Digitainment — Privacy Policy
Version: 1 (2026-10)
Effective date: 9 October 2026
1. Who we are
Digitainment.io, Bossestraße 7e, 10245 Berlin, Germany, is the controller for personal data about you as a user of the Digitainment platform (the “Service”): your account, billing and usage data. For the data you store in the Service about other people, such as your contacts, we are your processor instead (Section 2). Full provider details are in our Impressum. Contact for privacy matters: support at digitainment.io.
2. Two different roles — please read
This policy explains how we handle personal data we control: the data about you as an account holder and visitor.
Separately, when you upload or record personal data about third parties (for example, promoter or venue contacts you add to your workspace; where the merchandise module is enabled, your own customers who buy merchandise; or, where you use Label Services, the artists, songwriters, producers and other contributors you credit on a release and anyone named in rights documents you upload), you are the controller of that data and we act as your processor. Our handling of that data is governed by our Data Processing Agreement, not this policy. This policy covers our own processing; the DPA covers processing on your behalf.
This includes the travel and identity details you record for band members and guests in Logistics: legal names, date of birth, nationality, passport number and passport expiry, and ID numbers. You are the controller of that data and we store it on your behalf. We hold passport numbers only because you choose to enter them, and only so that you can pass them to a travel agent for an international flight booking.
3. What we collect and why
| Data | Purpose | Legal basis (GDPR Art. 6) |
|---|---|---|
| Account data (name, email, agency details, credentials) | Create and operate your account | Contract performance, Art. 6(1)(b) |
| Billing data (plan, transactions; card data handled by Stripe) | Process payments, invoicing, tax | Contract performance / legal obligation, Art. 6(1)(b),(c) |
| Usage and log data (IP, device/session, actions, timestamps) | Provide, secure and improve the Service; prevent abuse | Legitimate interests, Art. 6(1)(f) |
| Communications (support requests, emails) | Respond to and support you | Legitimate interests / contract, Art. 6(1)(f),(b) |
| Website statistics for our public website (page visited, language, the referring website or campaign tag, mobile or desktop, and a daily anonymous visitor code; see Section 9) | Understand how visitors find us and which pages lead to signups | Legitimate interests, Art. 6(1)(f) |
| Your Anthropic API key, where you connect one (Section 4) | Hold and use the key you supply so that AI-assisted features can run on your own AI provider account; we provide no AI processing of our own | Contract performance, Art. 6(1)(b) |
| Terms of Service acceptance: the version accepted, the accepting user and email address, date and time, IP address and browser user agent | Evidence that and when your agency accepted each version of our Terms of Service | Contract performance, Art. 6(1)(b); legitimate interests, Art. 6(1)(f) |
| Label Services signing records (Section 4a): the signer's typed name and position, drawn or typed signature, email address and account, authentication method, IP address, browser user agent, date and time, and a copy and SHA-256 fingerprint of the exact text signed | Evidence who accepted the Label Services Terms and who signed each Distribution Agreement, in which version, and when; and establish, exercise or defend legal claims | Contract performance, Art. 6(1)(b); legitimate interests, Art. 6(1)(f) |
| Label payout data: legal name, whether the label is a company or an individual, address, country, VAT or tax number, the bank account you give us for payouts (stored encrypted), and the royalty statements and payouts we make to you | Pay you your share of Net Income under the Distribution Agreement; accounting and tax | Contract performance / legal obligation, Art. 6(1)(b),(c) |
| Personal label invites: the email address we send an invite to, the label name, the proposed deal share and our note | Send a personal invite to join on a percentage-based deal, and set up the account if it is accepted | Steps prior to entering a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f) |
We do not sell your personal data.
4. AI-assisted features run on your own AI provider account
We do not provide AI as part of the Service, and we do not pay for, resell, or stand behind any AI processing. To use the AI-assisted features you connect your own Anthropic API key in the Service's settings. You hold the Anthropic account, you contract with Anthropic directly, you are billed by Anthropic, and you accept Anthropic's own terms. Without a key connected, the features are unavailable and nothing is sent anywhere.
When you invoke one of these features, you are instructing us to send the relevant content from our servers to your Anthropic account under your key. What happens to it there is governed by your agreement with Anthropic, not by this policy. Anthropic is therefore not one of our sub-processors and is not listed in Section 6; it is your own provider. We give no warranty about its processing, security, retention, availability, or output, and we accept no responsibility for it. If you want that processing to stop, remove your key.
What we are responsible for is our side of it. We store the key encrypted at rest, restrict access to it to your account owner, never display it again after you save it, and use it for nothing except the features you invoke. You can replace or remove it at any time; removing it disables AI features for your workspace.
The content sent includes venue names and addresses for research, the record content you ask an assistant to work with, and, when you ask the assistant to read an uploaded show file (for example a flight or hotel confirmation) to suggest schedule entries, the contents of that file. Such documents can contain personal details such as passport numbers; the assistant is instructed to ignore them and we do not store them, but the file itself is sent to your Anthropic account on your instruction. We do not use these features to make decisions producing legal or similarly significant effects about you without human involvement.
