bases for processing (EEA/UK users)

If you are in the European Economic Area or the UK, we rely on the following legal bases to process your personal data:

Performance of a contract – where processing is necessary to deliver our services or take steps at your request;
Legitimate interests – where we have a legitimate business interest that is not overridden by your rights and interests;
Legal obligations – where processing is required by law;
Consent – where you have given us clear permission, for example for certain marketing or cookies. You can withdraw consent at any time using the contact details below or the unsubscribe options in our communications.

7. How we share your information

We may share your information with:

Group companies – other SAP Music Group entities involved in providing services or administering your account;
Service providers – companies that help us operate our business (for example hosting providers, analytics tools, payment processors, IT and support services);
Music and rights industry partners – including DSPs, PROs, CMOs, collection societies, sub-publishers, labels, distributors, music supervisors and licensing partners to enable distribution, publishing administration and licensing;
Professional advisers – including lawyers, auditors and accountants, where reasonably necessary;
Authorities and regulators – where required by law or to protect our rights, your rights or the rights of others; and
Third parties involved in a business transaction – in connection with a merger, acquisition, financing or sale of all or part of our business (subject to appropriate safeguards).

8. International transfers

Because we operate in several countries and work with global partners, your information may be transferred to and processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.

Where required by law (for example under the UK GDPR or EU GDPR), we will put in place appropriate safeguards for such transfers, such as standard contractual clauses approved by the relevant authorities.

9. Cookies and similar technologies

We use cookies and similar technologies to operate our websites and portals, understand how they are used and improve user experience. Cookies may be:

Strictly necessary – required for the site or portal to function (for example log-in and security cookies);
Performance/analytics – to help us understand traffic and usage patterns; and
Functionality or preference – to remember choices such as language or region.

Depending on your location, you may see a cookie banner or settings tool that allows you to accept or reject non-essential cookies. You can also modify your browser settings to manage cookies, although blocking some cookies may affect how our Services function.

10. Data retention

We keep your personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

When we no longer need personal data, we will delete or anonymise it. In some cases we may retain limited information (for example basic contract and payment records) for longer periods where required by law or to establish, exercise or defend legal claims.

11. Your rights

Depending on your location and subject to certain conditions and exemptions, you may have some or all of the following rights:

to access your personal data and receive a copy;
to request correction of inaccurate or incomplete data;
to request deletion of your data in certain circumstances;
to object to or request restriction of processing;
to withdraw consent where we rely on consent;
to receive certain data in a structured, commonly used format and have it transmitted to another controller where technically feasible; and
to lodge a complaint with your local data protection authority.

To exercise your rights, please contact us using the details in Section 13. We may need to verify your identity before responding to your request.

12. Children

Our Services are not primarily directed at children. We do not knowingly collect personal data from children without appropriate consent where required by law. If you believe we have collected personal data from a child without the necessary consent, please contact us and we will take appropriate steps to investigate and, where applicable, delete the data.

13. How we protect your information

We use a combination of technical and organisational measures designed to protect your personal data against unauthorised access, loss, misuse or disclosure. No system can be guaranteed to be completely secure, but we work to keep your information safe and review our security measures regularly.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will take reasonable steps to notify you, for example by updating the “Last updated” date, posting a notice on our website, or contacting registered portal users.

We encourage you to review this page periodically to stay informed about how we handle your information.

15. Contact us

If you have any questions about this Privacy Policy or how we handle your personal data, you can contact us at:

Email: privacy@sapmusicgroup.com
Website: sapmusicgroup.com
Postal (UK): SAP Media Publishing Ltd, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom