Legal

Privacy
Policy.

How we collect, store, use, and protect your personal data — including data processed through advertising platform integrations such as the Google Ads API.

Last updated: 10 October 2026

1. Who we are

ŌTOCRACY (“ŌTOCRACY”, “we”, “us”, or “our”) operates this website and provides music marketing and advertising-campaign management services for recording artists and labels. This Privacy Policy explains what personal data we collect, why we collect it, how we store and manage it, and the rights you have over it.

The service is operated by Otocracy Group OÜ, a private limited company registered in Estonia (registry code 17554151), with its registered office at Sepapaja tn 6, Lasnamäe linnaosa, 15551 Tallinn, Harju maakond, Estonia. See our company details page for full registration information.

We are the data controller for the personal data described here, with one important exception: fan data collected through an artist’s smartlink or download gate belongs to that artist. The artist is the data controller; we process it on their behalf (see section 5 and our data processing terms). If you have any questions about this policy or how we handle your data, contact us at office@otocracy.com.

2. Data we collect

We collect the following categories of personal data:

  • Account & contact data: name, email address, and any details you submit through our forms, audits, or checkout (for example when requesting a campaign or creating a client account).
  • Campaign & artist data: links to your music, release information, artist or label profile details, and the goals you share with us so we can run your campaigns.
  • Roster data: where a label or artist manager holds a roster account, the artist names, links, and release information they add for the artists they represent. The label or manager confirms they are authorised to share it; our data processing terms apply to it.
  • Fan data processed for artists: email addresses and related interaction data that fans submit on an artist’s smartlink or download gate page. This data belongs to the artist (see section 5); we hold and process it only on their instructions.
  • WhatsApp messages: if you contact us via the WhatsApp link on our site, we receive your phone number, your WhatsApp profile name, and the messages you send. That conversation is carried and stored by WhatsApp Ireland Ltd. (Meta) under their own privacy terms, which we do not control. We keep these chats only to answer you and to follow up on what we discussed. If you would rather not use WhatsApp, email works just as well and shares no phone number.
  • Meta lead form data: if you fill in one of our forms on Facebook or Instagram, Meta passes us your name, email address and your answers (your role, when your next release is due, your monthly promotion budget and a link to your music), plus which ad you came from. We use them to prepare your call and to email you about it, and every email has an unsubscribe link. We send our newsletter only if you ticked that box.
  • Advertising-platform data: where you authorize us to manage advertising on your behalf, we access connected accounts (such as Google Ads, Meta, TikTok, and YouTube) through their official APIs. This may include campaign configuration, performance metrics, and aggregated reporting. We only access what is required to operate the campaigns you have asked us to run.
  • Payment data: transactions are handled by our payment processor. We receive confirmation and order details but do not store full card numbers on our servers.
  • Usage & technical data: IP address, browser type, device information, and pages visited, collected through cookies and similar technologies to keep the site secure and improve it.

3. How we use your data

We use personal data to:

  • Provide, operate, and manage the services you request;
  • Set up, run, optimize, and report on advertising campaigns across connected platforms;
  • Communicate with you about your account, campaigns, and support requests;
  • Tell Meta, linked to the form you sent, whether you booked a call, attended it or became a client, so we can see which of our ads work;
  • Process payments and issue receipts;
  • Maintain security, prevent fraud, and comply with our legal obligations;
  • Improve the performance and content of our website.

Our legal bases for processing are the performance of our contract with you, your consent (which you may withdraw at any time), our legitimate interests in operating and securing the service, and compliance with applicable law.

4. Advertising platform integrations

When you connect an advertising account, we use the official APIs provided by those platforms — including the Google Ads API, Meta Marketing API, TikTok Marketing API, and YouTube/Google APIs — strictly to manage the campaigns you have authorized.

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements. We do not sell platform data, use it for advertising unrelated to your campaigns, or allow humans to read it except where necessary to operate the service, for security purposes, or as required by law. You can revoke our access to any connected account at any time from within that platform’s own settings.

