SNGLS DAO and its partners and affiliates (also referred to as “SNGLS DAO”, “we”, “our”, “us”) is a governance technology layer that controls the parameters of the SNGLS Media Distribution Protocol. Please read this data protection notice carefully to understand how we may collect, use and disclose personal data of artists, creators and users (also referred to as “you”, “your”).
Responsible body is:
Poststrasse 30, 6300 Zug, Switzerland
You can contact our company Data Protection Officer at:
Address: Poststrasse 30, 6300 Zug, Switzerland
We process personal data that we receive from our customers as part of our business relationship.
Relevant personal information is:
In addition, we may also collect:
We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR):
SNGLS DAO, affiliated legal entities and, if applicable, third-party service providers contracted by SNGLS DAO, gain access to your data to the extent that the data is required to fulfill the respective contractual and legal obligations. Our service providers and deputy agents may also receive data for these purposes, provided they maintain the appropriate level of confidentiality.
It should be noted that we, as a firm, are under a contractual obligation to maintain secrecy about all customer-related information we have. We may only disclose information about you if it is required by law or if you have given your consent for us to do so.
Under these conditions, recipients of personal data may include companies in the following categories:
Processing of personal data in this context may happen for any of the following purposes:
Other data recipients may be those parties to which you have consented us to transmit data, or for which you have exempted us from keeping secrecy.
Please note that the consent may have been issued directly to us or directly to an external intermediary (e.g. a comparison portal).
A transfer of data to offices in the countries outside the European Union (so-called “third countries”) takes place when:
Furthermore, a transfer of your personal data to third-country entities is foreseen in the following cases:
Your personal data will be processed in the areas of account management, payment transactions, and risk model development within SNGLS DAO at our locations within the European Economic Area and the US, in compliance with European data protection standards.
The use of third country service providers can be authorized if they provide additional written instructions on how they will comply with the level of data protection in Europe and ensure the adequate level of protection by applying one of the following measures:
We process and store your personal information as long as it is necessary for the fulfillment of our contractual and legal obligations.
If the data is no longer required for the fulfillment of contractual or legal obligations, it will be regularly deleted, unless temporary further processing of that data is necessary for the following purposes:
Each data subject has the right to information under Article 15 of the GDPR, the right of correction under Article 16 GDPR, the right to cancellation under Article 17 GDPR, the right to restriction of processing under Article 18 GDPR, the right to object under Article 21 GDPR and the right to data portability under Article 20 GDPR. In addition, there is the right of appeal to a competent data protection supervisory authority (Article 77 GDPR).
You may revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent that were issued to us or our predecessors prior to the validity of the Basic Data Protection Regulation, i.e. before May 25, 2018. Please note that the revocation only works for the future; processing that took place before the revocation is not affected.
As part of our business relationship, you must provide the personal information necessary to enter into a business relationship and perform its contractual obligations, or we are required to collect it by law. Without this information, we will generally not be able to enter into contractual relationship or provide you with our services.
In particular, according to the money laundering regulations, we may be obliged to identify you prior to the establishment of a business relationship on the basis of your identity document and to record the name, place of birth, date of birth, nationality, address and identity card details. In order for us to be able to fulfill this legal obligation, you must provide us with the necessary information and documents in accordance with the Anti Money Laundering Act and immediately notify us of any changes that occur during the business relationship. If you do not provide us with the necessary information and documents, we may not start or continue a potential business relationship with you.
To establish and conduct the business relationship, we may use automated decision-making processes in accordance with Article 22 GDPR. If required by law, we inform the customer in such a case, taking into account the provisions of Article 13 paragraph 2 lit. f GDPR specifically about this and its rights under Article 22 (3) GDPR.
We sometimes process your data automatically with the aim of evaluating certain personal aspects (so-called profiling). For example, we use profiling in the following cases:
Due to legal and regulatory requirements, we are committed to combating money laundering, the financing of terrorism and property-related offenses. Data evaluations may be carried out to provide you with targeted information and advice on products. To this end, we may use evaluation tools that enable needs-based communication and advertising, including market and opinion research.
Pursuant to Article 6 (1) lit. e GDPR (Data Processing in the Public Interest) and Article 6 (1) lit. f GDPR (data processing on the basis of a balance of interests) you have the right, at any time during your relationship with us, to prevent the processing of your personal data and profiling, as that term is defined under Article 4(4) GDPR. If you object, we will no longer process your personal information or engage in profiling unless we can establish, in accordance with GDPR guidelines, compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or that the processing is for the purposes of asserting, exercising or defending legal claims.
In individual cases, we process your personal data in order to operate direct mail. You have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is associated with such direct mail. If you object to such processing for direct marketing purposes, we will no longer process your personal data for these purposes.
The objection should be in writing and should be directed to:
Address: Poststrasse 30, 6300 Zug, Switzerland
A cookie (“Cookie” or “Cookies”) is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some Cookies are only accessed when certain features are used or certain preferences are selected, and some Cookies are constantly used. You can find out more about each of our current Cookies on the list below. We update this list periodically, so there may be additional Cookies that are not yet listed. Web beacons, tags and scripts may be used on our website or in emails to help us to deliver Cookies, count visits, understand use and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis.
Please note, in this regard, your opt-out options as listed in the notes below regarding the use of web analytics services.
When a Cookie is created, it is assigned a randomly generated identification number. Your name, your IP address or similar data that would allow the Cookie to be assigned to you will not be stored in the Cookie. We only save a session identifier to recognize the user. We also do not store any information in the Cookies that third parties can evaluate. Our Cookies therefore contain pseudonymous data.
You can read how to activate or deactivate Cookies in the help function of your browser.
However, some features on our website, such as online application and online customer service, require Cookies to enable navigation and control access. The complete functionality of the website is therefore only available for activated Cookies.
Click here to learn more about the “Private Browsing” setting and managing Cookie settings in Firefox;
Click here to learn more about “Incognito” and managing cookie settings in Chrome;
Click here to learn more about “InPrivate” and managing cookie settings in Internet Explorer; and
Click here to learn more about “Private Browsing” and managing cookie settings in Safari.
If you want to learn more about Cookies, or how to control, disable or delete them, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third-party advertising networks, including Google, permit users to opt out of, or customize preferences associated with your internet browsing. To learn more about this feature from Google, click here.
In accordance with Article 21 (1) of the General Data Protection Regulation, you can object at any time to the processing of data through Cookies by the web analysis service used by SNGLS DAO by setting a "blocker cookie" (also called "opt-out cookie"). You can find out how to set a blocker cookie by exploring the links in the below section "Which web analytics services do we use?".
For web audience measurements, we use Matomo (http://www.matomo.org), a cookie based open source web analysis service that we operate on our web server. Matomo helps us understand how visitors use our website. Matomo truncates your IP address so we cannot identify you. We use the information generated by Matomo solely to evaluate how our audience uses the website, i.e. to comply anonymously aggregated reports on website activities. We do not pass any personal data to third parties.
The legal basis for this processing is our legitimate interest in measuring our reach and improving our website. You may disable Matomo based web audience measurement by disabling cookies as mentioned above.
Integration of services and contents of third parties
It may happen that content from third parties, such as videos from YouTube or Facebook, maps from Google Maps, RSS feeds or graphics from other websites are included on the snglsDAO website. This always presupposes that the providers of this content (hereinafter referred to as "third party provider") perceive the IP address of the users in order to send the content to the browser of each user. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. However, we do not have any influence on whether the third parties provide the IP address. If we learn additional information about the policies of the third party providers, we will inform the users.