Privacy Policy

Privacy Policy SYYK

As of September, 2022

1. SUBJECT MATTER AND SCOPE OF APPLICATION

We take the protection of your personal data very seriously. With this Privacy Policy, we inform you which personal data we collect and how and for what purposes it is processed. We always treat your personal data in accordance with the statutory data protection regulations and this Privacy Policy.

2. CONTROLLER AND DATA PROTECTION OFFICER

Controller is Steyoyoke Recordings, Dottiest. 7, 10367 Berlin. Email: nft@steyoyoke.com (hereinafter „SYYK“).

3. VISITING OUR WEBSITE

3.1 Log Files

Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer. The following data is logged:

· IP address of the calling computer

· Operating system of the calling computer

· Browser version of the calling computer

· Name of the retrieved file/website

· Date and time of retrieval

· Transferred amount of data

· Referring URL

This data is processed in order to be able to present the website, to ensure the security, availability and integrity of the website (e.g., detection and defense against DoS attacks or access by bots), to improve the quality and presentation of the website, to be able to identify and correct errors and for statistical purposes.

This data is regularly deleted after a few days .

Our website is hosted by a service on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country outside the EU without an adequate level of data protection. We provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Binding Corporate Rules and/or Standard Contractual Clauses) upon request.

The legal basis for this data processing is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the above purposes.

3.2 Content Delivery Network

We use a Content Delivery Network (CDN) to increase the security and delivery speed of the website and the Platform. A CDN is a network of servers distributed worldwide that is capable of delivering optimized content to users. For this purpose, personal data may be processed in server log files of the CDN.

The provider of the CDN acts as a data processor for us on the basis of a data processing agreement pursuant to Art. 28 GDPR.

Since a CDN represents a network of servers distributed worldwide, the use of a CDN may result in the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is to increase the security and delivery speed of the website and the SYYK Platform.

4. CONTACT AND CRM

If you contact us, e.g. by e-mail, via a contact form or via live chat, the information you provide will be stored for the purpose of processing the request.

We need the information requested in a contact form or live chat to process your request, to address you correctly and to send you a reply.

The legal basis for this data processing is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the communication with prospects, visitors and customers. If the purpose of the contact is to conclude a contract, the additional legal basis for processing is Art. 6 (1) lit. b) GDPR.

Inquiries and customer relations are regularly stored and processed in our CRM system. The legal basis for this storage and processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the marketing of our products and services and the maintenance of our prospect and customer relationships.

5. OPENING AN ACCOUNT

Users of SYYK’s web-based and/or mobile application (hereinafter “Platform”) may buy and sell NFTs. Via the Platform, sellers/creators may manage their NFT shop and their NFT offerings and Acquirers may purchase NFTs and manage their purchased NFTs.

5.1 Platform

The hosting of the web-based application takes place with a service provider on the basis of a data processing agreement pursuant to Art. 28 GDPR.

With regard to the use of a content delivery network (CDN) to increase the security and the delivery speed of the platform, reference is made to the statements above regarding the website.

5.2 Registration and Opening of an Account

To use the platform, you must register as a user and open an account. The data requested as part of the registration as a user is required by us to set up your account.

Registration takes place either via an e-mail with a Magic Link or by means of a link to your non-custodial wallet.

The registration will be confirmed to you by e-mail.

For sending the e-mail with the magic link, we use a service provider as a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This data processing may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

You can provide further personal data in your account on a voluntary basis. However, this provision of further data is not mandatory for the use of the platform.

6. NFTS

6.1 LICENSING AND ACQUISITION OF NFTS

After successfully opening an account, Creators may transfer usage and distribution rights to NFTs to SYYK via the Platform.

Acquirers may acquire NFTs from SYYK via the Platform.

During these transactions, the data required for the respective transaction is processed.

The ownership information on the individual NFTs is stored on the blockchain and the acquired NFT is linked and visible in the user’s respective crypto wallet.

It is possible that individual NFTs are linked to certain additional services defined as part of the purchase of the NFT, so-called “Rewards”, this can be, for example, a VIP ticket for a concert or a “Meet and Greet”. In the context of providing the Rewards, further personal data of the User may be required for the performance of the contract.

