Notice pursuant to Art. 13 EU Regulation 2016/679 for the Processing of Personal Data

We inform you that, in accordance with EU Regulation 2016/679 (infra: “Regulation”), your Personal Data will be processed by Sugarmusic S.p.A. a Socio Unico with registered office in Galleria del Corso, 4 - 20122 Milan (MI), as data controller ("Data Controller”).

Purpose, legal basis and voluntary nature of the processing

The Data Controller will process your personal data (art. 4.1 of the Regulations) specifically your first name, last name and e-mail address, for the following purpose:

Sending via automated tools (e-mail, push notifications, SMS) of newsletters and promotional and marketing communications about the Owner's products and initiatives, including communications aimed at conducting market research and participation in prize shows and events.

It should be noted that the Data Controller collects a single consent for the marketing purposes described herein, pursuant to the General Provision of the Guarantor for the Protection of Personal Data “Guidelines on Promotional Activities and Countering Spam” of July 4, 2013; if, in any case, you wish to object to the processing of your data for marketing purposes performed by the means indicated herein, as well as to revoke the consent given; you may do so at any time by contacting the Data Controller at the contact details indicated in this notice, without affecting the lawfulness of the processing based on the consent given before revocation.

The legal basis of processing for the above purposes refers to the expression of consent by the data subject to the processing of his or her personal data (Art. 6.1.a of the Regulation).

The provision of your Personal Data is voluntary; no consequences are foreseen in case of your refusal.

Recipients of personal data

Your Personal Data may be shared with:

persone persons authorized to process your Personal Data in accordance with Articles 29 and 32(4) of the Regulations and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who must process your Personal Data by reason of their job duties, system administrators;

subjects who, in the provision of services in favor of the Company, process data on behalf of the Company itself and typically act as Data Processors (e.g., contracting companies in the case of entrusting work, even partial, to external companies; third parties involved in the management of information systems and web platforms; third-party collaborators that the Company uses for specific services of a technical and/or organizational nature - such as IT service providers, external collaborators and consultants; companies belonging to the Group; etc.). For a complete and updated list of Data Processors, write to privacy@sugarmusic.com

entities and authorities, which normally act as autonomous Data Controllers within the meaning of Article 4(7) of the Regulation, to which it is mandatory to communicate your Personal Data in accordance with the regulatory provisions applicable to the Company or by virtue of contractual obligations or in execution of pre-contractual measures.

With regard to the possible transfer of Data to Third Countries, the Data Controller informs that the processing will take place according to one of the modalities allowed by the applicable law, such as the consent of the Data Subject, the execution of a contract concluded between the Data Subject and the Data Controller or the execution of pre-contractual measures adopted at the request of the Data Subject; the conclusion or execution of a contract concluded between the Data Controller and another natural or legal person in favor of the data subject; the adoption of Standard Clauses approved by the European Commission; the selection of entities operating in countries considered safe by the European Commission. You can get more information, upon request, from the Data Controller at the contacts above.

How your personal data will be processed

In relation to the stated purposes, the processing of personal data is carried out using manual, computer and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data, in addition to compliance with the specific obligations enshrined in the law.

Data retention

Your Personal Data will be kept only as long as necessary for the purposes for which it is collected, respecting the principle of minimization set forth in Article 5(1)(c) of the GDPR. In particular, Your Personal Data will be kept for 24 (twenty-four) months.

More information is available from the Data Controller.

I suoi diritti privacy (ex artt. 15 e ss. del Regolamento)

You have the right to request from the Company, at any time, access to your Personal Data, its rectification or erasure, the restriction of processing, and to receive the data concerning you in a structured, commonly used, and machine-readable format in the cases provided for under Article 20 of the Regulation.

We also inform you that you have the right to object ex art. 21 of the Regulation, for legitimate reasons, to the processing of your data, for example you may object at any time to the sending of direct marketing with automated tools (sms, mms, email, push notifications, fax) and not (paper mail, telephone with operator); moreover, it remains without prejudice to the possibility of exercising this right in part, that is, in this case, objecting, for example, only to the sending of promotional communications carried out by automated tools.

At any time you may revoke ex art. 7 of the Regulation, the consent already given, without affecting the lawfulness of the processing carried out prior to the revocation of consent.

Requests should be addressed in writing to the Data Controller at the following address.: privacy@sugarmusic.com

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to applicable law.

