Privacy Policy

1. TrackOut - Our Privacy Policy

1.1 This Privacy Policy explains how [TRACKOUT LEGAL ENTITY NAME e.g. PT Saga Group] (“TrackOut,” “we,” “us,” or “our”) collects, uses, shares, stores, protects, and otherwise processes personal data relating to the TrackOut website, applications, beat catalog, project and recording tools, customization features, licensing features, subscription services, communications, APIs, and other related products and services (collectively, the “Services”).

1.2 Personal data (“Personal Data”) means information that relates to an identified or identifiable individual, whether directly or indirectly, including information that can identify a person when combined with other information reasonably available to us.

1.3 This Privacy Policy applies to visitors, account holders, subscribers, license holders, and other individuals who access or use the Services.

1.4 This Privacy Policy contains the following sections:

• a) Information we collect
• b) How we use your Personal Data
• c) Sharing your Personal Data
• d) How we store, protect and retain your Personal Data
• e) Children’s Privacy
• f) Other websites and third-party services
• g) Your privacy rights and choices
• h) AI and automated processing
• i) Contacting us about your Personal Data
• j) Changes to this Privacy Policy

2. Information We Collect

A. Information you provide to us directly

2.1 Account and Registration Information

2.1.1 When you create an account, we may collect information such as your name, username, email address, password or authentication credentials, country or region, date of birth or age information where required, profile image, and identifiers received from a third-party sign-in provider if you choose to register using services such as Google or another supported provider.

2.1.2 Certain account or profile information may be displayed to other users if TrackOut provides public profiles or community-facing features. We will identify which fields are public before you submit or publish them.

2.2 Profile Information

2.2.1 You may choose to provide additional profile information, such as a display name, profile picture, biography, links, artist or creator information, and other information about yourself or your music.

2.2.2 Please use discretion when deciding what information to make public or share with other users through the Services.

2.3 Creative Content and Project Data

2.3.1 When you use TrackOut’s creative tools, we may collect and process content that you upload, record, create, save, modify, or export through the Services. This may include vocal recordings, demos, stems, audio files, lyrics, project titles, notes, and other project content.

2.3.2 We may also process project configuration data such as beat selections, saved projects, arrangement or section changes, BPM or pitch settings, mute or solo states, effects settings, and technical data required to preview, render, synchronize, transcode, or export a project.

2.3.3 TrackOut does not acquire ownership of your original user content merely because you upload it to the Services. Ownership, licenses granted to TrackOut for operating the Services, and rights relating to beats or other licensed content are governed separately by our Terms of Use and applicable license agreements.

2.4 Licensing, Subscription and Entitlement Information

2.4.1 When you claim, purchase, receive, download, or manage a beat license, subscription, or other entitlement, we may collect records such as your user ID, license ID, beat or track ID, license type, license version, claim or transaction date and time, subscription tier, entitlement status, and related download or export history where necessary for license administration.

2.4.2 Certain license and transaction records may be retained after a project is deleted or an account is closed where reasonably necessary to establish license history, resolve disputes, prevent fraud or unauthorized licensing, comply with accounting or tax obligations, or meet other legal requirements.

2.5 Payment and Billing Information

2.5.1 Payments may be processed by third-party payment providers. Depending on the payment method and provider, we may receive information such as your billing name, billing address, transaction status, payment method type, limited payment identifiers, invoice information, and transaction metadata.

2.5.2 We generally do not receive or store complete payment card numbers where payment details are collected directly by a third-party payment processor. [CONFIRM BASED ON TRACKOUT’S PAYMENT ARCHITECTURE].

2.6 Communications and Support Information

2.6.1 We may collect communications between you and TrackOut, including support requests, reports, feedback, survey responses, emails, and other messages, together with information reasonably necessary to investigate and respond to those communications.

B. Information collected automatically when you use the Services

2.7 Usage, Log and Device Information

2.7.1 When you use the Services, certain information may be collected automatically, including your Internet Protocol (“IP”) address, browser type and version, operating system, device type, language, referring and exit pages, timestamps, pages or screens viewed, clicks and interactions, feature usage, session information, error logs, crash information, network information, approximate location derived from IP address, and security or fraud-prevention signals.

2.8 Cookies and Similar Technologies

2.8.1 The Services may use cookies, local storage, pixels, software development kits, and similar technologies to operate the Services, maintain sessions, remember preferences, understand product performance, prevent abuse, and, where applicable and permitted, measure marketing or advertising effectiveness.

2.8.2 Where applicable law requires consent for non-essential cookies or similar technologies, we will request that consent before using them. You may also be able to manage certain technologies through your browser, device, or consent settings. Some features may not function properly if required technologies are disabled.

