Privacy Policy

A. Introduction

Nadascore is an artificial intelligence (AI)-powered music intelligence platform operated by PT Multikanal Novel Seberkat Salihara ("Nadascore", the "Company", "we", "us", or "our"). We respect and are committed to protecting the privacy and Personal Data of all users of our Services.

This Privacy Policy explains how Nadascore collects, obtains, accesses, uses, processes, analyzes, stores, discloses, transfers, protects, and/or deletes Personal Data in connection with the provision and use of our music analytics platform, market intelligence services, AI-powered features, third-party platform integrations, websites, applications, and other services provided by Nadascore (collectively, the "Services").

This Privacy Policy is drafted and interpreted in accordance with:

• Law Number 27 of 2022 concerning Personal Data Protection of the Republic of Indonesia, including its implementing regulations, as amended from time to time ("PDP Law");
• Other applicable laws and regulations of the Republic of Indonesia relating to data protection and electronic information; and
• Regulation (EU) 2016/679 (General Data Protection Regulation or "GDPR"), to the extent applicable to the processing of Personal Data of users located within the European Economic Area ("EEA"), the United Kingdom, or other jurisdictions that adopt similar data protection standards.

By accessing the Services, registering an account, connecting third-party accounts, or otherwise using the Services, you acknowledge that you have read and understood this Privacy Policy. Your use of the Services is subject to this Privacy Policy, our Terms of Service, Data Deletion Policy, and any other policies, guidelines, or terms that may be implemented by Nadascore from time to time (collectively, the "Terms").

If you do not agree to this Privacy Policy or the applicable Terms, you must not access or use the Services.

B. Definitions

• Personal Data means any information relating to an identified or identifiable individual, whether directly or indirectly, either on its own or in combination with other information, as defined under applicable laws and regulations.
• Sensitive Personal Data means categories of Personal Data that are subject to enhanced legal protection under applicable laws, including but not limited to health data, biometric data, genetic data, certain financial information, children's data, religious or belief-related data, criminal records, and other categories designated under applicable laws and regulations.
• Input means any data, information, instructions, queries, prompts, materials, content, or other information submitted, uploaded, transmitted, or otherwise provided by a User through the Services.
• Output means any result, recommendation, analysis, summary, insight, classification, score, or other output generated by Nadascore's systems based on Input or data processed through the Services.
• Processing means any operation performed on Personal Data, whether by automated means or otherwise, including collection, recording, organization, storage, use, analysis, disclosure, transmission, deletion, or destruction of Personal Data.
• Personal Data Controller means a party that determines the purposes and exercises control over the Processing of Personal Data.
• Personal Data Processor means a party that Processes Personal Data on behalf of a Personal Data Controller.
• Services means the Nadascore platform and all related features, services, technologies, applications, websites, dashboards, analytics systems, AI-powered features, third-party integrations, and other services made available by Nadascore from time to time.
• Market Data means data about artists, recordings, releases, charts, playlists, audiences, and markets that Nadascore obtains from licensed data partners (including Soundcharts) or from public sources and public interfaces (including the YouTube Data API), and that is the same for every User who follows the same artist.
• Connected Account Data means data that Nadascore obtains, with a User's authorization, through a third-party account the User connects to the Services, such as YouTube, TikTok, Instagram, or Spotify for Artists.
• Account Activity Data means data that results from an Account's use of the Services, including the tasks recommended to it and their completion, dismissal, and verification; the outcomes and attributions measured afterwards; release plans and campaigns; pitches; conversations with AI-powered features; artist persona inputs; facts and other information the User enters; feedback and ratings; preferences learned from the Account's activity; and Connected Account Data.
• Account means a User's Nadascore account together with the members of that User's team, if any.
• AI Data Learning means the optional program described in the AI Data Learning Addendum, under which an Account's Account Activity Data contributes, in de-identified and aggregated form, to improving recommendations for other participating Accounts.
• The Nadascore Journal means the official blog newsletter operated by Nadascore, containing articles, essays, and editorial content relating to the music industry and Nadascore's services, delivered periodically to Users who have voluntarily subscribed through a double opt-in mechanism.

C. Personal Data Controller

For the purposes of this Privacy Policy, the Personal Data Controller is:

PT Multikanal Novel Seberkat Salihara
One Pacific Place, Jl. Jend. Sudirman Kav. 52–53, 15th Floor, RT.5/RW.3, Senayan, Kebayoran Baru, South Jakarta 12190, Indonesia.
Email: hello@nadascore.com

In providing the Services, Nadascore acts as the Personal Data Controller for Personal Data processed through the Services. However, in certain circumstances, including when Nadascore provides services to corporate customers, music labels, artist management companies, studios, agencies, or other organizations that determine the purposes and means of Processing Personal Data, Nadascore may act as a Personal Data Processor on behalf of such customers in accordance with the applicable agreement.