The legal basis for data processing in the case of licensing and acquisition of NFTs is in any case Art. 6 (1) lit b) GDPR (necessity for the performance of the contract).

6.2 PAYMENT PROCESSING

When purchasing NFTs, payments can be made by credit card via Stripe and by cryptocurrencies via Coinbase (“Payment Service Providers”).

Data processed by the Payment Service Providers may include inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and information about the respective purchase.

The processing of this data is necessary to perform the transactions with the respective payment service provider. The data entered is processed exclusively by the respective selected payment service provider. We do not receive any account- or credit card-related information, but only the information whether a payment was made or not.

The data protection information of the respective payment service provider, which is available on the website or in the app of the respective payment service provider, applies to data processing in the context of payment processing.

7. NEWSLETTER

7.1 Registration

On our website, you can register to receive a newsletter by e-mail. During registration, the data from the input mask, the IP address of the calling computer and the date and time of registration are transmitted to us. For the processing of the data, your consent is obtained during registration and reference is made to this Privacy Policy.

In order to verify that a registration for the sending of a newsletter is made by the actual owner of an e-mail address, we use the so-called “double opt-in” procedure. In this process, after registration of an e-mail address, a confirmation e-mail is sent to the registered e-mail address. Registration for the newsletter is only completed when a confirmation link contained in the confirmation e-mail is activated. The IP address of the calling computer and the date and time of activation of the confirmation link are also transmitted to us.

The registration for the newsletter can be terminated at any time by using the unsubscribe link contained in each newsletter or by contacting us at the above contact details.

The legal basis for the processing of data after registration for the newsletter is your consent pursuant to Art. 6 (1) lit. a) GDPR.

7.2 Email Newsletter for Existing Customers

If you register as a user of our app and provide your e-mail address, this may subsequently be used by us to send you an e-mail newsletter if you have not objected to such use. In such a case, the email newsletter will only be used to send direct advertising for our own similar goods or services. You can object to the use of your e-mail address at any time, without incurring any costs other than the transmission costs according to the basic rates, by using the unsubscribe link contained in every newsletter or by contacting us at the above-mentioned contact details.

The legal basis for sending the newsletter as a result of the sale of goods or services is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR.

7.3 Newsletter Analytics

A statistical analysis of usage data may be carried out for our newsletters. For this purpose, we may record both the openings of the e-mail and the internal clicks. This information serves the purpose of measuring and optimizing the success of our newsletter campaigns by making the newsletter content more relevant to our target group.

The legal basis for this analysis is your consent pursuant to Art. 6 (1) lit. a) GDPR.

7.4 Newsletter Service Provider

We use an external service provider as a data processor for sending and analyzing our newsletter on the basis of a data processing agreement pursuant to Art. 28 GDPR.

8. COOKIES

Our website uses cookies. Cookies are pieces of information that are transferred from our web server or third-party web servers to your browser and stored there for later retrieval. Cookies may be small files or other types of information storage. Information is stored in cookies that is related to the specific end device used. Cookies contain a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. A cookie also contains information about its origin and the storage period. However, this does not mean that we gain immediate knowledge of your identity.

8.1 Technically Necessary/Essential Cookies

When visiting our website and using the Platform, cookies are set that are absolutely necessary for the operation of the website or the platform. These essential cookies may be, for example, cookies that are required for the display of the website with a content management system, which are used to recognize language settings, or which are used to document whether you have consented to the setting of further (non-essential) cookies or whether you have rejected them.

The technically necessary cookies, including their purpose and storage period or deletion period, are explained to you in our cookie banner, which is displayed when you access the website.

The legal basis for the processing of personal data using essential cookies is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the operation of our website.

8.2 Non-Essential Cookies

We also use non-essential cookies, for example to collect additional information about the interests of visitors to our websites or about their usage behavior, in order to analyze and optimize our website and generally our customer interactions on this basis.

Non-essential cookies, including their purpose and storage period or deletion period, are also explained to you in our cookie banner, which is displayed when you access the website.

Non-essential cookies are only set if you have expressly consented to the setting of non-essential cookies. You can also select different categories of non-essential cookies that you wish to allow in the cookie banner.

The legal basis for the processing of personal data using such non-essential cookies is your explicit consent pursuant to Art. 6 (1) lit. a) GDPR.

