What happens to the fan emails a download gate collects, who decides it, and how an artist gets the whole list back.
When a fan gives their email address to a download gate, the artist who created that gate decides why it was collected and what happens to it next. In data-protection terms the artist is the controller and Otocracy Group OÜ is the processor: we run the gate, store the list and send the mail the gate promises, on the artist’s instructions.
For our own site — visitors to otocracy.com, people who contact us, customers of our campaign services — we are the controller, and the privacy policy covers that.
Per fan, per gate:
No names, no phone numbers, no payment details, no advertising profile. A fan never makes an account and is never asked for anything beyond the address.
A gate collects nothing until the fan types their address and submits it, and it delivers nothing until they click the link in the confirmation mail. That double opt-in is the record of consent, and it is stored with its timestamps.
Every mail sent to a fan carries a one-click unsubscribe. An unsubscribed address stops receiving mail immediately, and stays on a suppression list so that it cannot be re-subscribed by a later import.
We process fan data only to:
We do not sell fan data. We do not rent, share or license it. We do not merge one artist’s fan list into another’s, and we do not mail an artist’s fans on our own behalf or about anything other than the download they asked for. Nothing about an artist’s own numbers is metered, withheld or charged for.
An artist can put their own Meta, TikTok or Google tag on their own gate. Those tags fire in the fan’s browser and send data to that platform under the artist’s account, not ours — for that data the artist is the controller and the platform is their processor. An artist who switches one on is responsible for disclosing it in their own privacy notice. We add no advertising or profiling tag of our own to a gate page.
These are the services that necessarily touch gate data. Each one is used for the single purpose named.
Where a sub-processor operates outside the EEA, the transfer runs on that provider’s Standard Contractual Clauses. We will name any new sub-processor here before it starts processing gate data.
Fan records live as long as the gate does. An artist can delete a gate, and can ask us to delete a single fan record or their entire list at any time; we act on that within 30 days, and unsubscribe suppression entries survive deletion precisely so that a deleted address is not mailed again by accident.
A fan can exercise the same rights directly — access, correction, deletion, or a copy of their record — by writing to office@otocracy.com. We answer them ourselves rather than sending them to the artist.
Fan data is held in an access-controlled database; the audio sits in a private bucket that is only ever served through short-lived signed links, never a public URL. Access is limited to the people who operate the platform. Transport is TLS throughout.
If we become aware of a breach affecting an artist’s fan data, we will tell that artist without undue delay, with what we know and what we are doing about it, so that they can meet their own notification duty as controller.
An artist can export their full fan list as CSV at any time, free, with no cap and nothing to upgrade. If an artist stops using Ōtocracy, they take the list with them and we delete our copy on request. There is no lock-in mechanism here, by design: the whole argument of the product is that an artist’s own audience is not something to be rented back to them.
Otocracy Group OÜ, Sepapaja tn 6, 15551 Tallinn, Estonia. Registry code 17554151.
Data protection questions, deletion requests and breach notifications: office@otocracy.com.
This page describes how the platform actually processes gate data. It is not legal advice and is not a signed data-processing agreement. An artist whose own obligations require a countersigned DPA should write to us and we will put one in place.