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This document sets out the Privacy Policy for the "Closer Music" website operating at https://closermusic.com , operated by CLOSER MUSIC Sp. z o.o. KRS: 0000282021 NIP: 8842624320, which in particular includes regulations concerning the protection of personal data and the security of other data entered into the Site by the User.
The Privacy Policy is an integral appendix to the Terms and Conditions of the "Closer Music" website.
Terms used in this document mean the following:
Personal Data Administrator (also referred to as the Administrator) - CLOSER MUSIC Sp. z o.o., with its registered office in Warsaw (02-819) at ul. Puławska 366, registered in the Register of Companies of the National Court Register kept by the District Court for the Capital City of Warsaw. XIII Economic Division of the National Court Register under KRS no. 0000282021, NIP 8842624320, REGON: 020531489, SHARE CAPITAL: PLN 624,050.00.
Site - the website at https://closermusic.com and all its sub-sites and the mobile application available on IOS and Android (App Store and Google Play).
User - an individual who uses the Site and provides personal data within it.
Personal data - information about a natural person identified or identifiable directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or by one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity, including image, voice recording, contact data, location data, information contained in correspondence, information collected through recording equipment or other similar technology,
GDPR - 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,
Terms and Conditions - Terms and Conditions of the "Closer Music" website operating at https://closermusic.com and the mobile application available on IOS and Android (App Store and Google Play).
The Administrator informs about the processing of data at the moment of its collection. The Administrator processes data to the extent, time and purposes each time indicated in the content provided under the forms used to collect personal data from the User or in the Privacy Policy.
The User may contact the Administrator in the manner of his/her choice:
Correspondence Address
Closer Music Sp. z o.o. 02-819 Warszawa, ul. Puławska 366
E-mail:
gdpr@closermusic.com
The Administrator uses all the technical and organisational possibilities at his disposal to ensure the security of the User's personal data and to protect them against accidental or intentional destruction, accidental loss, modification, unauthorized disclosure or access.
Entrusted data is stored on top-of-the-range equipment and servers in appropriately secured information storage centres, to which only authorized persons have access.
The Administrator shall carry out Personal data processing activities in compliance with all legal and technical requirements imposed on him by the Personal data protection legislation.
The Administrator shall analyze, on an ongoing basis, the risks involved in his personal data processing and shall ensure that only authorized persons have access to the data and only to the extent necessary for the performance of their duties.
The Administrator shall take all necessary measures to ensure that also his subcontractors and other cooperating entities apply appropriate security measures when processing Personal Data on its behalf.
The Administrator undertakes to keep security copies containing the User's personal data, which does not affect the duration of the processing of the data processed by the Administrator.
Personal Data may be disclosed to recipients such as:
Subcontractors who cooperate with the Administrator (including, in particular, suppliers responsible for the operation of IT systems, entities such as banks and payment operators, marketing agencies, entities providing other IT and software services)
To the competent authorities and third parties, if such a need arises under the applicable legislation and if they make a request for such information on the appropriate legal basis.
Other entities within the Closer Music group, to the extent necessary for the uniform management of the Site.
Entities providing consultancy services to the Administrator (e.g. legal assistance, accounting, taxation).
Postal service providers.
If the Personal Data changes, the User should update it by sending an appropriate message to the Administrator.
The User has the following rights:
The right of access to the Personal Data,
The right to obtain a copy of the Personal Data that the Administrator processes,
The right to rectify the Personal Data,
the right to erasure of Personal Data (on this basis, you may request the erasure of Data the processing of which is no longer necessary for the performance of any of the purposes for which it was collected),
the right to restrict the processing of Personal Data,
the right to portability of Personal Data,
the right to object to the processing of Personal Data for marketing purposes (You may object at any time to the processing of Personal Data for marketing purposes, without having to justify such objection),
The right to object to other purposes of processing (the User may object at any time - on grounds related to his/her particular situation - to the processing of Personal Data which is carried out on the basis of the legitimate interest of the Administrator; such objection requires justification),
The right to withdraw consent, if the Personal Data is processed on the basis of the consent given (withdrawal of consent does not affect the lawfulness of the processing carried out before its withdrawal),
The right to lodge a complaint with the supervisory authority supervising the processing of Personal Data, which has jurisdiction over the User's habitual residence, place of work or the place where the alleged infringement was committed. In Poland, the supervisory authority is the President of the Office for Personal Data Protection.
