Privacy Policy
Last updated: [Month D, YYYY]
This page is a template. Placeholder text. Final wording is provided by the client after legal review. The Analytics and cookies section must describe Google Analytics 4 and Cloudflare Turnstile before analytics is switched on.
Who we are
ALBOREKS is an independent music label. This policy explains what personal data we process when you use ALBOREKS.com, why, and what your rights are.
Controller: [Legal entity name] [Registered address] [Country]
Contact: Email · Write to us / Telegram · @AlboreksSupportBot
[If the controller is established outside the EU: EU representative under Article 27 GDPR — name and address.]
We have not appointed a Data Protection Officer, as we are not required to.
What we collect
1. Visiting the site
When you open any page, our server records technical data: IP address, date and time, requested page, referring page, browser and operating system.
Purpose: delivering the site, security, preventing abuse.
Legal basis: our legitimate interest in a secure, working site (Art. 6(1)(f) GDPR).
Kept for: 14 days, then deleted automatically.
2. Demo submissions
When you submit a demo, we receive: artist or project name, email address, link to your music, genre and message (if provided), and your confirmation that the music is your own.
Purpose: reviewing your music and replying to you.
Legal basis: steps taken at your request before a possible agreement (Art. 6(1)(b) GDPR).
Demos are reviewed by people. We do not use automated decision-making.
You must be 18 or older to submit a demo. Providing this data is voluntary, but we cannot review a demo without it. We do not store submissions on our web server. They are delivered to us by email.
3. Email and Telegram
When you write to us, we receive your message and contact details. On Telegram, we see your Telegram name, username and messages. Telegram processes this data as an independent controller under its own privacy policy.
Purpose: answering your request.
Legal basis: Art. 6(1)(b) GDPR for requests related to an agreement; otherwise our legitimate interest in responding (Art. 6(1)(f) GDPR).
4. Spam protection
The demo form is protected by Cloudflare Turnstile. It processes technical signals such as IP address, browser characteristics (User-Agent, TLS fingerprint) and the site address, only to tell people from bots. Turnstile loads only on the Demos page. It does not set advertising cookies or build profiles.
Legal basis: our legitimate interest in protecting the form from abuse (Art. 6(1)(f) GDPR).
5. Embedded video
Artist pages may include YouTube videos. The player loads only after you click play, from youtube-nocookie.com. Until then, no data is sent to Google. Once you click, Google processes your data under its own privacy policy.
Legal basis: your action of starting the video (Art. 6(1)(a) GDPR).
Analytics and cookies
Necessary storage
We store your cookie choice in your browser (key: alboreks_consent) so we don't ask again on every page.
Legal basis: our legal obligation to document consent (Art. 6(1)(c) GDPR).
Kept for: 6 months, then we ask again.
Google Analytics 4 (only with your consent)
If you click Accept, we use Google Analytics 4 to understand how the site is used: pages viewed, time on site, device type, approximate location (country, city), and clicks on contact links and external links. Google states that Google Analytics 4 does not log or store IP addresses. Google signals and ad personalization are turned off. We do not send form data, email addresses or names to Google Analytics.
Cookies set by Google Analytics:
_ga — distinguishes visitors — up to 2 years
_ga_<ID> — keeps session state — up to 2 years
Legal basis: your consent (Art. 6(1)(a) GDPR).
Analytics data is kept for 14 months.
If you click Reject, Google Analytics does not load and no analytics cookies are set.
You can change your choice at any time via Cookie settings in the footer. Withdrawing consent does not affect processing that took place before.
How long we keep data
Server logs — 14 days
Demo submissions — 12 months, then deleted
Email and Telegram messages — 12 months after the last message Cookie choice — 6 months Google Analytics data — 14 months
If we sign an agreement with you, we keep the data needed for that agreement for as long as the law requires.
Your rights
Under the GDPR, you have the right to:
— access the personal data we hold about you
— correct inaccurate data
— have your data deleted
— restrict processing
— receive your data in a portable format
— object to processing based on our legitimate interest
— withdraw consent at any time, with effect for the future
To use any of these rights, contact us. We reply within one month.
You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live or work. Our lead authority: [Supervisory authority name and website].
Contact
Email · Write to us
Telegram · @AlboreksSupportBot