FreqMusic  -  Privacy Policy


Welcome to the FreqMusic Privacy Policy. Thank you for using FreqMusic.


We care about your privacy and are committed to protecting your Personal Information. Our view is that you should always know what kind of information we collect about you and how we use it. Therefore, this Privacy Policy sets out we how collect and use your Personal Information, and the rights and choices available to you regarding such Personal Information. That is the basic purpose of this Privacy Policy.


Please read this Privacy Policy and our Terms of Use and make sure you fully understand them before you access or use any of our services. 


It’s important that you read the following

This Privacy Policy (“Privacy Policy”) describes how we, Sine Music Ltd. (“FreqMusic”, “”, “we” or “us”), collect and use information relating to our all our Users’, whether Partners and/or Listeners (“User” or “you”), Partner and/or Listener Accounts (“User Account(s)”) in connection with any access and use of the FreqMusic Platform (the “FreqMusic Platform”) and the FreqMusic’s Services (the “Services”).


The purpose of this Privacy Policy is to provide you with information regarding when, why and how we collect and use your Personal Information, as well as an explanation of your rights.


Please be aware that this Privacy Policy is not intended to override the terms of any rights you may have under applicable data privacy laws.


Please be aware that this Privacy Policy only applies to our Services. We are not responsible for the privacy practices of other websites, apps and services and we recommend that you review the privacy policies of each of these before sharing any Personal Information.


We do not sell your Personal Information to anyone. Further, you are the owner of your Personal Information and can request its modification or deletion at any time.

If you have any questions regarding this Privacy Policy, please contact our Privacy Officer at


This Privacy Policy has been prepared based on provisions of a number of legislations, including Art. 13/14 of Regulation (EU) 2016/679, also known as the General Data Protection Regulation (“GDPR”).


This Privacy Policy is effective from 19th July 2020.


Information we collect


Information that doesn’t identify you

Such information may be made available to us, or collected automatically through the use of our Services (“Non-Personal Information”). Such Non-Personal Information does not enable us to identify you and it mainly consists of technical and aggregated usage information, such as your browsing activity on the Services, session heatmaps and scrolls, non-identifying information regarding your device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.


Information that identifies you (“Personal Information”)

The Personal Information collected by us mainly consists of contact details (such as e-mail address), details regarding a browsing or usage session (such as IP address, Geo-location and/or device unique identifier, Partner Channels followed, comments, Partner Content uploaded, listened to, shared or browsed), correspondences (including those made through or uploaded to our Services), and any other Personal Information you may provide us with through your use of the Services.


Some pointers for you

Any Personal Information we request and which is not provided by you, may make it impossible for us to provide you with the full extent of our Services.

If you are uncertain about which Personal Information is mandatory, then you’re most welcome to contact our Privacy Officer at for more information.

Any use of Cookies or of other tracking tools by us or by Third-party Services, serves the purpose of providing the Services required by you, in addition to any other purposes described further in this Privacy Policy.

You are responsible for any third-party Personal Information obtained, published or shared by you through our Services and therefore you confirm that you have such third-party’s consent to provide such Personal Information to us.


We collect information in a number of ways


Through your use of the Services 

When you use our Services, including when you browse the FreqMusic Platform, register a User Account, create or edit your Partner Channel and upload Partner Content, we are aware of it and we will gather, collect and record such uses, sessions and related information, either independently or with the help of Third-Party Services, including through the use of “cookies” and other tracking technologies, as further detailed below.

Information which you provide us voluntarily

We collect the Personal Information you provide us when you register to our Services, when you submit or upload such Personal Information as you use any of our Services and/or when you contact us directly by any communication channel (e.g. emails). 



Why do we collect such information?

  1. To provide and operate the Services.

  2. To further develop, customize and improve our Services, based on Users’ common or personal preferences, experiences and difficulties.

  3. To provide our Users with ongoing customer assistance and technical support.

  4. To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section ‎I below).

  5. To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;

  6. To enhance our data security and fraud prevention capabilities.

  7. To comply with any applicable laws and regulations.


When we use your information

  1. To perform a contract or take steps to enter into a contract with you (e.g. to provide you with our customer assistance and technical support), or

  2. To comply with a relevant legal or regulatory obligation that we have, or

  3. To support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of our campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.


