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Privacy Policy

This English translation is provided for convenience. The German version is legally binding.

Table of Contents

  1. 1. Controller
  2. 2. Overview of Data Processing
  3. 3. Website Provision and Log Files
  4. 4. Waitlist
  5. 5. Registration and User Account
  6. 6. Profile Data and Onboarding
  7. 7. Payment Processing
  8. 8. Payouts and Credit Notes
  9. 9. Content Submissions (Song Requests)
  10. 10. File Uploads
  11. 11. Support Requests
  12. 12. Moderation and Banning
  13. 13. Automated Decision-Making
  14. 14. Web Analytics
  15. 15. Error Tracking
  16. 16. Bot Prevention
  17. 17. Affiliate Program
  18. 18. Cookies and Similar Technologies
  19. 19. Recipients and Third-Country Transfers
  20. 20. Your Rights
  21. 21. Data Retention
  22. 22. Changes

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Sinio UG (haftungsbeschränkt)
Marienthaler Straße 91
20535 Hamburg, Germany
Email: [email protected]

For any data protection inquiries, please contact us at [email protected].

2. Overview of Data Processing

SlideUp is a live interaction platform for creators and fans. We only process personal data to the extent necessary for providing our platform and related services. Processing is carried out in accordance with the GDPR and applicable German data protection law.

Categories of data subjects:

  • Creators — registered users who receive and manage content via the platform
  • Fans — registered or unregistered users who submit content
  • Website visitors — persons visiting our website

3. Website Provision and Log Files

Each time our website is accessed, access data is automatically collected and stored in server log files. This includes:

  • IP address of the requesting device
  • Date and time of access
  • Page or file accessed
  • Browser type and version
  • Operating system
  • Referrer URL

This processing is necessary for providing and securing the website.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the secure provision of the website).

4. Waitlist

When you sign up for our waitlist, we process the following data:

  • Creator name
  • Email address
  • Country
  • Social media URL
  • Time of registration

This data is used to manage the waitlist and to contact you when access is granted.

Legal basis: Art. 6(1)(a) GDPR (consent). You may withdraw your consent at any time by contacting us via email. Data will be deleted once the waitlist purpose ceases or you withdraw your consent.

5. Registration and User Account

During registration, we process your email address and password to provide your user account. Authentication is handled by a specialized authentication service.

Legal basis: Art. 6(1)(b) GDPR (performance of contract).

6. Profile Data and Onboarding

During the onboarding process, we collect additional personal data required for contract performance and compliance with legal obligations:

  • Personal data: First name, last name, date of birth, place of birth, phone number
  • Address data: Street, house number, postal code, city, country
  • Business data: Entity type, company name (if applicable)
  • Tax data: Tax ID, trade register number, VAT ID, tax status, small business classification, country of tax residency

This data is processed for identity verification, payout setup, and compliance with tax law obligations.

Legal basis: Art. 6(1)(b) GDPR (performance of contract) and Art. 6(1)(c) GDPR (legal obligation) in conjunction with Sec. 147 AO (German Fiscal Code), Sec. 257 HGB (German Commercial Code).

7. Payment Processing

Payments are processed through a payment service provider based in the USA. The following data is processed:

  • Payment amounts and currency
  • Payer's country
  • Payment status and references
  • Subscription data (term, plan, status)

Full payment data (e.g., credit card numbers) is processed exclusively by the payment provider. We only store reference identifiers.

Legal basis: Art. 6(1)(b) GDPR (performance of contract). Transfer to the USA is based on Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR.

8. Payouts and Credit Notes

To process payouts to creators and issue credit notes, we process:

  • Payout amounts, fees, and net amounts
  • VAT-relevant data (VAT scenario, amount, rate)
  • Creator's name, address, and tax data at the time of credit note issuance

The retention of personal data in credit notes is required to comply with Sec. 14 UStG (German VAT Act — mandatory invoice content) and the tax retention obligation under Sec. 147 AO (retention period: 10 years).

Legal basis: Art. 6(1)(b) GDPR (performance of contract) and Art. 6(1)(c) GDPR (legal obligation) in conjunction with Sec. 14 UStG, Sec. 147 AO.

9. Content Submissions (Song Requests)

When fans submit content (e.g., song requests) via the platform, we process:

  • Submitter's name
  • Submitter's message
  • Media URL and metadata (title, artist, duration)
  • IP address
  • Time of submission

For registered fans, submissions are linked to the user account. For unregistered fans (guests), the IP address and provided name are stored.

Legal basis: Art. 6(1)(b) GDPR (performance of contract) for registered users; Art. 6(1)(f) GDPR (legitimate interest in providing the service) for guests.

10. File Uploads

Users may upload various files, including audio files, profile pictures, background media, and support attachments. Uploaded files are stored within the EU.

Legal basis: Art. 6(1)(b) GDPR (performance of contract).