D. Scope of This Privacy Policy

This Privacy Policy applies to all Processing of Personal Data carried out by Nadascore in connection with the provision, operation, management, and use of the Services, including websites, applications, AI-powered features, third-party integrations, subscription services, communications with Users, and other activities related to the operation of the Services.

This Privacy Policy does not apply to third-party websites, applications, platforms, services, or products that have their own privacy policies. Nadascore is not responsible for the privacy practices of such third parties, and Users are encouraged to review the privacy policies of each third party before using their services.

E. Personal Data We Collect

Nadascore may collect, receive, access, or process the following categories of Personal Data:

E.1 Account Data

We may collect information that you provide when creating or managing an account, including but not limited to:

• Name
• Email address
• Profile photo
• Password in encrypted or hashed form
• Language preferences
• Time zone
• Phone number or WhatsApp number (if provided)
• Subscription package information
• Subscription and service usage history

E.2 Third-Party Platform Integration Data

If you connect a third-party account through OAuth or other authorization mechanisms, we may receive data permitted by the relevant platform, including but not limited to:

We do not access private messages, personal contact lists, or any other information that has not been made available through the permissions granted by you to Nadascore. Nadascore's use and transfer of information received from Google APIs will comply with the Google API Services User Data Policy, including the Limited Use Requirements. Users may revoke Nadascore's access to their Google or YouTube accounts at any time through their Google Account security settings. Further information is available in the Google Privacy Policy and the YouTube Terms of Service.

Editing your YouTube videos (optional). If you choose "Allow Nadascore to edit this channel", Google grants Nadascore the YouTube permission to manage your videos. We use it only to update the title, description, tags and translations of a video you select, after you review the suggested change and confirm it. We keep the previous version so you can undo the change from Nadascore. We never upload, delete or make videos private, and we never post comments or ratings. You can remove this permission at any time in your Google Account.

Connected Account Data is visible only to the User who connected the account, and only while the connection is active. It is not made available to other Users, including other Users who follow or manage the same artist, and it is used for AI Data Learning only as described in section I.

E.3 Artist and Roster Data

For Users utilizing roster, artist management, label, studio, or similar features, we may process: (i) artist names; (ii) public social media accounts; (iii) public metadata; (iv) music catalog information; (v) release information; (vi) public performance data; and (vii) other data lawfully obtained from public sources or licensed data partners.

E.4 Usage Data

We may collect information regarding your use of the Services, including:

• Pages visited
• Features used
• Account activity
• AI feature usage history
• Notification preferences
• Access times
• IP addresses
• Browser information
• Device information
• Operating system
• Log and diagnostic data

E.5 Communication Data

We may retain:

• Customer support correspondence
• Questions and support requests
• Feedback forms
• Email communications
• WhatsApp communications
• Records of consent and communication preferences

E.6 Newsletter Subscription Data

If you choose to subscribe to The Nadascore Journal, we collect: (i) your email address; (ii) language preferences; (iii) subscription status; and (iv) the registration timestamp. This data is collected and processed solely for the purpose of delivering the newsletter and is not used for any other purpose, shared with, or sold to any third party.

E.7 Payment Data

We may receive limited payment-related information, including:

• Payment status
• Subscription package type
• Subscription period
• Transaction history
• Last four digits of a payment card (if available)
• Other information necessary for payment administration

Nadascore does not store full payment card numbers or other payment credentials.

Nadascore may also collect and process publicly available information regarding artists, creators, musical works, social media accounts, or other parties relevant to the functions of the Services, to the extent permitted by applicable law.

F. Sources of Personal Data

Nadascore may obtain Personal Data directly from Users, through use of the Services, from third-party platforms connected by Users, identity and payment providers, licensed data partners, publicly available sources, and other parties legally authorized to provide information to Nadascore.

Users are requested not to submit Sensitive Personal Data or other information subject to special protection into AI features unless such submission is necessary and permitted under applicable law.

If a User provides Personal Data belonging to another individual, the User represents and warrants that the User has the necessary legal basis, consent, authority, or other rights to provide such Personal Data to Nadascore and to permit the Processing described in this Privacy Policy.

G. Legal Basis for Processing Personal Data

To the extent required by applicable law, Nadascore processes Personal Data based on one or more of the following legal bases:

G.1 Performance of a Contract

Processing is necessary to provide, operate, and manage the Services requested by the User, including account management, authentication, payments, reporting, and related functions.