(Version 1 of 30th January 2025)

Notice pursuant to Art. 13 EU Regulation 2016/679 for the Processing of Personal Data- Scouting

We inform you, pursuant to Art. 13 of the EU Regulation 2016/679 (infra: “Regulation”), that your Personal Data provided through the online form (master data: first name, last name; contact data: e-mail address, telephone number; material published at the indicated links, including Music Demos, i.e. music tracks in physical/digital format owned by the user or with respect to which the user disponses the relevant permissions ; professional category; information pertaining to his/her professional profile and/or artistic career; alias/art name/pseudonym) will be processed by Sugarmusic S.p.A. with registered office in Galleria del Corso, 4 - 20122 Milan (MI), as data controller ("Data Controller”), for the following purposes:

Scouting activities for the evaluation of musical proposals and possible collaborative relationships, including future ones, including recontacting, using the contact information provided, in order to schedule any meetings and/or auditions that may be necessary for evaluation.

The legal basis for the processing for the above purpose is the performance of a contract to which the data subject is a party or of pre-contractual measures taken at the request of the data subject, pursuant to Art. 6(1)(b) of the Regulation.

The provision of your Personal Data for the above purposes is voluntary, but if you fail to do so, it will not be possible to follow up on the scouting activity.

The data may be accessible to other companies in the Group to which the Controller belongs for the same purposes as above and/or for administrative-accounting purposes; this processing is done on the basis of the legitimate interest of the Controller under Article 6(1)(f) of the Regulation to meet internal administrative, financial and accounting needs, taking into account the provisions of Recital 48 of the GDPR.

Your Personal Data may be shared with:

persone persons authorized to process your Personal Data in accordance with Articles 29 and 32(4) of the Regulations and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who must process your Personal Data by reason of their job duties, system administrators;

subjects who, in the provision of services in favor of the Company, process data on behalf of the Company itself and typically act as Data Processors (e.g., contracting companies in the case of entrusting work, even partial, to external companies; third parties involved in the management of information systems and web platforms; third-party collaborators that the Company uses for specific services of a technical and/or organizational nature - such as IT service providers, external collaborators and consultants; companies belonging to the Group; etc.). For a complete and updated list of Data Processors, write to privacy@sugarmusic.com

entities and authorities, which normally act as autonomous Data Controllers within the meaning of Article 4(7) of the Regulation, to which it is mandatory to communicate your Personal Data in accordance with the regulatory provisions applicable to the Company or by virtue of contractual obligations or in execution of pre-contractual measures.

With regard to the possible transfer of Data to Third Countries, the Data Controller informs that the processing will take place according to one of the modalities allowed by the applicable law, such as the consent of the Data Subject, the execution of a contract concluded between the Data Subject and the Data Controller or the execution of pre-contractual measures adopted at the request of the Data Subject; the conclusion or execution of a contract concluded between the Data Controller and another natural or legal person in favor of the data subject; the adoption of Standard Clauses approved by the European Commission; the selection of subjects adhering to international programs for the free circulation of data or operating in countries considered safe by the European Commission. More information is available upon request from the Data Controller.

In relation to the stated purposes, the processing of personal data is carried out using manual, computer and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data, in addition to compliance with the specific obligations enshrined in the law.

Your Personal Data will be retained in accordance with the principles of minimization and limitation of storage referred to in Article 5, par. 1, lett. c) and e) of the Regulation for a period of 12 (twelve) months from their provision, in order to allow the Data Controller to complete the evaluation process, as well as to meet the need to evaluate possible future collaborative relationships. At the end of this period, your data will be permanently deleted.

Pursuant to Articles 15 et seq. of the Regulation, the data subject has the right to request at any time, access to his or her personal data, rectification or erasure of the same (pursuant to Articles 16 and 17 of the Regulation), limitation of processing in the cases provided for by Article 18 of the Regulation, to object to processing (pursuant to Article 21 of the Regulation) , to obtain in a structured, commonly used and machine-readable format the data concerning him or her, in the cases provided for by Article 20 of the Regulation.

At any time, the data subject has the possibility to lodge a complaint with the competent supervisory authority (Garante per la Protezione dei Dati Personali) pursuant to Article 77 of the Regulation, if he or she considers that the processing of your data is contrary to the legislation in force.

Requests should be addressed in writing to the Data Controller at the following address: privacy@sugarmusic.com.

(Version 1.2 of 6th May 2025)

PRIVACY POLICY 

Privacy Notice pursuant to Article 13 of EU General Data Protection Regulation 2016/679 (GDPR)

Sugarmusic S.p.A. a Socio Unico with registered office at Galleria del Corso 4, 20122 Milan (hereinafter the “Company” or “Data Controller”), is constantly committed to protecting its users' online privacy. 

