Privacy policy.

01Who we are

subTotem Ltd, registered in England and Wales (company number 17145546), is the data controller for the information described here. That means we're responsible for how it's used and kept.

This policy covers the subTotem website and the subTotem app. For anything about your data, including any of the requests in section 9, email legal@subTotem.com.

02What we collect

What you give us

• Your account: email address, password (stored only as a scrambled hash we can't reverse), display name, username, country and whether your email has been confirmed. If you're a listener and choose to say, the town you're from, picked from a list (you can change or remove it in Settings).
• Signing in with Google: if you choose to, we store that you used Google, the account reference Google gives us, and the email address and name it reports. We never get your Google password.
• Artists: your real name, location, biography, pictures, links, genres, roles, your music and its credits (songwriters, producers and musicians), your diary, events, videos and merch, and your PRS for Music answer and IPI/CAE number if you give one, and the domain you connect to your page, if you connect one.
• Artists being paid: the bank account your earnings go to, as described under Payments below.
• Buying something: your name, email address, the delivery address you give on Stripe's payment page, anything you tell the artist about the order (including messages on your order's page), its tracking, and what you bought. You don't need an account to buy; if you're signed in, the order is also kept with your account.
• Asking to hear when an artist posts to you, if you're outside the UK: your email address, your country and which artist. We use it for one email, when that artist starts posting to your country.
• The waiting list: your name, country, and your email address or WhatsApp number.
• Joining an artist's email list: your email address, whether you said you're 18 or over, and when you confirmed or unsubscribed.
• Your date of birth, the first time you try to message an artist, turn on a fan page, or review an album. We ask once and don't ask for proof. It's used only to check you're old enough (14 for messages, 18 for a fan page, reviews and photos), and whether the extra protections for under-18s apply. You can't change it yourself afterwards, so if it's wrong, email us.
• Managers and labels: who works with which artist, what each artist chose to share, and a record of every change a manager or label makes in an artist's account (when, and what kind of change), which the artist can see. An invitation to someone not on subTotem yet keeps the name and email address the manager gave us, used only to invite them. The same goes for a manager's or label's team: the name and email address of each person they invite, which artists they work on and what they can do there, and the record names which of them made each change. For a label: whether each artist chose to be listed on the label's page, which releases each artist agreed are "Released on" it, the label's playlists, and the release dates it pencils in for its artists, which each artist can see. A demo an artist sends a label: which tracks, their message, and the label's answer, kept so both can see it. A label's roster press kit: which artists it chose, and how often the kit's link has been opened. A showcase is a gig in the host artist's account, like any other.
• Band and team logins: the name and email address of each person an artist adds to their account as a band member or on their team, whether they've joined, what the artist lets them do there, and a record of every change each of them makes (when, and what kind of change), which the artist can see. If an account is handed to someone else, a record of who handed it to whom and when, and, if we did it, why.
• To-do lists: the tasks people on an artist's account, or on a manager's or label's team, add: what needs doing, a note, who it's for, by when, who added it and who ticked it off, kept for 30 days once done, and whether you want the morning email of what's due. Everyone on the list sees its tasks; a manager's or label's teammate sees only those about the artists they work on. Some tasks subTotem adds itself, such as an order to post (by its reference, never the buyer's name) or a demo to listen to, and ticks off once it's done; a list can also keep its own checklist for releases.
• Royalty splits: who is in a track's split, their part and percentage, when each agreed or said no, and, for someone invited who isn't on subTotem yet, the name and email address the artist gave us, used only to invite them. Kept as the record of what was agreed, and for working out payments.
• Files artists send each other: the files, their names and sizes, who sent them to whom, any message, and how often they've been downloaded. They're deleted 30 days after sending, unless one of you marks a file as on a release of yours; then it's kept while that release is up.
• A fan page on subTotem.fans, if you're a Champion aged 18 or over and turn one on: the address you choose, a few lines about you, and which parts you show. It shows your name and picture, and only what you switch on: your town, the playlists you share, the artists you follow or back (never how much), your top artists and tracks over the last 30 days, gigs you have tickets for (the name, date and town, never the venue), and your reviews and photos on albums. Anyone with the link can see it; it isn't listed or searchable on subTotem, and search engines are kept away unless you allow them. It goes offline if you stop being a Champion, and is deleted with your account.
• Reviews and photos on albums, if you're a Champion aged 18 or over and add them: what you write about an album (a one-line summary and the review itself), whether you say you know the artist or were given something by them, and up to four photos on it, each with a caption, with when you added them. They're shown with your name, and a link to your fan page if you have one, where each review has a page of its own.
• Review copies, if you're a Champion aged 18 or over and switch them on: that you want them and the genres you'll take. For each copy an artist sends you: when it was sent, opened and played, and whether you said you'd review it or passed. If you ask for an artist's next releases, that you asked and when; the artist can see it.
• The reviewers you follow, if you follow a Champion's reviews: who and since when, so their new reviews come to What's new. The Champion sees how many people follow them, never who.
• Asking a producer about a service on their page: your name, email address and message. We pass them straight on to the producer by email and don't keep them.
• Anything you write to us, such as a support email.
• Feedback you send from Send feedback: what it's about, what you wrote, a screenshot if you add one, and what the page sends with it, which it shows you before you send: the page you were on, your account, your browser and screen size, and the last error the page hit or the last thing that didn't load, if either happened in the last half hour. We use it to answer you and fix what's wrong, and you can see each one and where it's got to in Settings → Feedback.

