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Personal Data Processing Policy

1. General provisions

1.1. This Personal Data Processing Policy defines the procedure for processing and protecting personal data of users of the White Rock service and is prepared in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”. The personal data operator is Individual Entrepreneur Kirill Sergeevich Bekichev, TIN 262810847515, PSRN 325265100031062.

1.2. The Policy applies to information the Operator receives when using the White Rock website and personal account, related subdomains, feedback forms, authorization, support, analytics, finance, AI generation features and other platform functions.

2. Key definitions

  • 2.1. Automated personal data processing — processing of personal data using computer hardware, software and network infrastructure.
  • 2.2. Blocking of personal data — temporary cessation of personal data processing except where processing is required to clarify such data.
  • 2.3. Service / website — the White Rock information resource, including the website, personal account, subdomains, interfaces, forms, document pages and other digital sections available to the user.
  • 2.4. Personal data information system — a set of personal data contained in databases, as well as information technologies and technical means ensuring their processing.
  • 2.5. Depersonalization of personal data — actions resulting in the inability to determine data ownership to a specific user without additional information.
  • 2.6. Personal data processing — any action or set of actions with personal data, including collection, recording, systematization, storage, clarification, use, transfer, blocking and destruction.
  • 2.7. Operator — a person independently or jointly with others organizing and carrying out processing of personal data of White Rock service users.
  • 2.8. Personal data — any information relating directly or indirectly to a specific or identifiable service user.
  • 2.9. User — any individual or legal entity, representative thereof or visitor using the website, personal account or other White Rock service features.
  • 2.10. Provision of personal data — disclosure of personal data to a specific person or specific group in the scope necessary to achieve a lawful processing purpose.
  • 2.11. Dissemination of personal data — disclosure of personal data to an indefinite group in cases and scope permitted by the user or provided by law.
  • 2.12. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, foreign person or foreign organization.
  • 2.13. Destruction of personal data — actions resulting in deletion of personal data without possibility of further recovery, unless otherwise required by law.

3. What data we process

3.1. The Operator may process the following categories of data: user name and contact details, email address, authorization and session data, profile information, information about releases, tracks, cover art, artists and other materials, text prompts and other data entered when using AI generation features, support messages, subscription, payment and payout data, as well as other information voluntarily provided by the user when using the service.

3.2. Technical and depersonalized data may also be collected: IP address, cookies, browser and device information, interface language, service usage events, visit statistics and personal account actions, including data obtained through analytics and metrics tools.

4. Purposes of personal data processing

4.1. Personal data is processed for user registration and identification, providing access to the personal account and service features, release placement and support, content moderation, AI generation services, interaction with music platforms and partners, and fulfillment of the Operator’s obligations to the user.

4.2. The Operator may use data to handle requests and inquiries, provide support, analytics, financial services, subscriptions, smart links, release status notifications, service messages, and to send news and offers if the user has not opted out of such messages.

4.3. Depersonalized and technical data is used to ensure service security, prevent abuse, improve interfaces, analyze user behavior, assess product quality and plan platform development.

5. Legal grounds for personal data processing

5.1. Legal grounds for processing include: user consent to personal data processing, necessity to perform the public offer and provide service features, compliance with the Operator’s obligations under the legislation of the Russian Federation, and the Operator’s legitimate interests in maintaining platform operation and security.

5.2. Technical and depersonalized data, including cookies and analytics data, is processed when using the website and personal account where permitted by the user’s device and browser settings and required for correct service operation.

6. Personal data processing procedure

6.1. The Operator takes necessary legal, organizational and technical measures to protect personal data from unauthorized access, modification, disclosure, deletion or other unlawful use. Data access is granted only to authorized persons and contractors within the scope of their tasks.

6.2. Personal data may be transferred to third parties and service partners only to the extent necessary for platform operation and service provision, including hosting, analytics, authorization, payment infrastructure, technical support providers, AI technology providers, music platforms and other counterparties involved in release placement and support.

6.3. The user has the right to receive information about processing of their data, request clarification, update, blocking or deletion unless otherwise required by law, service obligations or necessity to retain data to protect the Operator’s rights and legitimate interests.

6.4. Personal data is processed for the period necessary to achieve processing purposes, maintain contractual relations, comply with legal requirements and resolve potential disputes. Consent may be withdrawn by contacting the Operator, but withdrawal may limit use of certain service features.

7. Cross-border transfer of personal data

7.1. Due to the nature of the White Rock service and interaction with foreign digital platforms, infrastructure, analytics and technology contractors, the Operator may carry out cross-border transfer of personal data to the extent necessary for service operation, release publication, analytics, support, AI generation and fulfillment of user requests.

7.2. Before such transfer, the Operator takes reasonable measures to verify recipients’ data processing conditions and ensures transfer on grounds permitted by applicable law, including with user consent or where necessary to perform the agreement.

8. Final provisions

8.1. For personal data processing inquiries, the user may contact the Operator at noreply@pinkq.music or through support channels provided by the service.

8.2. The Operator may amend this Policy. A new edition takes effect upon publication on the website unless a different date is specified. Continued use of the service after publication constitutes acceptance of the current version.

8.3. The current version of the Policy is published on the White Rock service website in the “Privacy policy” section.