Where do we store your information?

Your Personal Information will be stored in data centers which are used by us or by Third-Party Service Providers in various jurisdictions. Please be aware that we or our Third-Party service providers may use jurisdictions as may be necessary for the proper delivery of our Services and/or as may be required by law.


Our employees and/or service providers that store or process your Personal Information on our behalf are each contractually committed to keeping it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.


We are based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.


Transferring your information

Personal Information is processed at our operating offices and in any other places where the parties involved in the processing are located.


We may, either by ourself or through Third-Party service providers, transfer your Personal Information outside of the jurisdiction in which you reside and as such, this Privacy Policy has also been prepared based on provisions of Art. 13/14 of Regulation (EU) 2016/679 (“GDPR”). To find out more about the place of processing by Third-Parties of such transferred Personal Information, please see please see the table in the following link: Link to third party services table.

Any transfer to a third country, outside the European Union, that does not ensure an adequate level of protection according to the European Commission, will be undertaken in accordance with the requirements of the GDPR.


Legal basis under GDPR

Under GDPR, we are required to have a legal basis for processing Personal Information of our User’s. Our legal basis may be one of the following:

  1. You have given your clear consent for one or more specific purposes and you will be able to opt-in and opt-out of consent at any given time.

  2. The processing of Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations.

  3. The processing of Personal Information is necessary for compliance with a legal obligation to which we are subject.

  4. The processing of Personal Information is necessary for protecting your vital interests or of another person.

  5. The processing of Personal Information is necessary for performing a task carried out in the interest of the public or as contained under the official authority given to the data controller. Notwithstanding, please be aware that you may object to such processing by providing a ground related to your particular situation to justify your objection.

  6. The processing of Personal Information is necessary for our legitimate interests or those of a third party. Notwithstanding, please be aware that you may object to such processing by providing a ground related to your particular situation to justify your objection.


Choices and rights you have regarding your information

In particular, you have the right to:  

  1. Withdraw your consent where you have previously given your consent to the processing of your Personal Information.

  2. Object to the processing of your Personal Information if the processing is carried out on a legal basis other than consent.

  3. Learn if Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Personal Information undergoing processing.

  4. Verify the accuracy of your Personal Information and ask for it to be updated or corrected.

  5. Restrict the processing of your Personal Information. In this case, we will not process your Personal Information for any purpose other than storing it.

  6. Obtain the erasure of your Personal Information from us.

  7. Receive your Personal Information in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Personal Information is processed by automated means.

  8. Bring a claim before your competent data protection authority.



Some further points on your above choices and rights

Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity for security purposes. 

We will make reasonable efforts to honour your request promptly, subject to legal and other permissible considerations.

Please note that permanently deleting your FreqMusic account erases all of your information from FreqMusic's databases. After completing this process, you will no longer be able to use any of your FreqMusic services, your account and all its data will be removed permanently and FreqMusic will not be able to restore your account or retrieve your data in the future.

You should also be aware that if you reside in a jurisdiction that imposes “data localization” or “data residency” obligations (namely, requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.


How long we keep your information

Personal Information shall be processed and stored  for as long as required by the purpose for which they have been collected (“Retention Period”). Therefore:


  1. We may retain your Personal Information for as long as your User Account is active, as indicated in this Privacy Policy or as otherwise needed to provide you with our Services.

  2. We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, to prevent fraud and abuse, to enforce our agreements and/or to protect our legitimate interests.

  3. Where your Personal Information is no longer required, we will ensure it is securely deleted.

  4. Once the Retention Period expires, Personal Information will be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.


Sharing your information with Third-Parties

FreqMusic may share your Personal Information with Third-Parties (or otherwise allow them access to it) only in the following ways:


Third-Party Services

FreqMusic has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks, data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services etc. (collectively, “Third-Party Service(s)”). 

While our Services may contain links to other services, we are not responsible for such services’ privacy practices. We encourage you to be aware and read the privacy statements of each and every such service before providing your Personal Information. This Privacy Policy does not apply to such linked third-party services.

