Privacy PolicyPrivacy Policy

entered into force on the 26th April 2024

1. INTRODUCTION

This Privacy Policy shall describe how we collect and process your personal data. It shall provide information on the purposes and the legal basis of the processing, the scope of the data to be processed, the identity of the data controllers and data processors, the duration of said processing, and your rights and remedies regarding data processing.

This Privacy Policy is designed to comply with the General Data Protection Regulation of the European Union, the GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC) and Act CXII of 2011 on Freedom of Information, the Information Act.

We reserve the right to unilaterally amend this Policy at any time. Naturally, we will notify data subjects of any changes by publishing the amended Privacy Policy on https://polyglotmusic.eu website. By using the service after the amendment has come into force, the user accepts the amended Privacy Policy. The data will be treated confidentially and all security, technical and organisational measures will be taken to ensure the security of the data.

2. THE DATA CONTROLLER

Music Hungary Zeneműkiadó Ltd.

Seat: 1012 Budapest, Kuny Domokos utca 9. I/3.

Company reg. number: 01-09-927501

E-mail: hangveto@hangveto.hu

Music Hungary Ltd. is engaged in the production and publishing of sound recordings, and enters into music publishing contracts with authors and performers, through which it represents them and acquires intellectual property rights. It also works in the field of knowledge transfer and music-related film productions, as well as a programme to boost international music distribution.

3. DATA PROCESSING

3.1. Processing of data in the course of sound recording and music publishing activities

The scope of the data processed: the name, address, date and place of birth of the artist, the name of the artist’s mother, the name (registered office, tax number, company registration number) of the company representing the artist in the conclusion of the contract, the name, e-mail address and telephone number of the person authorised to represent the company; the same data of the other copyright holders of the work; the same data of the other artists still included in the phonogram.

Purpose of processing: conclusion of the contract, making and publishing the phonogram, management of the musical works.

Legal basis for processing: the legal basis is the conclusion and performance of the contract and our legitimate interest in fulfilling our legal obligations relating to the concluded contract and the verification thereof.

Transfer of data: the names of the authors / artists are transferred to our partners who produce the media, artwork and covers for the sound recordings, on the basis of our legal obligation to include their names, and to the extent necessary for our contracts with the music publishers on behalf of the artists. We will also publish the names of authors / artists on the basis of the right to attribute authors and performers.

Time limit for deletion of data:

Deadline for deletion of data: we will keep the data for as long as it is justified for accounting or tax procedure reasons, i.e. for 8 years after the last document has been completed (Section 169 (2) of the Act on Accounting). If a dispute arises in connection with the contract or its performance, the data will be kept for the duration of the dispute.

3.2. Data management in the POLYGLOT project

The programme, co-funded by Creative Europe, involves seven countries exchanging songs on the basis of a set of criteria and trying to promote localised versions of other countries’ songs (translated into their own language) in each other’s markets.

3.2.1. For authors / artists who apply to the Open Call:

The scope of the data processed: name, contact e-mail address, telephone number, introductory material, image and sound recordings, the names of the authors of the submitted songs.

Purpose of the processing: pre-registration for the advertised programme and identification of the registrant in order to participate in the programme.

Legal basis for the processing: voluntary consent of the data subjects and the fulfilment of our contractual obligations for the implementation of the POLYGLOT project, and respect for copyright.

3.2.2. For authors / artists who are selected to participate in the project and with whom we sign a contract to use their song:

The scope of the data processed:

The name of the author / artist, the name of the company (registered office, tax number, company registration number) that represents the author / artist in the contracting process, the name of the person authorised to represent this company, e-mail address, telephone number, the names of other artists still involved in the performance,
The details of the author / artist in the introduction and CV sent by the author / artist, including the details of the photographer who took the photographs included in the promotional material received from the artist and the details of the editor who otherwise contributed to the production of the material, if included in the material received,
The image and/or sound recording (video clip) of the performance and the personal data contained therein.
In the case of a successful participation in the public vote (taking place in 2026), a concert performance will also take place, and therefore additional data necessary for booking accommodation and purchasing airline tickets will be recorded at the time of the contract: name, address, date and place of birth, mother’s name, passport number, possible food sensitivities (in case of catering requirements) of the performers and of the persons travelling together.
A recording of the concert will be made, in the form of images and/or sound.
A picture and a sound recording (werk videos) of the song will be made.

Purpose of processing: is the conclusion and performance of the contract, the performance at the event, the adequacy of the catering service related to the performance (prevention of allergic reactions), airline tickets and accommodation reservations, contact management, coordination of organisational issues. The visual and/or audio material of the artists’ performances is intended to be used for news coverage or other promotional purposes. Promotional material is intended to promote the event and the performers to the public through publication.

Legal basis for processing is the conclusion and performance of the contract and our legitimate interest in fulfilling and proving our legal obligations in relation to the concluded contracts. The legal basis for the processing of visual and/or audio material of the artists’ performances is the consent of the artists. The inclusion of the names of the authors of the promotional material is also required by copyright law, so the legal basis for this processing in the promotional material is the fulfilment of our legal obligations.

3.2.3. In the case of artists who perform the songs but are not contracted by Music Hungary Ltd., their data will be made available to the POLYGLOT Project consortium members on the basis of the contract with our partner:

The scope of the data processed:

the name of the artist, the name (registered office, tax number, company registration number) of the company representing the artist in the contract, the name, e-mail address and telephone number of the person authorised to represent the company, the name, e-mail address and telephone number of the tour manager, the name of other artists who will be involved in the performance,
If your arrangement wins the public vote (taking place in 2026), it will be recorded at a live event, in the form of visual and/or audio material.
In the case of song recording, a picture and a sound recording (werk video) will be made.