A) Source of Personal Data and Data Controller

This document has been drafted pursuant to Article 13 of EU Regulation 2016/679 (hereinafter the “Regulation”) to inform you about our privacy policy. It describes the general methods of processing users’ personal data and how your personal information is managed when you use our website www.sugarmusic.com (hereinafter the “Website”). The information and data you provide or that are otherwise acquired in connection with the use of the Company's services – such as access to the restricted area of the Website, newsletters, etc. (hereinafter the “Services”) – will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that underpin the Company’s operations.

In accordance with the Regulation, processing carried out by the Company will be based on the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity, and confidentiality.

The data controller for the processing carried out through the Website is Sugarmusic S.p.A. a Socio Unico, with registered office at Galleria del Corso 4, 20122 Milan, as defined above. You may contact the Company for any information regarding the processing of personal data.

This notice applies only to this Website and not to other websites that may be accessed by the user via links. Specific information notices and any requests for consent regarding individual processing activities may be provided in specific sections of the Website.

B) Types of Data

In connection with your visit of the Website, we inform you that the Company will process personal data (Article 4(1) of the Regulation), hereinafter referred to as “Personal Data”. Specifically, the Personal Data processed through the Website includes the following:

1)         Browsing data

The IT systems and software procedures employed for the operation of the Website acquire, during their normal  operation, certain Personal Data, the transmission of which is implicit in the use of Internet communication protocols. Such information is not collected to be associated with identified individuals, however, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the Website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), and other parameters related to the user’s operating system and IT environment. This data is used solely to obtain anonymous statistical information on the use of the Website and to ensure its proper functioning (see Cookie Policy – www.sugarmusic.com/cookie-policy), to identify anomalies and/or abuses, and is deleted immediately after processing. The data could be used by competent authorities to ascertain responsibility in case of potential cybercrimes against the Website.

2)         Data voluntarily provided by the user

Apart from what has been  specified for browsing data, users are free to provide personal data requested in any forms on the website (e.g., to subscribe newsletters, registration for free, etc.). Failure to provide such data may result in the inability to deliver the requested service. In such cases, only the data strictly necessary to provide the requested service will be collected (see specific information notices). 

While using certain Website Services, you may provide the Company with Personal Data of third parties. In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities. In this regard, you hereby fully indemnify the Company against any complaints, claims, or demands for compensation for damages that may arise from third parties whose Personal Data has been processed through your use of the Website’s  functionalities in violation of applicable data protection laws. In any case, should you provide or otherwise process Personal Data of third parties when using the Website, you guarantee – and assume all related responsibility – that such processing is based on an appropriate legal basis pursuant to Article 6 of the Regulation that legitimizes the processing of the information in question.

C) Purpose of the processing and legal bases

The processing of your personal data, subject to your specific consent where necessary, has the following purposes:

To enable the provision of the Website’s Services;

The legal basis for the processing is the performance of a contract to which the data subject is a party or the implementation of pre-contractual measures taken at the data subject’s request (Article 6(1)(b) of the Regulation).

Providing Personal Data for these purposes is optional, but failure to do so may result in the inability to activate certain Services provided by the Website.

D) Recipients of Personal Data

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

individuals who are authorized by the Company to process Personal Data, as necessary to carry out activities strictly related to the provision of the Services, who have committed to confidentiality or are under a proper legal obligation of confidentiality (e.g., employees and system administrators).

third parties potentially in charge of managing the Website, typically acting as Data Processors (the full and updated list of Data Processors is available at www.sugarmusic.com)

entities, bodies, or authorities to whom the data must be disclosed under legal provisions or orders from authorities. 

E) Transfers of Personal Data

Some of your Personal Data may be shared with recipients located outside the European Economic Area. The Company ensures that the processing of your Personal Data by such recipients is carried out in compliance with the Regulation. In fact, such transfers may be based on an adequacy decision, on Standard Contractual Clauses approved by the European Commission, or another appropriate legal basis. 

F) Retention of Personal Data

Your Personal Data will be stored only for as long as necessary for the purposes for which it was collected, in compliance with the data minimization principle under Article 5.1(c) of the Regulation.

In any case, your personal data will be retained for the time required to provide the Website’s Services. For data retention periods related to specific forms on the Website, please refer to the relevant information notices.

G) Your Privacy Rights under Articles 15 et seq. of the Regulation

Pursuant to Articles 15 and following of the Regulation, you have the right to request from the Company, at any time, access to your Personal Data, its rectification or erasure, object to its processing, request the restriction of processing in the cases provided for under Article 18 of the Regulation, and to receive the data concerning you in a structured, commonly used, and machine-readable format in the cases provided for under Article 20 of the Regulation.

Requests must be submitted in writing to the Data Controller at the following address: privacy@sugarmusic.com 

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to applicable law.

