Privacy Policy


Personal data” means any information relating to an identified or identifiable natural person. Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and/or behaviour.

In order for SMG Music and Multimedia Limited (“Snapmuse”) to be able to provide you with the Service (as defined in the General Terms and Conditions - Website ) as well as to be able to provide you with individualised offers regarding the Service and products available from Snapmuse, Snapmuse collects personal data from you.

SMG Music and Multimedia Ltd, the operator of this website and provider of the Service, is a subsidiary of SMG MULTİMEDYA VE PROJE HİZMETLERİ TİCARET A.Ş, (Reşitpaşa Mah. Katar Cad. Arı-8 Binası No:2/11/3 Sarıyer - İstanbul - Türkiye

This Privacy Policy will let you know how we look after the personal data which we collect from you in connection with the Service, and any related content, products and services. This Privacy Policy also informs you as to our obligations and your rights under data protection law.

It is very important that you read through this Privacy Policy before you subscribe to our Service.

Who is responsible for your personal data?

For the purposes of the EU General Data Protection Regulation (EU Regulation 679/2016) (the “GDPR”), Snapmuse is the data controller with regard to the personal data described in this Privacy Policy.

“Data controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed, who/which make independent decisions in relation to the personal data and/or who/which otherwise control that personal data.

If you have any questions about this Policy or about our data protection compliance please contact us via the details provided below.

Personal data which we collect

Snapmuse collect the following personal data from you in order to provide the Service:

  • Registration information including name, address, country, phone number, e-mail address, IP-address, age and date of birth, gender and other information which you voluntarily may provide when you sign up for our Service;
  • Broad, non-specific location, about where you are which we derive from your IP-address;
  • Usage data: The music you listen to and your interaction with the Service. This allows us to make recommendations to you and suggest relevant music and Services to you;
  • Technical and sensor information necessary to operate the Service. This includes the type of browser and device you use, data from the touchscreen, and information from your device’s accelerometer and gyroscope sensors. This enables you to control the Service and allows us to do simple things like rotate videos and recommend music;
  • Cookie data and URL information, network connection type, browser type, language and information enabling digital rights management and operating system (for more details on our use of cookies please see our Cookie Policy);
  • Widgets, which may be used to show personalised content or advertising; and
  • Payment data, which includes credit or debit card information and other financial data which we need in order to process your payment.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

The type of personal information listed below is only collected in order to offer you additional features. We will never process any of the following information unless you have chosen to share it with us, or decided to opt out from the features:

  • Your specific location; and
  • Your photos.


Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How do we collect your personal data?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your registration information and payment data by filling in forms or by corresponding with us. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter contests, campaigns and/or surveys; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
    • Technical data from the following parties:
      • analytics providers such as Google based outside the EU; and
      • advertising networks.
    • Contact, financial and transaction data from providers of technical and payment services.

The purposes for collecting personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer
  • Registration information
  • Photo
  • Location
Performance of a contract with you
To process and deliver your order including:
  1. Manage payments, fees and charges
  2. Collect and recover money owed to us
  1. Registration information
  2. Payment data
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or Privacy Policy
  2. Asking you to leave a review or take part in contests, campaigns and/or surveys
Registration information Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in contests, campaigns and/or surveys Registration information Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Registration information
  2. Usage data
  3. Technical and sensor information
  4. Location
  5. Cookie data and URL information
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Registration information
  2. Usage data
  3. Technical and sensor information
  4. Location
  5. Cookie data and URL information
  6. Widgets
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  1. Usage data
  2. Technical and sensor information
  3. Location
  4. Cookie data and URL information
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  1. Registration information
  2. Usage data
  3. Technical and sensor information
  4. Location
  5. Cookie data and URL information
  6. Widgets
Necessary for our legitimate interests (to develop our products/services and grow our business)


We may use your registration information, usage data, cookie data and widgets to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.


We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes.


You can ask us or third-parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


Snapmuse also use cookies in order to provide the Service. Information about how we use cookies can be found in our Cookie Policy . Information stored in cookies may be stored and processed for as long as necessary if you accept this Policy and create an account.

YouTube API Services

Snapmuse’s API Client uses YouTube API Services. If you are using our Service on YouTube, you hereby by agreeing to our Privacy Policy also certify that you have read and agree to YouTube terms of Services and Google’s Privacy Policy.

