Privacy policy

In accordance with the statutory provisions of data protection law (in particular the new version of the German Federal Data Protection Act (BDSG) and the European General Data Protection Regulation (GDPR)), we inform you below about the type, scope and purpose of the processing of personal data by our company. This privacy policy also applies to our websites and social media profiles. With regard to the definition of terms such as”personal data” or “processing”, we refer to Art. 4 GDPR.

Name and contact details of the person responsible
Our controller (hereinafter “controller”) within the meaning of Art. 4 (7) GDPR is:

VERmusic / TRUPIC Management
Silvia Murauer
Reutterstr. 68a
80689 Munich
Germany
E-mail address: management[at]trupic-music.com

data.

1. Types of data that we process
Usage data (access times, websites visited, etc.), communication data (IP address, etc.),

Optimizing the website technically and economically, enabling easy access to the website, making the website
user-friendly, avoiding SPAM and misuse, providing websites with functions and content, uninterrupted, secure
operation of our website

3. Categories of data subjects pursuant to Art. 13 (1) e) GDPR
Visitors/users of the website. The persons concerned are collectively referred to as “users”.

Legal basis for the processing of personal data

Below we inform you about the legal basis for the processing of personal data:

1. If we have obtained your consent for the processing of personal data, Art. 6 para. 1 sentence 1 lit. a)
   GDPR is the legal basis.
2. If processing is necessary for the performance of a contract or in order to take steps at your request
   prior to entering into a contract, the legal basis is Article 6(1)(b) GDPR.
3. If processing is necessary to fulfill a legal obligation to which we are subject (e.g. statutory retention
   obligations), Art. 6 para. 1 sentence 1 lit. c) GDPR is the legal basis.
4. If processing is necessary to protect the vital interests of the data subject or another natural
   person, the legal basis is Art. 6 para. 1 sentence 1 lit. d) GDPR.
5. If the processing is necessary to protect our legitimate interests or those of a third party and your
   interests or fundamental rights and freedoms do not outweigh this, Art. 6 para. 1 sentence 1 lit. f)
   GDPR is the legal basis.

Disclosure of personal data to third parties and processors

We do not pass on any data to third parties without your consent. Should this nevertheless be the case, the
data will be passed on on the basis of the aforementioned legal bases, e.g. when passing on data to online
payment providers to fulfill the contract or due to a court order or due to a legal obligation to hand over the
data for the purpose of criminal prosecution, to avert danger or to enforce intellectual property rights.
We also use processors (external service providers, e.g. for web hosting of our websites and databases) to
process your data. If data is passed on to the processors as part of an agreement on order processing, this
is always done in accordance with Art. 28 GDPR. We select our processors carefully, monitor them regularly
and have been granted the right to issue instructions regarding the data. In addition, the processors must
have taken appropriate technical and organizational measures and comply with the data protection
regulations according to BDSG n.F. and GDPR.

Data transfer to third countries

The adoption of the European General Data Protection Regulation (GDPR) has created a uniform basis for
data protection in Europe. Your data will therefore primarily be processed by companies to which the GDPR
applies. However, if processing is carried out by third-party services outside the European Union or the
European Economic Area, these must fulfill the special requirements of Art. 44 et seq. GDPR must be met.
This means that the processing is carried out on the basis of special guarantees, such as the EU
Commission’s officially recognized determination of a level of data protection corresponding to the EU or
compliance with officially recognized special contractual obligations, the so-called “standard contractual
clauses”.
Insofar as we obtain your express consent to the transfer of data to the USA due to the ineffectiveness of
the so-called “Privacy Shield”, in accordance with Art. 49 para. 1 sentence 1 lit. a) GDPR, we would like to
point out the risk of secret access by US authorities and the use of the data for surveillance purposes,
possibly without legal remedies for EU citizens.

Deletion of data and storage duration

Unless expressly stated in this privacy policy, your personal data will be deleted or blocked as soon as you
revoke your consent to the processing or the purpose for the storage no longer applies or the data is no
longer required for the purpose, unless its further storage is necessary for evidence purposes or there are
statutory retention obligations to the contrary. This includes, for example, commercial law retention
obligations for business letters in accordance with Section 257 (1) HGB (6 years) and tax law retention
obligations in accordance with
§ 147 para. 1 AO of supporting documents (10 years). If the prescribed retention period expires, your data will
be blocked or deleted unless storage is still required for the conclusion or fulfillment of a contract.

Existence of automated decision-making

We do not use automated decision-making or profiling.

Provision of our website and creation of log files

1. If you only use our website for information purposes (i.e. no registration and no other transmission
   of information), we only collect the personal data that your browser transmits to our server. If you
   wish to view our website, we collect the following data:
   • IP address;
   • Internet service provider of the user;
   • Date and time of retrieval;
   • Browser type;
   • Language and browser version;
   • Content of the retrieval;
   • Time zone;
   • Access status/HTTP status code;
   • Amount of data;
   • Websites from which the request comes;
   • Operating system.
   This data is not stored together with your other personal data.
2. This data serves the purpose of user-friendly, functional and secure delivery of our website to you
   with functions and content as well as their optimization and statistical evaluation.
3. The legal basis for this is our legitimate interest in data processing in accordance with Art. 6 para.
   1 sentence 1 lit. f) GDPR, which also lies in the above purposes.
4. For security reasons, we store this data in server log files for a storage period of days. After this
   period has expired, they are automatically deleted unless we need to retain them for evidence
   purposes in the event of attacks on the server infrastructure or other legal violations.