H) Amendments

This privacy policy is effective as of 30/01/2025. The Company reserves the right to modify or simply update its content, in part or in full, including due to changes in applicable legislation. The Company will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website.

The Company therefore invites you to regularly review this section to be aware of the latest and most up-to-date version of the privacy policy, so that you are always informed about the data collected and how the Company uses it.

(version 1 of 30/01/2025)

COOKIE POLICY 

Notice pursuant to Art 13 of the EU General Data Protection Regulation 2016/679 (GDPR).

This notice is an extension of the information on the use of cookies and other technical identifiers provided to the data subject through the simplified notice on the banner shown when accessing this website.

This page is addressed to users who consult the website accessible electronically at the following address: www.sugarmusic.com  (the “Site”)

The Data Controller is Sugarmusic S.p.A. a Socio Unico with registered office in Galleria del Corso, 4 - 20122 Milan (MI) (hereinafter the “Company” “Data Controller”).

1. Definitions, characteristics and enforcement

Cookies are small text files that sites visited by the user send and record on your terminal device (computer or mobile devices such as smartphones and tablets), to be then retransmitted to the same sites on your next visit.

It is precisely because of cookies that a site remembers the user's actions and preferences (such as, for example, login data, language chosen, font size, other display settings, etc.) so that they do not have to be indicated again when the user returns to visit said site or navigates from one page to another of itCookies, therefore, are used to perform computer authentication, session tracking, facilitation of content enjoyment, and storage of information regarding the activities of users accessing a site and may also contain a unique identifier code that allows tracking of the user's navigation within the site itself for statistical or advertising purposes.

Classification of Cookies

In connection with your visit of the Site, in addition to cookies stored directly by the site you are visiting (so-called “first-party cookies”), you may also receive on your computer cookies from sites or web servers other than the one you are visiting (so-called “third-party cookies”).

Some operations could not be accomplished without the use of cookies, which in some cases are therefore technically necessary for the very operation of the site.

There are various types of cookies, depending on their characteristics and functions, and these can remain on the user's computer for different periods of time: so-called “session cookies” which are automatically deleted when the browser is closed; so-called “persistent cookies,” which remain on the user's equipment until a predetermined expiration date.

Then there are cookies, so-called “analytics cookies,” used for the purpose of evaluation with regard to the effectiveness of an information society service provided, for the design of a website or to help measure its “traffic,” i.e., the number of visitors including possibly broken down by geographic area, time slot of connection or other characteristics.

Under current Italian law, the use of cookies does not always require the user's express consent. In particular, the so-called “technical cookies”, i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communication network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. In other words, these are cookies that are indispensable for the operation of the site or necessary to perform activities requested by the user, in the absence of which certain operations could not be performed or would be more complex and/or less secure.

Among technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see Guidelines cookies and other tracking tools of June 10, 2021 and subsequent clarifications, hereinafter only “Guidelines”) also includes:

analytics cookies if through their use the possibility of arriving at the direct identification of the data subject is precluded (so-called “single out”), thus preventing the use of analytics cookies that may be direct and unique identifiers. In addition, their structure must provide for the possibility of referring them not to one but to several devices, so as to create reasonable uncertainty about the IT identity of the subject receiving it (usually by masking portions of the IP address within the cookie itself as indicated in the Guidelines). Finally, in order to be identified as technical, analytics cookies should be limited to the production of aggregate statistics only and that they are used relative to a single site/mobile application, so as not to allow tracking of a person's browsing using different applications or browsing different websites; session cookies;

For so-called “profiling cookies,” vice versa, i.e., those aimed at creating profiles related to the user and used in order to modulate the provision of the service in a personalized manner beyond what is strictly necessary for the provision of the service or to send targeted advertising messages in line with the preferences expressed by the same in the context of web browsing and/or to carry out analysis and monitoring of visitor behavior, prior consent of the user is required.

Types of cookies used by the Site

The Data Controller has classified the cookies in use according to their type of use as follows.

Since the obligation to comply with the relevant regulations also descends for third-party cookie providers, we refer to the link to the web pages of the third-party sites, in which the user can find the cookie consent collection forms and their related notices.

Google Analytics / Facebook Pixel

This website uses Google Analytics or Facebook Pixel, two web analysis services provided respectively by Google Inc. (“Google”) and Facebook. These services use "cookies" to help the website analyze how users interact with the site. The information generated by the cookies about your use of the website is transmitted to and stored on the servers of these Providers. The Providers will use this information to evaluate your use of the website, compile reports on website activity for website operators, and provide other services relating to website activity and internet usage. The Providers may also transfer this information to third parties where required by law or where such third parties process the information on the Providers' behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, doing so may prevent you from using the full functionality of this website. By using this website, you consent to the processing of your data by these third-party Providers in the manner and for the purposes outlined above.