The Administrator may refuse to delete he User's personal data if the preservation of the personal data is necessary due to an obligation imposed on the Administrator by law.
The user has the right to submit a request for the exercise of his/her rights as indicated above by letter or electronic means (e-mail).
The Administrator's contact details are indicated in § 3 section 2.
If, on the basis of the request referred to in section 4, the Administrator is not able to determine and identify the natural person whom the request relates to, the Administrator will request additional information from the applicant. Failure to provide additional information shall result in refusal to comply with the applicant's request.
The Administrator shall respond to the request no later than one month after its receipt. If it is necessary to extend this deadline, the Administrator shall inform the applicant of the reasons for it and the expected deadline for responding to the request.
Personal data are processed for the following purposes and on the following grounds:
Use of the Site:
Personal data of all Users (including: IP address or other identifiers and information collected through cookies or other similar technologies), are processed by the Administrator:
for providing services by electronic means (legal basis: necessity of processing for the performance of the contract - Article 6(1)(b) GDPR),
for advertising, analytical and statistical purposes (legal basis: consent - Article 6(1)(a) GDPR),
for enabling the proper use of the Website and for ensuring the security of the Site (legal basis: the Administrator's legitimate interest - Article 6(1)(f) GDPR, which is to ensure the functionality and security of the Site),
for verifying of the user's location and the presentation of the relevant language version (legal basis: consent - Article 6(1)(a) GDPR)
for establishing and pursuing claims or defending against claims (legal basis: the Administrator's legitimate interest - Article 6(1)(f) GDPR, which is to protect the Administrator's rights).
Registration on the Website, order form:
In order to set up, operate and maintain a User Account, the User is requested to provide the Personal Data indicated in the registration form. Providing the data is not obligatory, but refusal to provide such data results in the inability to operate and maintain a User Account.
In order to place an order on the Site, the User is asked to provide the Personal Data indicated in the order form. Providing the data is not obligatory, but refusal to provide it results in inability to place an order.
The Personal Data indicated by the User is processed by the Administrator:
for providing services electronically (legal basis: necessity of processing for the performance of the contract - Art. 6(1)(b) GDPR),
for complying with the Administrator's legal obligations under relevant legislation, including tax legislation (legal basis: legal obligation Article 6(1)(c) GDPR),
for establishing and pursuing claims or defending against claims (legal basis: the Administrator's legitimate interest - Article 6(1)(f) GDPR, which is to protect the Administrator's rights).
for providing the services and all settlements (monetary or otherwise) connected to the provision of services (legal basis: necessity of processing for the performance of the contract - Art. 6(1)(b) GDPR),
for the purpose of concluding a license agreement and verifying identity when concluding the license agreement (legal basis: the Administrator’s legitimate interest – Article 6(1)(f) GDPR which is to protect the Administrator’s rights),
for verifying that the registration of the account is done by a human being (legal basis: the Administrator’s legitimate interest – Article 6(1)(f) GDPR which is to protect the Administrator’s rights),
or confirming the identity of the person entitled to take advantage of the free trial period and ensure the security of users by preventing the unauthorized setting up of accounts on the site using third-party e-mail addresses and telephone numbers ( legal basis: the Administrator’s legitimate interest – Article 6(1)(f) GDPR which is to protect the Administrator’s rights),
for direct and indirect marketing purposes (legal basis: consent - Article 6(1)(a) GDPR),
Subcontractors processing Personal Data:
For the provision of the service indicated above, the Administrator uses Subcontractors. To the extent indicated above, the Operators and the parties responsible for the proc
ONLINECITY.IO ApS
Buchwaldsgade 50,
5000 Odense C
The Subcontractor is used in the process described in point 2(v) and 2(vii). The data shall be processed for the period of performance of the service or fulfillment of the order and for the period of limitation of claims.
Google Inc.,
1600 Amphitheatre Pkwy, Mountain View
CA 94043-1351, USA
The Subcontractor is used in the process described in point 2(vi). The data shall be processed until User verification is completed.