Artists and labels use our smartlink and download-gate pages to collect fan email addresses. For that data, the artist (or label) is the data controller and we are the processor: the list belongs to them, we store and handle it only to provide the service they asked for, and we never use it for our own marketing, never sell it, and never share it with other artists. The full terms are in our data processing terms.

  • What is collected: the email address a fan submits, if they submit one, and basic technical data about each visit used for the artist’s or label’s analytics: country and city (worked out from the request; the IP address itself is not stored), device type, operating system, browser, the website the visit came from, the campaign tags on the link, which platform button was tapped, and an anonymous visitor number that changes every day. That number is made without cookies, from a random value we delete after a day, so it cannot follow you from one day to the next or be traced back to you.
  • Release-day notifications: where a fan has left their email for an artist, that artist’s new release can trigger a notification email. Every such email carries a working unsubscribe link.
  • The suppression list: when anyone unsubscribes or an address bounces, it goes onto our suppression list and is not emailed again, across all sending we do. We keep the suppressed address itself precisely so that we can honour the opt-out.

6. How we share data

We do not sell your personal data. We share it only with service providers who help us run the service, and only to the extent necessary:

  • Advertising platforms (Google, Meta, TikTok, YouTube) to deliver your campaigns;
  • Analytics providers (Google, Microsoft) to measure how our website is used, as described in section 8;
  • Infrastructure & hosting providers that store data and run our application on our behalf;
  • Payment processors to complete transactions;
  • Email delivery providers to send the transactional and notification emails described in this policy;
  • Scheduling and customer-relationship tools (Calendly, Cal.com, Attio) to book and manage the calls you ask for;
  • Authorities where disclosure is required by law.

These providers process data under contract and are not permitted to use it for their own purposes.

7. How we store and protect data

Personal data is stored on secured, access-controlled infrastructure. We apply encryption in transit, restrict access to authorized personnel, and retain data only for as long as needed to provide the service, meet legal and accounting obligations, and resolve disputes. When data is no longer needed, we delete or anonymize it. No method of transmission or storage is perfectly secure, but we take reasonable technical and organizational measures to protect your information.

8. Cookies and advertising pixels

We use cookies and similar technologies to keep the site working, to understand how it is used, and to measure our own advertising. What happens on your first visit depends on which country you are visiting from. Our hosting provider derives the country from your IP address; for this purpose we keep only its two-letter code, in the oto_geo cookie described below:

  • Visitors in Germany (and visitors whose country we cannot determine) see a banner that asks for their choice first. Nothing beyond essential cookies runs until they choose.
  • Visitors everywhere else do not see a banner. For them, the analytics cookies (Google Analytics, Microsoft Clarity) and the marketing cookies (Meta Pixel) described below are set by default from the first page.

Wherever you are, you can switch analytics and marketing off, or change or withdraw your choice, at any time through Cookie Settings in the footer of every page (or the small “Cookies” button on pages without that footer). When you switch them off, we stop them and delete their cookies from your browser, and that choice then applies on every later visit, whatever country you visit from. Your choice is kept for six months, after which the rules above apply again.

