Privacy

In this Privacy Policy, the 'Service' refers to the services provided on the Orbit Media, which include, but are not limited to, an online platform enabling music artists to join, download, create, and distribute music products, including audio, video, and immersive formats, and allowing labels and producers to upload recordings for use in these music products. 'Users' refers to customers, members, or any individual who accesses the Orbit Media platform.

This Site is operated with a commitment to protecting your privacy. We aim to comply with applicable data protection laws, including the General Data Protection Regulation (GDPR), regarding the personal information you provide.

The data controller is: DeVest d.o.o. Prolaz Marije Krucifikse Kozulić 1 51000 Rijeka, Croatia Represented by Michael Hasler, CEO Email: [email protected]

For data protection inquiries, please contact us at the address provided above.

The information we collect ('Information') may include names, addresses, Date of Birth (including year of birth), Country of residence, financial details (bank account, credit/debit card numbers, expiry dates, wallet addresses), and email addresses. If you are a registered member, the Information includes personal details submitted to Orbit Media and details of your platform visits. We will not sell, distribute, or disclose your Information without your consent, except as required or permitted by law.

We collect and process this Information for the following purposes and on the following legal bases:

Performance of Contract (Art. 6(1)(b) GDPR): To provide the Service, manage accounts, and process transactions; Legal Obligation (Art. 6(1)(c) GDPR): To verify your age (FSK standards) and comply with international regulatory and tax reporting obligations, including the EU’s DAC8 directive and AML/KYC requirements; Legitimate Interest (Art. 6(1)(f) GDPR): To prevent fraud, maintain security, and improve our platform; Consent (Art. 6(1)(a) GDPR): For the newsletter signup and subscription described in the Newsletter section below.

As a user within the European Union, you have the following rights regarding your personal data:

1. Right of Access (Art. 15 GDPR): You can request a copy of the personal data we hold about you. 2. Right to Rectification (Art. 16 GDPR): You can ask us to correct inaccurate or incomplete data. 3. Right to Erasure ("Right to be Forgotten") (Art. 17 GDPR): You can request that we delete your data under certain conditions. 4. Right to Restriction of Processing (Art. 18 GDPR): You can ask us to limit how we use your data. 5. Right to Data Portability (Art. 20 GDPR): You can request a transfer of your data to another service. 6. Right to Object (Art. 21 GDPR): You can object to the processing of your data for specific purposes (e.g., direct marketing). 7. Right to Lodge a Complaint (Art. 77 GDPR): You have the right to complain to a data protection authority.

To exercise these rights, please contact us at [email protected].

Please notify us of any changes to the Information you have submitted. You can update your basic Information by contacting us at [email protected]

We may use your Information to notify you about important updates, changes to Orbit Media, and our terms and conditions. We may also provide you with information about our products and services. With your permission, we may allow selected third parties to contact you about relevant products and services. You can opt out of these communications by contacting us at [email protected].

Newsletter subscriptions are governed by the separate Newsletter section below. Signing up for the Orbit newsletter does not give permission for selected third parties to send you their own marketing.

We share data with third-party service providers (Processors) to operate the platform. These include:

Payment & Crypto Gateways: Transak, Revolut (for transaction processing and compliance); Invoicing & Fiscalization: Billko (for tax compliance and invoice generation); Infrastructure: Cloud and storage providers; Email Delivery: Brevo (formerly Sendinblue), for sending newsletter confirmation emails through our email delivery integration.

Your Information may be transferred to and stored outside of the EEA. We take steps to ensure adequate protection (e.g., Standard Contractual Clauses) as required by GDPR. By submitting your Information, you agree to this transfer, storage, and processing.

In the event of a merger or acquisition, your personal data may be transferred as an asset.

You can subscribe to news from Orbit, stories from creators and new releases without creating an Orbit account. We require your email address. You may also provide your name, role (such as artist, independent label or listener) and primary interest. These additional fields are optional and help us understand our audience and the topics that interest them; leaving them blank does not prevent signup.

We process your newsletter signup and subscription on the basis of your consent under Article 6(1)(a) GDPR. After signup, we send a confirmation email. Clicking the confirmation link activates your subscription automatically when the page opens in your browser. Any additional profile details requested afterwards are optional and do not affect your subscription. The confirmation link expires after 24 hours. We record your subscription status and the dates of signup, confirmation and any unsubscribe request to manage your subscription and record these choices.

You can withdraw your newsletter consent at any time using the unsubscribe link provided in newsletter emails or by contacting [email protected]. Withdrawal stops future newsletter use of your details and does not affect the lawfulness of processing based on consent before withdrawal. You do not need an Orbit account to unsubscribe.

We use Brevo (formerly Sendinblue) as our email delivery processor. For the signup confirmation, our integration sends Brevo your recipient email address and the message content, including confirmation and unsubscribe links. Your optional name, role and interest are stored by Orbit and are not included in this confirmation email or sent as contact attributes by the signup integration. Brevo processes technical delivery information as part of providing its service. Further information about its processing arrangements and subprocessors is available in Brevo's Data Processing Agreement.

Brevo's email-open and link-click tracking is enabled. Tracking pixels and tracked links can record whether an email was opened or a link was clicked and associate that activity with the recipient. These records support email engagement reports and are separate from the information needed simply to deliver an email.

We store your email address, any optional details you provide, subscription status and signup-related timestamps in our subscriber database. Expiry of a confirmation link does not itself delete the signup record. Unsubscribing marks the subscription as inactive for newsletter delivery, but does not automatically erase the stored record or optional details. You may request erasure or exercise your other data protection rights by contacting [email protected], as described in the Your Rights Under GDPR section.

To remember your popup choice, the website stores a preference in your browser. Dismissing the newsletter popup suppresses it for 30 days. A successful signup request or confirmation stores a marker that suppresses future automatic prompts; this marker has no automatic expiry. These preferences do not contain your email address. You can remove them by clearing the website's browser data, which does not unsubscribe you from the newsletter.

The Service may integrate with third-party platforms such as Comparo d.o.o. for specific features (e.g., rewards or advertising). These partners may have their own independent Terms & Conditions and Privacy Policies. When you interact with these integrated services, your data may be processed by these partners as independent or joint data controllers. We recommend reviewing their respective legal documents. We are not responsible for the data processing practices of these independent third parties.

We may use cookies to monitor platform usage and improve our services. You can refuse cookies in your browser settings, but this may affect platform functionality. We may also use IP addresses, operating systems, and browser types to analyze usage trends, without personal identification.

We use security systems to protect your Information. However, Internet transmissions are not guaranteed to be 100% secure. We are not responsible for unauthorized access or loss of personal information beyond our control. Please note that emails and messages sent via the website are not secure unless encrypted.

We may update this Privacy Policy from time to time. The amended version will be published on Orbit Media.