Stripe Payments Europe Limited
1 Grand Canal Street Lower, Grand Canal Dock,
Dublin, D02 H210, Ireland
The Subcontractor is used in the process described in point 2(iv). The data shall be processed for the period of performance of the service or fulfillment of the order and for the period of limitation of claims.
PayU S.A.
Grunwaldzka 182
60-166 Poznań
The Subcontractor is used in the process described in point 2(iv). The data shall be processed for the period of performance of the service or fulfillment of the order and for the period of limitation of claims.
Amazon Web Services EMEA SARL
38 Avenue John F. Kennedy, L-1855, Luxembourg
The Subcontractor is used in the process described in point 2(i). The data shall be processed for the period of performance of the service or fulfillment of the order and for the period of limitation of claims.
Intuit Mailchimp
405 N Angier Ave. NE Atlanta,
GA 30308 USA
The Subcontractor is used in the process described in point 2(viii). The data shall be processed until consent is revoked.
Mailjet
43 rue de Dunkerque
75010 Paris
The Subcontractor is used in the process described in point 2(viii). The data shall be processed until consent is revoked.
Fakturownia Sp. z o.o.
ul. Juliana Smulikowskiego 6/8
00-389 Warsaw
The Subcontractor is used in the process described in point 2(iv) and 2(ii). The data shall be processed for the period of performance of the service or fulfillment of the order and for the period of limitation of claims.
Artia International S.R.L.
Bld. Decebal 28, Bucharest, Romania
The Subcontractor is used in the process described in point 1(i) and 1(iv). The data shall be processed for the period of performance of the service or fulfillment of the order and for the period of limitation of claims.
Newsletter, webchat, push notifications and SMS/MMS marketing services:
Users who have requested the Administrator to do so receive email, webchat, push notifications SMS or MMS messages with advertising content. Subscribing to the Newsletter, webchat, push notifications, and SMS/MMS marketing services involves providing the User's Personal Data to the Administrator. Provision of data is not mandatory, but refusal to provide such data results in the inability to provide Newsletter webchat, push notifications, and SMS/MMS marketing services. The Personal Data indicated by the User is processed by the Administrator:
for analytical and statistical purposes (legal basis: consent - Article 6(1)(a) GDPR),
for establishing and asserting claims or defending against claims (legal basis: the Administrator's legitimate interest - Article 6(1)(f) GDPR, which is to protect the Administrator's rights),
for the Administrator's marketing purposes - directing through the Newsletter, webchat, push notifications, MMS and SMS marketing content, (legal basis: the Administrator's legitimate interest - Article 6(1)(f) GDPR - dictated by the User's consent to use the Newsletter, webchat, push notifications, service and SMS/MMS marketing granted on the basis of relevant regulations).
for profiling to analyze the User's behavior and creating a forecast for the future, which is sued for displaying content to the User in accordance with the User's individual preferences and interests (legal basis: consent - Article 6(1)(a) GDPR).
Contact form, chat, traditional and electronic correspondence (e-mail)
The User may address messages to the Administrator using electronic mail using the Administrator's contact details available on the Site, the Terms of Use or this Privacy Policy, as well as through the contact form available on the Site and via chat.
Personal Data contained in such correspondence shall be used by the Administrator solely for the purpose of communication and settlement of the matter to which the correspondence relates. The basis for the processing of the Data is the Administrator's legitimate interest - Article 6(1)(f) of the GDPR - consisting in the maintenance of the correspondence addressed to it in connection with its business activity, and in the case of contact related to the services provided or a contract - the necessity of the processing to perform the contract - Article 6(1)(b) of the GDPR.
Contact by telephone or via other platforms
The User may contact the Administrator by telephone and via e- mail for purposes related to the services provided or the contract concluded and for other matters. In the event of telephone contact on matters not related to the concluded contract or the provided service, the Administrator may require the provision of Personal Data only if it is necessary to handle the reported matter. The legal basis for the processing of Personal Data is the legitimate interest of the Administrator - Article 6(1)(f) GDPR - consisting in the necessity to resolve the reported matter related to the Administrator's business activity, and in the case of contact related to the provided services or contract - the necessity of processing to perform the contract - Article 6(1)(b) GDPR.