What we record as you use subTotem

• Plays and streams: which track you played, when, and whether it counted as a paid stream. This is how artists get paid, so we have to keep it accurate. With each play we also keep the town and country your connection comes from, as our network provider Cloudflare works them out from it — never your IP address, and nothing more precise than a town. A play's town and country are deleted after 400 days.
• Producers' share pages: when you play a preview or open the page of a beat, stem pack or service, we count it once a day, using a one-way scramble of your connection's address and browser with the date, which can't be turned back into either. It's only so the producer can see how many people looked and listened. Kept 400 days.
• Visits to the website: when a public page opens, your browser tells us which page it is and the name of the site you came from, never the page on it. We note the country your connection is in, as our network provider Cloudflare works it out, and whether you're on a phone, tablet or computer. To tell one visit from another we use a one-way scramble of your connection's address and browser with a random value that we replace every day and then delete, so it can't be turned back into either, and can't link you from one day to the next. Neither your address nor your browser is kept. It uses no cookie and stores nothing on your device, and it isn't linked to your account, so we can see how many people came and where they went, never who they are. If your browser sends a Global Privacy Control or Do Not Track signal, we don't count you. It's on subTotem's public pages and the sign-in and sign-up screens, not once you're signed in, and never on a page with a private link in its address.
• How many people are using subTotem right now: while you're signed in and using subTotem (the website open in a tab you're looking at, the subTotem app open or playing music, or subTotem Live open), it tells us so once a minute. All it sends is a random number made for that tab, or for that time the app's open, which isn't stored on your device and is forgotten when you close it, and whether it's the website or which app. Your sign-in comes with it so we can check you're signed in and whether you're an artist, a listener and so on, but we don't keep anything that says who you are: we keep only that random number, where it's from and the kind of account, for ten minutes. We don't know who is using subTotem, it's kept anonymous, and we only ever see totals. If your browser sends a Global Privacy Control or Do Not Track signal, the website doesn't send it; those are browser settings, so they don't reach the apps.
• Playlists you make, and comments you leave on tracks.
• Private messages between you and an artist: what was written, when it was sent and read, and whether either of you has muted, closed, blocked or reported the conversation.
• Push notifications: if you turn them on in the app, the notification token your phone gives us.
• Technical information that arrives with any web request, such as your IP address and browser. We use it to keep subTotem working and to stop abuse, and we don't store it in our database alongside your account.

Payments

When you pay us, we never see or store your card number or your bank details. Payments are handled by Stripe, and you type your details into Stripe's own form or on Stripe's page. All we keep is the reference Stripe gives us for your customer record and your Direct Debit, plus what you're subscribed to and when it renews.

