Privacy Policy

1. Data controller

The controller of your personal data is Secret Hit LLC, located at [DIRECCIÓN POSTAL DE SECRET HIT LLC]. For any privacy matter, write to us at fabriziojamil@gmail.com.

2. Data we collect

Data you give us

• Creators: name, email, WhatsApp number with country code, password (stored encrypted), country, main platform, username, follower count, links to your profiles, screenshots of your audience analytics, and links and screenshots of your posts.
• Artists, labels, agencies and managers: account type, name, artist name, label or company, email, WhatsApp number with country code, country, Spotify profile, song details, official sound links, cover art and campaign instructions.
• Payments: payment method, details to receive or send payments (for example a PayPal email or account number), proofs of payment, transaction references and, where applicable, tax forms.
• Communications: the messages you send us and our replies.

Data collected automatically

• IP address, browser and device type, pages visited, access dates and times, and the essential cookies described in the Cookie Policy.

Data from public sources

• Public information from your social media profiles and posts (username, followers, visible content and metrics) that we review to verify your eligibility and your posts.

3. How we use your data

• To create and manage your account.
• To verify that you meet the platform requirements and that your audience is real.
• To show you campaigns, verify your posts and calculate your payouts.
• To process artist deposits, creator payouts, referral commissions and refunds.
• To send you notices about your account, campaigns, payments and changes to our policies.
• To contact you on WhatsApp about your account, campaigns and payouts.
• To send you news about new campaigns and opportunities on WhatsApp, only if you allowed it by ticking the corresponding box. You can withdraw that permission in your profile, by replying STOP to our messages or by writing to us.
• To show artists the results of their campaigns.
• To prevent fraud, protect the security of the platform and enforce our Terms.
• To comply with legal, accounting and tax obligations.
• To improve the platform. We will only send you marketing communications if you allow it, and you can withdraw that permission at any time.

4. Legal bases

We process your data because it is necessary to perform our contract with you (these Terms), because we have a legitimate interest in operating and protecting the platform, because the law requires it, or because you gave us your consent or authorization, which you can withdraw at any time.

5. Who we share your data with

We do not sell your personal data. We only share it in these cases:

• With the artists of the campaigns you take part in: your username, social network, approximate follower count and the link to your post. We do not share your email, WhatsApp, legal name or payment details with artists.
• With providers that help us operate: web hosting, email delivery, WhatsApp (by Meta Platforms) to send you messages, and payment processors or banks (for example PayPal, Payoneer or local banks). They only receive the data needed to provide their service.
• With our affiliates (VIP Music Records LLC and its affiliates) to operate and manage the platform.
• With legal, accounting and tax advisors, under a duty of confidentiality.
• With authorities, when the law requires it or to protect our rights, the rights of users or of third parties.
• In a merger, acquisition or sale of assets, with the successor, who must respect this policy.

6. International transfers

Secret Hit LLC is a United States company and our servers and providers may be in the United States or other countries. By using the platform, your data may be transferred outside your country. Where the law requires it, we apply appropriate safeguards, such as contractual clauses with our providers.

7. How long we keep your data

• Account data, while the account is active and for up to 2 years after it is closed, to handle claims.
• Records of payouts, deposits, proofs of payment and tax forms, for the period required by tax and accounting laws, which may be up to 7 years.
• Analytics screenshots from rejected applications, for up to 12 months after the decision.

After those periods, we delete or anonymize the data.

8. Your rights

Depending on the law of your country, you may have the right to:

• Know and access the data we hold about you.
• Update or correct inaccurate data.
• Ask us to delete your data, except data we must keep by law.
• Object to or restrict certain uses of your data.
• Receive your data in a portable format.
• Withdraw your consent or authorization.
• File a complaint with the data protection authority of your country.

To exercise them, write to fabriziojamil@gmail.com from your account email. We may ask for information to verify your identity. We will reply within the applicable legal deadlines.

9. Country-specific information

Colombia

We process your data under Law 1581 of 2012 and its regulations. When you register, you give us your prior, express and informed authorization to process your data for the purposes of this policy. You can submit inquiries and claims to fabriziojamil@gmail.com; we will handle them within the legal deadlines (generally 10 business days for inquiries and 15 business days for claims). The competent authority is the Superintendencia de Industria y Comercio.

Brazil

If you are in Brazil, we process your data under the Lei Geral de Proteção de Dados (Law 13,709/2018). You can exercise your data subject rights by writing to fabriziojamil@gmail.com and file complaints with the Autoridade Nacional de Proteção de Dados (ANPD).

Mexico

If you are in Mexico, you can exercise your rights of access, rectification, cancellation and objection (ARCO) by writing to fabriziojamil@gmail.com, under Mexican law on personal data held by private parties.

European Union and United Kingdom

If you are in the European Economic Area or the United Kingdom, you have the rights under the General Data Protection Regulation, including the right to lodge a complaint with your supervisory authority.

California and other US states

We do not sell or share your personal data for cross-context behavioral advertising. You can ask to know what data we hold, to correct it or delete it, and you will not be discriminated against for exercising your rights.

10. Minors

The platform is not directed at people under 18 and we do not knowingly collect their data. If we learn that a minor created an account, we will close it and delete their data. If you believe this happened, write to fabriziojamil@gmail.com.

11. Security

We apply reasonable technical and organizational measures to protect your data, such as encrypted connections (HTTPS), encrypted passwords and restricted access to information. No system is completely secure; if an incident affects your data, we will notify you where the law requires it.

12. Cookies

We use essential cookies for the platform to work. See the details in our Cookie Policy.

13. Changes to this policy

We may update this policy. We will publish the new version on this page with its update date and, if the changes are material, we will notify you by email or in your dashboard.

14. Contact

Secret Hit LLC

[DIRECCIÓN POSTAL DE SECRET HIT LLC]

Privacy email: fabriziojamil@gmail.com