Privacy policy

Last updated May 8th, 2023

1. Data Controller

Family in Music Ltd (3003543-1), Keilasatama 2B, 02150, Espoo, Finland

2. General Info

We are committed to protecting your privacy. We collect and process some information about you, so we want to take some time to tell you about it. This privacy policy (“Privacy Policy”) is intended to help you better understand what and how we process and protect your information when you access or use the FAIM Services, and how you may exercise your rights as a data subject.

Please read this Privacy Policy carefully prior to using FAIM Services.

In this Privacy Policy, the word “User” or “you” refers jointly to our and our group companies’ customers, potential customers, other persons or legal entities accessing or using the FAIM Services, including the Website. To the extent you open an account on behalf of a company, organization, or other entity, then “User” and “you” includes you and that entity and any data subject (from within your organisation) whose personal data is shared with the Company at any time. All capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms of Service, Subscription Terms of Service and the Distribution Agreement, as applicable.

You must be age of eighteen (18) or older.

3. Collection of Personal Information

In connection with the FAIM Services, we collect and store personal information about and from you. In a nutshell, this means data created and/or transferred when you:

  • visit our Website;
  • otherwise use FAIM Services;
  • add payment methods for the Subscription Services;
  • upload music through the Distribution Service;
  • give your payment details for the Distribution Service;
  • submit your details for withholding tax purposes related to distribution Revenue payouts;
  • contact us, including our customer support;
  • connect to us through Third Party Services;
  • connect to Third Party Services via us;
  • sign up to one of our newsletters;
  • participate in a contest organised by us; and
  • participate in an event organised by us.

The personal information collected and processed by us can be divided into two general data categories: User Data and Analytics Data.

4. Collection of User Data

User Data necessary to use the FAIM Services (excluding the Distribution Service). When you start using the FAIM Services and create a Account, you need to provide us with the following information:

  • e-mail address;
  • password;
  • location; and
  • in case you connect to the FAIM Services using credentials from a Third Party Service like Google or Facebook, you authorise us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information connected to such Third Party Service such as, like your name, profile picture, age, country, hometown, e-mail address, date of birth and gender.

User Data necessary to use the Subscription Services (excluding the Distribution Service). When you start using the Subscription Services, you need to provide us with the following information:

  • e-mail address;
  • payment card details;
  • country; and
  • indication of whether you are an enterprise or an individual.

User Data that necessary to use the Distribution Service. When you use the Distribution Service, some additional information must be provided by you. This includes:

  • artist name;
  • audio files;
  • track/album titles;
  • artwork;
  • other required Metadata;
  • other required Related Material;
  • information relating to your payment details (as required for the purposes of receiving Distribution Royalties, such as name, bank account number, PayPal address, tax identification number, tax card, date of birth, e-mail, home address, country/region, vendor ID, whether you’re a private person or a business, VAT-number and Vendor ID). We only obtain enough information to be able to make the pay-out, to comply with our legal obligations and to prevent and detect fraud. We use a Third Party Service for processing of payments. Please note that different data requirements may apply depending on whether you are a Finnish User or a User from the rest of the world.

User Data you provide us directly. Your user experience may be improved by providing us with the following information:

  • full name;
  • mobile phone number;
  • date of birth;
  • address;
  • submitted user content, such as your bio, roles, services, page names, user names, links, avatars, photos, linked videos, location, social media and/or other service account names and other information. You don’t have to provide additional information on your profile. However, profile information helps you to get more from the FAIM Services, including helping industry professionals and business opportunities find you;
  • information you provide when rating the FAIM Services;
  • information you provide when providing feedback;
  • marketing opt-ins and opt-outs;
  • information you provide when connecting us or other Users; and
  • information you provide by phone or in e-mail or chat correspondence with us.

5. Collection of Analytics Data

Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal information under applicable laws and we will treated as personal information.  

Device Data. We may collect information on your device(s) relating to the following:

  • device identification number,
  • device IMEI;
  • device type;
  • device family;
  • device country;
  • device region;
  • device city;
  • device language;
  • device IP address;
  • network ID;
  • browser type and version;
  • operating system;
  • internet service provider;
  • advertising identifier of your device;
  • visitor identifier; and
  • cookie-related data.

Usage Data. We may collect the information on your use of the FAIM Services relating to the following:

  • time spent on the FAIM Services;
  • interaction with the FAIM Services;
  • content you post to the FAIM Services;
  • the URL of the website you visited before and after visiting the FAIM Services;
  • the time and date of your visits to the FAIM Services;
  • the sections of the FAIM Services you visited; and
  • information on how your Recordings stream.

