Privacy and Cookie Policy Statement pursuant to Art. 13 of EU General Data Protection Regulation No. 2016/679 (GDPR)

Sugarmusic SPA, with registered office at Galleria del Corso 4, 20122 Milan, [Italy], (hereinafter “Sugarmusic”), is constantly committed to protecting the on-line privacy of its users.

A)      Source of personal data and Data Controller

This document was drafted pursuant to Art. 13 of EU Regulation No. 2016/679 (hereinafter: “Regulation“) to make you aware of our Privacy Policies. The general methods for processing the personal data of the website users and the cookies are described, as well as how your personal information is managed when you use our website www.sugarmusic.com (hereinafter “Website”). The information and data you provide or otherwise acquired when using the services of Sugarmusic, such as for example: access to the allocated area of the Website, newsletters, etc. , hereinafter “Services”, will be processed in compliance with the provisions of the Regulation and the confidentiality obligations on which Sugarmusic bases its business.

According to the Regulation standards, the processing carried out by Sugarmusic is based on principles of lawfulness, correctness, transparency, restriction of the purposes and of storage, data minimisation, exactness, integrity and confidentiality.

The Data Controller in charge of the processing carried out through the Website is Sugarmusic , with registered office at Galleria del Corso 4, Milan, [Italy]. You may write to it for any information concerning personal data processing.

Requests for information are to be made in writing and emailed to the Data Controller at sugarmusic@legalmail.it.

This Privacy Policy Statement is only rendered for this Website and not for other websites possibly examined by the user via links. Please refer to possible specific Website sections, where specific information and any requests for consent for individual processing are available.

B)      Types of data

Following browsing the Website, we inform you that Sugarmusic only processes personal data [Art. 4(1) of the Regulation] (hereinafter “Personal Data”.

In particular, the following Personal Data are processed via the Website:

1.       Browsing data

During normal operation, the computer systems and software procedures designated to run the Website acquire certain Personal Data, the transmission of which is implicated in using Internet communication protocols. This information is not collected to be associated with identified individuals, rather due to the fact that the very nature of this information could allow the users to be identified through processing and associations with data held by third parties. This category of data includes IP addresses or domain names of the computers used by the users to connect to the Website, URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in sending the request to the server, the size of the file obtained by way of response, the numeric code indicating the data response status of the server (successful, error, etc.) and other parameters concerning the user’s operating system and computer environment. These data are only used in order to obtain anonymous statistical information on Website use and to control its proper operation (see the cookies section below) and to identify anomalies and/or abuse, and they are deleted immediately after the processing. The data could be used by the competent authorities to ascertain liabilities in the event of hypothetical computer crimes to the detriment of the Website.

2.       Data provided voluntarily by the Data Subject

Apart from what is specified for the browsing data, the user is free to provide his/her Personal Data indicated on any application forms on the Website (e.g. to activate newsletters, for free registration, to make a purchase, etc.). Failure to provide the data could result in the impossibility of providing the Service. In these cases, only the information required for the Service requested (see the specific instructions for details) are requested.

When using certain Website Services, the Personal Data of third parties you have sent to Sugarmusic could be processed. In such a hypothesis, you are the autonomous Data Controller, taking on all the legal obligations and responsibilities. In this regard, you grant the broadest indemnification with respect to any dispute, claim, request for compensation for damage due to processing, etc., Sugarmusic may be subjected to by third parties whose Personal Data were processed through the use of the Website functions in violation of the applicable standards on personal data protection. In any case, should you provide or in any other manner process Personal Data of third parties when using the Website, you guarantee, from now on, while assuming all associated responsibilities, that such particular processing hypothesis is based on a suitable legal basis pursuant to Art. 6 of the Regulation that legitimises processing the information in question.

C)      Processing purposes and legal bases

The processing of the Personal Data we intend carrying out, upon specific consent by you when required, serves the following purposes:

• Allowing the Services on the Website to be provided

The legal basis for the processing is the execution of pre-contractual measures implemented on request by the same [Art. 6(1)(b) of the Regulation] because the processing is required in order to provide the Service.

Providing Personal Data for these purposes is optional but possible failure to provide the data could result in the impossibility of activating the Services provided by the Website.

D)     Intended recipients of the Personal Data

Your Personal Data may be shared for the above purposes, with:

• persons authorized by Sugarmusic to process Personal Data, which is required to perform activities strictly associated with providing the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees and system administrators);

• third parties possibly appointed with managing the Website who typically act in their role as Data Supervisors (the complete and up-to-date list of Data Supervisors is provided and available at www.sugarmusic.com);

• subjects, institutions or authorities to whom it is mandatory to disclose your Personal Data in virtue of legal provisions or orders from the authorities.

E)      Transferring Personal Data

Some of your Personal Data are shared with intended recipients who may be outside the European Economic Area. Sugarmusic guarantees that these intended recipients process your Personal Data in compliance with the Regulation. Indeed, the transfers may be based on a decision of adequacy on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis.

F)       Your privacy rights pursuant to Articles 15 of the Regulation, as integrated and amended

Pursuant to Articles 15 of the Regulation, as integrated and amended, you have the right, at any time, to request from Sugarmusic: access to your Personal Data, the rectification or erasure thereof, or to object to the processing thereof; you have the right to request the restriction of the processing in the cases set forth by Art. 18 of the Regulation, and also to obtain the data concerning you in a format that is structured, common and readable by an automated device, in the cases set forth by Art. 20 of the Regulation.

Requests are to be made in writing and emailed to the Data Controller at sugarmusic@legalmail.it.

In any case, you always have the right to make a complaint to the competent Supervisory Body (Data Protection Authority) pursuant to Art. 77 of the Regulation should you feel your Personal Data have been processed contrarily to the legislation in force.

G)     Amendments

This Privacy Policy has been in effect since 22/05/2018. Sugarmusic reserves the right to amend or simply update the contents hereof, in whole or in part, also due to changes in the applicable legislation. Sugarmusic will inform you of these changes are soon as they are introduced, and they will be binding as soon as they are published on the Website.

Sugarmusic therefore invites you to regularly visit this section for the most recent and up-to-date version of the Privacy Policy so you are always updated on the data collected and the use thereof by Sugarmusic.