1. Data Controller Information
| Company Name: | DEAO LLC DBA DEAO Music |
| Address: | 5630 Venice Blvd #1081, Los Angeles, CA 90019, USA |
| Legal Contact Email: | legal@deaomusic.com |
| Support Contact Email: | support@deaomusic.com |
2. Personal Information We Collect (Categories and Sources)
We collect and have collected the following categories of Personal Information from you within the last twelve (12) months:
| Category of Personal Information | Specific Data Elements Collected | Source of Collection |
| Identifiers & Contact Data | Full Name, Email Address, Mobile Number, Full Address. | Directly from the user (via registration/lead forms). |
| Financial & Commercial Data | Bank Account Information, Average Monthly Income (Lead Stats). | Directly from the user (via registration/onboarding). |
| Professional/Employment Data | Lead Stats (Artist/Label status) and Music Catalog details. | Directly from the user (via registration/onboarding). |
| Sensitive Personal Information (SPI) | Copy of government-issued ID (Passport, Driver’s License, etc.) used for verification. | Directly from the user, processed via our third-party verification tool (Veriff). |
| Internet/Network Activity | IP Address, Device Type, Operating System, Browser Type, pages viewed, and metadata of usage. | Automatically collected (via cookies, logs, and analytics tools). |
CPRA/GDPR Note: The government-issued ID is considered Sensitive Personal Information (SPI) under CPRA and special categories of data under GDPR, requiring careful handling as detailed below.
3. Purposes of Processing and Legal Basis (GDPR)
We use the Personal Information we collect for the following specific purposes, relying on a lawful basis for processing as required by the GDPR and other applicable laws:
| Purpose of Processing | Legal Basis (GDPR) | CCPA/CPRA Business Purpose |
| Account Creation and Management | Contract: Necessary for the performance of the contract (DEAO Music Terms of Service). | Performing Services: Providing our distribution service. |
| Service Provision (Payments, distribution, etc.) | Contract: Necessary for the performance of the contract. | Performing Services: Processing transactions and fulfilling service requests. |
| Identity Verification (Via Veriff) | Legal Obligation & Legitimate Interest: Fraud prevention, AML/KYC compliance. | Security/Fraud: Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. |
| Service Improvement & Customization | Legitimate Interest: Improving our Service and providing tailored solutions. | Research/Internal Use: Undertaking internal research for technological development and demonstration. |
| Transactional Communications (Account updates, service changes, industry news) | Contract: Necessary for the performance of the contract (transactional service updates). | Performing Services: Communicating with you about your account. |
| Marketing Communications/Newsletter | Consent: User has explicitly opted-in via the subscription link or checkbox. | Marketing/Advertising: Providing advertising and marketing services. |
| Security and Legal Compliance | Legal Obligation & Legitimate Interest: Protecting our business and complying with legal mandates. | Legal Compliance & Security: Complying with legal obligations. |
4. Disclosure and Sharing of Personal Information
We may disclose or share your Personal Information with the following categories of third parties for the Business Purposes listed in Section 3:
| Category of Third Party | Business Purpose of Disclosure | Specific Third Parties |
| Service Providers/Vendors | To perform functions on our behalf (hosting, development, support, billing). | Odoo, Cloudflare. |
| Payment Processors | To process payments, payouts, and royalty distributions. | Stripe, PayPal. |
| Verification Partners | To verify your identity as required for contractual and regulatory compliance. | Veriff. |
| Analytics Providers | To analyze Service usage and optimize performance. | Google Analytics. |
| Advertising Platforms | For targeted advertising, measurement, and campaign optimization. | Google Ads, Facebook Ads, TikTok Ads. |
| Legal Compliance | To comply with legal obligations, enforce our rights, or respond to government requests. | Regulatory authorities, courts. |
DEAO Music does not sell Personal Information in exchange for monetary consideration. However, we may "share" Personal Information (as defined under CPRA) for cross-context behavioral advertising with platforms like Google Ads, Facebook Ads, and TikTok Ads. California Residents have the Right to Opt-Out of Sharing (See Section 7.B).
5. Cookies and Tracking Technologies
We use cookies, pixels (including Facebook, TikTok, and Google pixels), and similar tracking technologies for:
- Functionality: Essential for the operation of the Service.
- Analytics: Measuring traffic and analyzing user behavior.
- Targeted Advertising: Delivering personalized content and advertisements.
You consent to the use of these technologies by using our Service. You may manage your cookie preferences through your browser settings or our dedicated consent management tool.
6. Data Retention
We retain your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
- If you cancel or delete your account, we retain your data for an additional period of 90 days to comply with legal obligations, resolve disputes, and enforce our agreements.
- Anonymized or aggregated data may be retained indefinitely for analytics and service improvement.
7. Your Privacy Rights (GDPR & CPRA/CCPA)
Depending on your jurisdiction, you may have specific rights regarding your Personal Information.
