PRIVACY NOTICE

LAST UPDATED: 17 SEPTEMBER 2026

THIS NOTICE EXPLAINS WHAT PERSONAL DATA IS COLLECTED THROUGH THIS WEBSITE, WHY, AND WHAT RIGHTS YOU HAVE REGARDING IT, IN LINE WITH THE EU GENERAL DATA PROTECTION REGULATION (GDPR).

1. WHO IS RESPONSIBLE (DATA CONTROLLER)

WIM GEMIS
EMAIL: SCHMUTZ@BUGEL.JETZT
OR USE OUR CONTACT FORM.

2. WHAT DATA WE COLLECT

WHEN YOU SUBSCRIBE TO OUR ARCHIVE ("SIGNAL.SUBSCRIBE"), WE COLLECT:

• YOUR EMAIL ADDRESS
• THE DATE AND TIME YOU SUBSCRIBED
• YOUR IP ADDRESS AT THE TIME OF SUBSCRIBING (USED FOR SPAM PREVENTION AND ABUSE DETECTION)

WE DO NOT COLLECT ANY OTHER PERSONAL DATA THROUGH THIS FORM.

3. WHY WE COLLECT IT (PURPOSE & LEGAL BASIS)

WE USE YOUR EMAIL ADDRESS SOLELY TO SEND YOU UPDATES RELATED TO THIS PROJECT ("TRANSMISSIONS"). THE LEGAL BASIS FOR THIS PROCESSING IS YOUR CONSENT (ART. 6(1)(A) GDPR), GIVEN WHEN YOU TICK THE CONSENT CHECKBOX AND SUBMIT THE FORM.

YOUR IP ADDRESS IS PROCESSED UNDER OUR LEGITIMATE INTEREST (ART. 6(1)(F) GDPR) IN PREVENTING SPAM AND ABUSE OF THE SIGNUP FORM.

4. HOW LONG WE KEEP IT

WE RETAIN YOUR EMAIL ADDRESS FOR AS LONG AS YOU REMAIN SUBSCRIBED. IF YOU UNSUBSCRIBE, YOUR RECORD IS MARKED AS UNSUBSCRIBED AND DELETED WITHIN 30 DAYS.

5. MEMBER ACCOUNTS

THE MEMBERS AREA (LOGIN) IS SEPARATE FROM THE MAILING LIST. YOU DO NOT NEED TO SUBSCRIBE TO CREATE AN ACCOUNT, AND CREATING AN ACCOUNT DOES NOT SUBSCRIBE YOU — THAT IS A SEPARATE, OPTIONAL CHECKBOX.

IF YOU REGISTER AN ACCOUNT, WE STORE:

• YOUR EMAIL ADDRESS
• A DISPLAY NAME, IF YOU CHOOSE TO GIVE ONE
• YOUR PASSWORD, STORED ONLY AS A ONE-WAY HASH — WE NEVER SEE IT
• REGISTRATION DATE, CONFIRMATION DATE AND LAST LOGIN DATE
• YOUR IP ADDRESS AT REGISTRATION (SPAM AND ABUSE PREVENTION)

IF YOU CHOOSE "KEEP ME LOGGED IN", A COOKIE HOLDING A RANDOM TOKEN IS STORED ON YOUR DEVICE FOR UP TO 90 DAYS. LOGGING OUT DELETES IT.

THE LEGAL BASIS IS PERFORMANCE OF A SERVICE YOU REQUESTED (ART. 6(1)(B) GDPR) FOR THE ACCOUNT ITSELF, AND OUR LEGITIMATE INTEREST (ART. 6(1)(F) GDPR) FOR ABUSE PREVENTION.

6. DOWNLOAD LOGGING

FILES IN THE MEMBERS AREA INCLUDE UNRELEASED MATERIAL. EVERY FILE YOU OPEN OR DOWNLOAD THERE IS LOGGED WITH YOUR EMAIL ADDRESS, THE FILE NAME, THE DATE AND TIME, YOUR IP ADDRESS AND YOUR BROWSER IDENTIFICATION.

WE DO THIS TO PROTECT UNRELEASED WORK AGAINST UNAUTHORISED REDISTRIBUTION, UNDER OUR LEGITIMATE INTEREST (ART. 6(1)(F) GDPR). THESE LOGS ARE NOT USED FOR PROFILING, ADVERTISING OR ANALYTICS, AND ARE NEVER SHARED WITH THIRD PARTIES.

LOGS ARE KEPT FOR 30 DAYS AND THEN DELETED.

7. ACCOUNT DELETION AND RETENTION

YOU CAN ASK US TO DELETE YOUR ACCOUNT AT ANY TIME VIA THE CONTACT FORM. DELETING YOUR ACCOUNT REMOVES YOUR EMAIL ADDRESS, NAME, PASSWORD HASH AND SAVED LOGIN SESSIONS. DOWNLOAD LOG ENTRIES MAY BE RETAINED FOR THE PERIOD ABOVE FOR THE PROTECTION PURPOSE DESCRIBED IN SECTION 6.

IF AN ACCOUNT IS NEVER CONFIRMED, IT IS DELETED AFTER 30 DAYS.

