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Privacy Policy – HAT Music App

Last updated: February 2025

1. Introduction

Welcome to the HAT Music app ("App"). Your privacy is very important to us. This Privacy Policy describes how we collect, use, and protect your personal information when you use the App.

2. Data Controller

The Data Controller is HAT Capital Partners S.r.l., with registered office at Viale Ranzoni, 2 – 20149, Milan, IT - (VAT 13925910963).

3. Information we collect and how we process it

When you use our App, we collect different types of information depending on the activities you perform: ▪ Usage data: we may collect information about how you access and use the App. This usage data may include information such as your device's Internet Protocol address, browser type, browser version, App sections visited, time and date of use, time spent on the App, unique device identifiers, and other diagnostic data. ▪ Personal data: when creating your account and profile on the App, we may ask you to provide certain personal data, which may include personal details, contact information, payment data, preferences, and references to social networks and external channels. Some of this data (specifically those marked with an asterisk "*" on the online form) is required for the creation and operation of your profile on the App. ▪ Performance data: through API integration with third-party platforms, we may process (and show you in the "Analytics" section) data relating to the performance of your social channels and the content uploaded to them, such as views on YouTube or Instagram. In addition to the data listed above, we may process further information such as chats, and transactions to and from your in-App "Wallet".

4. Use of information and legal basis

We use the information collected for various purposes: ▪ Usage data: to provide you with a better experience on our App, as well as to detect, prevent, and address any technical issues. The legal basis for the use of this data is legitimate interest (Art. 6(e) GDPR). ▪ Personal data: personal details, contact information, as well as certain banking information, to provide our service or to provide support to users. The legal basis for the use of this data is the performance of a contract or pre-contractual measures taken at the request of the user (Art. 6(b) GDPR). ▪ Performance data: to provide you with the "Analytics" service and allow you to monitor in a single App the performance of all your social channels and newly posted content. The legal basis for the use of this data is user consent (Art. 6(a) GDPR). Failure to provide consent will prevent use of the "Analytics" service.

5. Disclosure and transfer of your data outside the European Economic Area

Your personal data will be processed within the European Economic Area (EEA). Should it become necessary to transfer the collected data outside the EEA, all appropriate safeguards will be adopted by the Controller in accordance with the GDPR.

6. Parties processing your data

Internal parties: your data will be processed by our employees duly authorized to process personal data and will be processed solely for the purposes for which it was collected. External parties: in addition to our employees, your data may be processed by parties external to our organization, such as the provider of our App's hosting service or the party managing online payment operations (e.g., Apple Pay, Stripe, etc.). In this case as well, all external parties authorized to process your data will be duly appointed as Data Processors and may only carry out the processing for which they have been appointed. With your explicit consent, we may also share your personal data with third parties such as scouting agencies for purposes related to promoting the user or offering services related to the music and arts industry. Consent to this processing may be given at the time of registration or subsequently and may be revoked at any time.

7. User rights

The GDPR grants you the following rights in relation to your personal data, which you may exercise within the limits and in accordance with applicable regulations: ▪ Right of access to your personal data (Art. 15); ▪ Right to rectification (Art. 16); ▪ Right to erasure (right to be forgotten) (Art. 17); ▪ Right to restriction of processing (Art. 18); ▪ Right to data portability (Art. 20); ▪ Right to object (Art. 21) and right to object to a decision based solely on automated processing (Art. 22); ▪ Right to withdraw, at any time, the consent given, without affecting the lawfulness of processing based on consent given before withdrawal (Art. 7.3). You may exercise your rights by contacting us at the details indicated in the "Contact" section of this policy.

8. Third-Party Services

Our App, as well as our website, may contain links to third-party sites, apps, and services. By clicking on a third-party link, you will be directed to the site, app, or service of that party. We recommend that you always review the Privacy Policy of the site or service visited or used. These sites, apps, and services belong to parties external to HAT Music and, therefore, we have no control over (and assume no responsibility for) the content therein or the processing carried out by them.

9. Contact

If you have any questions about this Privacy Policy, you can contact us by sending an email to ciao@hatmusic.it.