Privacy policy

Policy in the area of privacy, cookies and rules for processing of personal data at Closer Music Sp. z o.o.

At Closer Music Sp. z o.o..we always take into account the interests of our partners and protect them at
every possible level. We value your privacy, so in order to ensure appropriate protection, we have
implemented the necessary technological solutions and organizational mechanisms. However, we
would like to encourage you to get acquainted with the following information regarding the operation
of www.closermusic.com and the processing of personal data in connection with the sale of goods
and provision of services to you.

Best regards,
The Management Board of Closer Music Sp. z o.o.

Closer Music Sp. z o.o. with its registered office in Warsaw ensures that its primary objective is to
guarantee the users of its services, including the website available at the domain address
www.closermusic.com (hereinafter referred to as the “Website”), privacy protection at least at such
a level that meets the requirements set out in applicable legal regulations, and, in particular, in
the Act on Providing Services Electronically of 18 July 2002, Personal Data Protection Act of 10
May 2018, and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27
April 2016 on the protection of natural persons with regard to the processing of personal data
on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection
Regulation).

The owner of the Website (personal data controller) reserves the right to make changes to this
Privacy Policy.

§.1 General information, cookies

1. Closer Music Sp. z o.o. (formerly Videotronic Media Solutions Sp. z o.o.) with its registered office in Warsaw (02-819) at ul. Puławska 366, registered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the capital city of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under KRS number 0000282021, NIP 884-262-43-20, REGON: 020531489, with the share capital of PLN 250,000 (fully paid up) is the owner and operator of the Website as well as the controller of the personal data processed, hereinafter referred to as the “Controller”.

2. The contact with the Controller regarding any matters related to the operation of the Website, as well as the processing and protection of your personal data is possible by means of traditional post (the address mentioned above) or by e-mail (email: [email protected])

3. Personal data shall be used only on the basis of the consents given by users or for the legitimate purpose and for the needs of performance of the contracts entered into between users and Closer Music Sp. z o.o. with its registered office in Warsaw. In doing so, the Controller shall apply a policy of minimalism, collecting and processing only those data which are necessary for the proper operation of the Website, performance of the contracts entered into and the fulfillment of the legal obligations for the period necessary to achieve those objectives. It should be pointed out that these data, although provided on a voluntary basis, are necessary for the proper provision of the services and fulfillment of the obligations imposed by law.

4. The principles of processing, entrusting and protecting personal data described in this Privacy Policy shall apply both to the data collected during and in connection with performance of contracts entered into by the Controller and users, the use of the Website (including contact forms available on the Website’s pages), and other forms of communication with the Controller.

5. The Website performs the functions of obtaining information about the Website’s users in the following way:

  • a) by automatically collecting information contained in cookies;
  • b) through voluntary provision of data by the Website’s users in the forms
    available on the Website’s pages;
  • c) by automatically collecting server logs by the hosting provider.

6. Cookies constitute IT data, in particular text files, which are stored on the Website User’s end device and are intended to be used on the Website’s web pages. Cookies usually contain the name of the website from which they originate, time for which they are stored at the end device and unique number.

7. During a visit on the Website,, we may automatically collect the Website user data concerning a user’s given visit on the Website, including, but not limited to, the IP address, type of web browser, domain name, number of views, type of the operating system, visit, screen resolution, number of screen colors, addresses of the web pages from which the Website you entered, and the time for which the Website was used.

8. Links to other web pages may appear on the Website. In such a case, the Controller shall not be responsible for the data privacy rules in force on those web pages. At the same time, the Controller encourages the Website’s user to become acquainted with the privacy policy in force on such web pages. This Privacy Policy does not apply to other websites.

9. The Controller is the entity which places cookies on the Website user’s end device, and gets access to them.

10. Cookies are used to create statistics which help understand how Website users use web pages, which allows improving their structure and content.

11. The Website uses the following types of cookies:

  • a) “necessary” cookies, which allow taking advantage of the various services
    available on the Website, e.g. authentication cookies;
  • b) cookies used for ensuring security, such as those used for detecting abuse;
  • c) “performance” cookies, which are used for collecting information about the way how users use the web pages of the Website;
  • d) “functional” cookies, which allow “remembering” the settings selected by the user and customizing the Website to the user, e.g. regarding the language selected.

12. The Website uses two basic types of cookies: “session cookies” and “persistent cookies”. “Session” cookies are temporary files stored on the user’s end device until the user leaves the web page, logs out, or turns off the software (web browser). “Persistent” cookies are stored on the user’s end device for the period set out in the cookie parameters or until the user removes them.