When you buy merch or tickets, you pay the artist. The payment goes through the artist's own Stripe account, on Stripe's page, and subTotem takes a 5% fee from it. We never see your card. Stripe tells us the name, email address and delivery address you gave and that the payment went through, so we can record the order and pass it to the artist.

When you watch an online gig, we note each screen using your ticket: a random code for that browser tab, and when it last checked in. That's so a ticket plays on no more screens than it has places. The notes are deleted after three days. The picture comes from Cloudflare Stream, by a link that only works for a few hours. The artist sees how many are watching, never who.

An online gig is recorded by Cloudflare Stream, which keeps the recording for 30 days. If the artist makes a replay, the cut is kept with subTotem's other files (Cloudflare R2) until they delete it or leave Encore, and it's backed up like everything else. It's the artist's picture and sound; nothing about the fans who watched is in it. Watching a replay works like watching the gig: by a link that only works for a few hours.

If you chat at an online gig, the name you choose and what you say are seen by everyone at that gig, by the artist and by a helper they choose. We keep them for 30 days in case anything is reported, then delete them; they aren't part of the replay. If you report a message, we see the message and that your ticket reported it.

A place in a hang-out room or at a free gig takes your name for the chat, your email address (the link only goes there) and your date of birth. The date of birth is checked against the age limit and not kept. We keep your name and address for 30 days after the room, then delete them; for a free gig, for as long as its replay can be watched with your place, or 30 days after the gig if there's none. The artist sees the name, never the address. A free gig is recorded like any online gig. A room isn't recorded: if it's on camera, Cloudflare Stream's copy is deleted a few minutes after it ends. Its chat works like an online gig's, and the artist can save the room's chat, names and all, and quote it, which the room tells you before you join.

When we pay you, it's different. Artists give us the UK bank account to send their earnings to — the name on it, the sort code and the account number — because we pay artists ourselves rather than through a third party. The sort code and account number are encrypted in our database, and are only ever decrypted to build a payment run. Nobody at subTotem browses them, and the site never shows them back to you beyond the last four digits.

We don't buy data about you from anyone, we don't track you across other websites, and we don't use your data for advertising.

03Why, and the legal basis

UK data protection law says we have to have a reason, in law, for each use. Ours are:

• To provide subTotem — your account, your page, playing music, taking payments, and paying artists what they've earned. Basis: performing our contract with you.
• To count streams and work out payments, including patronage. Basis: performing our contract, and our legitimate interest in paying artists accurately.
• To show artists where their listeners are — towns and countries, and how many come back, as totals, never a list of people. Basis: our legitimate interest, and the artist's, in knowing where to play and whom they're reaching; a town only shows once 3 or more people have listened there.
• To keep subTotem safe — confirming your email, stopping fake accounts, and finding artificial streams. Basis: our legitimate interest in protecting the service and the artists on it.
• To keep private messages safe — using your date of birth to check you're old enough to message an artist, stopping contact details being passed to or from anyone under 18, and looking into a message someone reports. We may also check each message automatically as it's sent, on Cloudflare's own computers (its Workers AI), for serious harm, for signs that an adult may be trying to harm a child, and for a young fan who may be at risk themselves. Nothing goes to another company. A message that looks seriously harmful to or from someone under 18 isn't delivered, and one with warning signs to someone under 18 waits until a person at subTotem has looked at it; a fan who may be at risk is never stopped, and is shown where to get help. The checks never close or ban anyone: a person at subTotem decides. Basis: our legitimate interest in protecting the people who use subTotem, children above all, and our duties under the Online Safety Act.
• To count visits to the website — how many people come, where from and where they go, as totals. Basis: our legitimate interest in knowing how subTotem is used and making it better. It can't tell us who anyone is, and you can opt out with your browser's Global Privacy Control or Do Not Track setting.
• To see how many people are using subTotem at once — totals for the website and each app, by kind of account. Basis: our legitimate interest in knowing how subTotem is used. It can't tell us who anyone is, and on the website you can opt out with your browser's Global Privacy Control or Do Not Track setting.
• To tell you things you need to know, such as a receipt, a failed payment or a change to these policies. Basis: performing our contract.
• To answer your feedback and fix what's wrong, including emailing you when something you reported is fixed. Basis: our legitimate interest, and yours, in subTotem working properly.
• To report plays of PRS members' songs to PRS for Music, once that reporting has started. Basis: our legitimate interest, and the artist's, in songwriters being paid.
• To send you an artist's emails, once you've joined their list and confirmed from the email we send you. Basis: your consent. Every email has a link to unsubscribe.
• To send you news or offers by email. Basis: your consent. You can withdraw it at any time, and every such email has an unsubscribe link.
• To meet our legal duties, such as keeping accounting records. Basis: legal obligation.

