Privacy Policy

Privacy Policy


We are committed to lawful, fair and transparent processing of Personal Data, adhering to the EU General Data Protection Regulation (GDPR). This file documents our general privacy-by-design considerations (articles 5, 6, 25 and 26 GDPR) and provides input for the information notice to the data subject (article 13 and 14 GDPR). A record of our processing activities is not required (article 30(1) and 30(5) GDPR).


Privacy Notice

We are DJ Monitor. We are based at Keizersgracht 313 +1, 1016 EE Amsterdam. If you have any questions regarding data protection or need assistance with resolving issues concerning your Personal Data, you can reach us at info@djmonitor.com.


This privacy policy applies to the Users of our website and Clients of DJ Monitor services. In this privacy notice, we describe:

  • The ways in which we collect Personal Data about you, whether you are a Client receiving our services or a User of our site.
  • How we use your Personal Data, and
  • The choices you have about your Personal Data.

We offer a variety of Services to our Clients and in that context process sizable amounts of Playlist data, some of which may be considered Personal Data under the GDPR.

Capitalized terms not defined in this Privacy Policy are defined in the General Terms and Conditions. We reserve the right to amend the Privacy Policy from time to time

1. What data we collect

In principle, we only process Personal Data of our Users and/or Clients when it is deemed necessary to provide a functional Site as well as to ensure the availability of our Services and purposes or when governed by legal requirements.

Each time our Site is accessed, the system automatically collects data and information from the computer system of the connecting computer.

1.1. The following data is collected in connection with our Services:

  1. Name. We collect the given names (first name, family name) of contact persons of Clients, and of contacts when they express interest in our Services when they call, email or send a message via the contact form on our website;
  2. Names of the authors, (performing) artists and other rights holders of musical works. We collect this data for the purpose of establishing music usage reports;
  3. Email address. We collect the email address of contact persons of Clients, and of contacts when they express interest in our Services;
  4. Postal address. We collect the postal address of Clients for billing purposes. In some cases, this is also the residence of a Client;

We collect data, including any Personal Data, for our customers/Clients, authors, performing artists, other rights holders of musical works, partners, and prospects directly from the data subjects or their collective management organizations, who provide it to us.

1.2. The following data is collected in connection with the use of our Site:

  1. the operating system of the User;
  2. the IP address of the User;
  3. date and time of the connection;
  4. internal User ID (registered Users);
  5. festival requests: contact name, phone, email address, company, and company address;
  6. uploader data: name, artist name, email, and other contact details.

The purposes for which we gather the data under point 1.2.:

  • System security
  • Analytics for purposes of website optimization

2. What do we use the data for, and on what legal basis

We may use the data collected under point 1.1 for the following purposes (“Purposes”):

  1. Royalty Distribution (e.g. to Collective Management Organizations and rights holders);
  2. Music Recognition services;
  3. Music Usage reporting
  4. Software as a Service;
  5. Data aggregation and distribution-related services; and
  6. trends and charts

Furthermore, we collect data to provide the service to contractual Clients and registered Users. Enabling and disabling recordings and storing the data in the system database is essential to the operation of the Service. Data collection is thus necessary to protect the vital interests of one or more participants.

DJ Monitor is provided with sound files of musical works, and any other information of these works necessary in order for DJ Monitor to conduct the Services as stated in the Terms and Conditions. DJ Monitor processes this information in its database to detect and recognize musical works played, and compiles music usage reports for the aforementioned Purposes. Amongst other things, the Service is intended to help Clients make correct music royalty payments through more accurate distribution; view data trends; and digitalize data reporting.

3. What legal basis we have

Our lawful basis for processing your Personal Data depends on the information concerned and the context in which it is processed. Generally, we are collecting the data to provide the service to contractual Clients and registered Clients. Enabling and disabling recordings and storing the data in the system database is essential to the operation of the Service. Data collection is thus necessary to protect the vital interests of one or more participants.

DJ Monitor is provided with sound files of musical works, and any other information of these works necessary to conduct the Services as stated in the Terms and Conditions. DJ Monitor processes this information in its database to detect and recognize musical works played and compiles music usage reports of the detected works, for the Purposes stated above.

We process your data based on the following legal grounds:

  • Contractual necessity: We process your personal data when it is necessary to fulfill our contractual obligations and provide the services to you as outlined in our Terms and Conditions.
  • Legitimate Interests: We may process your personal data based on our legitimate interests, which include providing accurate royalty distribution to Collective Management Organizations (CMOs) for music royalty payments. We ensure that our legitimate interests do not override your rights and interests in protecting your data.
  • Consent: In certain cases, we may ask for your explicit consent to process your personal data for specific purposes. You have the right to withdraw your consent at any time.
  • Legal obligations: We may process your personal data to comply with our legal obligations as required by applicable laws and regulations.

An evaluation of the data for marketing purposes does not take place in this context.