G.2 Consent

Processing is carried out based on consent given by the User, including for marketing communications, WhatsApp notifications, the use of cookies or similar non-essential technologies, and other activities requiring consent under applicable law. With respect to subscriptions to The Nadascore Journal, the Company implements a double opt-in mechanism, whereby a new subscription is activated only after the User confirms their email address via a confirmation link sent by Nadascore, as a form of the User's explicit consent. Participation in AI Data Learning is likewise based on consent, which the User gives or withdraws in Settings → Privacy, as described in the AI Data Learning Addendum.

G.3 Legitimate Interests

Nadascore may process Personal Data for legitimate interests provided such interests are not overridden by the User's rights and freedoms, including service development and improvement, usage analytics, system and network security, prevention of abuse and fraud, business continuity, service performance monitoring, and the safe and responsible development of AI features.

G.4 Legal Obligations

Processing may be carried out where necessary to comply with legal obligations, regulations, court orders, requests from competent authorities, or other compliance requirements.

H. Purposes of Processing Personal Data

We may use Personal Data for the following purposes:

• to provide, operate, manage, maintain, and improve the Services;
• to create, manage, verify, and secure User Accounts;
• to provide music analytics features, market intelligence, reports, dashboards, and AI-powered features;
• to process payments, manage subscription Services, and administer transactions;
• to send notifications and communications relating to the Services;
• to provide customer support;
• to enable collaboration, connection, and communication features among Users who have given their consent;
• to conduct usage analysis, product development, and Service quality improvement;
• to prevent misuse, illegal activities, fraud, and security incidents;
• to protect the rights, interests, and security of Nadascore, Users, and third parties;
• to deliver The Nadascore Journal articles to Users who have voluntarily subscribed and confirmed their consent through a double opt-in mechanism; and
• to comply with legal obligations, regulations, court orders, and requests from competent authorities.

I. AI Technologies

Nadascore utilizes artificial intelligence (AI), machine learning, large language models (LLMs), predictive analytics, natural language processing, and similar technologies to provide analytics, recommendations, classifications, scoring, summaries, insights, and other functions that may be made available from time to time.

To provide certain features, Nadascore may engage third-party AI technology providers, including Anthropic PBC or other providers designated from time to time. Data processed through AI-powered features may be transmitted to such providers to the extent necessary to provide the functions or Services requested by the User. Subject to the applicable contractual arrangements, Users' Personal Data, Inputs, and Outputs are not used to train such providers' AI models unless otherwise disclosed to Users or required by applicable law.

When using AI-powered features, Users may provide Inputs in the form of data, instructions, queries, prompts, materials, or other information, which may generate Outputs in the form of recommendations, analyses, summaries, classifications, scores, insights, or other forms of output. Nadascore may process Inputs and Outputs to provide the Services, maintain system security, perform troubleshooting, prevent misuse, comply with legal obligations, and improve the operational quality of the Services.

The Services may also utilize automated processing, including profiling and algorithmic analytics, to generate Nadascore Scores, performance analyses, recommendations, market insights, and other indicators. Where reasonably necessary, Nadascore may review Inputs, Outputs, User activities, or other data processed through the Services, through automated means and/or authorized personnel, for security purposes, misuse prevention, incident investigation, customer support, and legal compliance.

Service Improvement and Continuous Learning. Nadascore distinguishes Market Data from Account Activity Data. Market Data is the same for every User who follows an artist and is used to provide the Services to all Users. Account Activity Data belongs to the Account that generated it: Nadascore uses it to provide the Services to that Account, including to personalize that Account's own recommendations, and does not show it to, or use it to shape the recommendations of, any other Account, including another Account that follows or manages the same artist.

Nadascore uses Account Activity Data to improve recommendations for other Users only if the Account has opted in to AI Data Learning under theAI Data Learning Addendum. AI Data Learning is off by default and can be switched on or off at any time in Settings → Privacy. For participating Accounts, Account Activity Data is used only as de-identified statistics combined across at least five participating Accounts, which are made available only to participating Accounts; when an Account switches it off, its data is removed from those statistics within 24 hours. Connected Account Data is never made available to other Users and is included in AI Data Learning only in that de-identified, aggregated form and only for participating Accounts. Research-derived playbooks, the Predictor, and insights built from Market Data remain available to all Users regardless of participation.

Nadascore does not use data licensed from Soundcharts to train any artificial intelligence model, whether Nadascore's own or a third party's, and does not use identifiable Personal Data to train third-party foundation AI models.

