DRAFT — NOT PUBLICATION-READY. This text describes the website features identified in the current project. Hosting settings, provider contracts, cookies, analytics, transfers and retention must be confirmed before launch.
1. Controller and scope
The Agency Milovanović (TAM), a Swiss-based artist agency with INTIMATE events and Shared Pulse Records, is responsible for the personal data it processes. Controller / proprietor: [INSERT full legal name]. Address: [INSERT full Swiss business address]. Privacy contact: [INSERT confirmed email]. This policy concerns this website and enquiries sent to TAM; third-party platforms apply their own privacy policies.
2. Website visits and hosting
The website is built and hosted with Framer. Delivering pages and protecting the service may involve technical information such as IP address, request time, requested page, browser/device details and diagnostic or security logs. [CONFIRM the precise data, Framer contracting entity, hosting locations, subprocessors, role allocation and retention using the current service documentation and agreement.] Do not treat these categories as a verified inventory of stored logs.
3. Contact enquiries and communication
When you contact TAM using an email or booking link, TAM receives the details you provide, which may include your name, email address, organisation and message or booking information. These details are used to answer your enquiry, discuss artist representation, events or releases, and manage any resulting business relationship. Please do not send unnecessary sensitive personal data. [CONFIRM the email provider, access arrangements and whether any enquiry forms are enabled before launch.]
4. Artist information and media
Artist profiles display names, biographies, portraits, genres, release information, videos and social or music links. This information is used to present the artists and their work. [CONFIRM the source, permission or other justification for publishing each artist’s personal data and media, and the process for corrections or removal requests.]
5. External music and social platforms
The website links to SoundCloud, Spotify, Beatport, Resident Advisor, Instagram and YouTube where provided in artist content. Following an external link takes you to a separate service, which may receive technical information and process data under its own privacy policy. TAM does not control those services. The presence of a link does not by itself mean that the platform’s player or tracking technology is embedded on this website.
6. Videos, artwork and embedded media
The project includes uploaded videos delivered through Framer’s asset service and externally hosted artwork, including SoundCloud artwork. Loading an external asset can disclose your IP address and request information to its host. Media components can also display third-party players when configured with supported media URLs. Such players may connect to their provider and use cookies or similar technologies. [CONFIRM every active embed, provider, loading behaviour, data flow and any consent requirement before publication; identify the relevant provider policies and implement blocking before consent where required.]
7. Cookies, analytics and preferences
No specific analytics or advertising tool is confirmed by this draft. This is not a statement that the live site uses no cookies or tracking. [AUDIT Framer site settings, custom code, browser storage, network requests and third-party media on the live site. Confirm whether Framer Analytics or any other measurement is enabled, which cookies or similar technologies are used, their purposes, providers and lifetimes.] Where required, obtain consent before loading non-essential technologies and provide an accessible way to withdraw it. Do not publish claims about cookie-free operation or analytics until verified.
8. Purposes and applicable legal grounds
Processing must comply with the Swiss Federal Act on Data Protection (FADP), including proportionality, transparency and purpose limitation. Depending on the activity, processing serves website delivery and security, responding to requests, preparing or performing agreements, presenting artists and meeting legal obligations. Where a justification is required under Swiss law, it must be established for the specific processing. If the GDPR applies, relevant grounds may include steps requested before a contract or contractual performance (Article 6(1)(b)), legal obligations (6(1)(c)), legitimate interests subject to a balancing assessment (6(1)(f)), or consent where required (6(1)(a)). [CONFIRM territorial applicability and map each actual processing activity to its applicable ground.]
9. Recipients and international transfers
Data may be accessible to authorised personnel and the hosting, email or media providers used for the relevant service. [CONFIRM the actual providers, processor agreements, recipients and destination countries.] Where data is transferred outside Switzerland, or outside the EEA when the GDPR applies, assess the destination and use an applicable adequacy decision or other lawful safeguards, such as approved standard contractual clauses with necessary adaptations and supplementary measures. [INSERT actual transfer arrangements and how to obtain information about safeguards.]
10. Retention and security
Personal data should be kept only for as long as necessary for its stated purpose, subject to applicable legal retention duties and the establishment, exercise or defence of claims. [INSERT confirmed retention periods or criteria for enquiries, correspondence, artist records, contracts, technical logs and backups, and the deletion process.] TAM should use appropriate technical and organisational safeguards proportionate to the risks. [CONFIRM actual security and access controls; do not claim measures that have not been implemented.]
11. Your privacy rights
Subject to the applicable law and its conditions, you may request information or access, correction, and deletion of personal data. Where the GDPR applies, rights may also include restriction, objection and data portability; you may withdraw consent for future processing without affecting the lawfulness of earlier processing. Swiss law also provides data portability in specified circumstances. Requests may require proportionate identity verification and may be limited by legal duties or third-party rights. Contact [INSERT privacy email]. You may contact the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, where applicable, lodge a complaint with the competent EU/EEA supervisory authority.
12. Review and information to confirm
Before launch, complete the controller’s identity, address and contact details; confirm hosting/email providers, active media embeds, cookies and analytics, recipients and transfer safeguards, retention schedules, rights-handling procedures and whether an EU/EEA representative is required. Review the final policy against the actual deployed website and obtain qualified legal advice. Effective date: [INSERT date after review]. Update this policy when relevant processing changes.