9. THIRD-PARTY TOOLS

We use third-party functionalities, plug-ins and tools on the website and as part of the Platform, for example, to expand the functional scope of the website and the Platform, to analyze the use of the Website and the Platform, and to optimize the content accordingly. We explain the third-party tools used below.

9.1 Google Tag Manager

On our website we use the tool Google Tag Manager. Google Tag Manager is provided by Google Ireland Limited in Ireland. Through this tool, website tags can be managed via an interface. Google Tag Manager only implements tags, but no cookies are used, and no personal data is collected. Google Tag Manager triggers other tags, which in turn may collect data, but Google Tag Manager does not access this data.

9.2 Web Analytics

We use web analytics services to understand how our website and our Platform are used by their visitors or users and to optimize the website and the Platform in terms of content and technology.

9.2.1 Google Analytics

We use the web analytics service Google Analytics with IP anonymization. Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”).

JavaScript tags allow us to collect information about your use of the website and the Platform. Google Analytics also regularly uses cookies to collect information about a user’s interactions with the website or Platform.

Within the scope of the use of Google Analytics, your IP address and information about the use of the website or Platform, browser type and version, operating system used, the previously visited page and the time of the server request are transferred to Google servers and processed there.

Within the scope of IP anonymization, the collected IP addresses of users within the European Economic Area are shortened before being transmitted to the USA. Only in exceptional cases, in the event of technical malfunctions in Europe, will the unabbreviated IP address be transmitted to Google in the USA and shortened there. The transmitted IP addresses are not merged with other data from Google.

Google will act for us as a processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

As explained, this may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

9.3 Fonts (Google Fonts)

In order to display the content of our website correctly and graphically appealing across browsers, we use the font library Web Fonts of Google Ireland Ltd. in Ireland (hereinafter “Google”). When you call up a website on which a font library is integrated, the required font is loaded into the browser cache in order to display texts and fonts correctly. In doing so, the operator receives the information that the font required for our website or platform was called up from your IP address.

You can prevent the use of such libraries and the associated data transmission by installing a JavaScript blocker (e.g. www.noscript.net). If the use of Web Fonts is not supported or prevented, a default font will be used by your computer.

Google acts for us as a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPr.

This may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

9.4 Ticketing and Livechat

When creating support tickets and during live chat, the contact data you provide and the other content you provide are collected and processed. In addition, information on the browser, the IP address and the location of the respective user are processed. This processing is carried out for the administration and processing of your support or contact request.

For the ticketing system and live chat, we use a service provider. The service provider acts for us as a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

The legal basis for this storage and processing is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest here is to communicate with the users of our website and the Platform and to provide users with optimal support.

10. SOCIAL MEDIA

10.1 Social Media Buttons

Social media buttons of various social media networks (e.g. Linkedin, Instagram, Twitter and Facebook) are integrated on our website.

If you click on one of these social media buttons, you will be redirected to our pages on the respective social media network. In this case, the provider of the respective social media network receives the information that your browser has accessed the corresponding page of our website, even if you do not have a profile with the respective social media network or are not logged in there. This information (including your IP address) is transmitted by your browser directly to a server of the respective provider. If you click on a social media button and are either logged in to the respective social media network or then log in to the page of the respective social media network, the transmitted information can be assigned to your account with the social media network.

For information on the purpose and scope of data collection and processing by the providers of the respective social media network, the provider identification, a contact option and your rights and setting options for data protection, please refer to the respective privacy policy of the providers of the social media networks.The legal basis for the integration and use of social media buttons is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the marketing of our offers and our website.

10.2 Social Media Pages

We maintain a publicly accessible profile on various social media networks (e.g. Linkedin, Instagram, Twitter and Facebook).

If you visit our social media pages and are logged in to the respective social media network, the provider of the respective social media network can analyze your usage behavior and assign the information collected to your account with the social media network and enrich it there. Even if you are not logged in or if you do not have an account with the respective social media network, personal data may be collected by the provider of the respective social media network, for example your IP address or data collected via a cookie.

The operators of the social media networks can use this data to create user profiles. Based on your user profile, you can then be shown interest-based advertisements both on the websites of the social media network and on other websites.