The assistants are named "Boris" (research) and "Lulu" (copywriting) by default, and you may rename them for your own workspace. The names are display labels only.
Venue research uses Anthropic's web-search capability to look up publicly available, non-personal venue information — for example capacity, technical specifications, and general venue contact points such as a booking@ address or venue switchboard number. It is instructed not to return the names of individuals or individual email addresses.
Research results stay in your own workspace and are not shared with other Service users. Results you obtain through AI research are yours; we do not add them to the shared Venue Database. That database is curated by us — including enrichment we carry out on our own account, separately from your key — so that its contents are reviewed before any user sees them. You may propose a correction to an entry in the shared Venue Database by editing that venue in your own workspace; such proposals are reviewed by us before any change is made to the shared Venue Database.
4a. Label Services
Where you use Label Services, some of the data involved is ours to control and some is yours:
- Ours (this policy): the signing records of your acceptance of the Label Services Terms and of each Distribution Agreement, your payout data, and personal invites (Section 3). Each signing record is kept with a copy of the exact text signed, so that either side can later show what was agreed. The Distribution Agreement is also signed by us; our signatory's record is kept the same way.
- Yours (DPA): release metadata, including the names and roles of the artists, songwriters, producers and other contributors credited on each track, and any rights documents you upload (for example artist, producer or sample-clearance agreements). You are the controller of that data and we process it on your behalf.
When you submit a release, you instruct us to deliver its metadata, audio and artwork to our distribution partner, The Orchard, in the United States, and through it to the digital stores and streaming services the release goes to. The Orchard receives that data as an independent company, under its own privacy policy: it distributes the release, keeps its own sales and accounting records, and sends us sales reports and statements, from which we pay you under your Distribution Agreement. Stores receive the release from The Orchard, not from us. Contributor credits are then published by those stores as part of the release, worldwide; that is the purpose of distribution. A new label uploads rights documents with every release; once we trust its record we may move it to providing them on request only. Rights documents are not sent with a release. We use them to check a release before delivery, and share them with The Orchard only when it asks for proof of rights, for example in a rights claim. See Section 6 and the DPA, Clause 4b.
5. Retention
We keep account data for the life of your account. An account is treated as inactive, and may be deactivated with its account/profile data deleted, after 12 consecutive months without a login (see Terms of Service, Section 13.3). Before deletion, we send a warning email to the account's registered contact address at least 30 days beforehand, so the Customer has the opportunity to log in or export its data first.
Billing and invoice records we issue to you for your subscription are retained independently of account status, as required by German commercial and tax law (HGB §257, AO §147, UStG §14b) — currently 8 years from the date each record was created (reduced from 10 years as of 1 January 2026 under the Bürokratieentlastungsgesetz IV; annual financial statements, balance sheets, and inventories remain subject to a 10-year period, though this does not affect individual invoices). This retention continues even after account deletion.
This retention duty is ours alone and covers only the invoices we issue to you. It does not extend to records you create within the Service for your own business purposes (for example, invoices you issue to promoters or venues, or merchandise sales records) — those are your Customer Data, you are the controller of them, and any statutory retention obligation for them is yours to meet under your own applicable law. We recommend exporting such records before an inactive account is deleted; see Terms of Service, Section 13.3.
Label Services records. Royalty statements and payout records are accounting records and are kept for 8 years, on the same basis as the invoices above. Signed Distribution Agreements, Label Services Terms acceptances and their signing records are kept for as long as the agreement runs and afterwards until claims under it are time-barred, and at least 6 years as commercial correspondence (HGB §257(1) no. 2-3, (4)), running from the end of the year in which the agreement ends. Like billing records, they are kept after account deletion. Personal label invites that are not accepted are deleted 90 days after the link expired or was revoked. An accepted invite is kept as the record of how the account was set up.
Server logs (web server and application logs, which include IP addresses) are kept for 14 days and then deleted automatically. Session records (IP address and browser, used to keep you signed in and to limit concurrent sessions) are removed once they have expired, at your next sign-in, and all of them when your account is deleted. The date and time of each sign-in (without IP address) is kept for the life of the account, to apply the inactivity rule in Terms of Service, Section 13.3. On account deletion, data we process on your behalf is handled per the DPA.