04Who else sees it

• Cloudflare — hosts subTotem, and stores our database and your files. When our safety checks on private messages are on, its Workers AI checks them; the models run on Cloudflare's own computers and the messages aren't used to train anything.
• Backblaze — keeps a locked copy of our database and your files in its Amsterdam data centre, so they'd survive anything happening to Cloudflare. A file you delete leaves it after 30 days, as with our other backup.
• Stripe — takes payments and holds the card and bank details you give it.
• Resend — sends our emails, such as confirmation codes and password resets.
• Amazon Web Services — sends artists' emails to the people on their lists, and the email on a release's day to anyone who asked for it, from its London region, and tells us when one bounces or is marked as spam.
• Expo — delivers push notifications to the app, if you've turned them on.
• Google — only if you choose to sign in with it.
• Google Fonts — our pages load their typefaces, and so do our emails in mail apps that show them, so Google receives your IP address when a page loads or such an email is opened.
• GeoNames — not a supplier of anything about you: the list of towns you pick from comes from GeoNames (CC BY 4.0). It's kept on our own site, so choosing a town tells GeoNames nothing.
• YouTube — an artist's video is played from YouTube in privacy-enhanced mode, so YouTube only hears from you if you press play. Once it has played for 30 seconds, we add one to that video's count for the artist; we don't record who watched.
• PRS for Music — plays of songs by PRS members, so songwriters are paid, once that reporting has started.
• A manager or label you work with, if you're an artist: what you choose to share with them, and nothing else. That includes the people on their team they give your account to, within what you share; the record of changes says which of them made each one. A label's public page shows your name, picture and where you're from only if you choose to be listed on it, and a release of yours only if you agree it's on that label. A label's roster press kit, a private link it sends to press and bookers, shows what your own press kit shows (your picture, one-liner, short bio, chosen tracks and a link to your kit) only while you share Press kits with that label. Its roster shop shows your merch only while you're listed on its page and share Sales with it; anything bought there is bought from you. A demo you send a label goes to the label and the people there it lets handle demos: your artist name, page, the tracks you chose (even ones that aren't out, which they can play but not download) and your message. They never see your bank details, payouts, plan, account settings or fan messages.
• Your band and team, if you're an artist: each person you add has a login of their own and sees what you tick for them in your account, and nothing else. Never your bank details, payouts, refunds, splits, plan or account settings, your email list's addresses, or a conversation with anyone under 18. If an artist adds you, they see your name and email address and a record of what you change in their account.
• The others in a royalty split you're in: your artist name, your part and your percentage, and whether you've agreed.
• An artist you send files to: the files, your message and your artist name, once they've said yes to taking files from you. They can download them while they're kept, and are responsible for what they do with them after that.
• A producer you ask about a service: your name, email address and message, sent to them by email so they can reply to you. From then on they're responsible for how they use them.
• An artist whose email list you join, if you said you're 18 or over: they can download your email address, and from then on they're responsible for how they use it. If you didn't say you're 18 or over, your address never leaves subTotem.
• An artist you buy from — your name, delivery address, email address and what you ordered, because they post it to you themselves. Only that, and only for orders you placed with them. They're the seller, so Stripe gives them the payment record too, as their own customer. Messages between you and the artist about an order go through subTotem by email, so neither of you sees the other's email address in them. Each ticket has its own link and QR code (subTotem.show/t/…), which shows the gig, the ticket and the name on the order to anyone holding it, so keep it to yourself as you would a paper ticket. On the night, door staff the artist chooses see the names on that gig's door list, for that gig only, until the day after. If you tell the artist an order hasn't arrived and they don't answer within a week, the order and its messages come to us, so we can help.