Social media profiles
The Administrator has its profiles on social media (Facebook, among others). The Administrator processes Personal Data left by persons responding to the profiles, e.g. comments or web IDs. The Administrator uses this data in order to run the profiles effectively, to enable activity on these profiles, as well as for analytical or statistical purposes. The legal basis for the processing of Personal Data is the Administrator's legitimate interest - Article 6(1)(f) of the GDPR - consisting in the promotion of its activities and services provided, and on the basis also of Article 6(1)(f) of the GDPR - for the purposes of potential claims or defense against third-party claims. The above does not apply to the processing of Personal Data by social networks, which are a separate data administrator. For the processing of data by social networks, please refer to their Personal Data processing policy.
The period of data processing depends on the service provided, the purpose and the basis for processing. As a rule of thumb, the data shall be processed for the period of performance of the service or fulfillment of the order and for the period of limitation of claims, i.e. in particular no longer than 3 years (in case of entrepreneurs or in case of the claim pertaining to periodical performance) or 6 years (in case of natural persons) with effect as of the last day of calendar year. In the case of torts, the period may be extended to 10 years from the date on which the event causing the damage occurred, but no longer than 3 years from the day the injured party learned or, with due diligence, could have learned about the damage and the person liable for its compensation. Where the basis for the processing of Personal Data is consent, the data is processed until the consent is effectively withdrawn. Where the basis for the processing of Personal Data is the legitimate interests of the Administrator, the data are processed until the fulfillment of the Administrator's legitimate interests forming the basis for such processing or until an objection to such processing is raised (whichever comes first). Where the basis for the processing of Personal Data is the fulfillment of a legal obligation incumbent on the Administrator, the Personal Data will be processed for the period required by the relevant legislation.
With regard to the operation of the account, the processing period for Personal Data is until the account is deleted, after which time the data is anonymised. The period for the processing of Personal Data referred to in section 2 may be extended in case the processing is necessary due to pending proceedings related to the establishment, investigation or defense of claims. Thereafter, the Personal Data may be processed only if and to the extent required by applicable law.
After the expiry of the processing period, the Personal Data shall be deleted or irreversibly anonymized.
The Administrator uses cookies. Cookies are small text files sent (saved) by the Site on the User's terminal device (e.g. computer, smartphone).
The Administrator uses cookies to provide services electronically, to improve and enhance their quality, as well as for analytical and statistical purposes and to adapt the Site to the needs of its Users. Through the use of cookies, the Administrator personalises content and advertising. The Administrator shares information about how the User uses the Website with trusted social, advertising and analytics partners in order to provide the best possible service in terms of e-store operation, analytics, customisation and personalisation.
The Website uses two types of cookies: "session cookies" and "permanent cookies" (persistent cookies). "Session" cookies are temporary files that are stored on the User's terminal equipment until they log off, leave the website or switch off the software (web browser).
"Permanent" cookies are stored in the User's terminal equipment for the time specified in the parameters of the cookies or until they are deleted by the User.
The Administrator uses the following types of cookies on the Site:
essential cookies - they enable the use of services and functionalities available within the Site, e.g. used for user authorization,
functional - they make it possible to remember User choices and to adjust them on the Site, e.g. with regard to language preferences, font size, appearance of the Site, etc.,
analytical - for obtaining a range of information, e.g. number of visits and sources of traffic on the Site. Collecting this data is used to determine which pages are most frequently visited and leads to the creation of statistics concerning traffic on the Site. The collection of this data is used by the Administrator to improve the efficiency of the Site. The collected data is processed in an anonymized form. This type of cookies includes Google Analytics cookies,
advertising - they make it possible to adjust the content displayed on and outside the Site, including advertising, to the interests of Users. Data on browsing history, activity on the Site (e.g. purchase history, use of services, type of content and advertising displayed) or geolocation data may be used to present personalised content. Based on Internet Protocol(s) (IP) Users can be identified by location.
A profile of the User's interests is built on the basis of information from the Site and the User's activity on other websites. This type of cookie includes Meta Pixel cookies.