For more information about Google Analytics click here.

For more information about Facebook Pixel click here.

Your decisions about cookies

You can select a feature whereby your computer will notify you whenever a cookie is set, or you can choose to disable all cookies. You can select such functionality through your browser settings. Each browser is slightly different, so we encourage you to identify in the “Help” menu of your browser the correct way to change cookie-related functionality. If you decide to disable cookies, you will not have access to many features that make your experience on our site more efficient and some of our services will not function properly. 

Privacy rights under Articles 15 et seq. of the EU General Data Protection Regulation

Pursuant to Articles 15 et seq. of the Regulation, you have the right to request from the Company, at any time, access to your Personal Data, the rectification or deletion thereof, you have the right to object to the processing, you have the right to request the limitation of processing in the cases provided for by Article 18 of the Regulation, as well as the right to obtain in a structured, commonly used and machine-readable format the data concerning you, in the cases provided for by Article 20 of the Regulation.

At any time he/she may revoke ex art. 7 of the Regulation, the consent already given, without affecting the lawfulness of the processing carried out prior to the revocation of consent.

Requests should be addressed in writing to the Data Controller at the following address: privacy@sugarmusic.com

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (the Italian Data Protection Authority – Garante per la Protezione dei Dati Personali), pursuant to Article 77 of the Regulation, if you believe that the processing of your personal data violates the applicable data protection legislation.

(version 1 of 30/01/2025)

Notice pursuant to Art. 13 EU Regulation 2016/679 for the Processing of Personal Data

Data Controller

We inform you that, in accordance with EU Regulation 2016/679 (infra: “Regulation”), your Personal Data will be processed by Sugar s.r.l. with registered office in Galleria del Corso, 4 - 20122 Milan (MI), as data controller ("Data Controller”).

Purpose, legal basis and voluntary nature of the processing

The Data Controller will process your personal data (art. 4.1 of the Regulations) specifically your first name, last name and e-mail address, for the following purpose:

Sending via automated tools (e-mail, push notifications, SMS) of newsletters and promotional and marketing communications about the Owner's products and initiatives, including communications aimed at conducting market research and participation in prize shows and events.

It should be noted that the Data Controller collects a single consent for the marketing purposes described herein, pursuant to the General Provision of the Guarantor for the Protection of Personal Data “Guidelines on Promotional Activities and Countering Spam” of July 4, 2013; if, in any case, you wish to object to the processing of your data for marketing purposes performed by the means indicated herein, as well as to revoke the consent given; you may do so at any time by contacting the Data Controller at the contact details indicated in this notice, without affecting the lawfulness of the processing based on the consent given before revocation.

The legal basis of processing for the above purposes refers to the expression of consent by the data subject to the processing of his or her personal data (Art. 6.1.a of the Regulation).

The provision of your Personal Data is voluntary; no consequences are foreseen in case of your refusal.

Recipients of personal data

Your Personal Data may be shared with:

persone persons authorized to process your Personal Data in accordance with Articles 29 and 32(4) of the Regulations and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who must process your Personal Data by reason of their job duties, system administrators;

subjects who, in the provision of services in favor of the Company, process data on behalf of the Company itself and typically act as Data Processors (e.g., contracting companies in the case of entrusting work, even partial, to external companies; third parties involved in the management of information systems and web platforms; third-party collaborators that the Company uses for specific services of a technical and/or organizational nature - such as IT service providers, external collaborators and consultants; companies belonging to the Group; etc.). For a complete and updated list of Data Processors, write to privacy@sugarmusic.com

entities and authorities, which normally act as autonomous Data Controllers within the meaning of Article 4(7) of the Regulation, to which it is mandatory to communicate your Personal Data in accordance with the regulatory provisions applicable to the Company or by virtue of contractual obligations or in execution of pre-contractual measures.

With regard to the possible transfer of Data to Third Countries, the Data Controller informs that the processing will take place according to one of the modalities allowed by the applicable law, such as the consent of the Data Subject, the execution of a contract concluded between the Data Subject and the Data Controller or the execution of pre-contractual measures adopted at the request of the Data Subject; the conclusion or execution of a contract concluded between the Data Controller and another natural or legal person in favor of the data subject; the adoption of Standard Clauses approved by the European Commission; the selection of entities operating in countries considered safe by the European Commission. You can get more information, upon request, from the Data Controller at the contacts above.