If you visit one of our social media pages, we are jointly responsible with the provider of the social media network for the collection and processing of your personal data that takes place there. For information on the collection and processing of your personal data that takes place there, we refer you to the privacy policy of the respective social media network.

You can assert your data subject rights in accordance with Chapter III. of the GDPR (right to information, correction, deletion, restriction of processing, data portability, etc.) both against us and against the provider of the respective social media network. In this context, we would like to point out that we can only influence the processing of personal data and the implementation of data subject rights within the framework of our social media pages within the scope of the possibilities made available to us by the respective provider.

The legal basis for our use of social media pages is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the presence and marketing of our products and services on the Internet.

11. JOB APPLICATIONS

We collect and process personal data of applicants for the purpose of processing the application process. If an applicant submits his or her application documents to us electronically, they are processed electronically.

If we conclude an employment contract with an applicant, the data transmitted will be processed in order to carry out the employment relationship in compliance with the statutory provisions. If no employment contract is concluded with the applicant, the application documents will be deleted immediately after completion of the application procedure, provided that deletion does not conflict with any overriding legitimate interest, such as the defence of claims or a preservation of evidence function according to the General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz – AGG).

The legal basis for this storage and processing is the performance of the contract or the implementation of pre-contractual measures pursuant to Art. 6 (1) lit. b) GDPR, in Germany § 26 BDSG.

12. VIDEO CONFERENCES AND WEBINARS

If you participate in a video conference, webinar or online meeting etc. organized by us. (hereinafter “video conferences”) organized by us, we process your personal data in the course of your participation.

When you participate in a video conference, various categories of data are processed. The scope of the data also depends on the data you provide before or during participation in a video conference.

If you participate in a video conference organized by us, you usually have to provide at least a name when registering. However, you can also use a pseudonym. Your IP address will also be processed to enable your participation and login information and device/hardware information will be stored. Your email address and profile picture will also be processed, if provided. If you dial in by phone, your phone number and IP address, if any, will be processed.

To enable participation in the video conference, data from your terminal’s microphone and any terminal video camera and, if you share your screen, information from this “screenshare” is processed. You can switch off or mute the camera or microphone yourself at any time. You always decide yourself whether and which parts of your screen are shared.

Audio and video recordings of the video conference can be made. In this case, MP4 files of all video, audio and presentation recordings are processed. There will always be an indication of the recording if one is made and, if necessary, the explicit consent of the participants to the recording will always be obtained.

You may have the opportunity to use the chat, question or survey functions in a video conference. In this respect, the text entries you make are processed in order to display them in the video conference and, if necessary, to record them.

Insofar as personal data of our employees is processed, § 26 BDSG (German Federal Data Protection Act) is the legal basis for data processing, insofar as German law is applicable to the processing of employee data.

If German law is not applicable to the processing of employee data or if, in connection with participation in video conferences, the processing of personal data is not necessary for the establishment, implementation or termination of the employment relationship, but is nevertheless an elementary component of participation in a video conference, our overriding legitimate interest pursuant to Art. 6 (1) lit. f) GDPR is the legal basis for the data processing. In these cases, our overriding legitimate interest is in the effective implementation of video conferences.

Furthermore, the legal basis for data processing when conducting video conferences is Art. 6 (1) lit. b) GDPR, insofar as the meetings are conducted in the context of contractual relationships or with a view to initiating a contractual relationship (for example, in the case of video conferences with our clients in the context of the implementation of a project or participation in a webinar).

Furthermore, the legal basis for data processing in the context of your participation in a video conference organized by us is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our legitimate interest in these cases is the effective implementation of video conferences.

We use one or more service providers as data processors for the implementation of video conferences on the basis of a data processing agreement pursuant to Art. 28 GDPR.

13. MERGERS AND ACQUISITIONS (M&A)

If we are involved in a restructuring, acquisition, asset sale, merger, financing, transfer of services to another provider, due diligence, insolvency or receivership, your personal data may be transferred to third parties to the extent legally permitted in connection with and as part of the relevant legal process, subject to the basic principles of data protection law.

14. AGE RESTRICTION

This website is not intended or designed for use by children under the age of 16. We do not knowingly collect personally identifiable information from or about anyone under the age of 16.

