Last Updated: 1st July 2026

SixtyFour Music & Sound Ltd, a company registered in England and Wales (company number 16681883), whose registered office is at International House, 101 King's Cross Road, London, WC1X 9LP, United Kingdom, trading as Trakr Music.

In this policy, "Trakr", "we", "us" and "our" mean the entity named immediately above.

We are the data controller for the personal data described in this policy.

Contact for privacy matters: contact@trakr.music

2. Scope

This policy explains how we collect and use personal data when you:

• visit our website at trakr.music (the "Site");

• contact us or submit an enquiry or demo request; or

• receive business-to-business outreach from us (see section 5).

This policy does not cover the Trakr platform. Where we process data on behalf of a customer under a pilot agreement, order form or master services agreement, we act as a processor, not a controller, and that processing is governed by the data processing agreement with that customer.

3. Personal data we collect

When you contact us or submit an enquiry:

DataExamplesIdentity dataName, job titleContact dataBusiness email address, telephone numberOrganisation dataCompany name, role, catalogue or repertoire context you choose to shareCorrespondence dataThe content of your message and our subsequent exchanges

When you visit the Site:

DataExamplesTechnical dataIP address, browser type and version, device type, operating systemUsage dataPages viewed, time of visit, referring source

Technical and usage data is collected by our hosting provider as part of delivering and securing the Site. We do not currently operate any third-party advertising or behavioural tracking on the Site.

When we contact you as a business prospect: see section 5.

We do not knowingly collect data from anyone under 18, and we do not collect special category data (such as health, ethnicity, political opinions or religious beliefs). Please do not send us such information.

4. How we use enquiry data, and our legal basis

PurposeLegal basisResponding to your enquiry or demo requestLegitimate interests — responding to someone who has approached us; and, where relevant, taking steps at your request prior to entering a contractArranging and conducting demo callsLegitimate interests / steps prior to a contractMaintaining a record of business contacts and correspondenceLegitimate interests — running and administering our businessSending you follow-up communications about TrakrLegitimate interests (business contacts) — see section 5 on your right to objectSite security, fraud prevention and troubleshootingLegitimate interests — protecting our systemsComplying with legal, regulatory and accounting obligationsLegal obligation

Where we rely on legitimate interests, we have considered whether our interest is overridden by your rights. You can object at any time — see section 9.

Please do not send confidential catalogue data, ownership records or contracts through the Site. Material of that kind should be exchanged only under an executed agreement and, where appropriate, a non-disclosure agreement.

5. Business-to-business outreach — how we may have your details

We carry out direct outreach to professionals working in music rights: at record labels, music publishers, distributors, rights administrators and their advisers.

Where we obtain this data. We source business contact details from third-party business data providers (principally Apollo.io), from public professional sources such as company websites and LinkedIn, from industry directories and public registries, and from conversations at industry events. We did not obtain it from you directly.

What we hold. Typically: name, job title, employer, business email address, business telephone number, publicly listed professional profile, and our record of any contact between us.

Why we do this. To tell relevant professionals about a service addressing a problem within their professional responsibilities — unlicensed and unattributed use of music catalogues. We rely on legitimate interests (UK GDPR Article 6(1)(f)). We have carried out a balancing assessment: the data is business contact data, used in a professional context, for a purpose relevant to the recipient's role, with an unsubscribe option in every message.

Marketing rules. Where we email a corporate subscriber (a limited company, LLP or equivalent), we rely on the corporate subscriber provisions of the Privacy and Electronic Communications Regulations 2003. Where the recipient is an individual, a sole trader or an unincorporated partnership, we send marketing email only with consent or on a soft opt-in basis.

Your rights here are absolute in one respect: you can object to direct marketing at any time and we will stop, with no need to give a reason. Reply to any message, or email contact@trakr.music, and we will remove you. We keep a minimal suppression record (your email address only) so that we do not contact you again — this is itself a legitimate interest and a practical necessity.

Notice under Article 14. This section is the privacy notice required where personal data is obtained from sources other than the data subject.