13. In most cases, web browsing software allows cookies to be stored on the user’s end device by default. The Website’s users can change the cookie settings at any time. These settings may be changed in the Internet browser (software) options, e.g. in a way that prevents automatic handling of cookies, or thanks to which the user will have to be notified whenever cookies are placed on the user’s device. Detailed information on the possibilities and ways of managing cookies is available in the internet browser’s settings.

14. Limitations on using cookies may influence certain functionalities available on the
Website.

§.2 Processing of personal data, their nature and the purposes of the processing of personal data

1. The personal data collected by the Controller are processed, in particular, pursuant to the Personal Data Protection Act of 10 May 2018 and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of
such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

2. The Website processes the personal data which are voluntarily provided to the Website by the user.

3. The Controller collects information concerning natural persons and natural persons conducting, in their own name, economic or professional activity, and concerning natural persons representing legal persons or organizational entities which are not legal persons to which the act confers legal capacity, hereinafter collectively referred to as the Users.

4. User personal data are collected in the case of:

  • a) registration of the account on the Website, in order to create and manage the individual account. Legal basis: the need to perform the contract on provision of the service of the Account (Article 6(1 (b) GDPR);
  • b) placing orders on the Website, to perform the contract. Legal basis: the need to perform the contract on provision of the service (Article 6(1)(b) GDPR);
  • c) subscription to the Newsletter, in order to perform the contract on the service provided by electronic means. Legal basis: the consent of the data subject for performance of the contract on provision of the Newsletter service (Article 6(1)(a) GDPR);
  • d) using the Licenses contact form service on the Website, in order to perform the contract performed by electronic means. Legal basis: the need to perform the contract on provision of the contact form service (Article 6(1)(b) GDPR);
  • e) using the contact form for Artists on the Website to perform the contract performed by electronic means Legal basis: the need to perform the contract on provision of the contact form service (Article 6(1)(b) GDPR).

5. When registering the account on the Website, the user shall provide:

  • a) e-mail address;
  • b) name and surname;
  • c) telephone number;
  • d) country of residence.

6. In the case of entrepreneurs, the above-mentioned scope of data is further extended to include:

  • a) entrepreneur’s business name;
  • b) country in which the enterprise operates.

7. When registering the account on the Website, the user defines his individual access password to the account. The user may change the password at a later date, in accordance with the rules described in section III.

8. When placing an order on the website, the user shall provide the following data:

  • a) e-mail address;
  • b) correspondence address details: zip code, city, street and house/apartment number;
  • c) name and surname;
  • d) telephone number;
  • e) PESEL

9. In the case of entrepreneurs, the above-mentioned scope of data is further extended to include:

  • a) entrepreneur’s business name;
  • b) NIP/EU VAT number or another tax identification number.

10. When using the Newsletter service, the user shall provide:

  • a) e-mail address;
  • b) name and surname;
  • c) telephone number;
  • d) country of residence/establishment.

11. In the case of entrepreneurs, the above-mentioned scope of data is further extended to include:

  • a) entrepreneur’s business name;
  • b) country in which the enterprise operates.

12. When using the Licenses contact form service, the user shall provide the following data:

  • a) e-mail address;
  • b) name and surname;
  • c) telephone number.

13. When using the contact form for Artists service, the user shall provide the following data:

  • a) e-mail address;
  • b) name and surname;
  • c) telephone number;
  • d) can attach a CV file with an MP3 demo or add links to the user’s works.

14. The information contained in the forms provided to the Controller by the Website user shall not be made available to third parties except for the situation in which it is done with the user’s consent, excluding the possibility of transferring them to other entities constituting IMS Capital Group, their subcontractors or when such obligation is based on generally applicable legal regulations.

  • a) The data indicated in the contact form shall be processed for the purposes resulting from the function of a given form, e.g. to get in touch with the Controller or for marketing of its own products and services as well as the products and services of entities associated with the Controller (Closer Music Sp. z o.o.), or to present the commercial offer, as well as for archiving and statistical purposes. The consent of the data subject shall be expressed by ticking a relevant checkbox in the contact form or in the e-mail message or from the level of an individual account registered by the user on the Website.

§.3 Security management - password

1. The Controller guarantees the Users a secure and encrypted connection during the personal data transfer and during the logging to the user account in the Website. The Controller uses the SSL certificate issued by one of the world’s leading companies dealing with security and encryption of data sent through the Internet.