We may also share information if the law requires it, or to protect someone's rights or safety. If subTotem is ever sold or merged, your data may transfer with it, and we'll tell you first.

We never sell your data, and we never share it for advertising.

05What's public

• Artists: your page, and what you put on it, is public to anyone on the internet, including search engines. That's the point of it. What you don't publish stays private to you.
• Listeners: what you play is never shown to other listeners. Artists see counts of their own streams and how many people played a track, not a list of who you are and what you played at what time. On Encore, an artist also sees which towns and countries their listeners are in, and are from if they've said, and how many come back, as totals; a town is only shown once 3 or more people have listened there or are from there, so you can't be picked out.
• Comments and playlists you choose to share are visible to others.
• Your delivery address is never public. It goes to the artist you bought from, and nobody else.
• A playlist a Champion shares can be seen by anyone with its link, with their name on it unless they choose to show "A subTotem Champion" instead. Stopping sharing ends the link.
• Private messages are between you and the artist. The artist sees your name, whether you support them, and a mark if you're under 18, never your date of birth. Nobody at subTotem reads a conversation unless something in it is reported or our automatic safety checks flag it, and then only that one. A manager or label working with an artist, or someone on the artist's band or team, will never see a conversation with anyone under 18.
• A Champion's fan page can be seen by anyone with its link, with only what they switch on.
• A Champion's reviews and photos on albums are public: on the artist's page, with their name, once the artist puts them up, and on their fan page unless the artist says no to one. Each review also has its own page on the Champion's fan page, at an address anyone with the link can open, and says whether they know the artist. Anyone can report one without an account; we keep the reason, what was reported, and a scrambled code made from the reporter's internet address, so one person can't send the same report again and again, never who they are. When the artist whose album it's on reports one, we know it was them.
• If you switch on review copies, artists on subTotem can see you on the list of reviewers: your name, the genres you take, how many reviews you've written, your latest review's line, and a link to your fan page if you have one. An artist who sends you a copy can see when you open and play it, and whether you review it or pass. A review of a release that isn't out yet stays off every public page until the day it is. The newest review an artist has put up on each release can also show to signed-in listeners in Find artists, with the reviewer's name.

06How long we keep it

• Your account and its content: until you delete your account. After that the record is closed straight away, so nothing of yours is reachable, and the data is wiped 30 days later. The 30 days give us a window to put it back if the account was closed by mistake or in error. Your pictures stop being shown the moment the account is closed. If the account has payment records, those stay for the periods below, kept under a blank account with no name, email or way to sign in, and are deleted when those periods end.
• A picture or file you remove: deleted when you remove it, unless it's still in use somewhere else on your page (a photo that's also a single's artwork, say). It stops loading within minutes. Our private backups keep a copy for 30 days in case of mistakes, then delete it too.
• Stream and payment records: kept as long as we need them for artists' statements, and for six years where accounting or tax law requires it. That includes a record of payments made to an artist, though not the account number they went to.
• An artist's bank details: until you change them or close your account. Changing them replaces what was there.
• Orders and delivery addresses: kept for six years, because an order is an accounting record and both you and the artist may need to refer to it. Each order keeps the address it was sent to, so changing your address later doesn't rewrite an old order. Messages about an order are kept for one year, then deleted; they go sooner if either account is deleted.
• Private messages and your date of birth: until you delete your account, like the rest of it. Deleting either account in a conversation deletes the conversation for both of you. A message we take down after a report is hidden from everyone straight away, and kept with the report until then. What our safety checks find is deleted six months after a person at subTotem has looked at it, and used for nothing else.
• Reviews and photos on albums: until you delete them, or your account. One we take down after a report goes from everywhere straight away, photo file and all. Reports are kept while we look into them, then with what we decided.
• Review copies: until you delete your account, or the artist takes the copy back. Switching review copies off takes you off the list straight away. Asking for an artist's next releases lasts until you or they stop it. Following a reviewer lasts until you stop, or either account is deleted.
• An artist's email list: while you're on it. When you unsubscribe, we keep your address marked as unsubscribed, so that artist can't email you again; ask us and we'll delete it altogether.
• The waiting list: until the role opens and you've been invited, or until you ask us to remove you.
• Asking to hear when an artist posts to you: until we've sent that one email, or until you ask us to remove it.
• Asking to hear when a release is out: until the day it comes out, when we send you that one email and delete your address. If it never comes out, we delete your address after 400 days. Ask us and we'll remove it sooner.
• Feedback you send: until you delete your account. A screenshot you add is deleted after 90 days; what you wrote stays, so you can still see it and where it got to.
• Visits to the website: 90 days, then deleted, leaving only each day's totals. Each day's random value is deleted the day after.
• How many are using subTotem right now: 10 minutes, then deleted.
• Confirmation codes and password reset links: a few hours, then they expire and are cleared.