8. WHERE YOUR DATA IS STORED

YOUR DATA IS STORED IN A DATABASE HOSTED BY HOSTYOU, LOCATED IN BELGIUM (EU). WE DO NOT SELL OR SHARE YOUR DATA WITH THIRD PARTIES FOR MARKETING PURPOSES. THE ONE EXCEPTION IS AD MEASUREMENT ON TRACK PAGES, AND ONLY IF YOU ACCEPT IT — SEE SECTION 12. MAIL IS SENT FROM OUR OWN SERVER; NO EXTERNAL MAILING SERVICE IS USED.

9. YOUR RIGHTS

UNDER THE GDPR, YOU HAVE THE RIGHT TO:

• ACCESS THE PERSONAL DATA WE HOLD ABOUT YOU
• REQUEST CORRECTION OF INACCURATE DATA
• REQUEST DELETION OF YOUR DATA ("RIGHT TO BE FORGOTTEN")
• WITHDRAW YOUR CONSENT AT ANY TIME, WITH NO EFFECT ON PROCESSING CARRIED OUT BEFORE WITHDRAWAL
• LODGE A COMPLAINT WITH YOUR LOCAL DATA PROTECTION AUTHORITY

TO EXERCISE ANY OF THESE RIGHTS, REACH OUT VIA OUR CONTACT FORM (SELECT "PRIVACY / DATA REQUEST" AS THE TOPIC).

10. UNSUBSCRIBING

EVERY EMAIL WE SEND INCLUDES A ONE-CLICK UNSUBSCRIBE LINK. YOU CAN ALSO REQUEST REMOVAL DIRECTLY VIA OUR CONTACT FORM.

11. COOKIES

THIS SITE USES NO ANALYTICS COOKIES. THE ONLY ADVERTISING COOKIE IS META'S _fbp, SET ONLY ON TRACK PAGES AND ONLY AFTER YOU ACCEPT MEASUREMENT (SEE SECTION 12).

IT USES TWO STRICTLY FUNCTIONAL COOKIES, BOTH ONLY IN THE MEMBERS AREA: A SESSION COOKIE THAT KEEPS YOU LOGGED IN WHILE YOU BROWSE, AND — ONLY IF YOU TICK "KEEP ME LOGGED IN" — A TOKEN COOKIE LASTING UP TO 90 DAYS. NEITHER IS USED TO TRACK YOU ACROSS OTHER WEBSITES, AND NO CONSENT BANNER IS REQUIRED FOR THEM.

TRACK PAGES WITH MEASUREMENT ALSO REMEMBER YOUR ACCEPT OR DECLINE CHOICE IN YOUR BROWSER'S LOCAL STORAGE, SO THE QUESTION DOES NOT RETURN ON EVERY VISIT. THIS IS STRICTLY FUNCTIONAL AND CONTAINS NOTHING BUT THAT CHOICE AND ITS DATE.

12. MEASUREMENT ON TRACK PAGES (META PIXEL)

SOME TRACK PAGES — THE PAGES FOR INDIVIDUAL RELEASES — CAN USE THE META PIXEL FROM META PLATFORMS IRELAND LTD. IT LOADS ONLY AFTER YOU PRESS ACCEPT IN THE BAR ON THAT PAGE. UNTIL YOU CHOOSE, OR IF YOU DECLINE, NOTHING FROM META IS LOADED AND NOTHING IS SENT. NO OTHER PAGE OF THIS SITE USES IT.

PURPOSE: MEASURING WHETHER ADS FOR A RELEASE REACH ANYONE. LEGAL BASIS: YOUR CONSENT (ART. 6(1)(A) GDPR).

WITH YOUR CONSENT, THE TRACK PAGE SENDS EXACTLY THREE EVENTS:

• A VISIT TO THE TRACK PAGE
• A CLICK ON [ PRE-SAVE ], WITH THE TRACK NAME
• A CLICK ON [ LISTEN ON SPOTIFY ], WITH THE TRACK NAME

NO NAME, EMAIL ADDRESS OR ANYTHING YOU TYPE IS SENT. META'S AUTOMATIC ADVANCED MATCHING AND AUTOMATIC EVENT DETECTION ARE SWITCHED OFF. AS WITH ANY REQUEST TO ITS SERVERS, META RECEIVES YOUR IP ADDRESS AND BROWSER DETAILS, AND SETS THE _fbp COOKIE (UP TO 90 DAYS) TO RECOGNISE A RETURNING BROWSER.

FOR COLLECTING AND SENDING THIS DATA, WE AND META ARE JOINTLY RESPONSIBLE. WHAT META DOES WITH IT AFTERWARDS FALLS UNDER META'S PRIVACY POLICY, WHICH MAY INVOLVE TRANSFERS OUTSIDE THE EU.

YOUR CHOICE IS KEPT FOR 6 MONTHS; AFTER THAT THE TRACK PAGE ASKS AGAIN. YOU CAN CHANGE IT AT ANY TIME WITH [ MEASUREMENT SETTINGS ] AT THE BOTTOM OF A TRACK PAGE, OR CLEAR IT HERE. CLEARING ALSO REMOVES META'S COOKIE FROM THIS SITE; THE NEXT TRACK PAGE ASKS AGAIN.