INFORMATION ON THE PROCESSING OF PERSONAL DATA

(Art. 13 of the EU EUROPEAN REGULATION 2016/679 – GDPR)

Dear Sir/Madam,

LUCID TUNES LTD wishes to inform you that the EU Regulation 2016/679 (GDPR) elevates the processing of personal data to the object of protection in order to ensure the protection of the rights and freedoms of natural persons. In compliance with the indicated legislation, the processing is based on the principles of fairness, lawfulness and transparency, minimization, limitation of storage and purpose of the same to protect your privacy and your rights. Information in accordance with Article 13 of the GDPR regarding the Hums app is provided below. Hums is a mobile application available on Android and iOS platforms. The app allows users to connect with others via a map-based interface to share and request personalized song recommendations. It emphasizes human interaction over algorithmic playlists, creating a unique, social music-sharing experience. Users can filter preferences, explore other profiles, and engage through chats, song collections, and requests.

DATA IDENTIFYING THE DATA CONTROLLER

LUCID TUNES LTD – Registered office at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX. You may contact the Data Controller at the e-mail address: legal@humsmusic.com to exercise the rights recognized by the GDPR and to know the updated list of all Data Processors.

PURPOSE OF PROCESSING

The personal data you provide, as a data subject, will be processed in accordance with current legislation and, subject to confidentiality obligations, exclusively for purposes related to the services provided with the Hums app by our company and in particular for:

  • Authentication
    • Sign-Up: Users can create an account using their email, a password, and a username. They may optionally upload an avatar; 
    • Onboarding: After sign-up, users select 1–10 favourite music genres; onboarding is mandatory and must be completed before accessing the app Hums;
    • Login: Users authenticate via email and password.
  • Map Functionality
    • View other users as pins, categorized by online and offline statuses (offline users appear dimmed).
    • Filter users based on: Status: listener or tune gurus; Music genres: filter users sharing similar interests; Location: users can search specific geographic areas;
    • Access user details such as username, avatar, and favourite genres;
    • Interact with users; 
    • Upon app launch, the user is prompted to grant location access; 
    • Users can view and interact with others globally without geographic restrictions.
  • Notifications
    • Displays songs shared with the user, allowing them to: Like or dislike the song, Add the song to their favourites, Preview or listen to the full song on Spotify, Apple Music, or YouTube Music (redirected to the selected platform; 
    • “Copy to clipboard” functionality enables manual song search.
  • My Collection
    • Displays all songs added from Spotify, YouTube Music, or Apple Music or favourited/liked tune recommendations from other users; 
    • Search functionality for easy retrieval; 
    • Manage songs: Mark/unmark as favourite; 
    • View and manage requests.
  • Messages
    • Access and manage chats with other users;
    • Send text-only messages (255-character limit);
    • Review and accept/reject new chat requests;
    • Delete chat history.
  • Music Integration
    • The app integrates with Spotify, Apple Music, and YouTube Music for seamless music experiences; 
    • If a song isn’t available on a specific platform, Users can switch to another platform or copy the artist and song name to the clipboard for manual search.
  • Other processing required by current regulations and/or necessary for the performance of the service request;
  • Administrative purposes, for obligations arising from civil and tax regulations;
  • Soft-spam activities i.e., the sending of promotional, through only the e-mail address to be provided by the User, for direct sales of services provided by the Owner similar to those of the Hums app or to mark third-party events. 

LEGAL BASIS OF PROCESSING 

The Legal Basis of the above processing is the performance of a contract (Art. 6.1.b), legal obligation (Art. 6.1.c) and the consent of the data subject as provided in Art. 6.1 [a] GDPR.

PROVISION OF DATA

The provision of data (username and email or favourite music genres) is mandatory for the purposes of the operation of the Hums app and related services. Refusal to provide the data will result in non-performance of the contract or operation of the Hums app. Data related to Map Functionality, Notification or Messages are not mandatory, but failure to provide them will result in the inability to use these features and thus a reduced experience on the usability of the Hums app.

The provision of data for soft-spam activities is totally free and is subject to your specific consent; if you do not provide consent the only consequence will be the impossibility for LUCID TUNES LTD to process your data for soft-spam purposes.

COMMUNICATION AND DISSEMINATION OF PERSONAL DATA

The personal data you provide may be processed and known by staff and collaborators of our Company, specifically authorized to process such data, for the sole purposes described above. These individuals will also process the data in accordance with Articles 5 and 6 of the GDPR, in a lawful and correct manner and limited to what is necessary to carry out their work duties.

Your personal data may also be disclosed for the above purposes to:

  • External Professionals or Consultants in case the consultancy is strictly necessary for the performance of the requested service;
  • Third-party service providers in order to follow up on the service you have requested; specifically, right now this is the list of third-party services connected to or utilized by the app Hums:
    • YouTube: Integration for accessing and sharing music tracks from YouTube;
    • Spotify: Integration for accessing and sharing music tracks from Spotify;
    • Apple Music: Integration for accessing and sharing music tracks from Apple Music;
    • Google Maps: Provides location-based functionalities, including geocoding and mapping features;
    • Expo: Used for managing push notifications to deliver updates and alerts to users in real time;
    • MailTrap: Email service for sending transactional emails to users;
  • Public Administrations where communication is required by law.

The data will not be further communicated or disseminated.

TRANSFER OF DATA

Personal data will be transferred to United Kingdom since the headquarters of LUCID TUNES LTD is in that country to which there is Commission Implementing Decision (EU) 2021/1773 of June 28, 2021 pursuant to Directive (EU) 2016/680 of the European Parliament and of the Council on the adequate protection of personal data by the United Kingdom. 

There is, in addition, a residual possibility of data transfer to non-EU countries; in each case, appropriate technical and organizational security measures have been taken in addition to the verification of the lawfulness of the transfer due to either the signing of contracts in accordance with Article 28 GDPR with standard contractual clauses in accordance with the currently applicable decision of the European Commission on protection clauses or the adequacy decision adopted by the European Commission.

DATA STORAGE

We would like to inform you that the personal data we collect are stored using technical and organizational methods appropriate to ensure the level of security with respect to the risk taking into account the state of the art, the nature, object and context and purpose of the processing, as well as the risk of varying likelihood and severity to the rights and freedoms of individuals. Each data is kept for the time necessary to fulfil obligations arising from contracts, laws and regulations and for possible inspections and in any case until the deletion of the account for everything related to the profile, preferences and playlists, etc.; while for data whose retention is mandatory, they will be kept for an indicative maximum time of ten years from the termination of the contract or the cancellation of the user. In the event that the Data Controller wishes to process your data for additional purposes and which have not been contemplated here, you will be expressly asked for your consent before such processing.

With regard to consent, the data will be kept until the consent is revoked.

DATA PROTECTION RIGHTS

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also request that we delete personal information that we hold about you.

You can object to processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information; if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

You also have the right to lodge a complaint with a Data Protection Authority about our collection and use of your personal information, in particular in the Member State in which you habitually live or work or in the place where the alleged violation took place.

Requests to the Data Controller for the exercise of the above rights should be addressed to email: legal@humsmusic.com.

Update to: March 2025

Consent to the processing of personal data (Art. 13 EU Regulation No. 2016/679)

Having read the extended information pursuant to Article 13 of EU Regulation No. 2016/679 on the processing of 

personal data, with regard to the purposes indicated above in the aforementioned notice, I hereby declare, with 

respect to:

Direct marketing activities, i.e. receiving, via automated means such as email or phone calls from one of our representatives, informational, promotional, commercial, and advertising materials or information regarding events and initiatives by 

LUCID TUNES LTD