How your personal data will be processed

In relation to the stated purposes, the processing of personal data is carried out using manual, computer and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data, in addition to compliance with the specific obligations enshrined in the law.

Data retention

Your Personal Data will be kept only as long as necessary for the purposes for which it is collected, respecting the principle of minimization set forth in Article 5(1)(c) of the GDPR. In particular, Your Personal Data will be kept for 24 (twenty-four) months.

More information is available from the Data Controller.

I suoi diritti privacy (ex artt. 15 e ss. del Regolamento)

You have the right to request from the Company, at any time, access to your Personal Data, its rectification or erasure, the restriction of processing, and to receive the data concerning you in a structured, commonly used, and machine-readable format in the cases provided for under Article 20 of the Regulation.

We also inform you that you have the right to object ex art. 21 of the Regulation, for legitimate reasons, to the processing of your data, for example you may object at any time to the sending of direct marketing with automated tools (sms, mms, email, push notifications, fax) and not (paper mail, telephone with operator); moreover, it remains without prejudice to the possibility of exercising this right in part, that is, in this case, objecting, for example, only to the sending of promotional communications carried out by automated tools.

At any time you may revoke ex art. 7 of the Regulation, the consent already given, without affecting the lawfulness of the processing carried out prior to the revocation of consent.

Requests should be addressed in writing to the Data Controller at the following address.: privacy@sugarmusic.com

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to applicable law.

(Version 1 of 30th January 2025)

Notice pursuant to Art. 14 EU Regulation 2016/679 for the Processing of Personal Data- Scouting

We inform you, pursuant to Art. 14 of the EU Regulation 2016/679 (infra: “Regulation”), that your Personal Data (master data: first name, last name; contact data: e-mail address, telephone number; material published at the indicated links, including Music Demos, i.e. music tracks in physical/digital format owned by the user or with respect to which the user disponses the relevant permissions ; professional category; information pertaining to his/her professional profile and/or artistic career; alias/art name/pseudonym) will be processed by Sugar S.r.l. with registered office in Galleria del Corso, 4 - 20122 Milan (MI), as data controller ("Data Controller”), for the following purposes:

Scouting activities for the evaluation of musical proposals and possible collaborative relationships, including future ones, including recontacting, in order to schedule any meetings and/or auditions that may be necessary for evaluation.

The legal basis for the processing for the above purpose is the performance of a contract to which the data subject is a party or of pre-contractual measures taken at the request of the data subject, pursuant to Art. 6(1)(b) of the Regulation. 

The source from which the above data originated is Sugarmusic S.p.A., a company part of Gruppo Sugar Holdings S.r.l.

Your Personal Data may be shared with:

persone persons authorized to process your Personal Data in accordance with Articles 29 and 32(4) of the Regulations and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who must process your Personal Data by reason of their job duties, system administrators;

subjects who, in the provision of services in favor of the Company, process data on behalf of the Company itself and typically act as Data Processors (e.g., contracting companies in the case of entrusting work, even partial, to external companies; third parties involved in the management of information systems and web platforms; third-party collaborators that the Company uses for specific services of a technical and/or organizational nature - such as IT service providers, external collaborators and consultants; companies belonging to the Group; etc.). For a complete and updated list of Data Processors, write to privacy@sugarmusic.com

entities and authorities, which normally act as autonomous Data Controllers within the meaning of Article 4(7) of the Regulation, to which it is mandatory to communicate your Personal Data in accordance with the regulatory provisions applicable to the Company or by virtue of contractual obligations or in execution of pre-contractual measures.

With regard to the possible transfer of Data to Third Countries, the Data Controller informs that the processing will take place according to one of the modalities allowed by the applicable law, such as the consent of the Data Subject, the execution of a contract concluded between the Data Subject and the Data Controller or the execution of pre-contractual measures adopted at the request of the Data Subject; the conclusion or execution of a contract concluded between the Data Controller and another natural or legal person in favor of the data subject; the adoption of Standard Clauses approved by the European Commission; the selection of subjects adhering to international programs for the free circulation of data or operating in countries considered safe by the European Commission. More information is available upon request from the Data Controller.

In relation to the stated purposes, the processing of personal data is carried out using manual, computer and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data, in addition to compliance with the specific obligations enshrined in the law.

Your Personal Data will be retained in accordance with the principles of minimization and limitation of storage referred to in Article 5, par. 1, lett. c) and e) of the Regulation for a period of 12 (twelve) months from their provision, in order to allow the Data Controller to complete the evaluation process, as well as to meet the need to evaluate possible future collaborative relationships. At the end of this period, your data will be permanently deleted. 