4. Who we share data with

We may share data with Third parties such as aggregators, distributors and digital service providers. Certain Services made available via www.djmonitor.com are delivered by third-party sites and organizations. By using any product, service or functionality originating from the www.djmonitor.com domain, you hereby acknowledge and consent that DJ Monitor may share such information and data with any third party with whom DJ Monitor has a contractual relationship to provide the requested product, service or functionality on behalf of www.djmonitor.com Clients and Users.

Uploader data, as defined in Article 1.2. (f), is subject to processing by all our Clients.

Furthermore we may share data with third-party service providers acting on our behalf, as well as third parties, for the purpose of collecting data for more accurate music royalty distribution. Amongst other things, the Service is intended to help Clients make correct music royalty payments through more accurate distribution; view data trends; and digitalize data reporting.

Please note that some of these countries may have data protection laws that differ from those in your country and may not provide the same level of protection. When transferring your information to third-party providers located outside of Europe, we will ensure appropriate safeguards are in place, including the use of standard contractual clauses established by the European Commission.

Our current (third party) processors are:

  • Moneybird, Twinfield and Basecone for accounting,
  • Google Inc.
  • Podio

5. How long and where do we store data

We retain personal data for different periods based on specific circumstances. For example, we will retain data during the distribution cycles of Collective Management Organizations (CMOs) to facilitate proper payments and resolve any disputes. Additionally, we may retain personal data for a longer period to fulfill our contractual obligations and perform due diligence for parties acquiring music rights. We adhere to applicable laws and regulations, and personal data is retained only for as long as necessary for the purposes it was collected. Once the retention period expires, we will delete or block the data in a manner that ensures its complete and irreversible destruction.

In addition, further storing may take place if it is intended by the European or national legislator in EU regulations, laws, or other regulations to which the person responsible is subjected to.

The storage of the data in log files is done to monitor the performance of our website and thus to ensure the operations of the site, as well as to ensure the security of our information technology systems.

6. How do we protect data

Regarding storage, we take appropriate measures to ensure data security and protect against unauthorized access, destruction, loss, alteration, or misuse. We maintain organizational, technical, and administrative safeguards aligned with the risk associated with the processing of personal data covered by this Privacy Policy. Access to personal data is limited to those who require it for operational purposes. We actively monitor our database's security to ensure data protection.

While we strive to maintain the security of your information, it's important to note that no data transmission over the internet or storage method is entirely secure. We cannot guarantee 100% security, accuracy, completeness, or timeliness of personal information. However, we take necessary steps to ensure that authorized personnel accessing personal data process it only as instructed, unless required by Union or Member State law.

We do not sell or share personal data, except for music credits, without the separate consent of the individuals involved. Our services are intended for users of legal age for personal data protection purposes, as defined by the applicable law. We undertake reasonable measures to protect your data; however, it is important to be aware of the inherent risks associated with data transmission and storage.

7. Transfer of your Personal Data

You should be aware that your Personal Data may be transferred from your home country to third parties. If you are an EU resident, this could imply that we also transfer data to countries that do not offer an adequate level of protection for your Personal Data. When we transfer this data, we will do so only when we have put in place appropriate safeguards to protect your Personal Data. Please contact us to get a copy of the safeguards that we have put in place. Our contact details are at the bottom of this text.

Third-party processors are strictly prohibited from transferring or authorizing the transfer of personal data to countries outside the EU and/or the European Economic Area (EEA) without prior written consent from DJ Monitor. In instances where personal data processed under this Agreement is transferred from a country within the European Economic Area to a country outside the European Economic Area, both parties shall ensure the adequate protection of the Personal Data. By default, the parties will rely on EU-approved standard contractual clauses for the transfer of Personal Data unless alternative arrangements have been agreed upon.

8. Your Rights

Privacy laws provide individuals with certain rights regarding their personal data. If you wish to exercise any of the rights mentioned below, please contact us at info@djmonitor.com. We will respond to all requests within a reasonable timeframe. If you are an EU resident, you have the right to lodge a complaint with your local EU data protection authority if you have any unresolved concerns.

If your Personal Data is processed as a Client or User, you are considered a data subject under the GDPR and have the following rights:

8.1 Right to information

You have the right to request confirmation from us as to whether we are processing Personal Data related to you. If such processing exists, you may request the following information:

  1. The purposes for which your Personal Data is processed.
  2. The categories of Personal Data that are processed.
  3. The planned duration of storage of your Personal Data or, if specific information is not possible, the criteria used to determine the retention period.
  4. Your right to rectify or erase your Personal Data, or restrict its processing.
  5. Your right to lodge a complaint with a supervisory authority.
8.2 Right to rectification

If your processed Personal Data is incorrect or incomplete, you have the right to request rectification and/or completion from us. We are obligated to make the necessary corrections promptly.

