Privacy Policy
11 October 2023
Data controller: Anotherblock AB
Registration number: 559341-5317
Address: Repslagargatan 17B, 118 46 Stockholm
Contact email: info@anotherblock.com
1. How we respect your privacy
When you use our website and services, we work hard to protect your information. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information. Our website use cookies for tracking and analytics purposes, please see separate cookie policy.
This website and our services are not directed toward children (as defined by local law) nor do we knowingly collect information from children (as defined by local law) without parental consent except where in compliance with applicable laws.
2. In this document we use certain defined terms
| “Personal Data” | When we refer to we mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. |
|---|---|
| ”NFT” | An NFT is a non-fungible token or similar digital item implemented on a blockchain, which uses Smart Contracts to link to or otherwise be associated with certain content or data consisting of a Recording. |
| “Recording” | This is a piece of recorded music owned and controlled by a Rightsholder. |
| “Rightsholder” | A Rightsholder is the person or entity that owns the rights in and to a Recording and has all rights to list the Recording for sale as an NFT pursuant to our Terms of Use. |
| “NFT Owner” | This is the person who acquires an NFT through our service and is entitled to a portion of the royalties that may be generated through the commercial exploitation of the Recording associated with the relevant NFT. |
| “Ownership Agreement” | This is an agreement between the Rightsholder and NFT Owner. We are not a party to any Ownership Agreements. The Ownership Agreement states the share of royalties that the NFT Owner is entitled to as and when (if at all) any royalties are generated and become payable to the NFT Owner. |
| “Smart Contract” | A Smart Contract is a program stored on the blockchain. This respect to our service, the Smart Contract functions as a payment instruction which reflects the terms of the Ownership Agreement. The Smart Contract details who the Rightsholder is, the percentage share due to NFT Owner(s) and the respective NFT Owner’s Wallet ID. |
| “Wallet ID” | When you purchase an NFT you will need to have a crypto wallet set up where you can safely keep your crypto and receive payments pursuant to the Ownership Agreement and the Smart Contract. Each NFT Owner’s Wallet ID will be visible at all times on the blockchain tied to the respective NFT. |
3. Personal data that we collect and why
Data that we collect from YOU:
| Categories of personal data | Description |
Account Information | While using our service, service providers may ask you to provide certain personal information in order to register with their services. The only information we receive regarding your account details are: - Whether you are a Rightsholder (or a person representing a Rightsholder), an NFT Owner or a person interested in becoming an NFT Owner - Wallet ID - Email address - Username for your account with google, X and/or apple |
| Rightsholder Information | This is information that distinguishes you from other Rightsholders and consists of the following data which is needed for you to sell NFTs on our service: - Full personal name - Artist name and other relevant credits on the Recording - Username and other handles or IDs that you use on the service - Company details such as organization number and address - Email address - Country - Image and other likeness (as shared by you on the service) - Wallet ID - Bank account details - Details about your ownership in the Recording, such as the percentage owned, desired percentage to sell, whether the Recording is released, how and in what capacity you control and/or own the Recording |
| Ownership Agreement Information | This is information that stems from the agreement between the NFT Owner and the Rightsholder and which sets the deal terms for sharing of royalties. |
NFT Owner Information NFT Owner Data | If you wish to purchase NFTs via our service, we will ask for the following information: - Wallet ID - The NFTs that you bid on and/or purchase - The amount paid for NFTs When purchasing NFTs via our service, we will collect the following information to comply with accounting purposes. - Country - Wallet ID |
| Regulatory Information | Whether you are an NFT Owner of a Rightsholder we may, from time to time, need to verify your identity for regulatory purposes and may request any of the following: - Identification, such as date of birth, passport or national ID card, bank statement or other information linking you to an address. |
| Recording Information | Prior to making a Recording available as an NFT on our service, we will need to know more about the specific recording data and credits, such as: - Voice and sounds - IPI number - ISRC codes for individual recordings - Meta data provided within or in connection with recordings - Image and other likeness (as shared by you on the service) - Artist name and aliases - Producer name and aliases |
| Royalty Statement Information | If you are a Rightsholder, you agree to share with us any and all royalty statements applicable to the exploitation of the Recording which has been made available as an NFT so that we may issue payments to the respective NFT Owner(s) Wallet ID pursuant to the Ownership Agreement and the Smart Contract. If and when a Recording licensed through our service is made available for commercial sales and exploitation this will generate certain information which is relevant to our obligation to collect payments and to report and pay royalties: - Relevant sales figures (i.e. number of streams, downloads, views etc) - Country of sales - ISRC-code - Meta data |
| Communications | You may choose to communicate with us in a number of ways in order request information about our services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us. When doing so we may collect your personal information, such as: - username - chat messages, email content, email address, phone number, or mailing address |
| Job Applications | You may be interested in working for us. If you apply for a job or internship, we will collect the information you submit to us. Typically, such information consists of: - Your personal application - CV and cover letter - Professional qualifications - Contact information such as email and/or phone number |
| Data that we collect from THIRD PARTIES: | |