6. Cookies and Web Beacons

We use various technologies to collect and store Analytics Data and other information when Users use the FAIM Services, including cookies and web beacons.

Cookies are alphanumeric identifiers in the form of small text files that are inserted and stored by your web browser on your device. They allow us to identify visitors and facilitate the use of the FAIM Services and to create aggregate information of our visitors. This helps us to improve the FAIM Services and better serve our Users. We and our third party advertiser partners may set and access cookies on your device to track and store preferential information about you. Gathered information is anonymous and on an aggregate level only, but we may be able to identify individual behaviour. Such aggregated information is used within our internal organisation and is only shared with third party advertisers on an aggregated and non-personally identifiable basis.

We may use the following types of cookies:

  • Necessary cookies are required for the operation of the FAIM Services.
  • Analytics/statistics cookies allow us to recognize and keep count of the number of visitors and see how visitors interact with the FAIM Services. This helps us improve FAIM Services.
  • Advertising cookies are used to deliver tailored advertising based on your preferences or interests across FAIM Services and devices and measuring effectiveness of advertisement.
  • Other cookies include cookies used e.g. to enable the sharing of content from the FAIM Services through social networking and other sites.

Your web browser is probably set to accept cookies by default. You may choose to set your web browser to refuse cookies, or to alert when cookies are being sent. Please note that some parts of the FAIM Services may not function properly if use of cookies is refused. The following links provide information on how to adjust the cookie settings on some popular browsers: Google ChromeFirefoxSafari.

Web beacons, also known as pixel tags and, are electronic images used together with cookies, allowing a website to access cookies and help tracking marketing campaigns and general usage patterns of visitors. No personally identifiable information about you is shared with third parties through the use of web beacons on the FAIM Services. If you turn off cookies, we can only see anonymous website visits. Access to cookies helps us to personalize your experience when you visit the FAIM Services. We may also include web beacons in e-mail messages that we send to you to determine your interest in and the effectiveness of such e-mails. We may also use web beacons externally. For example, we may report aggregate information about visitors, such as demographic and usage information, to our affiliates or other third parties. We may also include Third Party Services’ web beacons within the FAIM Services.

7. Use of Information

Some information is necessary in order for us

  • to provide the FAIM Services according to the Terms of Service;
  • to provide the paid Subscription Services under FAIM Services according to the Subscription Terms of Service;
  • for our compliance with legal obligations

We will process your information for the following purposes and legal bases:

  • to administer your Account and your profile, to enable, provide, improve and maintain the FAIM Services and, if applicable, to provide integration with a Third Party Service; (contract or its preparation, legitimate interest)
  • to identify you, as required for providing the FAIM Services; (contract or its preparation, legitimate interest)
  • to personalize and improve your experience and any advertising made available on or outside the FAIM Services; (consent)
  • to make sure the FAIM Services is technically functional and to develop new products and FAIM Services; (legitimate interest)
  • to analyse your use of the FAIM Services and how you interact with our ads; (consent)
  • to create research insights, reports and analyses, including the composition of the audience that viewed certain content; (legitimate interest, consent)
  • to create categories based on demographics, interests and preferences in order to facilitate interest-based advertising; (consent)
  • subject to your consent, to communicate with you, either directly or through any of our partners, via e-mails, notifications, or other ways of messaging; (consent)
  • for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity, for other internal purposes, and as otherwise described to you at the time of collection; (legitimate interest)
  • to promote the FAIM Services, either within or outside the FAIM Services; (legitimate interest, consent)
  • to enable Subscription Services; (contract or its preparation, legitimate interest)
  • to process your pay-outs and prevent or detect fraud; (contract or its preparation, legitimate interest, statutory obligation)
  • to enforce this Privacy Policy, the Terms of Service, the Subscription Terms of Service, the Distribution Agreement, and any other terms or guidelines that you have agreed to, including to protect the rights, property, or safety of us, Users, or any other person, or any content within the FAIM Services; (statutory obligation, legitimate interest) and
  • for any other purpose stated in this Privacy Policy

We will retain the personal data we collect from you for a period of 6 years after the termination of our agreement. After this period, your data will be anonymized and stored or erased. Data retention is necessary for us to:

  • Meet customer expectations;
  • Comply with applicable laws and regulations;
  • Comply with requirements from the Finnish Tax Administration;
  • Process any outstanding payments owed to you; and
  • Prevent fraudulent activities, other types of fraud, or criminal activity.