15. RECIPIENTS OF DATA

Within our company, those internal departments or organisational units receive your data which they need to fulfil their tasks, to fulfil contracts with you if necessary, for data processing with your consent or to safeguard our overriding legitimate interests.

Data will only be passed on to third parties within the framework of legal requirements. We will only pass on your data to third parties if, for example, this is necessary for contractual purposes on the basis of Art. 6 (1) lit. b) GDPR or to safeguard our overriding legitimate interest pursuant to Art. 6 (1) lit. f) GDPR in the effective conduct of our business operations.

Insofar as we use service providers within the framework of the provision of the website and/or Platform or other services, we take appropriate legal precautions as well as appropriate technical and organisational measures to ensure the protection of your personal data.

16. YOUR RIGHTS

You have the rights explained below with regard to the personal data processed by us concerning you:

16.1 Right of Access

You can request information in accordance with Art. 15 GDPR about your personal data that we process.

16.2 Right to Rectification

If the information concerning you is not (or no longer) accurate, you may request a correction in accordance with Art. 16 GDPR. If your data is incomplete, you may request that it be completed.

16.3 Right to Erasure

You may request the erasure of your personal data in accordance with Art. 17 GDPR.

16.4 Right to Restriction of Processing

In accordance with Art. 18 GDPR you have the right to request restriction of processing of your personal data.

16.5 Right to Object to Processing.

You have the right to object at any time on grounds relating to your particular situation to the processing of your personal data which is carried out on the basis of Art. 6 (1) lit. e) or lit. f) GDPR in accordance with Art. 21 (1) GDPR. In this case, we will not further process your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves to assert and exercise or defend against legal claims (Art. 21 (1) GDPR).

In addition, according to Art. 21 (2) DSGVO, you have the right to object at any time to the processing of personal data concerning you for the purposes of direct marketing; this also applies to any profiling, insofar as it is related to such direct marketing.

16.6 Right to Withdraw Consent

Insofar as you have given your consent for processing, you have a right to withdraw your consent pursuant to Art. 7 (3) GDPR.

16.7 Right to Data Portability

You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format (“data portability”) as well as the right to have this data transferred to another controller if the conditions of Art. 20 (1) lit. (a) and (b) GDPR are met.

16.8 Exercise of Rights

You can exercise your rights by notifying the above contact details for the data controller or the data protection officer.

16.9 Right to complain to the Data Protection Authorities

If you believe that our processing of your personal data violates data protection law, you also have the right to complain to a data protection supervisory authority of your choice pursuant to Article 77 of the GDPR.

The data protection supervisory authority responsible for us is the Berlin Commissioner for Data Protection and Information Security, Friedrichtstr. 219, 10969 Berlin.

17. COMPULSORY DATA AND PROFILING

The provision of personal data is neither required by law nor by contract, and you are not obliged to provide personal data, although the provision of personal information is required for the conclusion of a contract to the extent that certain details are required in order to conclude (and perform) a contract.

We do not perform automated decision making, including profiling.

18. INFORMATION SECURITY AND DELETION

We take appropriate technical and organizational measures in accordance with the state of the art to ensure a level of protection for the personal data we process that is appropriate to the risk of the respective processing and to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

Our website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as orders, inquiries or payment data that you send to us.

Our employees receive regular training on data protection and information security and are committed to confidentiality and data protection.

A restrictive rights and roles concept on a “need to know” basis ensures that employees only have access to the personal data they absolutely need to perform their duties.

We adhere to the principles of data avoidance and data economy and only store your personal data for as long as is necessary to achieve the respective purpose of the data processing purposes or as stipulated by the storage periods provided by law. If the purpose of storage no longer applies or if a storage period provided for by law expires, the personal data will be routinely anonymized or deleted in accordance with the statutory provisions.

19. AMENDMENT OF THIS PRIVACY POLICY

We reserve the right to amend this Privacy Policy from time to time so that it always complies with current legal requirements or in order to implement changes to our services in the Privacy Policy, e.g. when introducing new services. Your renewed visit will then be subject to the amended Privacy Policy.

Steyoyoke Recordings

© 2022 Steyoyoke NFT. ALL RIGHTS RESERVED.