11. Support Requests

When you submit a support request, we process the subject, message content, and any attached files.

Legal basis: Art. 6(1)(b) GDPR (performance of contract) for existing users; Art. 6(1)(f) GDPR (legitimate interest) for pre-contractual inquiries.

12. Moderation and Banning

To enforce our terms of service and protect the platform from abuse, we process:

  • IP addresses
  • Device identifiers
  • Moderation actions (type, timestamp, acting person)

This data is used to enforce bans and ensure accountability of moderation decisions. Our legitimate interest in protecting the platform and its users from abuse outweighs the data subjects' interest in non-processing.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest).

13. Automated Decision-Making

Submitted content may be subject to automated review by an AI-based service. The review serves to detect content that violates our terms of service. Based on this review, content may be automatically flagged for manual review or rejected.

Pursuant to Art. 22(3) GDPR, you have the right to:

  • contest the automated decision,
  • obtain human review, and
  • express your point of view.

You may exercise these rights by contacting the creator or submitting a support request.

The AI service is based in the USA. Data transfer is based on Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. The provider does not use transmitted data for its own training purposes.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in content safety).

14. Web Analytics

We use a web analytics service to analyze and improve the use of our platform. Analytics are only performed with your explicit consent. Without your consent, no analytics data is collected.

The analytics service operates on servers within the EU.

Legal basis: Art. 6(1)(a) GDPR (consent).

15. Error Tracking

To ensure the stability and functionality of our platform, we use an error tracking service. In the event of an error, information about the error is automatically transmitted, including error messages, device and browser information, and potentially user context data.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in maintaining a functional service).

16. Bot Prevention

To protect our platform from automated access and abuse, we use a bot prevention service. Interaction data is processed to distinguish between human users and automated access.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in protection against automated abuse).

17. Affiliate Program

As part of our affiliate program, we process data for referral attribution, commission calculation, and affiliate payout processing.

Legal basis: Art. 6(1)(b) GDPR (performance of contract).

18. Cookies and Similar Technologies

We use the following categories of cookies:

  • Strictly necessary cookies: For authentication and session management. These cookies are essential for the operation of the platform and do not require consent.
  • Analytics cookies: Only set with your explicit consent. You may withdraw your consent at any time via the cookie banner.
  • Local storage: We use your browser's local storage to save your cookie preferences and language setting.

Legal basis: Art. 6(1)(a) GDPR (consent) for non-essential cookies; Art. 6(1)(f) GDPR (legitimate interest) for strictly necessary cookies.

19. Recipients and Third-Country Transfers

We transfer personal data to the following categories of recipients:

  • Payment service provider (USA): Processing of payments, payouts, and subscriptions. Transfer mechanism: Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR.
  • AI moderation service (USA): Automated content review. Transfer mechanism: Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR.
  • Authentication and database service (EU): User authentication, data storage, and file storage.
  • Web analytics service (EU): Usage analytics (with consent only).
  • Error tracking service: Error reports and performance monitoring.
  • Device identification service: Device recognition for ban enforcement.
  • Bot prevention service: Protection against automated access.

For transfers to third countries (in particular the USA), we ensure an adequate level of data protection through Standard Contractual Clauses (Art. 46(2)(c) GDPR). We have entered into data processing agreements pursuant to Art. 28 GDPR with all processors.

20. Your Rights

You have the following rights regarding your personal data at any time:

  • Access to your stored data (Art. 15 GDPR)
  • Rectification of inaccurate data (Art. 16 GDPR)
  • Erasure of your data (Art. 17 GDPR), unless statutory retention obligations apply
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Objection to processing, in particular processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR)
  • Withdrawal of consent with effect for the future (Art. 7(3) GDPR)
  • Contestation of automated decisions and the right to obtain human review (Art. 22(3) GDPR)

To exercise your rights, contact us at [email protected].

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The competent authority for us is:

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Str. 22, 7. OG
20459 Hamburg, Germany

21. Data Retention

Personal data is deleted once the purpose of storage ceases, unless statutory retention obligations apply. Specifically:

  • Contract and payment data: 10 years after the end of the contractual relationship (Sec. 147 AO, Sec. 257 HGB)
  • Credit notes and invoice data: 10 years (Sec. 14 UStG, Sec. 147 AO)
  • Account data: Duration of the contractual relationship, then deletion subject to statutory retention periods
  • Waitlist data: Until the purpose is fulfilled or consent is withdrawn
  • Support requests: 3 years after resolution (standard limitation period, Sec. 195 BGB)
  • Analytics data: Until consent is withdrawn
  • Ban and moderation data: For the duration of the ban or the contractual relationship

22. Changes

We reserve the right to update this privacy policy to reflect changes in the legal framework or changes to the service. In the event of material changes, we will notify you separately. The current version is always available on this page.

Last updated: April 2026

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