8.3 Right to Restriction of Processing

Under certain conditions, you may request the restriction of processing your Personal Data. These conditions include:

  1. Disputing the accuracy of your Personal Data, giving us time to verify its accuracy.
  2. The processing being unlawful, and you refuse the erasure of your Personal Data, requesting the restriction of its use instead.
  3. We no longer require your Personal Data for processing purposes, but you need it for the establishment, exercise, or defense of legal claims.
  4. You have objected to the processing pursuant to Article 21(1) of the GDPR, and it is still under consideration whether our legitimate grounds override your reasons.

If your Personal Data has been restricted, it may only be used, aside from storage, with your consent or for the establishment, exercise, or defense of legal claims, the protection of the rights of another individual or legal entity, or important public interest reasons.

Before lifting any processing restrictions, we will notify you as a Client or User.

8.4 Right to Erasure

You have the right to request the deletion of your Personal Data without undue delay, and we are obligated to delete it immediately if one of the following applies:

  1. Your Personal Data is no longer necessary for the purposes for which it was collected or processed.
  2. You withdraw your consent to the processing, and there is no other legal basis for processing.
  3. You object to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for processing.
  4. Your Personal Data has been processed unlawfully.
  5. Deletion is necessary to comply with a legal obligation under Union or Member State law.
  6. Your Personal Data was collected in relation to information society services offered to you as a minor under Article 8(1) of the GDPR.
8.4.1 Information to third parties

If we have made your Personal Data public and are obligated to delete it under Article 17(1) of the GDPR, we will take appropriate measures, considering available technology and implementation costs, to inform other processors processing your Personal Data about your request for deletion, including any links or copies of your Personal Data.

8.4.2 Exceptions

The right to erasure does not apply if processing is necessary:

  1. To exercise the right to freedom of expression and information.
  2. To fulfill a legal obligation imposed on us by Union or Member State law, or to perform a task carried out in the public interest or in the exercise of official authority.
  3. For reasons of public interest in the area of public health, in accordance with Articles 9(2)(h) and (i) and Article 9(3) of the GDPR.
  4. For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, in accordance with Article 89(1) of the GDPR, where erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing.
  5. For the establishment, exercise, or defense of legal claims.
8.5 Right to Notification

If you have exercised your right to rectification, erasure, or restriction of processing, we are obliged to inform recipients to whom your Personal Data has been disclosed, unless it proves impossible or involves disproportionate effort. Upon your request, we will provide you with information about these recipients.

8.6 Right to Data Portability

You have the right to receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from us, provided that:

  1. The processing is based on your consent under Article 6(1)(a) or Article 9(2)(a) of the GDPR, or on a contract under Article 6(1)(b) of the GDPR.
  2. The processing is carried out by automated means.

When technically feasible, you have the right to have your Personal Data transmitted directly from us to another controller. This right shall not adversely affect the rights and freedoms of others. However, the right to data portability does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority delegated to us.

8.7 Right to Object

You have the right to object, on grounds relating to your particular situation, to the processing of your Personal Data based on Article 6(1)(e) of the GDPR, including profiling based on those provisions. We will no longer process your Personal Data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless the processing is necessary for the establishment, exercise, or defense of legal claims.

If your Personal Data is processed for direct marketing purposes, you have the right to object at any time to the processing of your Personal Data for such marketing. This includes profiling related to direct marketing. If you object to processing for direct marketing purposes, we will no longer process your Personal Data for those purposes.

You also have the option to exercise your right to object in the context of the use of information society services, notwithstanding Directive 2002/58/EC, using automated means incorporating technical specifications.

8.8 Right to Withdraw Consent

You have the right to withdraw your consent to data protection at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. However, the use of DJ Monitor's services and/or purposes will no longer be possible after the withdrawal.

9. Cookies and Other Technologies

Our website utilizes cookies to improve your browsing experience and provide you with specific functionalities. Cookies are small text files that are stored on your device when you visit a website.

We use PHP session ID number cookies to maintain your session on our website. These cookies enable us to personalize your browsing experience and remember your preferences, such as language and currency settings. They are automatically deleted when you close your browser.

Additionally, we employ reCAPTCHA cookies provided by Google to prevent automated bots and spam on our website. These cookies allow us to distinguish between humans and bots, thereby enhancing security measures. Please note that these cookies are governed by Google's Privacy Policy and Terms of Service.

By continuing to use our website, you consent to the use of cookies as described above. If you prefer not to accept cookies, you have the option to change your browser settings to disable or limit their use. However, please be aware that doing so may impact the functionality and performance of our website.

10. Version information

This policy was last updated on 1 July 2023. It can be viewed on: https://djmonitor.com/privacy-notice/

11. Contact information

Company name:
DJ Monitor B.V.
Address:
Keizersgracht 313 +1, 1016 EE Amsterdam
Personal Data Processing:
Customer and Partner Database
Creation date/last update:
29 January 2019/1 July 2023
Contact:*
privacy@djmonitor.com
* Not formally a DPO under the GDPR.