Welcome to the Privacy Policy of WELKER ("we," "us," or "our"). This Privacy Policy governs how we collect, use, process, store, protect, and share your personal information when you interact with our website (welkermusic.com), social media platforms (e.g., Instagram, SoundCloud, Spotify), and any related services connected to the WELKER project, led by Brazilian producer Eduardo Welker and managed by Sunburn MGMT. This policy complies with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and Brazilian General Data Protection Law (LGPD).
By accessing or using our services, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use our services.
### 1. Scope of This Policy
This Privacy Policy applies to all personal data we collect through:
- Our website and any subdomains.
- Our profiles on third-party platforms (e.g., Instagram, SoundCloud, Spotify).
- Forms, emails, or communications you submit via our "Contact" section or other interactions.
- Cookies and tracking technologies used on our website.
It does not apply to third-party websites or services linked from our site, which are governed by their own privacy policies.
### 2. Definitions
- Personal Data: Any information relating to an identified or identifiable natural person, such as name, email address, IP address, or device information.
- Data Subject: Any individual whose personal data we process.
- Processing: Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
### 3. Types of Personal Data We Collect
We may collect the following categories of personal data:
- Contact Information: Name, email address, and any other information you provide through our contact form or email communications (e.g., sent to johnny@sunburnmgmt.com).
- Usage Data: Information about your interaction with our website, including:
- IP address.
- Browser type and version.
- Pages visited, time spent, and clickstream data.
- Device information (e.g., device type, operating system).
- Cookie Data: Data collected via cookies, web beacons, or similar technologies to enhance user experience and analyze site performance.
- Third-Party Data: Information collected by third-party platforms (e.g., Instagram, SoundCloud, Spotify) when you interact with our profiles or links, subject to their privacy policies.
We do not collect sensitive personal data (e.g., racial or ethnic origin, political opinions, health data) unless explicitly provided by you and required for specific purposes (e.g., accessibility requests).
### 4. How We Collect Your Personal Data
We collect personal data in the following ways:
- Directly from You: When you fill out our contact form, subscribe to updates, or communicate with us via email or social media.
- Automatically: Through cookies, web analytics tools, and tracking technologies when you visit our website.
- Third Parties: From social media platforms, analytics providers, or other partners, subject to your consent or their privacy policies.
### 5. Purposes and Legal Bases for Processing
We process your personal data for the following purposes, based on the legal bases under applicable law:
- To Respond to Inquiries (Contractual Necessity): We process your name and email address to respond to your messages or requests via our contact form, fulfilling our contractual obligations or pre-contractual measures.
- To Improve Our Services (Legitimate Interest): We analyze usage data and cookie information to enhance our website, content, and music services, based on our legitimate interest in improving user experience and business operations.
- To Comply with Legal Obligations (Legal Obligation): We may process data to comply with legal requirements, such as tax laws, data retention regulations, or court orders.
- With Your Consent: For marketing purposes (e.g., newsletters, promotional updates), if you explicitly consent. You may withdraw consent at any time by contacting us at johnny@sunburnmgmt.com.
If we process data based on legitimate interest, we ensure it does not override your fundamental rights and freedoms.
### 6. Sharing of Personal Data
We do not sell, rent, or trade your personal data. We may share your data only in the following circumstances:
- Service Providers: With third-party vendors (e.g., website hosting, analytics, email services) who assist us in operating our services, under strict confidentiality agreements and only to the extent necessary.
- Legal Requirements: When required by law, regulation, or legal process (e.g., subpoenas, court orders), or to protect our rights, property, or safety.
- Business Transfers: In connection with a merger, acquisition, or sale of all or part of our assets, where your data may be transferred to the new owner, subject to this Privacy Policy.
- With Your Consent: If you explicitly agree to share your data with third parties (e.g., social media platforms).
We do not share data with advertisers or data brokers unless required by law or with your consent.
### 7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. Specific retention periods include:
- Contact information: Up to 3 years after your last interaction, unless you request deletion.
- Usage data: Up to 12 months for analytics purposes.
- Cookie data: As specified in our cookie policy or until you delete them via your browser settings.
You may request deletion of your data at any time by contacting us at johnny@sunburnmgmt.com.
### 8. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:
- Encryption of data in transit and at rest.
- Access controls and authentication protocols.
- Regular security audits and updates.
However, no method of transmission or storage over the internet is completely secure. We cannot guarantee absolute security, and you acknowledge this risk by using our services.
### 9. Your Rights as a Data Subject
Under applicable data protection laws (e.g., GDPR, CCPA, LGPD), you have the following rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Correct inaccurate or incomplete data.
- Right to Erasure ("Right to Be Forgotten"): Request deletion of your data, subject to legal obligations.
- Right to Restriction: Limit how we process your data under certain conditions.
- Right to Data Portability: Receive your data in a structured, commonly used format.
- Right to Object: Object to processing based on legitimate interest or direct marketing.
- Right to Withdraw Consent: Withdraw consent for processing where consent is the legal basis.
- Right to Lodge a Complaint: File a complaint with a supervisory authority (e.g., data protection authority in your jurisdiction).
To exercise these rights, contact us at johnny@sunburnmgmt.com. We will respond within 30 days or as required by law.
### 10. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to enhance functionality and analyze usage. You can manage cookie preferences through your browser settings or by contacting us. For more details, see our Cookie Policy (if applicable, or integrate it here).
- Essential Cookies: Necessary for website operation (e.g., session management).
- Analytical Cookies: Used to track website performance and user behavior (e.g., Google Analytics).
- Functional Cookies: Enhance user experience (e.g., remembering preferences).
You may opt out of non-essential cookies, but this may affect site functionality.
### 11. International Data Transfers
If you are located outside Brazil, the United States, or the European Economic Area (EEA), your data may be transferred to and processed in these regions. We ensure that such transfers comply with data protection laws, using standard contractual clauses (SCCs) or other approved mechanisms under GDPR or LGPD.
### 12. Third-Party Links
Our site contains links to third-party platforms (e.g., Instagram, SoundCloud, Spotify). We are not responsible for their privacy practices. Review their privacy policies before interacting with their services.
### 13. Children’s Privacy
Our services are not directed to individuals under 16. We do not knowingly collect personal data from minors. If we become aware of such collection, we will delete the data and notify the parent or guardian. If you believe a minor has provided us with data, contact us at johnny@sunburnmgmt.com.
### 14. Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or business operations. Changes will be posted on this page with the update date. Continued use of our services after such changes constitutes your acceptance of the new policy.
### 15. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:
- Email: johnny@sunburnmgmt.com
- Data Protection Officer (DPO): [Insert DPO Name or Role, if applicable]
You may also contact the relevant data protection authority in your jurisdiction if you believe your rights have been violated.