Pursuant to Articles 15 et seq. of the Regulation, the data subject has the right to request at any time, access to his or her personal data, rectification or erasure of the same (pursuant to Articles 16 and 17 of the Regulation), limitation of processing in the cases provided for by Article 18 of the Regulation, to object to processing (pursuant to Article 21 of the Regulation) , to obtain in a structured, commonly used and machine-readable format the data concerning him or her, in the cases provided for by Article 20 of the Regulation. 

At any time, the data subject has the possibility to lodge a complaint with the competent supervisory authority (Garante per la Protezione dei Dati Personali) pursuant to Article 77 of the Regulation, if he or she considers that the processing of your data is contrary to the legislation in force.

Requests should be addressed in writing to the Data Controller at the following address: privacy@sugarmusic.com.

(Version 1.0 of 6th May 2025)

Notice pursuant to Art. 13 EU Regulation 2016/679 for the Processing of Personal Data

Data Controller

We inform you that, in accordance with EU Regulation 2016/679 (infra: “Regulation”), your Personal Data will be processed by Creazioni Artistiche Musicali - C.A.M. s.r.l con sede in Galleria del Corso, 4 - 20122 Milano (MI), as data controller ("Data Controller”).

Purpose, legal basis and voluntary nature of the processing

The Data Controller will process your personal data (art. 4.1 of the Regulations) specifically your first name, last name and e-mail address, for the following purpose: 

Sending via automated tools (e-mail, push notifications, SMS) of newsletters and promotional and marketing communications about the Owner's products and initiatives, including communications aimed at conducting market research and participation in prize shows and events.

It should be noted that the Data Controller collects a single consent for the marketing purposes described herein, pursuant to the General Provision of the Guarantor for the Protection of Personal Data “Guidelines on Promotional Activities and Countering Spam” of July 4, 2013; if, in any case, you wish to object to the processing of your data for marketing purposes performed by the means indicated herein, as well as to revoke the consent given; you may do so at any time by contacting the Data Controller at the contact details indicated in this notice, without affecting the lawfulness of the processing based on the consent given before revocation.

The legal basis of processing for the above purposes refers to the expression of consent by the data subject to the processing of his or her personal data (Art. 6.1.a of the Regulation).

The provision of your Personal Data is voluntary; no consequences are foreseen in case of your refusal.

Recipients of personal data 

Your Personal Data may be shared with:

persone persons authorized to process your Personal Data in accordance with Articles 29 and 32(4) of the Regulations and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who must process your Personal Data by reason of their job duties, system administrators;

subjects who, in the provision of services in favor of the Company, process data on behalf of the Company itself and typically act as Data Processors (e.g., contracting companies in the case of entrusting work, even partial, to external companies; third parties involved in the management of information systems and web platforms; third-party collaborators that the Company uses for specific services of a technical and/or organizational nature - such as IT service providers, external collaborators and consultants; companies belonging to the Group; etc.). For a complete and updated list of Data Processors, write to privacy@sugarmusic.com 

entities and authorities, which normally act as autonomous Data Controllers within the meaning of Article 4(7) of the Regulation, to which it is mandatory to communicate your Personal Data in accordance with the regulatory provisions applicable to the Company or by virtue of contractual obligations or in execution of pre-contractual measures.

With regard to the possible transfer of Data to Third Countries, the Data Controller informs that the processing will take place according to one of the modalities allowed by the applicable law, such as the consent of the Data Subject, the execution of a contract concluded between the Data Subject and the Data Controller or the execution of pre-contractual measures adopted at the request of the Data Subject; the conclusion or execution of a contract concluded between the Data Controller and another natural or legal person in favor of the data subject; the adoption of Standard Clauses approved by the European Commission; the selection of entities operating in countries considered safe by the European Commission. You can get more information, upon request, from the Data Controller at the contacts above.

How your personal data will be processed 

In relation to the stated purposes, the processing of personal data is carried out using manual, computer and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data, in addition to compliance with the specific obligations enshrined in the law.

Data retention

Your Personal Data will be kept only as long as necessary for the purposes for which it is collected, respecting the principle of minimization set forth in Article 5(1)(c) of the GDPR. In particular, Your Personal Data will be kept for 24 (twenty-four) months. 

More information is available from the Data Controller.

I suoi diritti privacy (ex artt. 15 e ss. del Regolamento)

You have the right to request from the Company, at any time, access to your Personal Data, its rectification or erasure, the restriction of processing, and to receive the data concerning you in a structured, commonly used, and machine-readable format in the cases provided for under Article 20 of the Regulation.

