Effective Date: 1.6.2024
Last Updated: 6.6.2024
At Vandall OÜ (the "Provider"), we are committed to treating our users' (the "User(s)"/"You"/"Your") personal data with care and respect in relation to Your use of the Vandall platform ("Vandall") and all services provided on Vandall (collectively the "Service").
This Privacy Policy describes how the Provider collects, uses, and shares the personal data of individuals whenever they use the Service.
Please read this policy carefully to understand the Provider’s views and practices regarding Your personal data and how the Provider will treat it. By using the Service, You agree to the Terms of Use and accept the practices set out in this Privacy Policy. Please do not use the Service unless You agree with the Terms of Use and this Privacy Policy.
References to “Provider”, “Vandall”, “we”, “our”, or “us” pertain to Vandall OÜ, a company incorporated under the laws of Estonia with VAT number EE102739965 and registry code 16904181, whose principal office is at Harju maakond, Tallinn, Mustamäe linnaosa, Laki tn 24/2, 12915, Estonia.
Privacy laws, including the EU General Data Protection Regulation (“EU GDPR”), give individuals rights over their personal data and regulate the collecting and processing of personal data. The Provider is responsible for collecting and processing personal data and deciding the purposes and means for which personal data is processed. Personal data is any information that directly or indirectly identifies a natural living person, e.g., name and address, but may also include other information (as set forth below) uploaded to the Service.
If you are an EU resident and would like to request that your data be securely removed from our systems, please send an email with proof of EU residency to hello@vandall.com. We will remove all relevant data, so long as that removal is technically feasible, does not impact our legitimate accounting or business practices, does not impede or restrict the rights of our other users, and does not violate other regulatory or legal standards with which we must comply.
The Provider collects and processes the following data about You and/or Your physical representatives and Users ("Data Subject") as provided to Provider by You when You:
1.1 Register: When creating a user account with the Provider, You will be required to provide the following information: name, surname, email, phone number, and IPI/IPN number. The Provider may store this information so that it can be used for purposes explained in Section 2.
1.2 Create a Song Project: When a User starts a Song Project, Users are required to provide certain information such as User’s name and the name of the Song Project. When a User starts or joins a Song Project, the Provider may also collect and process other information disclosed by other Users, such as information about User’s (or other third party contributor’s) skills (e.g., instruments User plays), experience (where, what and when User performed), membership in relevant organizations, relevant agreements, User’s representation, location, lyrics, songwriter splits, distribution arrangements, photos, and recordings of the User.
1.3 Use the Service: When a User uses the Service, certain information will be collected automatically, including: (i) information about User’s interactions with the Service; (ii) the details of the queries a User makes; (iii) content they post, upload and/or contribute to the Service; (iv) technical data, which may include the URL Users have come from or gone to, User’s IP address, unique device ID, network and computer performance, browser type, language and identifying information, and operating system; and (v) location information. The Provider may store this information so that it can be used for purposes explained in Section 2.
1.4 Failure to Provide Relevant Data: The Provider may be unable to provide the Services in full if the User fails to provide the relevant data stated above.
1.5 Website Visits: When You visit the Provider’s website, the Provider may automatically collect information about Your visit through the use of cookies as explained in more detail below.
We use the information we collect to:
a. Provide, maintain, and improve our app and services. b. Process transactions and send you related information, including confirmations and invoices. c. Send you technical notices, updates, security alerts, and support messages. d. Respond to your comments, questions, and requests, and provide customer service. e. Communicate with you about products, services, offers, promotions, and events offered by Vandall and others, and provide news and information we think will be of interest to you. f. Monitor and analyze trends, usage, and activities in connection with our app and services. g. Personalize and improve the app and provide advertisements, content, or features that match user profiles or interests.
3.1 General Sharing: The Provider may share and/or disclose personal data about Users to its contractors, service providers, partners, potential investors, or buyers of all or part of the Provider, and to collecting societies, within the EU/EEA and outside the EU/EEA, to countries or territories whose laws may not provide an adequate level of protection for personal data, for the purposes stated in Section 2 above.
You understand that the Provider has no control over these third parties and no responsibility for the technologies they employ. Where such third parties process personal data on the Provider's behalf, the Provider will take every precaution to protect Your personal data as if it were being used in the EU. Provider will use one of the below safeguards to ensure protection:
3.2 Recognition and Credit: For the purpose of spreading recognition and credit to Users in relation to their contributions to musical works, the Provider may also share and/or sell personal data provided in the Service, such as Your name and role in the creation or production of music, to third parties who collect or publish information relating to track or other music information, such as online streaming services or collecting societies.
3.3 Marketing: The Provider will not sell or share Your contact details for marketing purposes without your prior consent.
3.4 Service Providers: Vandall may provide your personal information to certain service providers who are working for or with Vandall, as described in this policy, and who require access to such information to facilitate the provision of services, such as the provision of data storage or processing activities. Vandall will always attempt to limit the submission of your personal information to what is reasonably sufficient and necessary for the service providers to carry out their responsibilities relating to the fulfillment of their services.
3.5 Compliance with Applicable Laws: We may disclose the information that we collect to a third party where we are legally required to do so to comply with any applicable laws, regulations, legal processes, or government requests, including to meet national security or law enforcement requirements.
3.6 Vital Interests and Legal Rights: We may disclose the information that we collect where we believe that it is necessary to protect the vital interests of any person, or to exercise, establish, or defend our legal rights.
3.7 Business Transactions: We may share or transfer the information that we collect in connection with, or during negotiations of, any merger or acquisition of any part of our business, sale of company assets, or financing.