J. Retention

Nadascore retains Personal Data for as long as necessary to fulfill the Processing Purposes described in this Privacy Policy, maintain contractual relationships with Users, comply with applicable legal and regulatory obligations, resolve disputes, enforce Nadascore's legal rights and interests, and for other legitimate purposes permitted under applicable law.

Once Personal Data is no longer required for such purposes, Nadascore will delete, destroy, anonymize, or de-identify the Personal Data in accordance with applicable law and Nadascore's Data Deletion Policy.

Aggregated, statistical, or anonymized data that can no longer identify any specific individual does not constitute Personal Data and may be retained and used for analytics, product development, and service improvement. Statistics derived from Account Activity Data are used for continuous learning only as described in section I and the AI Data Learning Addendum.

K. User Responsibilities and AI Limitations

Users are responsible for ensuring that any Personal Data, artist data, social media accounts, or third-party information provided to Nadascore has been lawfully obtained and has the necessary legal basis under applicable law. Users represent and warrant that they possess all rights, consents, permissions, and authorities necessary to provide such data to Nadascore. Nadascore is not responsible for data or information provided, uploaded, connected, or processed by Users without adequate rights, authority, consent, or legal basis. In the event of claims, objections, demands, or disputes relating to data provided by a User, the User shall be responsible for such data in accordance with applicable law. Nadascore reserves the right to delete, restrict, or refuse Processing of data suspected to have been obtained or provided without a valid legal basis.

Output generated by AI systems may be predictive, probabilistic, or based on data available at the time of processing. Accordingly, Nadascore does not guarantee that any Output will always be accurate, complete, up-to-date, error-free, or suitable for any particular purpose. AI-generated Output is not intended to constitute legal, financial, investment, tax, accounting, employment, or other professional advice. Users are responsible for conducting independent verification and assessment before relying on any Output for business, commercial, investment, legal, or other important decisions.

L. Cookies and Similar Technologies

Nadascore uses cookies, local storage, session storage, pixel tags, and similar technologies to operate, secure, maintain, and improve the Services, including for user authentication, session management, preference storage, usage analytics, service performance measurement, abuse prevention, and user experience enhancement.

In jurisdictions that require consent for the use of non-essential cookies or similar technologies, Nadascore will obtain the necessary consent before such technologies are used.

Users may configure, restrict, or disable cookies through their browser or device settings. However, doing so may affect the availability or functionality of certain parts of the Services.

M. International Data Transfer

Nadascore operates globally and may process, store, access, or transfer Personal Data to countries outside the jurisdiction where the User is located. Where Personal Data is transferred outside Indonesia, Nadascore will implement the measures required under the PDP Law and its implementing regulations.

For Users located in the EEA or the United Kingdom, transfers of Personal Data outside the EEA or the United Kingdom will be carried out using lawful transfer mechanisms under the GDPR, including but not limited to:

• Standard Contractual Clauses (SCCs);
• Adequacy decisions; and
• Other mechanisms recognized under the GDPR.

By using the Services, Users understand that Personal Data may be processed in multiple jurisdictions as necessary for the operation of the Services.

N. Data Security

Nadascore implements reasonable technical, administrative, and organizational measures to protect Personal Data against unauthorized access, use, alteration, disclosure, loss, or destruction. Such measures may include:

• Encryption of data in transit and at rest;
• Role-based access controls;
• User authentication and authorization;
• System activity logging and monitoring;
• Regular security testing;
• Data backups; and
• Security incident response procedures.

However, no security system can be guaranteed to be completely secure or free from risk.

O. Disclosure of Personal Data and Service Providers

Nadascore may disclose Personal Data to lawful third parties as necessary for the purposes described in this Privacy Policy, including:

• Technology and infrastructure service providers;
• AI service providers;
• Payment service providers;
• Communication service providers;
• Analytics service providers;
• Auditors, legal advisors, and professional consultants;
• Affiliates and companies within the same corporate group;
• Regulators, government authorities, law enforcement agencies, or other parties as required by law; and
• Other parties in connection with mergers, acquisitions, corporate restructurings, financings, asset sales, or other corporate transactions, provided that such Processing is carried out in accordance with applicable law and the recipient is subject to substantially equivalent data protection obligations.

Other Users (Collaboration Features). Where a User voluntarily chooses to use any collaboration, connection, or sharing features available through the Services and provides explicit consent (opt-in), Nadascore may disclose certain contact information, including but not limited to the User's email address, to other Users to the extent reasonably necessary to facilitate such collaboration or connection. Such disclosure is based on the User's consent and is limited to the information reasonably necessary for the relevant purpose. The User may withdraw such consent at any time, in which case Nadascore will cease any further disclosure of the User's Personal Data to other Users. However, any Personal Data that has already been disclosed to other Users prior to the withdrawal of consent may continue to be retained, used, or otherwise processed by such Users in connection with the relationship or interaction already established.