We also inform you that you have the right to object ex art. 21 of the Regulation, for legitimate reasons, to the processing of your data, for example you may object at any time to the sending of direct marketing with automated tools (sms, mms, email, push notifications, fax) and not (paper mail, telephone with operator); moreover, it remains without prejudice to the possibility of exercising this right in part, that is, in this case, objecting, for example, only to the sending of promotional communications carried out by automated tools. 

At any time you may revoke ex art. 7 of the Regulation, the consent already given, without affecting the lawfulness of the processing carried out prior to the revocation of consent.

Requests should be addressed in writing to the Data Controller at the following address.: privacy@sugarmusic.com 

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to applicable law.

(Version 1 of 30th January 2025)

Notice pursuant to Art. 14 EU Regulation 2016/679 for the Processing of Personal Data- Scouting

We inform you, pursuant to Art. 14 of the EU Regulation 2016/679 (infra: “Regulation”), that your Personal Data (master data: first name, last name; contact data: e-mail address, telephone number; material published at the indicated links, including Music Demos, i.e. music tracks in physical/digital format owned by the user or with respect to which the user disponses the relevant permissions ; professional category; information pertaining to his/her professional profile and/or artistic career; alias/art name/pseudonym) will be processed by Creazioni Artistiche Musicali - C.A.M. s.r.l with registered office in Galleria del Corso, 4 - 20122 Milan (MI), as data controller ("Data Controller”), for the following purposes:

Scouting activities for the evaluation of musical proposals and possible collaborative relationships, including future ones, including recontacting, in order to schedule any meetings and/or auditions that may be necessary for evaluation.

The legal basis for the processing for the above purpose is the performance of a contract to which the data subject is a party or of pre-contractual measures taken at the request of the data subject, pursuant to Art. 6(1)(b) of the Regulation. 

The source from which the above data originated is Sugarmusic S.p.A., a company part of Gruppo Sugar Holdings S.r.l.

Your Personal Data may be shared with:

persone persons authorized to process your Personal Data in accordance with Articles 29 and 32(4) of the Regulations and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who must process your Personal Data by reason of their job duties, system administrators;

subjects who, in the provision of services in favor of the Company, process data on behalf of the Company itself and typically act as Data Processors (e.g., contracting companies in the case of entrusting work, even partial, to external companies; third parties involved in the management of information systems and web platforms; third-party collaborators that the Company uses for specific services of a technical and/or organizational nature - such as IT service providers, external collaborators and consultants; companies belonging to the Group; etc.). For a complete and updated list of Data Processors, write to privacy@sugarmusic.com

entities and authorities, which normally act as autonomous Data Controllers within the meaning of Article 4(7) of the Regulation, to which it is mandatory to communicate your Personal Data in accordance with the regulatory provisions applicable to the Company or by virtue of contractual obligations or in execution of pre-contractual measures.

With regard to the possible transfer of Data to Third Countries, the Data Controller informs that the processing will take place according to one of the modalities allowed by the applicable law, such as the consent of the Data Subject, the execution of a contract concluded between the Data Subject and the Data Controller or the execution of pre-contractual measures adopted at the request of the Data Subject; the conclusion or execution of a contract concluded between the Data Controller and another natural or legal person in favor of the data subject; the adoption of Standard Clauses approved by the European Commission; the selection of subjects adhering to international programs for the free circulation of data or operating in countries considered safe by the European Commission. More information is available upon request from the Data Controller.

In relation to the stated purposes, the processing of personal data is carried out using manual, computer and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data, in addition to compliance with the specific obligations enshrined in the law.

Your Personal Data will be retained in accordance with the principles of minimization and limitation of storage referred to in Article 5, par. 1, lett. c) and e) of the Regulation for a period of 12 (twelve) months from their provision, in order to allow the Data Controller to complete the evaluation process, as well as to meet the need to evaluate possible future collaborative relationships. At the end of this period, your data will be permanently deleted. 

Pursuant to Articles 15 et seq. of the Regulation, the data subject has the right to request at any time, access to his or her personal data, rectification or erasure of the same (pursuant to Articles 16 and 17 of the Regulation), limitation of processing in the cases provided for by Article 18 of the Regulation, to object to processing (pursuant to Article 21 of the Regulation) , to obtain in a structured, commonly used and machine-readable format the data concerning him or her, in the cases provided for by Article 20 of the Regulation. 

At any time, the data subject has the possibility to lodge a complaint with the competent supervisory authority (Garante per la Protezione dei Dati Personali) pursuant to Article 77 of the Regulation, if he or she considers that the processing of your data is contrary to the legislation in force.

Requests should be addressed in writing to the Data Controller at the following address: privacy@sugarmusic.com.

(Version 1.0 of 6th May 2025)