1. We use so-called cookies when you visit our website. Cookies are small text files that your Internet
   browser places and stores on your computer. When you visit our website again, these cookies
   provide information to automatically recognize you. Cookies also include so-called “user IDs”,
   where user information is stored by means of pseudonymized profiles. When you visit our website,
   we inform you about the use of cookies for the aforementioned purposes and how you can object
   to this or prevent their storage (“opt-out”) by means of a reference to our privacy policy.
   A distinction is made between the following types of cookie:
   • Necessary, essential cookies: Essential cookies are cookies that are absolutely necessary for the operation of the website in order to store certain functions of the website such as logins, shopping cart or user input, e.g. regarding the language of the website.
   • Session cookies: Session cookies are required to recognize multiple uses of an offer by the same user (e.g. if you have logged in to determine your login status). When you visit our site again, these cookies provide information to automatically recognize you. The information obtained in this way is used to optimize our services and make it easier for you to access our site. When you close the browser or log out, the session cookies are deleted.
   • Persistent cookies: These cookies remain stored even after the browser is closed. They are used to store the login, to measure reach and for marketing purposes. They are automatically deleted after a specified period, which may vary depending on the cookie. You can delete the cookies at any time in the security settings of your browser.
   • Cookies from third-party providers (third-party cookies, especially from advertisers): You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. However, we would like to point out that you may then not be able to use all the functions of this website. Read more about.
     These cookies can be found in the respective privacy policies of the third-party providers.
2. Data categories: User data, cookie, user ID (inb. the pages visited, device information, access times and IP addresses).
3. Purposes of processing: The information obtained in this way serves the purpose of optimizing our web offers technically and economically and to provide you with easier and more secure access to our website.
4. Legal basis: If we process your personal data with the help of cookies on the basis of your consent (“opt-in”), then Art. 6 para. 1 sentence 1 lit. a) GDPR is the legal basis. Otherwise, we have a legitimate interest in the effective functionality, improvement and economic operation of the website, so that in this case Art. 6 para. 1 sentence 1 lit. f) GDPR is the legal basis. The legal basis is also Art. 6 para. 1 sentence 1 lit. b) GDPR if the cookies are set to initiate a contract, e.g. for orders.
5. Storage period/deletion: The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. Cookies are otherwise stored on your computer and transmitted from it to our website. As a user, you therefore have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.
   
   Here you will find information on deleting cookies by browser::Chrome: https://support.google.com/chrome/answer/95647
   Safari: https://support.apple.com/de-at/guide/safari/sfri11471/mac
   Firefox: https://support.mozilla.org/de/kb/cookies-und-website-daten-in-firefox-loschen
   Internet Explorer: https://support.microsoft.com/de-at/help/17442/windows-internet-explorer-delete-manage-cookies
   Microsoft Edge: https://support.microsoft.com/de-at/help/4027947/windows-delete-cookies
6. Objection and “opt-out”: You can generally prevent cookies from being stored on your hard disk,
   regardless of consent or legal permission, by selecting “do not accept cookies” in your browser
   settings. However, this may result in a functional restriction of our offers. You can object to the use
   of cookies from third-party providers for advertising purposes by opting out via this American
   website (https://optout.aboutads.info) or this European Website (http://www.youronlinechoices.com/de/praferenzmanagement/).

1. When contacting us by e-mail or post, your data will be processed for the purpose of handling the contact request.
2. If you have given your consent, the legal basis for the processing of the data is Art. 6 para. 1 sentence 1 lit. a) GDPR. The legal basis for the processing of data transmitted in the course of a contact request or e-mail, letter or fax is Art. 6 para. 1 sentence 1 lit. f) GDPR. The controller has a legitimate interest in the processing and storage of the data in order to be able to answer user inquiries, to preserve evidence from liability reasons and to be able to comply with its statutory retention obligations for business letters. If the contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 sentence 1 lit. b) GDPR.
3. We may store your details and contact request in our Customer Relationship Management System (“CRM System”) or a comparable system.
4. The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input screen of the contact form and those sent by email, this is the case when the respective conversation with you has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified. We store inquiries from users who have an account or contract with us for a period of two years after termination of the contract. In the case of statutory archiving obligations, the deletion takes place after their expiry: end of commercial law (6 years) and tax law (10 years) retention obligation.
5. You have the option to revoke your consent to the processing of personal data at any time in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR. If you contact us by email, you can object to the storage of your personal data at any time.