C. Information we receive from third parties

2.9 We may receive information from third parties when you choose to use or connect their services with TrackOut, including authentication providers, payment processors, analytics providers, referral partners, and other integrations. The information we receive depends on your settings, the relevant integration, and the third party’s own practices.

3. How We Use Your Personal Data

3.1 How we process your Personal Data depends on your interaction with the Services and the purpose for which the data is required. Where applicable law requires a specific lawful basis, we rely on one or more lawful bases such as performance of a contract, compliance with legal obligations, our legitimate interests where permitted, and your consent where required.

3.2 We may use Personal Data for the following purposes:

• a) create, authenticate, secure, and administer your account;
• b) provide access to the beat catalog and relevant discovery or recommendation features;
• c) create, save, process, preview, customize, render, export, and otherwise operate projects and audio features;
• d) generate, administer, verify, and maintain license claims, license records, and user entitlements;
• e) provide subscription features and manage billing or transaction status;
• f) remember your settings and preferences;
• g) communicate with you about your account, licenses, subscriptions, security, support requests, and service updates;
• h) provide customer support and respond to feedback, reports, or disputes;
• i) monitor usage, performance, reliability, and product metrics;
• j) diagnose technical issues, test features, improve the Services, and develop new functionality;
• k) protect TrackOut, its users, beat licensors, rights holders, and the Services against fraud, abuse, unauthorized access, license manipulation, copyright misuse, security threats, or illegal activity;
• l) comply with tax, accounting, copyright, legal, regulatory, and law-enforcement obligations where applicable;
• m) send marketing communications where permitted and subject to any required consent or opt-out rights; and
• n) carry out other purposes disclosed to you at the time the Personal Data is collected or with your consent where required.

4. Sharing Your Personal Data

4.1 We may share Personal Data with the following categories of recipients where reasonably necessary for the purposes described in this Privacy Policy:

• a) Related entities. Businesses that are legally part of the same corporate group as TrackOut, if any, subject to applicable privacy requirements.
• b) Service providers and processors. Third parties that help us provide, secure, host, maintain, analyze, or support the Services, such as cloud infrastructure, database, object storage, content delivery, authentication, email, customer support, monitoring, analytics, security, and professional service providers.
• c) Payment providers. Third-party processors that facilitate payments, billing, subscriptions, refunds, invoicing, or fraud prevention.
• d) Professional advisers. Lawyers, accountants, auditors, insurers, and other professional advisers where reasonably necessary.
• e) Authorities and legal recipients. Government bodies, regulators, courts, law-enforcement agencies, or other parties where disclosure is required or permitted by law or reasonably necessary to protect rights, safety, property, users, or the Services.
• f) Corporate transaction recipients. Actual or prospective buyers, investors, lenders, successors, or advisers in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, subject to appropriate confidentiality and legal safeguards.

4.2 We expect service providers that process Personal Data on our behalf to protect that information and process it only for authorized purposes, subject to applicable contracts and law.

4.3 We may use or share aggregated or de-identified information that can no longer reasonably identify you, where permitted by law.

5. How We Store, Protect and Retain Your Personal Data

5.1 Personal Data may be stored or processed in countries where TrackOut, its affiliates, or its service providers operate. Depending on TrackOut’s production infrastructure, this may include countries outside Indonesia. [CONFIRM ACTUAL HOSTING, DATABASE, STORAGE, CDN, BACKUP, AND PROCESSING LOCATIONS BEFORE PUBLICATION].

5.2 Where Personal Data is transferred across borders, TrackOut will take steps required by applicable law to provide appropriate safeguards for the transfer and processing of that data.

5.3 We use reasonable technical and organizational measures designed to protect Personal Data against unauthorized access, loss, misuse, alteration, disclosure, or destruction. No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

5.4 You are responsible for maintaining the confidentiality of your account credentials and should notify us promptly if you suspect unauthorized access to your account.

5.5 We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain legitimate license records, comply with legal, accounting, or tax requirements, resolve disputes, prevent fraud and abuse, and enforce our agreements.

5.6 Retention periods may differ depending on the category of data. For example, active project data may be deleted following user deletion requests or account closure subject to operational backup cycles, while certain license, transaction, security, or legal records may be retained for a longer period when there is a valid reason to do so. [APPROVE INTERNAL RETENTION SCHEDULE BEFORE PUBLICATION].

6. Children’s Privacy

6.1 The Services are not intended for children under 13 years of age, and TrackOut does not knowingly collect Personal Data from children under 13 without legally valid parental or guardian authorization where required.

6.2 If we learn that Personal Data from a child has been collected in violation of applicable law, we will take reasonable steps to delete or otherwise address that information.

6.3 If you are a parent or legal guardian and believe a child has provided Personal Data to TrackOut in violation of applicable requirements, please contact us using the details in Section 11.