To support the provision of the Services, Nadascore uses service providers and sub-processors that may process Personal Data on behalf of Nadascore, including:

This list of service providers and sub-processors may be updated from time to time as operational needs change.

Nadascore does not sell Personal Data to third parties and does not disclose Personal Data to data brokers for commercial purposes.

P. Data Subject Rights

To the extent permitted by applicable law, Users may have the following rights regarding Personal Data processed by Nadascore:

• The right to obtain information about the Processing of Personal Data;
• The right to access Personal Data;
• The right to complete, update, and/or correct inaccurate Personal Data;
• The right to withdraw previously given consent;
• The right to unsubscribe from The Nadascore Journal at any time via a one-click unsubscribe link included in every newsletter email sent by Nadascore, and such withdrawal of consent shall not affect the lawfulness of any processing carried out prior to its withdrawal;
• The right to request deletion or destruction of Personal Data;
• The right to restrict Processing in certain circumstances;
• The right to object to certain Processing activities;
• The right to obtain and/or transfer Personal Data in a structured and commonly used format, where required by applicable law;
• The right to lodge a complaint with the competent authority; and
• Other rights granted under the PDP Law, GDPR, or other applicable laws.

Nadascore may request additional information to verify a User's identity before processing a request. Nadascore may refuse or limit the exercise of certain rights to the extent permitted by applicable law, including where the request may affect the rights of others, violate legal obligations, or compromise the security and integrity of the Services.

Requests for deletion of Personal Data will be processed in accordance with Nadascore's Data Deletion Policy, which forms an integral part of this Privacy Policy.

Q. Special Notice for Users in the EEA and the United Kingdom

Users located in the EEA and the UK may be entitled to additional rights under the GDPR, including the right not to be subject to a decision based solely on automated processing, including profiling, where such decision produces legal effects concerning them or similarly significantly affects them.

R. Children and Individuals Lacking Legal Capacity

The Services are not directed to individuals who, under applicable law, do not have the legal capacity to act independently.

Nadascore does not knowingly collect or process Personal Data of children or individuals under guardianship without the consent, supervision, or other legal basis required by applicable law.

If Nadascore becomes aware that such Personal Data has been processed without an adequate legal basis, Nadascore may take appropriate measures, including restricting Processing, deleting the relevant Personal Data, or suspending access to the Services.

Parents, guardians, legal representatives, or other authorized persons who believe that Personal Data has been provided to Nadascore without proper authority may contact Nadascore using the contact information provided in this Privacy Policy.

S. Personal Data Breaches

Nadascore maintains procedures to detect, investigate, handle, and respond to security incidents and Personal Data breaches.

In the event of a Personal Data breach that poses a risk to individuals' rights and freedoms, Nadascore will take the measures required by applicable law, including:

• Investigating and mitigating the incident;
• In the event of a Personal Data protection failure, Nadascore will provide notice to the relevant data subjects and competent authorities no later than three (3) × twenty-four (24) hours after becoming aware of such breach, in accordance with applicable laws and regulations;
• Notifying affected data subjects where required by law or where necessary to protect their interests; and
• Taking corrective actions to prevent recurrence.

T. Changes to This Privacy Policy

Nadascore may modify, update, or revise this Privacy Policy from time to time to reflect changes in the Services, business practices, technologies used, legal and regulatory requirements, or other operational needs.

The latest version of this Privacy Policy will be made available through Nadascore's website or platform. If there are material changes that affect Users' rights or obligations, Nadascore may provide additional notice through email, in-app notifications, the website, or other reasonable methods. The date of the latest update will always be stated at the beginning of this Privacy Policy.

Continued use of the Services after changes become effective constitutes acceptance of the updated Privacy Policy.

U. Contact Us

If you have questions, requests, complaints, or wish to exercise your rights regarding Personal Data as described in this Privacy Policy, you may contact:

PT Multikanal Novel Seberkat Salihara
One Pacific Place, Jl. Jend. Sudirman Kav. 52–53, 15th Floor, RT.5/RW.3, Senayan, Kebayoran Baru, South Jakarta 12190, Indonesia
Email: hello@nadascore.com
Website: nadascore.com

International Card Payments:
For subscriptions billed in Indonesia through Xendit, you contract with PT Multikanal Novel Seberkat Salihara at the address above. For subscriptions paid by international card, payment processing is provided by Nadascore Pte. Ltd. (UEN 202631926D), 68 Circular Road, #02-01, Singapore 049422, which acts as the merchant of record for such card transactions.