| Usage Information | This is aggregated and anonymized data that we collect from our service providers as and when you use the service: - Technical data, such as, IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform - Data about your visits on our website (clickstream, date, time etc) - Data about which site you visited prior to our service - The time and date of your visit on our service, and the time spent on our site - Data about page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page - Information about your devices, device identifiers, and from which devices you visit our website and make use of the service, which may include mobile network information (including phone number), IP address, language and time zone, operating system, hardware version, device locations (including country specific geographic locations) - Other online identifiers (such as cookies, pixel tracking technologies) |
| Digital Currency Exchange Information | In accordance with applicable laws, we or our service providers may obtain information about you from public databases, credit bureaus and ID verification service providers for the purpose of verifying your identity. Such information may include: - Full name - Address - Publicly available information - credit history - status on any sanctions’ lists maintained by public authorities, and other relevant data. We obtain this information only to comply with our legal obligations, such as anti-money laundering laws. In some cases we may process additional information about you to assess risk and ensure that our services are not used fraudulently or for any type of illicit activities. |
| Promotions | Not everyone who wishes to purchase a specific NFT may get the opportunity to do so. This is because NFTs are sold through a bidding process. If you have entered into a bidding process, we store your information and contact you through your account when new NFTs are on offer. Your information will only be collected with your consent. |
| Log-In and Chat Service Functions | Our service uses third party services providers to enable you to create an account with our service, log in and communicate with us and other users. We use following third-party services to deliver: - Privy.io for log-in Functions - Chat Service Functions If you decide to register through or otherwise grant us access to a third-party service, we may collect certain personal data that is already associated with your account on said service, such as your name, your email address, your activities, or your contact list associated with that account. The information that we collect will be subject to the information that you choose to share through said third-party service. Your interactions with third-party service providers are always subject to and governed by the privacy policy applicable to the service. Link to Privy.io’s privacy policy - https://www.privy.io/privacy-policy Our service may include widgets such as “share this” buttons. |
| NFT Payment and Access Solutions | All purchases of NFTs and offers to buy NFTs flow through third party services which offer: - NFT Access List Functions - Purchase and Payment Functions Any information you share with third-party service providers will be subject to the privacy policies and terms of use applied by the respective company offering said services. We will not receive more information that the information you share with said companies and which they are allowed to share pursuant to privacy laws and the respective privacy policies. |
| Data that we collect from the BLOCKCHAIN | |
| NFT Owner Payment Information | As and when royalties become due to the NFT Owner we collect the following data from activity that is publicly visible and/or accessible on blockchains. This may include: - blockchain addresses - information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us - Smart Contract information - Wallet ID |
4. Our legal grounds for processing personal data
Our purposes and legal basis for data processing Our purposes | Legal basis for our purpose | Categories of personal data use for our purposes | |
| Providing our service | Performance of a contract Legitimate interest Consent | Account Information NFT Owner Data | |
| Troubleshootingresolving issues, diagnosing problems | Performance of a contract Legitimate interest | Usage Data Communications | |
| Marketing, campaigns and promotions | Legitimate interest Consent | Account Information Communications Promotions | |
| Developing and improving the service and new functions | Legitimate interest Consent | User data Usage date Communication data | |
| Fulfilling contractual obligations to third parties | Performance of a contract Legitimate interest | Account Information NFT Payment and Access Information NFT Owner Payment Information Rightsholder Information NFT Owner Information | |
| Handling infringement matters | Legitimate interest | Account Information Recording Information NFT Owner Information Royalty Statement Information Communications | |
| Making royalty payments | Performance of a contract Compliance with a legal obligation | NFT Payment and Access Information Royalty Statement Information Payment Information Ownership Agreement Information | |
| Contacting you for A&R and other creative purposes | Legitimate interest | Recording Information Rightsholder Information | |
| Recruitment | Legitimate interest | Job Applications Communications | |
| Regulatory purposes | Legal Requirements | Regulatory Information |
5. Who we share your personal data with We may share your personal data
with selected third parties:
| Categories of recipients | Our purpose for sharing data: |
|---|---|
| Service providers | To enable service providers to provide the services we need them to fulfil in order for us to be able to keep the service available. Service providers are third party companies that we engage for: - Log-In and Communications Functions - NFT Access Lists and Promotions - Payment providers and crypto wallet services |
| Royalty accounting services: | Services that we engage in order to receive royalty statements. |
| Potential buyers of the service: | Any tentative third-party buyer of our business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. All or substantially all our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets. |
| Fraud protection and credit risk reduction; | If we believe in good faith that we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. |
| Authorities: | If we believe in good faith that we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others. |
| Direct marketing purposes: | We may share your personal data, such as your name and email address, with our business partners, on the legal basis of your consent. |
6. Ownership Agreement
Please note that we are not a party to the Ownership Agreement between the NFT Owner and the Rightsholder. The percentage of royalties payable to the NFT Owner can be observed publicly from the blockchain that is the NFT.
