Privacy Notice pursuant to Article 13 of EU General Data Protection Regulation 2016/679 (GDPR)

Sugarmusic S.p.A. a Socio Unico with registered office at Galleria del Corso 4, 20122 Milan (hereinafter the “Company” or “Data Controller”), is constantly committed to protecting its users' online privacy.

A) Source of Personal Data and Data Controller

This document has been drafted pursuant to Article 13 of EU Regulation 2016/679 (hereinafter the “Regulation”) to inform you about our privacy policy. It describes the general methods of processing users’ personal data and how your personal information is managed when you use our website www.sugarmusic.com (hereinafter the “Website”). The information and data you provide or that are otherwise acquired in connection with the use of the Company's services – such as access to the restricted area of the Website, newsletters, etc. (hereinafter the “Services”) – will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that underpin the Company’s operations.

In accordance with the Regulation, processing carried out by the Company will be based on the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity, and confidentiality.

The data controller for the processing carried out through the Website is Sugarmusic S.p.A. a Socio Unico, with registered office at Galleria del Corso 4, 20122 Milan, as defined above. You may contact the Company for any information regarding the processing of personal data.

This notice applies only to this Website and not to other websites that may be accessed by the user via links. Specific information notices and any requests for consent regarding individual processing activities may be provided in specific sections of the Website.

B) Types of Data

In connection with your visit of the Website, we inform you that the Company will process personal data (Article 4(1) of the Regulation), hereinafter referred to as “Personal Data”. Specifically, the Personal Data processed through the Website includes the following:

1) Browsing data

The IT systems and software procedures employed for the operation of the Website acquire, during their normal  operation, certain Personal Data, the transmission of which is implicit in the use of Internet communication protocols. Such information is not collected to be associated with identified individuals, however, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the Website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), and other parameters related to the user’s operating system and IT environment. This data is used solely to obtain anonymous statistical information on the use of the Website and to ensure its proper functioning (see Cookie Policy – www.sugarmusic.com/cookie-policy), to identify anomalies and/or abuses, and is deleted immediately after processing. The data could be used by competent authorities to ascertain responsibility in case of potential cybercrimes against the Website.

2) Data voluntarily provided by the user

Apart from what has been  specified for browsing data, users are free to provide personal data requested in any forms on the website (e.g., to subscribe newsletters, registration for free, etc.). Failure to provide such data may result in the inability to deliver the requested service. In such cases, only the data strictly necessary to provide the requested service will be collected (see specific information notices). 

While using certain Website Services, you may provide the Company with Personal Data of third parties. In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities. In this regard, you hereby fully indemnify the Company against any complaints, claims, or demands for compensation for damages that may arise from third parties whose Personal Data has been processed through your use of the Website’s  functionalities in violation of applicable data protection laws. In any case, should you provide or otherwise process Personal Data of third parties when using the Website, you guarantee – and assume all related responsibility – that such processing is based on an appropriate legal basis pursuant to Article 6 of the Regulation that legitimizes the processing of the information in question.

C) Purpose of the processing and legal bases

The processing of your personal data, subject to your specific consent where necessary, has the following purposes:

To enable the provision of the Website’s Services;

The legal basis for the processing is the performance of a contract to which the data subject is a party or the implementation of pre-contractual measures taken at the data subject’s request (Article 6(1)(b) of the Regulation).

Providing Personal Data for these purposes is optional, but failure to do so may result in the inability to activate certain Services provided by the Website.

D) Recipients of Personal Data

Your Personal Data may be shared, for the purposes listed above, with:

individuals who are authorized by the Company to process Personal Data, as necessary to carry out activities strictly related to the provision of the Services, who have committed to confidentiality or are under a proper legal obligation of confidentiality (e.g., employees and system administrators).

third parties potentially in charge of managing the Website, typically acting as Data Processors (the full and updated list of Data Processors is available at www.sugarmusic.com)

entities, bodies, or authorities to whom the data must be disclosed under legal provisions or orders from authorities.

E) Transfers of Personal Data

Some of your Personal Data may be shared with recipients located outside the European Economic Area. The Company ensures that the processing of your Personal Data by such recipients is carried out in compliance with the Regulation. In fact, such transfers may be based on an adequacy decision, on Standard Contractual Clauses approved by the European Commission, or another appropriate legal basis.

F) Retention of Personal Data

Your Personal Data will be stored only for as long as necessary for the purposes for which it was collected, in compliance with the data minimization principle under Article 5.1(c) of the Regulation.

In any case, your personal data will be retained for the time required to provide the Website’s Services. For data retention periods related to specific forms on the Website, please refer to the relevant information notices.

G) Your Privacy Rights under Articles 15 et seq. of the Regulation

Pursuant to Articles 15 and following of the Regulation, you have the right to request from the Company, at any time, access to your Personal Data, its rectification or erasure, object to its processing, request the restriction of processing in the cases provided for under Article 18 of the Regulation, and to receive the data concerning you in a structured, commonly used, and machine-readable format in the cases provided for under Article 20 of the Regulation.

Requests must be submitted in writing to the Data Controller at the following address: privacy@sugarmusic.com

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to applicable law.

H) Amendments

This privacy policy is effective as of 30/01/2025. The Company reserves the right to modify or simply update its content, in part or in full, including due to changes in applicable legislation. The Company will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website.

The Company therefore invites you to regularly review this section to be aware of the latest and most up-to-date version of the privacy policy, so that you are always informed about the data collected and how the Company uses it.