8. Disclosure of Personal Information

This section describes some of the ways that your personal information may be disclosed. Please note that we never share or sell your identifiable personal data to third parties for their own purposes. We only do this for the purpose of providing you with and enabling the FAIM Services.

Advertisers. We may aggregate personal information and disclose such information in a non-personally identifiable manner to advertising partners and other third parties for their marketing and promotional purposes. However, in these situations, we do not disclose to these entities any information that could be used to identify you personally without your explicit consent. We also partner with third parties who use cookies and similar tracking technologies to serve targeted advertising/content to you via the relevant third party platform based on your profile/interests. Your information is used by the third party platform provider to identify your account and serve advertisements to you. While we will not share information that identifies you by name with unaffiliated third parties for their own use, such third parties may be able to identify you with sufficient data from other sources.

Analytics Partners. We share data with the companies that compile it to provide analytics. Analytic services may e.g. track and report Website traffic and User activity in the FAIM Services.

Business Partners. We may share personal information with our business partners. For example, when one or more of our business partners co-organise or co-sponsor a promotion, contest or event, we may share some or all of the information collected in connection with such promotion, contest or event with such business partner.

Distribution. The information you provide us in connection with your use of the Distribution Service, will be used to perform and provide our Distribution Service, by disclosing, to the extent needed, such information to the Intermediary, Stores and other relevant partners. Such information may include:

  • artist name;
  • full name;
  • company name;
  • audio file;
  • ISRC and UPC;
  • track/album titles;
  • artwork;
  • other Metadata (defined in the Distribution Agreement);
  • other Related Material (defined in the Distribution Agreement); and
  • name of contributors (if applicable).

The payment information you provide us in connection with the Distribution Service, will be used to perform and provide the pay-outs, by delivering, to the extent needed, such information to the Payment Provider. Such information may include:

  • full name;
  • email address;
  • bank account number;
  • PayPal address;
  • tax identification number;
  • tax card;
  • date of birth;
  • home address;
  • country/region;
  • company name;
  • VAT number; and
  • vendor ID.

Profile and User Generated Content. Your profile is fully visible to all Users, subject to your settings, it can also be hidden from public view. Other Users will see a variable amount of your personal data depending on your settings, degree of connection with the viewing User, person’s usage of our FAIM Services, access channels and search types (e.g., by name or by keyword) may impact the availability of your profile and whether they can view certain fields in your profile.

Third Party Services and Other Third Parties. Some parts of the FAIM Services and services used in connection with and/or for supporting the FAIM Services may be provided by Third Party Services and other third parties. We may share your information with Third Party Services or other third parties to perform functions, process data and help provide the FAIM Services. Where a Third Party Service or other third party processes personal information directly on our behalf (e.g., a hosting an integral technical part of FAIM Services), it is subject to privacy and security obligations consistent with this Privacy Policy and applicable law. Where a Third Party Service or other third party uses data on its own behalf, such processing is subject to its own privacy policies and applicable laws. If you provide information to a Third Party Service or other third party directly, then such party’s use of your information is governed by their applicable privacy policy. Because we do not control the privacy practices of these Third Party Services or other third parties, you should evaluate their practices before deciding to use their services, whether or not such service is linked to or integrated in FAIM Services.

In addition to the above, we may also share your information with relevant third parties for these limited purposes:

  • to allow a merger, acquisition, or sale of all or a substantial portion of our assets or other change of control;
  • to respond to legal process if we believe in good faith that it is necessary to do so;
  • to comply with the requirements of mandatory applicable law;
  • to protect the safety of any person;
  • to protect the rights and property of us, including to enforce this Privacy Policy, the Terms of Service, the Subscription Terms of Service, the Distribution Agreement, and any other terms or guidelines that you have agreed to;
  • to address fraud and resolve disputes;
  • to address security or technical issues;
  • to publish anonymised or pseudonymised data about the use of the FAIM Services; and
  • to allow other companies belonging to the same group to use your information as specified in this Privacy Policy.

Please note that we cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example, without limiting the foregoing, we may be forced to disclose personal information to the authorities or third parties under certain circumstances, or third parties may unlawfully intercept or access your transmissions or communications.

9. Newsletters, Non-Critical Notices and Special Offers

By opting in during the signup process, you consent to receive our newsletters, industry news digests, non-critical notices, and/or special offers (collectively referred to as ‘Newsletters’) via email.

