Legal information.

01Who We Are and Where This Policy Applies

Donaldson Music Group (DMG) is an independent South African music administration, publishing and record label Solutions company, headquartered in Seshego, Polokwane, Limpopo. DMG acts as the parent company of a group of music-related subsidiary companies and brands (together, the “DMG Group”).

This policy applies to our website (the “Site”), our demo submission form, the Roster Portal, and every other website, platform, form or portal operated by DMG or any DMG Group company that links to this page. Subsidiary companies do not need to publish their own privacy policy. By linking to this page, a DMG Group company adopts this policy, and DMG and that company will handle your personal information in line with it.

We process personal information in accordance with the South African Protection of Personal Information Act 4 of 2013 (POPIA) and other applicable data protection laws.

02Information We Collect

We may collect the following types of information:

Personal Information: This includes information that can identify you as an individual, such as your name, email address, phone number, billing information, and any other information you provide voluntarily when you interact with our Platforms (for example, through forms, sign-ups or purchases). Depending on how you deal with us, it may also include:

• your stage name, legal name and WhatsApp contact number;
• links to your music, cloud storage folders and public profiles (such as Facebook, Spotify and YouTube);
• information about the music you create, including ownership, composer and split details;
• banking and payment details needed to pay royalties and process transactions;
• identity, tax or other documents we are legally required to hold; and
• the content of your communications with us, including email and messaging apps such as WhatsApp.

Non-Personal Information: This includes data that does not identify you personally, such as your browser type, device type, IP address, language preferences, referring URLs, and other technical details automatically gathered when you access our Site.

Cookies and Similar Technologies: We use limited cookies and similar technologies. Section 10 explains this in detail.

Information from Third Parties: We may receive information about you and your music from digital service providers, collecting societies, distribution partners and other rights organisations where this is needed to deliver our Solutions.

03Demo Submissions

When you submit music to our curation team through our online form, we collect your stage name (optional), legal full name, WhatsApp number, email address, a link to your music in cloud storage, your Facebook profile or page link, and, optionally, your Spotify and YouTube links.

We use this information to review your music, verify your online presence, contact you about your submission and, where we offer a deal, to begin onboarding. Submissions are received through Google Forms and stored in Google Sheets and email tools used by our team. Google acts as a third-party provider on our behalf, and your information may therefore be stored on servers outside South Africa (see section 8).

Please only share links you are happy for our team to open, and do not include identity numbers or banking details in a submission. By submitting, you confirm that the contact details are yours and that you own or control the rights to the music you share. Submitting music does not guarantee a deal.

If your submission is not taken forward, we may keep your details for a reasonable period for record-keeping and to avoid duplicate submissions. You may ask us to delete them at any time, subject to applicable law.

04The Roster Portal

The Roster Portal is a secure platform for artists and labels who have been invited to join the DMG roster. It is operated separately from the Site, but this policy also applies to it, together with any terms in your agreement or on the Portal itself.

Through the Roster Portal, we may process your account details (such as your name, email address, phone number, stage name and company), login credentials, contract and rights information, catalogue and release details, royalty statements and payment details, documents you upload or download, messages to our team, and technical logs such as your IP address, device and the time of access.

We use this information to administer your agreement, deliver releases and rights management, report and pay royalties, provide documents, offer support, and keep the Portal secure and free from fraud.

You are responsible for keeping your login details confidential. Please tell us immediately if you believe someone has accessed your account without permission.

05How We Use Your Information

We use the information we collect for the following purposes:

• To provide and improve our Solutions and products.
• To review and respond to music submissions.
• To administer publishing, distribution, label and representation arrangements, including contracts, rights registration, reporting and royalty payments.
• To operate the Roster Portal and give you access to your account and documents.
• To communicate with you, including responding to inquiries or providing support.
• To send you marketing communications (if you have opted in to receive them).
• To monitor and analyse trends and usage to improve the functionality of the Site.
• To detect, prevent and investigate fraud, misuse and security incidents.
• To comply with legal obligations or protect our rights and interests.

06Lawful Grounds for Processing

We only process personal information where the law allows us to. Depending on the situation, we rely on one or more of the following grounds: your consent; the need to conclude or perform a contract with you; a legal obligation that applies to us; or our legitimate interests, or those of a third party, where these are not outweighed by your rights. Where we rely on consent, you may withdraw it at any time.