2. If a user who has an account on the Website has lost the access password, the Website allows generating a new password. The Controller does not send a password reminder. The password is stored in the encrypted form, in a manner which makes reading it impossible. In order to generate a new password, the user needs to enter the -email address in the form available under the “Forgot your password?” link provided next to the form for logging in to the account on the Website. The user, to the e-mail address provided during the registration or saved in the latest account profile change, will receive a message containing a link to a dedicated form made available on the Website, where the user will have the possibility of setting a new password.

3. The Controller never sends any correspondence, including e-mail messages with requests for login information, and, in particular, for the account password to the user
account.

§.4 Rights of data subject

1. The Website user and entities being a party to a commercial contract entered into with the Controller (on provision of services or sale of goods) have, in particular, the right to:

  • a) view the personal data provided, At the user’s request, the Controller shall compile a list of the data processed in a structured computer file in one of the commonly used formats;
  • b) request the transfer of personal data to another controller, change, rectify, supplement or delete them completely. The Controller shall respond to each request without delay, by the deadline set out for each of these actions in legal regulations.
  • c) request to restrict the scope of the processing. For example, if the user has given consent for the processing of data allowing presentation of a commercial offer electronically, he can withdraw that consent at any moment, and at the same time can keep using the Controller’s services under a contract entered into earlier, or by communicating via email. Giving the consent and its withdrawal does not have a specific formal form – it may take place both in the written form and through, among other things, e-mail: [email protected] or from the level of an individual account registered by the user on the Website.
  • d) object to the Controller against the processing of personal data.
  • e) lodge a complaint with the supervisory authority (President of the Personal Data Protection Office) against the processing of personal data.

§.5 To whom data are made available or entrusted

1. The data provided in the contact forms on the Website may be made available to entities which provide certain technical services; it, in particular, applies to providing information about the owner of a registered domain to the entities which are operators of the internet domain or other entities with whom the Controller cooperates to that or similar extent.

2. The user personal data are stored in a database in which the technical and organizational measures have been used to ensure the protection of the data processed in accordance with the requirements laid down in the personal data protection regulations.

3. In the cases confirmed by law, the Controller may make available part of the personal data of the Website Users to third parties for the purposes connected with protection of the third parties’ rights, and, in particular, for protection of copyrights, but it shall happen at the written request of such a party. The entity submitting the request shall be obliged to prove the breach of its right, and, in particular, to prove that it has the copyright to the work. There must be suspicion that the rights of the entity submitting the request have been breached. The Controller may also make available the personal data collected on the basis of the Website user’s consent or at the request of state authorities authorized to obtain them under legal regulations. The correspondence sent to the Controller is archived, and, in certain cases, may be used for evidence purposes.

4. User personal data are the subject to Controller’s profiling, i.e. automated processing that allows adapting the content presented to specific audiences. Should profiling result in taking decisions which result in legal consequences for users or influence users in a similarly significant way, the Controller may perform it only on the basis of the user’s consent. The consent may be withdrawn at any time. Processing of data until the Users withdraw their consent remains legal.

§.6 Server logs

1. According to the practice adopted by most websites, the Controller stores http inquiries sent to the Website server (logs are created at the server layer for information about certain Website user behavior). The resources browsed are identified through URL addresses. The precise list of information stored in the web server log files is as follows:

  • a) the public IP address of the computer from which the inquiry was sent;
  • b) the client station name – identification performed by http protocol (if possible);
  • c) the user name provided in the authorization (logging) process;
  • d) the time when the inquiry arrived;
  • e) http response code;
  • f) the number of bytes sent by the server;
  • g) the URL of the web page previously visited by the Website user (referrer link), if the Website was accessed via the link;
  • h) information about the user’s web browser;
  • i) information about the errors that occurred when http transaction was executed. This information is not associated with specific persons who browse through the web pages available as part of the Website. To ensure the best quality of the Website, the Controller from time to time analyzes log files in order to determine which pages of the Website are visited most frequently, which web browsers are used, whether the web page structure is free from errors, etc.

2. The logs collected by the Controller are stored as a support material for a period of time allowing Website’s proper administration. The information contained in them shall not be disclosed to any other entities, except for the entities which have personal, capital or contractual links with the Controller, or if such an obligation arises under the law. Statistical data helping to administer the Website can be generated from the information contained in these files. The summaries showing such statistics do not include the features identifying the persons who visit the Website.

§.7 Privacy Policy changes

1. The Privacy Policy is subject to change.

2. Should you have any questions, please send them to: [email protected]

3. Latest update: 26 February 2021

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