6. Who we share data with

We do not sell personal data, and we do not share it for third-party marketing.

We share personal data with the following categories of recipient, all of whom act on our instructions as processors, or as controllers in their own right where indicated:

RecipientRolePurposeLocationFramer B.V.ProcessorWebsite hosting and delivery; handling enquiry form submissionsNetherlands (EU), with sub-processors that may be outside the UK/EEAGoogle (Google Workspace / Gmail)ProcessorBusiness email — enquiries are delivered to and stored in our inboxEU/USApollo.io, Inc.Independent controller and processorSourcing business contact data; managing outreach records and suppression listsUnited StatesProfessional advisers (lawyers, accountants)ControllersAdvice, audit, dispute resolutionUKRegulators, law enforcement, courtsControllersWhere required by lawUK

We may also disclose personal data to a buyer or successor entity in connection with a reorganisation, merger, or transfer of our business — including the transfer of this business to a newly incorporated Trakr company, in which case that entity will become the controller on the terms of this policy.

7. International transfers

Some of our providers are located outside the United Kingdom. Where personal data is transferred outside the UK, we rely on one or more of the following safeguards:

• an adequacy decision by the UK Government covering the recipient country (this covers our EU-based providers, including Framer B.V.);

• the UK Extension to the EU–US Data Privacy Framework, where the recipient is certified under it; or

• the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment.

You may request further information about the safeguards applied to a particular transfer by emailing contact@trakr.music.

8. How long we keep data

DataRetentionEnquiries that do not lead to a relationship24 months from last contact, then deletedEnquiries and correspondence with active or prospective customersDuration of the relationship, then 6 years (the limitation period for contractual claims)Prospect contact dataReviewed every 12 months; deleted where there has been no engagement for 24 monthsMarketing suppression listRetained indefinitely — this is the only way to honour your objectionServer and security logsTypically 30–90 days, as determined by our hosting providerRecords required for tax and accounting6 years from the end of the relevant financial year

9. Your rights

Under UK GDPR you have the right to:

• Access — obtain a copy of the personal data we hold about you;

• Rectification — have inaccurate data corrected;

• Erasure — have data deleted, where there is no overriding reason for us to keep it;

• Restriction — ask us to pause processing while a concern is resolved;

• Portability — receive certain data in a machine-readable format;

• Object — object to processing based on legitimate interests. Where you object to direct marketing, we must stop — there is no balancing test.

To exercise any of these, email contact@trakr.music. We will respond within one month. There is no fee unless a request is manifestly unfounded or excessive.

We may need to verify your identity before acting on a request.

Complaints. If you are unhappy with how we have handled your data, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk, by calling 0303 123 1113, or by writing to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

10. Cookies and similar technologies

Our Site uses only strictly necessary cookies and equivalent technologies — those required to deliver the Site securely and to make the enquiry form work. These do not require your consent under the Privacy and Electronic Communications Regulations 2003.

We do not currently use analytics, advertising or behavioural tracking cookies. If this changes, we will update this policy and present a cookie banner allowing you to accept or reject non-essential cookies before they are set.

You can control cookies through your browser settings, though blocking strictly necessary cookies may prevent parts of the Site from working.

11. Security

We take reasonable technical and organisational measures to protect personal data, including encrypted transmission (HTTPS), access controls on our systems, multi-factor authentication on business accounts, and limiting access to personal data to those who need it.

No system is completely secure. We cannot guarantee the security of data transmitted to the Site, and any transmission is at your own risk. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where the risk is high, notify you directly.

12. Changes to this policy

We may update this policy from time to time. The date at the top shows when it was last revised. Where changes are material, we will take reasonable steps to bring them to your attention.

13. Contact us

Questions about this policy, or about how we handle your data:

• Email: contact@trakr.music

• Post: SixtyFour Music & Sound Ltd, International House, 101 King's Cross Road, London, WC1X 9LP

We have not appointed a Data Protection Officer, as we are not required to do so.