07How We Share Your Information

We do not sell or rent your personal information to third parties. However, we may share your information in the following circumstances:

Third-Party Providers: We may share your information with trusted third-party providers who help us operate our Platforms, for example website hosting, cloud storage, form handling, email and productivity tools (such as Google Workspace and Zoho), payment processing and customer support. These providers are obligated to protect your data and may only use it for the purposes for which it was shared.

Industry Partners: We may share the information needed to deliver our Solutions with digital service providers, distribution partners, collecting societies and rights organisations.

DMG Group Companies: We may share information with other companies in the DMG Group, in line with this policy.

Legal Requirements: We may disclose your information if required to do so by law or in response to a legal request (for example, a subpoena or court order) or if we believe such action is necessary to comply with legal obligations, protect our rights, or prevent fraud or illegal activities.

Business Changes: If DMG or a DMG Group company is involved in a merger, acquisition or sale of assets, your information may be transferred as part of that transaction, subject to this policy.

08Transfers Outside South Africa

Some of our providers and industry partners are located outside South Africa, and music distribution is global by nature. Where we transfer your personal information to another country, we take reasonable steps to ensure it is protected to a standard comparable to the protection it receives under South African law.

09How Long We Keep Your Information

We keep personal information only for as long as it is needed for the purposes described in this policy, including to perform our contracts, keep accurate rights and royalty records, and meet legal, tax and accounting requirements. When information is no longer needed, we delete or de-identify it.

10Cookies and Similar Technologies

Cookies are small text files stored on your device when you visit a website. Similar technologies, such as browser storage, work in a comparable way. They can make a website work, remember your choices or help the owner understand how it is used.

Our Site: At the time of writing, our Site does not use advertising or analytics cookies. It may use strictly necessary technologies, such as browser storage, to work properly and keep it secure.

The Roster Portal: The Roster Portal uses cookies and similar technologies that are necessary to sign you in, keep your session active and protect your account.

Third parties: Our Site loads fonts from Google Fonts, which means Google may receive technical information such as your IP address and browser details. Our hosting provider may also record technical information, such as IP addresses and requests, in server logs for security and performance. When you follow links to third-party sites, such as social media platforms, those sites may set their own cookies, which are covered by their own policies.

The types of cookies we may use are:

• Strictly necessary: needed for the Site or Portal to work and stay secure. These do not need your consent.
• Functional: remember choices you make, such as your preferences.
• Analytics: help us understand how the Site is used. We do not currently use these.
• Advertising: used to show relevant adverts. We do not use these.

You can control or delete cookies through your browser settings. Blocking strictly necessary cookies may stop the Roster Portal from working properly. If we introduce analytics or other non-essential cookies in future, we will update this page and, where the law requires, ask for your consent first.

11Data Security

We take the security of your personal information seriously and use reasonable physical, electronic, and administrative safeguards to protect it. However, please note that no method of data transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security. If we become aware of a security compromise that affects your personal information, we will notify you and the Information Regulator as the law requires.

12Your Rights and Choices

You have certain rights regarding the information we collect about you:

Access and Update: You may access and update your personal information by contacting us or through your account settings on the Roster Portal.

Opt-Out: You can opt out of receiving marketing emails by following the unsubscribe instructions in the email or by contacting us directly.

Delete Your Data: You may request that we delete your personal data, subject to applicable legal obligations.

Object or Restrict: You may object to, or ask us to restrict, certain processing of your personal information, and you may withdraw any consent you have given.

Complain: If you believe we have not handled your personal information properly, please contact us first so that we can put it right. You also have the right to complain to the Information Regulator (South Africa) at inforegulator.org.za.

13Children’s Privacy

Our Platforms are not intended for children under the age of 18, and we do not knowingly collect personal information from children without the consent of a parent or legal guardian. If you believe we have inadvertently collected information from a child, please contact us so that we can delete the information.

14Third-Party Links

Our Platforms may contain links to third-party websites. We are not responsible for the privacy practices or the content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

15Terms and Conditions

Our Terms, Standards and Code of Conduct are available through the Terms link in our website footer. Together with your agreement with us, they set out the terms on which we provide our Solutions. If there is any difference between them and a signed agreement with us, the signed agreement applies.

16Changes to This Page

We may update this page from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we update it, we will post the updated version here and update the “Last updated” date at the bottom of this page.

17Contact Us

If you have a question about this page, or want to exercise any of your rights, please reach out through our Contact page. Please mention the DMG Group company or platform your question relates to, so that we can respond quickly.