Purpose of processing: fulfilment of the contract with our partner, performance at the event, coordination of organisational issues. The visual and/or audio material of the artists’ performances is intended to be used for news coverage or other promotional purposes.

Legal basis for processing: the performance of a contract with our partner and our legitimate interest in complying with and proving our legal obligations in relation to the contracts concluded.

3.2.4. In the case of persons participating in the POLYGLOT Project events, in the case of appearing in the photos taken there, and in our materials presenting our partners:

The scope of the data processed:

– name, CV details, portrait or other photo.

Purpose of processing: be used for news coverage or other promotional purposes for the event. The presentation of our partners is for information and promotional purposes.

Legal basis for processing: Our legitimate interest in fostering our relationships and promoting our activities and the POLYGLOT Project.

In all cases described in point 3.2.2. and 3.2.3.:

Transfer of data: the data described above will be transferred to the extent necessary to our partners involved in the organisation of the events: the accommodation organiser, the accommodation provider, the tour operator, the airline, the co-organiser. We will only transfer the data to our partners who provide sufficient guarantees to implement appropriate technical and organisational measures to ensure compliance of the processing with the requirements of the GDPR and to protect the rights of the data subjects.

The personal data provided during online registration may also be processed by our contractual partners providing online web services and event management.

In all cases described in point 3.2.:

Time limit for deletion of data: we will keep the data for as long as it is justified for accounting and tax procedure reasons, i.e. for 8 years after the last document has been completed (Section 169 (2) of the Act on Accounting). If a dispute arises in connection with the contract or its performance, the data will be kept for the duration of the dispute.

In the case of artists with whom we have not concluded a contract but who have consented to the processing of their data, the period of data processing is 6 months after the end of the programme for which they have registered or after the acceptance of the accounts closing the project.

3.3. Websites, sending newsletters

The scope of the data processed: On our website you can also subscribe to our newsletter by entering your name and e-mail address.

Purpose of processing: sending e-mail newsletters to interested parties about events and programmes organised by us and updates of the project. If you subscribe to receive our newsletter, we may send newsletters to subscribers at a frequency of our choosing.

Legal basis for processing: voluntary consent of the data subjects.

Transfer of data: the data will not be transferred and will be processed by the service provider of our websites. Our newsletter database and the sending of newsletters is carried out by Mailjet’s newsletter sending service. On our website, you can also subscribe to our newsletter by entering your name and e-mail address.

Purpose of processing: If you subscribe to receive our newsletter, we may send newsletters to subscribers at a frequency of our choosing.

Legal basis for processing: voluntary consent of the data subjects.

We process the data provided until the data subject who subscribes has opted out of the use of the data for this purpose. You can unsubscribe from the newsletter by clicking on the unsubscribe link at the bottom of the newsletter. Personal data will be deleted within 10 working days of receipt of the request.

4. DATA STORAGE, DATA SECURITY

Our computer systems and other data storage locations are located at our headquarters and at our IT service providers and data processors.

4.1. Paper documents

We have a large number of written, paper-based contracts. These are stored in folders in the office. Our more recent contracts and other documents are also stored digitally in scanned form.

4.2. Musical material

We receive a large amount of musical material in the course of our activities. These are stored in our office, either saved digitally or on media, labelled and categorised.

4.3. Informatics

We select and operate the information technology tools used to process personal data in the provision of the service in such a way that the data processed:

We select and operate the IT tools used to process personal data in the provision of the service in such a way that the data processed:

a) accessible to those authorised to access it (availability);

b) its credibility and authenticity are ensured (authenticity of processing);

d) protected against unauthorised access (data confidentiality).

In particular, appropriate measures will be taken to protect the data against unauthorised access, alteration, disclosure, disclosure, erasure or destruction, accidental destruction, damage or loss, and inaccessibility resulting from changes in the technology used.

We use Google Drive for all our work and to manage our documents and daily work database. This gives us remote access to all our documents. Our documents are protected by Google’s system, including GDPR-compliant data protection. Our employees also work in the office via online access to Google Drive. Access to Google Drive is granted via a dedicated account to which individual access rights can be assigned. Our stored directory structure is backed up and stored on an external storage medium.

We provide our employees with a company mobile phone and telephone number. Contact details of partners, customers and suppliers are stored on the phones. The phones are also used to view e-mail accounts and for correspondence, so e-mail addresses and data received via e-mail are also processed in accordance with this Privacy Notice.

We do not use access control or camera surveillance systems.

5. THE RIGHTS OF DATA SUBJECTS

Data subjects may have access to their personal data processed by us, i.e. they may request information, in particular, on the scope, purpose, duration, source and sharing of data and their data protection rights. The request for information is free of charge, but we are entitled to charge a fee for any further requests for information relating to the same data.

If the data we process is not accurate, the data subject may request that it be corrected. The data subject may also request the erasure of personal data we process or the restriction of our processing, provided that this is not restricted by law.

Where processing is based on consent, the data subject may withdraw his or her consent at any time in the future.

The data subject may, in the context of his or her right to data portability, request that a machine-readable and non-proprietary copy of his or her personal data provided to us and processed on the basis of his or her consent or for the performance of a contract be provided to us or transferred to another controller upon his or her request.

The data subject has the right to object to the processing and use of his or her personal data in our legitimate interests.

The data subject has the right to lodge a complaint about our processing. To respond to a complaint received by us as soon as possible and in any event within 30 days. Complaints may also be lodged with the competent authority (National Authority for Data Protection and Freedom of Information, NAIH, address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; phone: +36-1-391-1400; e-mail: ugyfelszolgalat@naih.hu) or the competent court in the place of residence or domicile of the data subject.