For detailed information regarding Third-Party Services access to your Personal Information, please see the table in the following link: [Link to cookies and tracking technologies table].


Third Party Platforms/Applications

You can share Partner Content and other Partner Channel information via third party social media platforms/applications, whose privacy policies will govern the sharing of such information. This Privacy Policy does not apply to such third-party platforms/applications.

Business Partners

We have a wide range of relationships with third party business partners with whom we may share certain information about how the FreqMusic platform performs. If we do share such information, we shall do so in an anonymous and aggregated manner.


Legal requests for information

Where permitted by local data protection laws, we may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we believe that the law requires us to do so, with or without notice to you.


Protecting you

We may share your Personal Information with others if we believe that this will help protect the rights, property or personal safety of FreqMusic, our Users or any member of the general public, with or without notice to you.


Rights holders

We have licenses in place with various rights holders in Partner Content. Under such licenses we are required to provide rights holders with certain usage information on an aggregated and anonymous basis.


Information about Cookies


Use of Cookies & Tracking Technologies

We, together with our analytics and technology partners, use certain monitoring and tracking technologies. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, to ensure that FreqMusic is secure and safe to use and in order to provide our Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Users’ preferences, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.


Cookies, may be strictly necessary or functional. Also, cookies may be transient (session) or permanent/stored (persistent).


In order for some of services to work properly, a small data file (“cookie(s)”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g. for uploading Partner Content etc.), monitoring performance of our Services and generally providing and improving our Services.


Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy as we do not have any control over them. For information regarding our use of cookies and the use of cookies by third parties, please see the table in the following link: [Link to cookies and tracking technologies table].


If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at (please note that this website is not provided by FreqMusic, and we, therefore, cannot ensure its accuracy, completeness or availability).


The following links explain how to access cookie settings in various browsers:


To opt out of being tracked by Google Analytics across all websites, visit the following link:


Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.



Communications we may send you

Promotional Messages

We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages and similar forms of communication from us or our partners (acting on our behalf) through such means.


If you do not wish to receive such promotional messages or calls, you may notify us at any time by contacting us at or by following the “unsubscribe” or “stop” instructions contained in the promotional communications you receive.


We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.


Service Messages

We may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance, reply to your support e-mail, send you reminders regarding your subscriptions, forward abuse and other complaints regarding your Partner Channel, or notify you of material changes to our Services.


It’s important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service Messages unless you are no longer a FreqMusic User (which can be done by deactivating your account).



Questions and Complaints

If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe we have not complied with this Privacy Policy or applicable data protection laws, please contact our please contact our Privacy Officer at

Our Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.


We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly.


We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with your local supervisory authority for data protection.


You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.



We have implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things:


We offer HTTPS secure access to most areas on our Services.


We regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third-Party Services for further enhancing the security of our Services and protection of your privacy.


Regardless of the measures and efforts taken by us, we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other Partner Content you upload, publish or otherwise share with us or anyone else.


We therefore encourage you to set strong passwords for your User Account, and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm.


If you have any questions regarding the security of our Services, you are welcome to contact us at


Partner Content

If you upload any Partner Content to your User Account or post it on your Partner Channel and provide it in any other way as part of the use of any of our Services, you do so at your own risk.


Please be aware that although we have put adequate security measures in place to protect your User Account and Personal Information, we cannot control the actions of other Users or members of the public who may access your User Account in circumvention of any privacy settings or security measures you or we may have placed on your User Account, Partner Channel (including, for instance, password-protected areas).


You understand and acknowledge that, even after its removal, copies of Partner Content may remain viewable if any third parties have copied or stored such Partner Content. 


We therefore advise against posting any Personal Information (via any means) you don’t wish to publicise.

Changes to this Privacy Policy

We may update this Privacy Policy as required by applicable law and/or to reflect changes to our information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole and good faith discretion), we will take reasonable measures to notify you of such changes prior to their becoming effective.


Additional information or assistance

If you have any questions about this Privacy Policy or wish to exercise any of your rights as described herein, please contact our Privacy Officer at