6. Sub-processors and recipients
We share personal data with service providers acting on our behalf (sub-processors), and, for Label Services, with our distribution partner as an independent recipient:
| Provider | Purpose | Location / transfer safeguard |
|---|---|---|
| Hetzner Online GmbH | Hosting / infrastructure | Germany (EU) |
| Stripe Payments Europe, Limited ("SPEL") | Payment processing for our own billing of your subscription (Terms of Service, Section 3.2). Separately, where you enable the merchandise module and connect your own Stripe account via Stripe Connect, Stripe additionally processes your own customers'/fans' order and payment data as our sub-processor, acting on your behalf as controller of that data — for online storefront checkout (Stripe Connect) and, where you enable it, for in-person card payments (Stripe Terminal, via a supported card reader), both under the same Connect relationship — see DPA, Annex II. That processing does not involve your subscription billing data and is not "payment processing" for our own account in the sense of this row. | Ireland (EU). Digitainment's Stripe account country is Germany, and under Stripe's Services Agreement the contracting entity is determined by account country — for merchants outside the Americas that maps to SPEL. Confirmed. This relationship itself involves no third-country transfer; Stripe's group also holds EU-US DPF certification and offers SCCs for any residual US-side processing. |
| Resend (legal entity: Plus Five Five, Inc.) | Transactional & marketing email | United States — primary processing in the US. Certified under the EU-US Data Privacy Framework; SCCs also included in Resend's DPA as a backstop. |
| Google (Maps/Places) | Venue lookup / mapping | US — Standard Contractual Clauses |
| SocialAPI.ai (legal entity: EP ENTPREPRISE, SIREN 102198884) | Social publishing (marketing module) | France (EU) — EU-established company; own infrastructure hosted in the EU (Hetzner, Germany; Cloudflare EU for media). Its own sub-processors include Stripe and Resend (both above, DPF-certified). |
| The Orchard (The Orchard Enterprises, Inc.) — independent recipient, not a sub-processor | Label Services: distribution of releases to digital stores and streaming services, sales reporting and accounting, under The Orchard's own privacy policy. Receives release metadata including contributor names and roles, audio and artwork; rights documents only when it asks for proof of rights. Delivers onward to stores, which publish the credits (Section 4a). | United States — EU Standard Contractual Clauses |
PayPal is not in this table either. Where a merchandise seller uses PayPal, its customer pays the seller directly through a PayPal.me link or QR code; we have no PayPal integration and send PayPal no personal data.
Anthropic is not in this table, and that is deliberate. AI-assisted features run on your own Anthropic key and account (Section 4), so Anthropic is your provider, not our sub-processor: we hold no contract with it for that processing, and the transfer safeguard is the one you have in place with Anthropic. We disclose the data flow in Section 4 so you know where content goes when you use those features.
7. International transfers
Where data is transferred outside the EEA, we rely on adequacy decisions (including the EU-US Data Privacy Framework for certified US recipients) or EU Standard Contractual Clauses with appropriate supplementary measures.
Release metadata delivered through Label Services goes to The Orchard in the United States under the safeguard stated in Section 6. Stores then make contributor credits publicly available worldwide as part of the release; that onward publication is the purpose of distribution and is carried out by the stores themselves.
Content you send to your own AI provider through the AI-assisted features (Section 4) is a different case: it goes to an account you hold, on your instruction, and the safeguard for it is the one you have agreed with that provider.
8. Your rights
Under the GDPR you have the right to access, rectification, erasure, restriction, data portability, and objection, and to withdraw consent at any time. To exercise these, contact support at digitainment.io. You may also lodge a complaint with a supervisory authority — for us, the Berliner Beauftragte für Datenschutz und Informationsfreiheit (Berlin Commissioner for Data Protection and Freedom of Information).
9. Cookies and website statistics
We use only cookies strictly necessary for authentication and security (and one that remembers the language you chose on our website). We do not use advertising or other non-essential cookies, and we use no third-party analytics service.
On our public website (the homepage, module, pricing, FAQ, comparison, contact and legal pages, and the signup page) we count visits with our own, cookieless statistics. For each page view we record the page, its language, the website you came from or the campaign tag in the link (for example utm_source), whether you use a mobile or desktop device, and an anonymous visitor code. That code is calculated from your IP address, your browser identification and a random value that changes every day; the random value is deleted the next day, so the code cannot be traced back to you or linked across days. Your IP address itself is not stored. Nothing is stored on your device. When you sign up, the first website or campaign you arrived from on that day is saved with your new account, so that we know which of our promotion efforts work. Page-view records are deleted after 13 months. We do not run these statistics inside the logged-in Service or on pages our customers publish (EPKs, company websites, shops, ticket pages). The legal basis is our legitimate interest in understanding how our website is found and used (Art. 6(1)(f) GDPR); because no information is stored on or read from your device for this, no consent is required.
10. Security
We apply technical and organisational measures to protect personal data, including encryption in transit, hardened authentication and session management, access controls, and restricted file storage. Sensitive identifiers are additionally encrypted at rest (AES-256-GCM): passport numbers, ID numbers, dates of birth, passport expiry dates, label payout bank details, and API keys you connect. Staff must re-enter their password to view or change these values, and access lapses after 10 minutes. On shared public pages, names and travel details stay locked until the visitor enters a 5-digit access code that you send separately from the link; repeated wrong guesses are blocked. No system is perfectly secure; we work to protect your data appropriately.
11. Changes
We may update this policy and will post the new version with an updated effective date, notifying you of material changes.
Contact: support at digitainment.io
Last updated: 24 October 2026