  • Counting visits, without cookies: we keep a daily tally of how many people opened each page, and which campaign they came from. It sets no cookie, stores no IP address and holds nothing that could identify you: the entry is a number, such as “12 visits to the audit page from Italy today”. This runs whatever you choose below, because it cannot track a person.
  • Google Analytics without cookies (when analytics cookies are off): so that our reports show our whole audience and not only the visitors with analytics cookies on, our server sends a copy of that visit count to Google Analytics 4 (Google Ireland Ltd.) for visitors who have switched analytics off, and for visitors in Germany who have not allowed it (yet). It covers the page you viewed (its address, without any parameters except campaign tags such as utm_source, and its title), the website that referred you (its domain only), the campaign tags in the link you followed, your country, the type of device, browser family, operating system and language, and whether you started or requested a Signal Audit or began a checkout. Nothing is stored on or read from your device for this, and no cookie is set. In place of a cookie, the visit carries a pseudonymous code that our server computes from your IP address and browser details together with a secret key that changes every day and is never stored. Your IP address itself is not sent to Google, no account or email is attached, and because the key changes at midnight (UTC), neither we nor Google can connect your visits on different days. We do this on the basis of our legitimate interest in understanding how our website is used and improving it (Art. 6(1)(f) GDPR). If your browser sends a Global Privacy Control or Do Not Track signal, we do not send this copy, and you can object at any time by writing to office@otocracy.com. When analytics cookies are on (because you allowed them, or by default outside Germany), this stops and Google Analytics measures your visits with cookies instead, as described next. Unlike that measurement, it never involves session replays, advertising or Meta.
  • Essential (always on): login and checkout sessions, security, the oto_consent cookie that remembers your cookie choice (six months), and the oto_geo cookie that holds only your two-letter country code, so the site knows whether to ask first (30 days).
  • Analytics (in Germany only with your consent; elsewhere on by default, and you can switch it off): Google Analytics 4 (Google Ireland Ltd., cookies _ga and _ga_*, up to two years) and Microsoft Clarity (Microsoft Ireland Operations Ltd., cookies _clck and _clsk, up to one year), which show us which pages work and which don’t. With Google signals turned on, Google may add aggregated age, gender and interest estimates for visitors signed in to a Google account who allow ad personalization; we only ever see these as totals, never per person. If you switch analytics off (or, in Germany, until you allow it), no Google Analytics or Clarity cookie is set and Clarity does not run; Google Analytics receives only cookieless signals without identifiers from your browser (Google Consent Mode), plus the cookieless copy of our visit count described above.
  • Marketing (in Germany only with your consent; elsewhere on by default, and you can switch it off): the Meta Pixel and Meta Conversions API (Meta Platforms Ireland Ltd., cookies _fbp and _fbc, 90 days). They tell Meta which of our pages you viewed and whether you requested a Signal Audit, created an account, started a checkout, or paid, together with your IP address and browser details. When you give us your email address in one of our forms (for example to receive a Signal Audit) or complete a purchase, we also send that address, hashed so Meta can only match it to an account it already knows. We use this to measure our Instagram and Facebook ads and to show our ads to people who have visited our site. For the collection and transmission of this data we and Meta are joint controllers; Meta’s own processing is governed by its privacy policy. If you switch marketing off (or, in Germany, until you allow it), none of this is sent.
  • Artist pixels on smartlink and gate pages: an artist may add their own advertising pixel to their smartlink or gate page, so their own ad account can measure their campaign. That pixel is controlled by the artist under the platform’s own terms and only loads after you allow it: on a smartlink, only in the small bar that asks first (“Allow” or “No thanks”); on a gate page, by ticking the consent box when you leave your email. It receives visit events, not the email address you submit. If the artist or label has connected Meta’s Conversions API, the same events (the page view, the platform you tapped, a sign-up) are also sent to Meta from our server on their behalf, with your IP address, browser details and Meta’s own cookie identifiers, so their ads still see them when a browser blocks the pixel. That happens only after you allowed the pixel, and never includes your email address. Your answer is remembered on your device for 180 days. Our own pixel never runs on those pages.

9. Your rights

Depending on your location, you have the right to access, correct, delete, or export your personal data; to object to or restrict certain processing; and to withdraw consent at any time. You may also lodge a complaint with your local data protection authority.

To exercise any of these rights, email us at office@otocracy.com. We will respond within the timeframe required by applicable law.

10. International transfers

Some of our providers may process data in countries other than your own. Where personal data is transferred internationally, we rely on appropriate safeguards, such as standard contractual clauses, to ensure it remains protected.

11. Children

Our services are intended for users aged 18 and over and are not directed at children. We do not knowingly collect personal data from children. If you believe a child has provided us data, contact us and we will delete it.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the date at the top of this page and, where appropriate, notify you. Your continued use of the service after an update means you accept the revised policy.

13. Contact us

For any question about this policy, your data, or to exercise your rights, contact us at office@otocracy.com.

Questions about your data? office@otocracy.com
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