A. Rights for All Users (Including GDPR Data Subjects)
| Right | Description | How to Exercise |
| Right of Access | Request a copy of the Personal Information we hold about you. | Email legal@deaomusic.com or support@deaomusic.com. |
| Right to Rectification | Request correction of any incomplete or inaccurate data. | Email legal@deaomusic.com or support@deaomusic.com. |
| Right to Erasure ("Right to be Forgotten") | Request deletion of your data, subject to legal exceptions. | Email legal@deaomusic.com or support@deaomusic.com. |
| Right to Object | Object to the processing of your data, including direct marketing. | Email legal@deaomusic.com or support@deaomusic.com. |
| Right to Withdraw Consent | Withdraw consent for future processing where consent was the legal basis (e.g., marketing). | Unsubscribe link: https://www.deaomusic.com/unsubscribe_from_list or email legal@deaomusic.com. |
GDPR Specific Right: You also have the right to lodge a complaint with a supervisory authority if you believe your rights under GDPR have been violated.
B. Rights for California Residents (CCPA/CPRA Consumers)
If you are a California resident, you have the following additional rights:
| CPRA Right | Description |
| Right to Know | Request the specific pieces and categories of Personal Information we have collected, the sources, the purposes for collection, and the categories of third parties with whom we share it. |
| Right to Delete | Request the deletion of your Personal Information, subject to certain legal exceptions. |
| Right to Opt-Out of Sharing | Opt-out of the "sharing" of your Personal Information for cross-context behavioral advertising (e.g., with platforms like Facebook Ads or Google Ads). DEAO Music does not "sell" Personal Information for monetary value. |
| Right to Limit Use of Sensitive Personal Information (SPI) | Request to limit the use and disclosure of Sensitive Personal Information (like your ID for verification) to only that which is necessary to provide the Service. |
| Right to Correction | Request the correction of inaccurate Personal Information. |
How to Exercise CCPA/CPRA Rights:
To exercise your Right to Know, Right to Delete, or Right to Limit Use of SPI, please submit a request to:
- Email: legal@deaomusic.com or support@deaomusic.com
We will verify your identity before processing your request.
8. Children’s Privacy
Our Service is strictly directed only to individuals who are 18 years of age or older and are capable of providing a valid ID for verification. We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have collected information from a minor without parental consent, we will take steps to delete that information promptly.
9. Data Security
We are committed to protecting your Personal Information. We implement reasonable technical and organizational security measures, including SSL encryption for data transmission and end-to-end encryption for sensitive areas, to protect against unauthorized access, disclosure, or destruction.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or through a prominent notice on the Service prior to the change becoming effective. Your continued use of the Service after the effective date of the revised Policy signifies your acceptance of the terms.
11. DEAO Social Hub and TikTok
DEAO Social Hub (https://socialhub.deaomusic.com) is DEAO Music's internal tool for publishing content to the social media accounts of our artists, divisions and brands. When an authorized user connects a TikTok account to it, we use TikTok's Login Kit and Content Posting API as described below.
Information we receive from TikTok
- Account identifier and tokens: your TikTok account's unique identifier (open ID) and the access and refresh tokens TikTok issues when you authorize the Service.
- Profile and posting settings: your display name (nickname), username and profile picture, and your current posting settings: the privacy levels your account allows, whether comments, Duet and Stitch are turned off, and the maximum video length you can post. We request these each time you open the TikTok posting options, to show you which account you are posting to and which options are available.
- Post status: the publish ID TikTok returns for each upload, its status, and the post's ID once TikTok makes it publicly available.
We do not receive your TikTok password, and we do not access your followers, messages, likes, viewing history or analytics.
How we use it
- To publish to your TikTok account the videos, captions and settings you choose in the Service, only after you submit them, plus the daily clips if you opt in for that video.
- To show you which account you are posting to, the privacy and interaction options your account allows, and the status of each post.
- To keep your connection working: tokens are refreshed automatically until you disconnect.
We do not sell TikTok data, use it for advertising, or share it with third parties, except with our hosting providers (Cloudflare, Inc., which stores the Service's data and content), when required by law, or with TikTok itself as part of publishing.
Storage and security
Tokens and post records are stored in the Service's database, hosted by Cloudflare, with access limited to the Service and authorized DEAO Music personnel. Profile pictures and posting settings are shown when requested and are not stored. Videos and images you upload are stored in the Service's storage so they can be published.
Retention and deletion
- Tokens and account identifier: kept until you disconnect the TikTok account in the Service, which deletes them at once.
- Post records (publish IDs, statuses, post IDs and usernames): kept as a history of what was published, until you ask us to delete them.
- Revoking access: you can also remove DEAO Social Hub's access to your account in your TikTok account settings, among the apps connected to it. After that, nothing more can be published to your account.
- Deletion requests: to delete the TikTok data we hold about you, email support@deaomusic.com. We will act within 30 days. TikTok's own handling of your data is governed by TikTok's Privacy Policy.