How long personal data is stored

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Where you ask to be unsubscribed from marketing communications we may keep a record of your email address and the fact that you have unsubscribed to ensure that you are not sent any further emails in the future.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Who we share information with

We may further share information with our music industry partners, customers and other cooperation partners in order to help them understand how the content is performing, with marketing partners who help us with promotional efforts, and with advertisers that allow us to offer services and promotional communication and help us understand how the users interact with advertisements.

We may also share information with analytical providers in order for us to analyse how our users use the Service and to improve their user experience.

We may also share certain information with other companies within the Snapmuse group and with third-parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Financial data and payment information is further collected and stored by us and/or our payment processor.

We may also share information for the purpose of responding to legal process (e.g. a court order), if we believe in good faith that it is necessary to do so; to comply with requirements of mandatory applicable law; to protect the safety of any person; and to address fraud, security, or technical issues.

Transferring of personal data to third countries

There are circumstances in which we will have to transfer your personal data out of the European Economic Area (“EEA”) for the purposes of carrying out the services we provide to you. We share your personal data within the Snapmuse group. This will involve transferring your data outside the EEA. We may also use external third-party service providers based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Where the need for such transfers arises we will always ensure that there are appropriate safeguards in place to protect your personal data such as:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Information shared by you

The Snapmuse Service is a social Service that offers the user many ways to find, enjoy and share content. You as a user may choose to share playlists, music or other content with other users who have subscribed for the Service. This information will, if shared, be publicly available to the user(s) you accept to share it with. You may change your settings and limit the information which you have made publicly available.

Third party applications

If you connect your account to a third-party application, Snapmuse may automatically share your activity and activity-related stories with that service, including the content you consume. You understand and agree that such information may be attributed to your account on the third-party application and may be published on such service.

You understand and agree that a third-party application’s use of information collected from you (or as authorised by you) is governed by the third-party application’s privacy policies and your settings on the relevant service, and Snapmuse’s use of such information is governed by this Privacy Policy and your account settings.

Contests, campaigns and surveys

From time to time, Snapmuse may offer you to take part in contests, campaigns and/or surveys. This Privacy Policy shall apply to such special promotions as well, unless otherwise is stated in the specific information provided for each promotion.


Snapmuse, and if applicable its cooperation partners, have taken several safety measures in order to protect personal data from loss, misuse, unauthorised access, disclosure, alteration or destruction. Personal data collected from you and processed by us will only be accessed by employees and companies that are in need to process such information.

Snapmuse is committed to protect user information. Your password protects your user account, so you should use a unique and strong password, limit access to your computer and browser, and log out after having used the Service. However, even if we take data protection precautions, no security measures are completely secure, and we do not guarantee the security of user information.


Snapmuse may display advertisements from third-parties and other content that links to third-party websites. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. Snapmuse do not control and will not be held responsible for third-parties’ processing of personal data. We strongly advise that you carefully review the terms and conditions and privacy policies of all linked third-party websites. We also reserve our right to discontinue any and all links to our website from third-party websites, at any time, at our sole and exclusive discretion.


The Service offered by Snapmuse is not directed to children under the age of 16. A person under the age of 16 will not be able to register for an account or be able to use the Service provided by Snapmuse. We do not knowingly collect personal information from children under 16 unless prior consent has been obtained from the holder of parental responsibility over the child.

If you are under the age of 16, do not use the Service and do not provide any personal information to us without providing us with parental consent first. If you are the holder of parental responsibility over a child under the applicable age limit and become aware that the child you are responsible for has provided personal information to Snapmuse, please contact us via the details provided below and you may request exercise of your applicable access, rectification, cancellation, and/or objection rights.

Your data protection rights

Under certain circumstances, by law you have the right to:

  • Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Object to automated decision-making including profiling, that is not to be the subject of any automated decision-making by us using your personal information or profiling of you.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
  • Withdraw your consent, where we are relying on it to use your personal data.


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance:

Contact Data Protection Commission
Telephone +353 57 8684800 / +353 761 104 800
Post Data Protection Commission

21 Fitzwilliam Square South

Dublin 2

D02 RD28


Changes to this privacy policy

Our Privacy Policy may change from time to time, and any changes to this Privacy Policy will be posted on our website and will be effective when posted. As your use of the Service is subject to your acceptance of this Privacy Statement, and any amendments thereto, please check back regularly.

If you do not wish to continue using the Service under the new version of the Privacy Policy, you may terminate your subscription with us by contacting us via the details provided below.

Additional information or questions

You can contact us with any queries, complaints or requests to exercise your data protection rights using the details below:

Contact SMG Music and Multimedia Ltd
Post: 5th Floor Rear, Connaught House, 1 Burlington Road, Dublin 4, Ireland