Privacy Policy

1. Legal Information

This privacy policy is issued by:

• Company Name: EUTERPA MUSIC
• Legal Form: SASU (Société par Actions Simplifiée Unipersonnelle)
• Registered Office: 154 Rue de Rome, 13006 Marseille, France
• SIRET: 952 413 771 00017
• RCS: Marseille 952 413 771
• VAT Number: FR13952413771
• Share Capital: 1,000 €
• President: Nelson Leeroy Nelson-Leeroy
• Contact: legal@euterpastudios.com

2. Introduction

In accordance with the French Data Protection Act (Loi Informatique et Libertés) of January 6, 1978, as amended, and the General Data Protection Regulation (GDPR - EU Regulation 2016/679), Euterpa Studios is committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (euterpastudios.com) or use our services.

3. Data Controller

The data controller responsible for your personal data is:

EUTERPA MUSIC
154 Rue de Rome
13006 Marseille, France
Email: legal@euterpastudios.com

4. Information We Collect

4.1 Personal Information

We collect personal information that you voluntarily provide to us when you:

• Create an account on our website
• Place an order for our services
• Subscribe to our newsletter
• Contact us for support or inquiries
• Participate in promotions or surveys
• Use our chat features (Euterpa GPT or WhatsApp)

This information may include: name, email address, phone number, billing address, payment information, and project details.

4.2 Automatically Collected Information

When you visit our website, we automatically collect certain information about your device and browsing activity:

• IP address and geolocation data
• Browser type and version
• Operating system
• Access times and dates
• Pages viewed and navigation paths
• Referring website
• Device identifiers

5. Legal Basis and Purpose of Processing

We process your personal data based on the following legal grounds under GDPR Article 6:

5.1 Contract Performance (Article 6.1.b)

To process and deliver your orders, manage payments, and provide customer support.

5.2 Legitimate Interest (Article 6.1.f)

To improve our website, analyze usage patterns, prevent fraud, and ensure security.

5.3 Consent (Article 6.1.a)

To send marketing communications, newsletters, and use analytics/marketing cookies.

5.4 Legal Obligation (Article 6.1.c)

To comply with accounting, tax, and other legal requirements under French law.

We use your information specifically to:

• Process and fulfill your orders
• Handle payments securely through our payment processor
• Communicate with you about your projects and services
• Provide customer support and respond to inquiries
• Improve our website, services, and user experience
• Send marketing communications (only with your explicit consent)
• Comply with legal and regulatory obligations
• Prevent fraud and ensure platform security
• Generate invoices and maintain accounting records as required by French law

6. Data Recipients and Third-Party Services

We may share your personal data with the following categories of recipients:

6.1 Service Providers

• Stripe: Payment processing (based in USA with GDPR compliance)
• Supabase: Database and authentication services
• Netlify: Website hosting and content delivery
• PlaylistPush: Playlist submission and promotion services
• JotForm: Contact form processing

6.2 Legal Requirements

We may disclose your information to:

• French tax authorities (Direction Générale des Finances Publiques)
• Law enforcement or regulatory authorities when required by French or EU law
• Legal advisors and auditors as necessary

All third-party service providers are contractually required to protect your data in accordance with GDPR standards.

7. International Data Transfers

Some of our service providers are located outside the European Economic Area (EEA). When we transfer your data internationally, we ensure adequate protection through:

• EU Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Privacy Shield framework (where applicable)

8. Cookie Policy

In accordance with Article 82 of the French Data Protection Act and GDPR Article 7, we use cookies and similar tracking technologies.

8.1 Types of Cookies

• Essential Cookies: Required for website functionality (no consent required)
• Analytics Cookies: To understand user behavior and improve our services (requires consent)
• Marketing Cookies: For targeted advertising and social media integration (requires consent)

You can manage your cookie preferences through our cookie consent banner or your browser settings. Rejecting non-essential cookies will not affect your ability to use our website.

9. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

• Customer data: Duration of business relationship plus 3 years (French commercial law)
• Accounting records: 10 years (French tax law requirement)
• Marketing data: 3 years from last contact (CNIL recommendation)
• Inactive accounts: Deleted after 3 years of inactivity
• Website logs: 12 months maximum

10. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction, including:

• SSL/TLS encryption for data transmission
• Encrypted storage of sensitive information
• Regular security audits and updates
• Access controls and authentication measures
• Staff training on data protection
• Incident response procedures

In the event of a data breach affecting your rights and freedoms, we will notify you and the CNIL (Commission Nationale de l'Informatique et des Libertés) within 72 hours as required by GDPR Article 33.

11. Your Rights Under GDPR and French Law

Under the GDPR and French Data Protection Act, you have the following rights:

11.1 Right of Access (Article 15)

You can request a copy of all personal data we hold about you.

11.2 Right to Rectification (Article 16)

You can request correction of inaccurate or incomplete data.

11.3 Right to Erasure - "Right to be Forgotten" (Article 17)

You can request deletion of your data, subject to legal retention obligations.

11.4 Right to Restriction of Processing (Article 18)

You can request that we limit how we use your data.

11.5 Right to Data Portability (Article 20)

You can request your data in a structured, machine-readable format.

11.6 Right to Object (Article 21)

You can object to processing based on legitimate interests or for direct marketing.

11.7 Right to Withdraw Consent

You can withdraw consent at any time for processing based on consent.

11.8 Right to Lodge a Complaint

You can file a complaint with the French supervisory authority:

CNIL (Commission Nationale de l'Informatique et des Libertés)
3 Place de Fontenoy
TSA 80715
75334 Paris Cedex 07, France
Website: www.cnil.fr

11.9 Exercising Your Rights

To exercise any of these rights, please contact us at:

• Email: legal@euterpastudios.com
• Mail: EUTERPA MUSIC, 154 Rue de Rome, 13006 Marseille, France

We will respond to your request within one month. You may be required to provide proof of identity for security purposes.

12. Minors

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor without parental consent, we will delete it immediately.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top indicates when this policy was last revised. We encourage you to review this policy periodically. Continued use of our services after changes constitutes acceptance of the updated policy.

14. Contact Information

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

EUTERPA MUSIC
154 Rue de Rome
13006 Marseille, France
SIRET: 952 413 771 00017
Email: legal@euterpastudios.com