Functional, analytical and advertising cookies may be installed by the Administrator and its trusted partners through the Site.
The legal basis for the processing of Personal Data in connection with the use of essential cookies is the legitimate interest of the Administrator (Article 6(1)(f) GDPR), which is to ensure the functionality of the Site. In the case of other cookies (functional, analytical, advertising), the basis for the processing of Personal Data is the User's consent (Article 6(1)(a) GDPR).
The consent referred to in paragraph 6 is given by means of the relevant form displayed during the first visit to the Site. The consent given may be withdrawn or adapted differently at any time. In order to change or withdraw the consent(s) granted, contact the Administrator.
The User may change the cookie settings from the level of the web browser. This option is not available for a change of essential cookies (essential cookie settings cannot be changed).
Changing the settings of cookies and similar technologies may affect the way the Site works and the services it provides.
The Site uses third party tools to collect cookies.
These entities process cookies in accordance with the rules set out in their privacy policies and other documents defining standards for cookies:
Google Analytics:
https://policies.google.com/technologies/cookies?gl=pl
https://support.google.com/analytics/answer/11397207?hl=en
Meta Pixel (Facebook + Instagram):
https://www.facebook.com/business/help/471978536642445?id=1205376682832142
https://www.facebook.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0
Hotjar:
https://help.hotjar.com/hc/en-us/articles/6952777582999-Cookies-Set-by-the-Hotjar-Tracking-Code
Tik Tok Pixel:
https://ads.tiktok.com/help/article/using-cookies-with-tiktok-pixel?lang=pl-PL
Reddit Pixel:
https://www.reddit.com/policies/privacy-policy
In accordance with the practice of most websites, the Administrator stores HTTPS requests directed to its server (server logs). Accordingly, the Administrator stores the following information:
IP addresses from which Users browse the information content of our website;
the time of the request coming in
time of sending the response,
the name of the User's station - identification via HTTPS protocol,
information on errors which occurred during the HTTPS transaction,
the URL of a page previously visited by the user (referer link),
information about the User's browser.
The collected logs are stored as support material for the administration of the Site. The information contained in them is not disclosed to anyone except those authorized to administer the Site. On the basis of log files, statistics may be generated to assist in the administration of the Site. Aggregate summaries in the form of such statistics do not contain any identifying characteristics of visitors to the Site.
The information contained in the log files is processed by the Administrator for technical and administrative purposes, to ensure the security of the IT system and the management of this system, as well as for analytical and statistical purposes - in this regard, the legal basis for the processing of Personal Data is the Administrator's legitimate interest (Article 6(1)(f) GDPR).
Within the framework of the Administrator's use of tools supporting its day-to-day operations provided e.g. by Google, Users' Personal Data may be transferred to a country outside the European Economic Area (EEA), in particular to the United States of America (USA) or another country in which an entity cooperating with it maintains tools for processing Personal Data in cooperation with the Administrator. The Administrator transfers Personal Data outside the EEA only when necessary and with an adequate level of protection, in particular through the use of standard contractual clauses issued by the European Commission.
This privacy policy is subject to updates due to the ongoing analysis of the technical and legal conditions related to the processing of Personal data.
This privacy policy is effective as of 18.06.2025
The Administrator of the Personal Data processed in connection with your use of the Site is Closer Music Sp. z o.o, e-mail address: e-mail address: gdpr@closermusic.com.
On this website we use cookies in which your personal data may be stored and subsequently processed for analytical and marketing purposes. The information obtained may be shared with our advertising, social media and analytics partners. Please refer to the Privacy Policy for more information. By consenting to the cookies you choose, you consent to the processing of your data to the extent you choose. Necessary cookies are processed on the basis of our legitimate interest - the correct and safe operation of the Site.
Please note that consent to the use of cookies and data processing can be withdrawn by you at any time.
Third party cookies
Approved third parties may also set cookies when you interact with our services. These third parties use cookies in the process of delivering content and to perform services on behalf of Closer Music sp. z o.o.
Below is a list of the third parties that may set cookies when you use Closer Music sp. z o.o. services. You can learn more about how these third parties use information collected through cookies by reviewing the privacy policies on their sites.