1. We have embedded YouTube videos from youtube.com on our website using the embedded function so that they can be accessed directly on our website. YouTube belongs to Google Ireland Limited, registration no.: 368047, Gordon House, Barrow Street, Dublin 4, Ireland.
2. Data category and description of data processing: Usage data (e.g. website accessed, content and access times). We have integrated the videos in the so-called “extended data protection mode” without using cookies to record user behaviour in order to personalize video playback. Instead, the video recommendations are based on the video currently being played. Videos played in enhanced privacy mode in an embedded player do not affect which videos are recommended to you on YouTube. When you start a video (click on the video), you consent to YouTube tracking the information that you have accessed the corresponding subpage or video on our website and using this data for advertising purposes.
3. Purpose of processing: Provision of a user-friendly offering, optimization and improvement of our content.
4. Legal basis: If you have given your consent (“opt-in”) for the processing of your personal data by the third-party provider using “etracker”, the legal basis is Art. 6 para. 1 sentence 1 lit. a) GDPR. The legal basis is also our legitimate interest in data processing for the above purposes in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR. In the case of services provided in connection with a contract, tracking and analysis of user behaviour is carried out in accordance with Art. 6 para. 1 sentence 1 lit. b) GDPR in order to be able to offer optimized services to fulfill the purpose of the contract with the information thus obtained.
5. Data transfer/recipient category: Third-party providers in the USA. The data collected is transferred to the USA and stored there. This also takes place without a user account with Google. If you are logged into your Google account, Google can assign the above data to your account. If you do not want this, you must log out of your Google account. Google creates user profiles from such data and uses this data for the purposes of advertising, market research or optimization of its websites.
6. Storage period: Cookies for up to 2 years or until you as the user delete the cookies.
7. Objection: You have the right to object to the creation of user profiles by Google. Therefore, please contact Google directly via the privacy policy below. You can opt out of advertising cookies here in your Google account: https://adssettings.google.com/authenticated.
8. In YouTube’s terms of use at https://www.youtube.com/t/terms and in Google’s privacy policy for advertising at https://policies.google.com/technologies/ads you will find further information.
9. Use of Google cookies and their advertising technologies, storage duration, anonymization, location data, how they work and your rights. General privacy policy of Google: https://policies.google.com/privacy.

1. We maintain profiles and fan pages on social media. When you use and access our profile in the respective network, the respective data protection notices and terms of use of the respective network apply.

2. Data categories and description of data processing: usage data, contact data, content data, inventory data. Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them). For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks. In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

3. Purpose of processing: Communication with users connected and registered on social networks; information and advertising for our products, offers and services; external presentation and image cultivation; evaluation and analysis of users and content of our social media presence.

4. Legal basis: The legal basis for the processing of personal data is our legitimate interest in the above purposes in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR. If you have given us or the person responsible for the social network consent to the processing of your personal data, the legal basis is Art. 6 para. 1 sentence 1 lit. a) in conjunction with Art. 7 GDPR. Art. 7 GDPR.

5. Data transfer/recipient category: Social network.
   
   
6. The data protection notices, information options and opt-out options of the respective networks / service providers can be found here:
   
   • Instagram – Service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) – privacy policy/opt-out: https://help.instagram.com/519522125107875, objection: https://help.instagram.com/contact/186020218683230; agreement on joint processing of personal data on Instagram pages (Art. 26 GDPR): https://www.facebook.com/legal/terms/page_controller_addendum.
   
   

Rights of the data subject

1. Objection or revocation against the processing of your data
   Insofar as the processing is based on your consent pursuant to Art. 6 para. 1 sentence 1 lit. a), Art. 7 GDPR, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.
   Insofar as we base the processing of your personal data on the balancing of interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR, you can object to the processing. This is the case if, in particular, the processing is not necessary for the performance of a contract with you, which is described by us in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or show you our compelling reasons worthy of protection on the basis of which we will continue the processing.
   You can object to the processing of your personal data for advertising and data analysis purposes at any time. You can exercise your right to object free of charge. You can inform us of your objection to advertising using the following contact details:
   VERmusic / TRUPIC Management
   Silvia Murauer
   Reutterstr. 68a
   80689 Munich, Germany
   E-mail address: management[at]trupic-music.com
2. Right to information
   You have a right to information about your personal data stored by us in accordance with Art. 15 GDPR. This includes, in particular, information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the origin of your data if it was not collected directly from you.
3. Right to rectification
   You have a right to rectification of incorrect data or completion of correct data in accordance with Art. 16 GDPR.
4. Right to erasure
   You have a right to erasure of your data stored by us in accordance with Art. 17 GDPR, unless statutory or contractual retention periods or other statutory obligations or rights to further storage prevent this.
5. Right to restriction
   You have the right to request a restriction on the processing of your personal data if one of the conditions in Art. 18 para. 1 lit. a) to d) GDPR is met:
   • If you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
   • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
   • the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, or
   • if you have objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet certain whether the legitimate reasons of the controller outweigh your reasons.
6. Right to data portability
   You have a right to data portability in accordance with Art. 20 GDPR, which means that you can receive the personal data we have stored about you in a structured, commonly used and machine-readable format or request that it be transferred to another controller.
7. Right to complain
   You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority, in particular in the Member State of your place of residence, your place of work or the place of the alleged infringement.