You may unsubscribe from our Newsletters at any time by editing your preferences under profile settings, following the instructions contained at the end of every such e-mail, or if a third party provides our Newsletter, in accordance with the instructions provided by such third party. You can unsubscribe from these at any time, by clicking “unsubscribe” in the bottom of the e-mail. While we try to ensure this information is viewable in all e-mail browsers, there may be cases where certain e-mail browsers do not display the unsubscribe information correctly. If you are having problems unsubscribing, please contact support or e-mail the entire Newsletter to with the word ‘UNSUBSCRIBE’ in the subject line, and you will be removed within 14 business days.

Please note that direct replies to any Newsletter are processed by computer and are not always viewed by a human.

10. Security

Security is important to us. We always do our best to maintain administrative, technical and physical safeguards to help protect your personal information from loss, misuse, unauthorised access, alteration or disclosure. In the unlikely event that an unauthorised third party compromises our security measures, we will, to the extent permitted by applicable laws, not be responsible for any damages directly or indirectly caused by an unauthorised third party’s ability to view, use or disseminate such information. Make sure you always protect your password and username to prevent anyone from accessing your information.

11. Links to Other Websites

The FAIM Services may include links to third party websites. Such links are not an endorsement by us of those websites and/or thew services offered on those websites. Third party websites may have different privacy policies, and we are not responsible for the privacy practices of those third party websites. If you click on a link to a third party websites, we encourage you to check the privacy policy of that website, as it may differ substantially from that of this Privacy Policy. We make no representations or warranties nor are we responsible for the privacy policies of any services other than the FAIM Services. If you decide to access any third party links appearing on the FAIM Services, you do so at your own risk.

12. Children

We do not accept people under the age of 18 to register in the Family in Music platform and therefore, we do not knowingly collect or maintain information from persons under 18 years of age. If you are under the age of 18, please do not provide us with any personal information or use the FAIM Services. If you are a guardian of a child under the age of 18 and become aware that your child has provided personal information to us, please contact support to request reviewing or removing any information stored.

13. Transfer to Other Countries

Our company operates from Finland, and our data is stored in EU. You understand that your information may be transferred to and stored outside of your area. The country your information is transferred to might not have the same protection laws as your country of residence. However, if we do transfer your information, we will make sure that we protect your personal data in accordance with the GDPR requirements and set up contracts with those parties to ensure this.

14. Other Applicable Terms

To review other applicable terms and conditions that apply to this Privacy Policy, including, without limitation, intellectual property rights, disclaimer of warranties, limitation of liability and resolving disputes, please review the Terms of Service, the Subscription Terms of Service and the Distribution Agreement.

15. Amendments and Modifications

This Privacy Policy may be updated from time to time in order to reflect the changes in data processing practices or otherwise. We reserve the right, at its sole discretion, to update, amend and/or change this Privacy Policy without prior notice and at any time. Up-to-date version of this Privacy Policy will be held on the Website. You are encouraged to revisit this Privacy Policy from time to time in order to review any changes that have been made. We will not substantially reduce your rights under this Privacy Policy without providing a notice thereof. Any notice will be provided by either displaying a notice within the FAIM Services or by sending you an e-mail. You have a right to lodge a complaint with a competent data protection authority if you consider that the processing of your personal data infringes current legislation. However, we request that the matter will be dealt with us in the first instance. The relevant authority in Finland is the Data Protection Ombudsman ( If you object to the updated Privacy Policy, please contact support to request termination of your account and discontinue using the FAIM Services.

16. Questions and Concerns

The data subject has several rights under applicable data protection laws.

Right of access and right of inspection.You have the right to obtain confirmation as to whether or not personal data concerning you is being processed. You have the right to inspect and view data concerning you and, upon a request, the right to obtain the data in a written or electric form. This applies to information that you have provided to us insofar the processing is based on a contract/consent.

Right to rectification and right to erasure.You have the right to demand the rectification of incorrect personal data concerning you and to have incomplete personal data completed. You have the right to require us to delete or stop processing your personal data, for example where the data is no longer necessary for the purposes of processing. However, please note that certain personal data is strictly necessary in order to achieve the purposes defined in this Privacy Policy and may also be required to be retained by applicable laws.

Right to data portability. You have the right to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format and, if desired, transmit that data to another controller. The right to data portability applies on the processing of the personal data based on consent or a contract.

Right to restriction of processing. You have the right, under conditions defined by data protection legislation, to request the restriction of processing of your personal data. In situations where personal data suspected to be incorrect cannot be corrected or removed, or if the removal request is unclear, we will limit the access to such data.

Right to object to processing.You have the right to object to the processing of your personal data where we are relying on legitimate interests as the legal ground for processing. For example, you may object to your personal data being used for marketing purposes.

Right to withdraw consent.In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time.

Don’t hesitate to contact our helpful support.