07Where it's stored

subTotem runs on Cloudflare's network, which has servers around the world, and our other providers are in the UK, the EU and the United States. That means your data may be handled outside the UK.

Where it is, we rely on the safeguards UK law allows: the UK's adequacy decisions for countries with equivalent protection, or the International Data Transfer Agreement, or the UK Addendum to the EU's standard contractual clauses, in our contracts with each provider.

08Cookies and storage

subTotem doesn't set advertising or analytics cookies, and doesn't track you across other websites. That's why you've never seen a cookie banner here. Counting visits to the website doesn't use a cookie either, and nor does counting how many people are using subTotem at once.

When you sign in, we keep a sign-in token and your basic account details in your browser's own storage, so you stay signed in. Clearing your browser data signs you out. Stripe sets what it needs to take a payment safely, and that's covered by Stripe's privacy policy.

09Your rights

Under UK data protection law you can ask us to:

• Give you a copy of the data we hold about you.
• Correct it if it's wrong. You can edit most of it yourself in Settings.
• Delete it. You can delete your account yourself in Settings. Some records, such as payments, we have to keep for the periods in section 6.
• Send it on, to you or to another service, in a machine-readable form.
• Stop or limit a use you object to, where we rely on legitimate interests.
• Withdraw consent you've given, such as for marketing emails.

Email legal@subTotem.com and we'll answer within one month. It's free, and we may ask you to confirm who you are first.

If you're not happy with how we've handled it, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We'd rather you came to us first, so we can put it right.

10Children

subTotem isn't meant for children under 13, and we don't knowingly collect their data. From 13 you can have a free listener account with a parent's or guardian's permission, and you need to be 18 or over to pay for a plan or join as an artist.

Messaging an artist is for 14 and over, and we ask for your date of birth before you can. Only a fan can start a conversation, never an artist, and messages are text only. If you're under 18, neither side can send a way to reach you outside subTotem, such as a phone number, email address, social handle or web link.

To keep you safe, messages may be checked automatically. If something looks wrong, a person at subTotem may read the conversation, and a message that could hurt you won't reach you. If something you write sounds like you might be in danger yourself, your message still goes, and we'll show you where to get help straight away.

If you're a parent and think your child has given us their data, email legal@subTotem.com and we'll delete it.

11Keeping it safe

• Your password is stored as a hash, not as text. Nobody at subTotem can read it.
• Everything between you and subTotem travels over an encrypted connection.
• Audio is only ever served through a short-lived signed link to someone allowed to play it. Artists' master files are never served at all.
• Only people who need it can reach personal data, and the details you pay us with sit with Stripe rather than with us.
• The bank account we pay an artist into is encrypted with a key held outside the database, so a copy of the database alone can't reveal it. Changing it needs your password, sends you an email, and holds payments for a few days — so if it wasn't you, there's time to stop it.

No service can promise perfect security, but if there's ever a breach that puts you at risk, we'll tell you and the ICO as the law requires.

12Changes and contact

If we change this policy in a way that affects you, we'll email you before it takes effect. The date at the top always shows when it was last changed.

Questions, requests and complaints: legal@subTotem.com, or write to subTotem Ltd, registered in England and Wales, company number 17145546.

See also our terms of use.