7. How we keep your personal data safe
We protect your personal data from all kinds of threats: loss, alteration, unauthorized disclosure, or access. We do this in a variety of ways depending on where we store and use it.
Occasionally, we might have to transfer your personal data to service providers and business partners located outside the European Economic Area. We do our best to keep your personal data safe in these cases. Please read section 9 in this Privacy Policy on how we may transfer data outside of the European Economic Area and the safeguards we apply.
8. how long we keep your personal data
We keep your personal data for as long as the personal data is relevant for use by us for the purposes as indicated in this Privacy Policy.
Please note that personal data that has been published online might be downloaded and shared by individuals. In such cases we do not control the source and will be unable to delete the personal data. We might also store your personal data longer than stated above if it is necessary because of legal requirements that we are subject to.
9. Transfers of your personal data outside the European Economic Area
Our sharing of your personal data in accordance with this Privacy Policy may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA we ensure a similar degree of protection is afforded to it. As a safeguard, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. In addition to this, we will implement requirements and safeguards that may be required by law.
You may be entitled, in accordance with applicable law, to request a copy of relevant safeguards implemented. Please contact us at info@anotherblock.com for any questions in this regard.
10. Your privacy rights
You have many rights regarding your personal data. Read more about them below. If you would like to exercise them or learn more about them, feel free to contact us. You can find contact details at the top and end of this Privacy Policy. Please note that some of the rights may not be applicable to you.
| Right of access | You have the right to obtain confirmation as to whether we process your personal data, and, if we do, request access to your personal data as well as information in relation to our processing. If you have any questions or would like to learn more about what personal data we process, you are always welcome to contact us, and we will provide you with further information |
|---|---|
| Right to rectification | If you believe we store incorrect personal data, such as misspelt or previous name or address, you can ask us to correct this |
| Right to erasure / right to be forgotten | You have the right to request that we permanently erase your personal data from our records. |
| Right to restrict the processing activities | You have the right to restrict our processing activities in certain situations. This means we will continue to store your personal data, but we will temporarily stop any other processing. Why would you want to do this? For example, if you have asked us to fix incorrect personal data. In this situation you may want us to stop processing until the personal data is correct. |
| Right to data portability | In certain situations, you have the right to ask us to send your personal data in digital form to you or directly to another controller. |
| Right to object | You have the right to object to the processing of your personal data, even when we have a legitimate legal reason to process it. You can do this when we process your personal data on the basis of our legitimate interest, and you believe your personal interest outweighs ours. If you do not want us using your personal data for direct marketing purposes, including profiling, we will comply in any case. |
| Right to withdraw consent | In case the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before this withdrawal. Please note that all aspects of an initiated marketing campaign cannot be stopped once initiated upon a withdrawal of consent. |
| Right to lodge a complaint with a supervisory authority | If you are not satisfied with the way we treat your personal data, you have the right to lodge a complaint against us to the relevant supervisory authority. |
11. Links to third-party websites and social media services
Our communication may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. We do not accept responsibility or liability for these third-party sites.
12. Changes to this Privacy Policy
Any material changes that we make to this Privacy Policy will be posted here prior to the changes becoming effective.
13. Who to contact
If you have any questions about this Privacy Policy or our processing of personal data, feel free to contact us at info@anotherblock.com.