Privacy Policy

1. Data controller

Soul Music Worldwide Co., Ltd. ("SMG," "we," "us," "our") is the data controller for personal information collected through soulmusic.asia and the OMG Distribution platform at app.omgmusic.asia. Our registered address is Tower A, Happy One Central, Thu Dau Mot, Binh Duong Province, Vietnam. Contact: info@soulmusic.asia.

For users in the European Economic Area (EEA), the United Kingdom or Switzerland, this policy describes our compliance with the General Data Protection Regulation (GDPR) and applicable national data protection laws.

2. Information we collect

Information you provide directly:

• Contact and enquiry data: Name, email address, company name, job title and message content submitted via our contact form or sent to our email address.
• Account registration data: Name, email address, company name and password when creating an account on the OMG Distribution platform.
• Content and catalog data: Audio files, metadata (artist name, track title, ISRC, UPC, release date, genre, territories), artwork and associated rights information submitted for distribution or catalog management.
• Service agreement data: Information provided during onboarding and in the course of service delivery, including bank account details for royalty payments.

Information collected automatically:

• Website analytics: Pages visited, time on page, referral source, device type, browser type and approximate geographic location, collected via analytics cookies.
• Platform usage data: Features used, release submissions, catalog actions and session data on the OMG Distribution platform.
• Technical data: IP address, HTTP request headers and server logs, processed by our infrastructure providers (AWS, Cloudflare) as part of standard operations.

3. Legal basis for processing (GDPR)

We process your personal data on the following legal bases:

• Contract performance: Processing necessary to deliver our music distribution, royalty accounting, catalog management and YouTube CID services under a signed service agreement.
• Legitimate interests: Website analytics, security monitoring and improving our services. We have assessed that our legitimate interests do not override your rights.
• Consent: Non-essential cookies and analytics tracking, which you may withdraw at any time through our cookie settings.
• Legal obligation: Retention of financial records and compliance with applicable Vietnamese and international laws.

4. How we use your information

We use personal information to:

• Respond to and manage service enquiries.
• Deliver music distribution, DDEX delivery, YouTube Content ID, royalty accounting and catalog management services.
• Process royalty payments and generate financial statements.
• Manage Platform accounts and subscriptions.
• Operate, monitor and improve the website and Platform.
• Detect, prevent and investigate fraud, security incidents and policy violations.
• Comply with legal obligations, including tax reporting and anti-money laundering requirements.

We do not sell, rent or share your personal information with third parties for their own marketing purposes.

5. Cookies and tracking

We use cookies and similar tracking technologies on our website. For full details, including a list of specific cookies and how to manage your preferences, please see our Cookie Policy.

In summary, we use:

• Essential cookies: Required for the website and Platform to function. Cannot be disabled.
• Analytics cookies: Used to understand how visitors use the website (e.g. Google Analytics). Require your consent.
• Preference cookies: Store your settings and preferences for a better experience.

6. Analytics providers

We use Google Analytics to analyse website usage. Google Analytics collects information about your device and browsing behaviour and sends it to Google LLC, which may process data in the United States. We have enabled IP anonymisation to reduce the precision of location data. Google's privacy policy is available at policies.google.com/privacy.

We may also use other analytics and performance monitoring tools. These are listed in our Cookie Policy.

7. Payment providers

Subscription payments for the OMG Distribution platform are processed by third-party payment providers. These providers collect and process payment card information directly and are subject to their own privacy policies and PCI-DSS compliance obligations. We do not store complete payment card numbers on our systems.

Royalty payments to rights holders are processed via bank transfer. We collect and retain bank account details (account holder name, account number, routing/SWIFT code) for the purpose of processing payments. This data is protected with appropriate technical and organisational security measures.

8. Third-party sharing

We share personal information with third parties only in the following circumstances:

• Service delivery: We share Content metadata and rights information with DSPs (e.g. Spotify, Apple Music, YouTube) and rights administration systems as necessary to deliver distribution services.
• Infrastructure providers: AWS (cloud hosting), Cloudflare (security and content delivery) and other infrastructure providers process data on our behalf under data processing agreements.
• Payment processors: Payment providers receive payment details necessary to process transactions.
• Legal requirements: We may disclose information to competent authorities where required by law or to protect our legal rights.

All third-party processors are subject to contractual obligations that require them to handle your data in accordance with applicable data protection law.

9. International data transfers

As a business operating in Southeast Asia with clients and technology partners worldwide, personal data may be transferred to countries outside Vietnam and the EEA. Where data is transferred from the EEA to countries without an adequacy decision, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, or other appropriate safeguards, to protect your data.

10. Data retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by law:

• Enquiry and contact data: Up to 3 years from the date of last contact.
• Account data: For the duration of your account, plus 2 years following closure.
• Content and catalog data: For the duration of the service arrangement, plus any period required to resolve outstanding claims or disputes.
• Financial records: Minimum 10 years as required by Vietnamese tax and accounting law.
• Analytics data: Up to 26 months, in line with Google Analytics default retention settings.

11. Your rights (GDPR and applicable law)

Subject to applicable law, you have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete data.
• Right to erasure: Request deletion of your personal data, subject to our legitimate interests and legal obligations.
• Right to restriction: Request that we restrict processing of your data in certain circumstances.
• Right to data portability: Receive your data in a machine-readable format and transfer it to another controller.
• Right to object: Object to processing based on legitimate interests, including for direct marketing.
• Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing.

To exercise any of these rights, contact us at info@soulmusic.asia. We will respond within 30 days. EEA residents may also lodge a complaint with their national data protection supervisory authority.

12. Children's privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If you become aware that a minor has provided us with personal information, please contact us immediately and we will take steps to delete it.

13. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction. These include encryption in transit (TLS), access controls, and regular security reviews. For information on our security practices, see our Security Policy.

14. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be notified via the Platform or by email where required by law. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of our Services after changes take effect constitutes acceptance.

15. Contact and data protection enquiries

For questions, concerns or to exercise your data protection rights, contact us at:

Soul Music Worldwide Co., Ltd.
Tower A, Happy One Central, Thu Dau Mot, Binh Duong Province, Vietnam
info@soulmusic.asia