Privacy Policy

Effective as of Thursday, June 18th, 2020.

Welcome to Starling, a service provided by Starling Records, LLC (dba Starling) (“Starling,” “we,” “us,” or “our”).

Starling provides a digital music distribution service which distributes music through online stores and streaming services on behalf of its customers and collects and distributes the related earnings.

This Privacy Policy explains how we collect, disclose and otherwise process Personal Data (defined below) when you use our website (the “Site”) and all related sites, widgets, tools, data, software, APIs and other services provided by Starling (together with the Site, “Service”), and your choices concerning our data practices.

You” or “your”, as used in this Privacy Policy, refers to the individual to whom Personal Data relates.

Please read this Privacy Policy before using our Service or submitting any Personal Data to Starling and contact us if you have any questions.

1. INFORMATION WE COLLECT

When you use our Service or otherwise interact with us, we collect information that alone or in combination with other information could be used to identify you (“Personal Data”) as follows:

Account Data

If you wish to register for the Service, you will need to provide us with certain Personal Data, such as your name, email address, password, postal address, phone number, as well as any biography/profile information (including profile photos) you would like associated with your music at online stores and streaming services.

Creator Data

We will collect information about how you categorize yourself with respect to your content (for example, whether you are a musician, a label or some other category of creator, the music you upload, and information relating to how often your music is played in online stores and streaming services).

Communication Data

If you contact customer service or otherwise communicate with us by email or otherwise, we may collect Personal Data related to those communications, including the contents of the communications and the data and time they occurred.

Payment Data

In order for us to pay your royalties to you, we will need to collect your PayPal ID and certain tax information. When you pay for our Service, we collect certain billing information through our payment processor Stripe, Inc. (“Stripe”), such as billing address, payment card details, and bank account information. Accordingly, in addition to this Privacy Policy and our Terms of Service, Personal Data related to the payments you make through the Service are also processed according to Stripe’s services agreement and privacy policy.

Fan Data

One aspect of the Service allows musicians and content creators registered to the Service to communicate with and better understand their fans. Accordingly, if you are a fan of one of our musician and content creator customers, we may collect your email address from online stores and streaming services if you follow or otherwise interact with our musician and content creator customers, so they can keep you posted on their news, events and other updates.

Social Media Data

We have pages on social media sites like Instagram, Facebook, Twitter, and YouTube (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us through your settings on the Social Media Site, such as your profile and contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Online Activity Data

When you visit, use and interact with the Site, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Site, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation pattern. In particular, the following information is created and automatically logged in our systems:

2. HOW WE USE PERSONAL DATA

We use Personal Data to provide the Service, including uploading your music to online stores and streaming services, sending accounting statements to you, and paying you the royalties you are owed. This processing is necessary to perform our contract with you.

We also use Personal Data as necessary for the following legitimate business interests:

For information about what we mean by legitimate interests and the rights of individuals in the European Union (“EU”), please see the “EU Users” section below.

Marketing. We may contact you to provide information we believe will be of interest to you. For instance, if you elect to provide your email address, we may use that information to send you promotional information about our products and services. If we do, where required by law, for example if you are in the EU, we will only send you such emails if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving emails by following the instructions contained in each promotional email we send you or by contacting us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Site and Services and to respond to your requests.

3. HOW WE SHARE AND DISCLOSE PERSONAL DATA

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

4. DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

5. UPDATE YOUR INFORMATION

If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us at support@starling.co. We will address your request as required by applicable law.

6. NOTICE TO CALIFORNIA RESIDENTS

Online Tracking and Do Not Track Signals: We may, and we may allow third party service providers to, use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will describe how we do so in this Privacy Policy.

Personal Data Collection, Use, and Disclosure: The following disclosures are intended to provide additional information about (1) the categories of Personal Data we collect, (2) the sources of Personal Data we collect, (3) how we use each category of Personal Data, and (4) how we disclose Personal Data. Nothing in this Notice limits our ability to use or disclose Personal Data as described above.

We do not and will not sell your Personal Data.

Privacy Rights: To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the Personal Data we collect:


Exercising Your Rights: California residents can exercise the above privacy rights by emailing us at support@starling.co

Verification: in order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Data for verification. If we cannot verify your identity, we will not provide or delete your Personal Data.

Authorized Agents: you may submit a request to know or a request to delete your Personal Data through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.

7. CHILDREN

Our Service is not directed to children who are under the age of 13. Starling does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Starling through the Service please contact us and we will endeavor to delete that information from our databases.

8. EU USERS

Scope. This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).

Data Controller. We are the data controller for Personal Data described in this Privacy Policy. You can find our contact information, and the contact information of our EU-based representative, in the “Contact Us” section below.

Legal Bases for Processing. This Privacy Policy (the paragraph “How We Use Personal Data”) describes the legal bases we rely on for the processing of your Personal Data. Please contact us if you have any questions about the specific legal basis we are relying on to process your Personal Data.

As used in this Privacy Policy, “legitimate interests” means our interests in conducting our business and developing a business relationship with you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Your Rights. Pursuant to the EU General Data Protection Regulation (or GDPR), you have the following rights in relation to your Personal Data, under certain circumstances:

Please see the “Contact Us” section below for information on how to exercise your rights.

9. INTERNATIONAL TRANSFER

Starling is based in the United States. If you are accessing our Service from the EU or other regions with laws governing data collection and use, please note that your Personal Data will be transferred to and stored in the United States as necessary for the purposes described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located.

Where we transfer your Personal Data out of the EU we will take steps to ensure that your Personal Data receives an adequate level of security protection where it is processed and your rights continue to be protected. Some of our service providers (such as Google LLC and Tipalti, Inc.) are certified to the Privacy Shield framework for data transfers (for more information visit https://www.privacyshield.gov/welcome). For more information, please contact us as described below.

10. LINKS TO OTHER WEBSITES

The Site may contain links to other websites not operated or controlled by Starling, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

11. COOKIES

We and our partners use cookies to operate and administer our Site, make it easier for you to use the Site during future visits, and gather usage data on our Site.

For more information about the cookies used on our Site, please refer to our Cookie Policy, which forms part of this Privacy Policy.

12. SECURITY

You use the Service at your own risk. We comply with industry standards to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Starling via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

13. YOUR CHOICES

Whether or not you provide Personal Data to us is completely up to you, but if you choose not to provide information that is needed to use some features of our Site, you may be unable to use those features. You can also contact us to request access to your data or to ask us to update, correct, or delete your Personal Data.

14. CHANGES TO THE PRIVACY POLICY

The Service, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

15. CONTACT US

If you have any questions about our Privacy Policy or the information practices of the Site, please feel free to contact us at support@starling.co.

If you are an individual in the EU, you can also contact EDPO, who has been appointed as Starling's representative in the EU pursuant to Article 27 of the GDPR on matters related to the processing of Personal data activities that take place in the EU. To make such an inquiry, please contact EDPO at https://edpo.brussels/.



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