6.4 TrackOut may apply additional age restrictions, parental-consent requirements, or youth protections in jurisdictions where they are legally required.

7. Other Websites and Third-Party Services

7.1 The Services may contain links to or integrate with third-party websites, applications, payment providers, authentication services, social platforms, or other services. This Privacy Policy does not govern independent third-party processing.

7.2 Third parties may have their own privacy policies, terms, and security practices. We encourage you to review those policies before providing Personal Data to or authorizing access by a third party.

7.3 TrackOut is not responsible for the privacy practices of independent third-party services that are outside our control.

8. Your Privacy Rights and Choices

8.1 Depending on where you live and the law that applies, you may have rights concerning your Personal Data. These may include the right to request access, correction, deletion, restriction of processing, withdrawal of consent, objection to certain processing, data portability, information about processing, or review of certain automated decisions.

8.2 You may also have the right to complain to a competent data protection or privacy authority if you believe your Personal Data has been processed unlawfully.

8.3 To exercise a privacy right, contact us at [privacy@trackout.io]. We may need to verify your identity before completing a request and may ask for information reasonably necessary for verification. We may deny or limit a request where permitted or required by law, and we will explain the applicable reason where legally required.

8.4 Deleting a TrackOut account may not result in immediate deletion of every record. We may retain information that must or may lawfully be kept, including certain license evidence, transaction records, security records, dispute records, or backups, subject to applicable retention limits.

8.5 Where marketing communications are sent, you may opt out through the unsubscribe mechanism in the message or through available account settings. We may still send non-marketing communications necessary to operate your account or provide the Services, including security, billing, transaction, license, and service notices.

8.6 Additional rights for users in certain jurisdictions

8.6.1 If you use the Services in the European Economic Area or the United Kingdom and applicable data protection law applies, you may have rights including access, rectification, erasure, restriction, portability, objection, withdrawal of consent, rights concerning certain automated decision-making, and the right to complain to a competent supervisory authority. Where required, our processing will rely on an applicable legal basis and international transfers will use a legally recognized transfer mechanism.

8.6.2 If Republic of Indonesia privacy law applies to TrackOut and to you, you may have rights including the right to know or access certain Personal Information, request deletion or correction, opt out of certain sale or sharing activities, limit certain uses of Sensitive Personal Information where applicable, and receive non-discriminatory treatment for exercising applicable rights. TrackOut will provide any additional notices or request mechanisms required if and when those provisions apply.

8.6.3 [CONFIRM WHETHER TRACKOUT REQUIRES AN EU OR UK REPRESENTATIVE, DATA PROTECTION OFFICER, OR ADDITIONAL JURISDICTION-SPECIFIC NOTICE BASED ON ACTUAL OPERATIONS].

9. AI and Automated Processing

9.1 [INCLUDE ONLY TO THE EXTENT APPLICABLE] TrackOut may use automated systems to support functions such as recommendations, search, security, moderation, audio processing, or customer support.

9.2 Before TrackOut enables a feature that sends user content or Personal Data to a third-party AI or model provider, this Privacy Policy should be updated as necessary to describe the purpose of processing, relevant categories of data, provider relationship, retention practices, user controls, and whether submitted content may be used to train or improve third-party models.

10. Legal Compliance and Protection

10.1 We may process, preserve, or disclose Personal Data where reasonably necessary to comply with applicable laws, regulations, legal processes, or valid governmental requests, or to establish, exercise, or defend legal claims.

10.2 We may also process Personal Data where reasonably necessary to investigate or prevent fraud, copyright abuse, license manipulation, security incidents, prohibited conduct, threats to users, or other misuse of the Services, subject to applicable law.

11. Contacting Us About Your Personal Data

11.1 If you have questions, concerns, feedback, or requests relating to this Privacy Policy or TrackOut’s processing of Personal Data, you may contact:

[TRACKOUT LEGAL ENTITY NAME e.g. PT Saga Group]

Privacy Contact / Data Protection Contact

Email: privacy@trackout.io

Registered Address: [REGISTERED ADDRESS]

Country: Indonesia

11.2 Where applicable, we will respond to valid privacy requests within the period required by law and may request reasonable information to verify your identity or authority to make the request.

12. Changes to This Privacy Policy

12.1 We may update this Privacy Policy from time to time to reflect changes to the Services, our practices, technology, legal requirements, or other operational needs.

12.2 When we make changes, we will update the date shown at the top of this Privacy Policy. If a change is material, we will provide additional notice where required or reasonably appropriate, such as through the Services or by email.

12.3 Where applicable law requires your consent to a new or materially changed processing activity, continued use of the Services will not replace any consent that we are legally required to obtain.