3.8 Your Specific Consent: We may share the information that we collect in other ways to which you specifically consent.
Data Subjects may be entitled, under local law, to exercise rights of access, rectification, erasure, or blocking of personal data processed by the Provider. The ability to exercise such rights may be limited by local law. If a Data Subject wishes to exercise any of these rights, they should write to hello@vandall.com stating Data Subject’s full name and, if applicable, their address, User name, and the email address used for registration. The Provider reserves the right to charge any fee permitted under national law to allow such rights to be exercised. California U.S.A. users under the age of 18 may request the removal of their content or information publicly posted on the Service by emailing us at hello@vandall.com. Please note that most of the user content that appears on the Service is stored and controlled by third-party providers; thus, complete and comprehensive removal of the content may not be possible.
4.1 Marketing Opt-Out: The User may at any time withdraw User’s consent to the use of their personal data for direct marketing purposes by emailing hello@vandall.com.
4.2 Data Retention: Provider will keep Your personal data only as long as necessary to provide You with the Service and for Provider’s legitimate and essential business purposes.
5.1 Security: Your privacy rights are important to us. Following the registration process, you may at any time choose to unsubscribe from our emails, while retaining access to our fee or subscription-based content. Every email sent by or on behalf of Vandall includes information as to how you can easily unsubscribe from such future communications. You may also unsubscribe from all or some of Vandall emails by updating your account settings with Vandall.
5.2 Account Deactivation: You may request to have your subscription deactivated and your information erased by emailing us at hello@vandall.com. Although Vandall may deactivate your registration or subscription pursuant to your request, it may continue to retain your information for reasonable and legitimate business purposes and as stated in this policy.
Provider may occasionally make changes to this Privacy Policy. When Provider makes material changes to this Privacy Policy, Provider will provide you with prominent notice as appropriate under the circumstances. For example, Provider may display a prominent notice within the Service or website, or send You an email or device notification.
We do not solicit or knowingly collect any personal information from children under the age of 13 without verifiable parental consent. If you are not 18 or older, you are not authorized to interact with Vandall. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors.
If you learn that a child under 13 has provided us with personal information without consent, please contact us. In addition, parents may use the following tips to help safeguard a child’s online experience: Teach children never to give out personal information, unless supervised by a parent or responsible adult, this includes their name, address, phone number, school, etc.; Know the sites your children are visiting and which sites are appropriate; Look for and understand privacy policies that govern websites that your child visits and know how your child’s information is being treated.
The Service is intended for users who are 18 years old or older. Provider does not knowingly collect personal data from children under the age of 18. If Provider becomes aware that it has inadvertently received personal data from a child under the age of 18, Provider will delete such data from its records.
You must ensure that any Data Subject who is Your physical representative or employee, whose personal data may be processed by the Provider, is made aware of the contents of this Privacy Policy and any sections to which it refers, and provides necessary consents, at the latest when their personal data is provided to the Provider.
8.1 You must also ensure that any personal data submitted by You relating to others (such as individuals not using the Service), whose personal data may be processed by the Provider, are made aware of the relevant contents and implications of the Terms of Use and provide You with any necessary consent to the collection and processing no later than at the time their personal data is shared with the Provider.
9.1 Third Party Websites: Some of the products or services made available through Vandall may be hosted on the website of Partners. This means that when you are on a Vandall website and click through to access those products or services, you may leave Vandall and be redirected to the site of the Partners, at which time you will be subject to the policies of the Partners. Vandall is not responsible for the privacy practices or the content of any of the Partners. You must review the privacy statements of each website you visit that collects information. This Policy applies only to information collected on Vandall.
9.2 Modifications and Amendments: Vandall may modify or amend this policy from time to time. We will not reduce your rights under this Privacy Policy without your consent. If we change our Privacy Policy, we will post those changes on this page in addition to updating the “Last Updated” date at the top of this Policy. For these reasons, we encourage you to read and access this Policy regularly. Your continued interaction with Vandall shall constitute your acceptance of any modified Policy. If we make any changes to the use of your personal information in a manner materially different from that stated at the time of collection, we will notify you by posting a notice on our website. If you object to any of such changes, or the overall Policy, please contact us via the contact information provided in this Policy.
9.3 Domestication and International Requests: Any person issuing legal process or legal information requests (e.g., discovery requests, warrants, or subpoenas) to Vandall shall properly domesticate the process or request and then serve Vandall in a jurisdiction where Vandall is resident or has a registered agent to accept such service on its behalf. Vandall does not accept legal process or requests directly from law enforcement entities outside the U.S. or Canada. Foreign law enforcement agencies should proceed through diplomatic or legal means to obtain data through a court where Vandall is located.
9.4 Translations: The English language version shall prevail. Any translations of this Policy are provided for convenience only.
This Policy was drafted with transparency, accuracy, and clarity in mind. However, it does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Requests should be sent to the address below.
Vandall is committed to resolving complaints about your privacy and our collection or use of your personal information. If you believe that Vandall has not complied with this Privacy Policy, or if you have any other complaint regarding the collection, use, or disclosure of information, Vandall will investigate your complaint and respond to you promptly. However, if you do not believe that we have responded to your complaint appropriately or in a timely manner, you may contact us at:
For any questions or concerns regarding this Privacy Policy, please contact us at:
Email: hello@vandall.com
Mailing Address:
Vandall OÜ
Harju maakond, Tallinn, Mustamäe linnaosa, Laki tn 24/2, 12915