Privacy Policy

1. Who We Are — Data Controller

Data Controller: Joshua Cartwright, Member/Manager — TriGlobe Recordings LLC

Location: Southcentral Pennsylvania, United States

Contact: josh@trigloberecordings.com

Website: trigloberecordings.com

As the data controller, TriGlobe Recordings determines the purposes and means of processing personal data submitted through this website and in connection with our services. We do not appoint a formal EU or UK Representative at this stage given our scale, but we respond directly to all data subject requests within the timeframes required by applicable law.

2. What Data We Collect

We collect personal data only when you voluntarily provide it through our website forms or in the course of a commercial relationship with TriGlobe Recordings. We do not use tracking cookies, behavioral advertising, or third-party analytics tools that collect data without your knowledge.

Data collected through our contact and commission forms:

• Name — first name, full name, or stage name as provided voluntarily.
• Email address — required for all form submissions to enable response and communication.
• Professional information — company name, title, project details, and similar information provided in the context of a commission request or service inquiry.
• Creative brief content — descriptions of projects, creative preferences, reference materials, and similar information submitted through commission request forms.
• Payment information — we do not store payment card data. Payment processing is handled by third-party providers (Stripe, PayPal, Venmo) under their own privacy policies.

Data collected through the blog submission form:

• Name — optional. If left blank, submissions are published as Anonymous.
• Email address — required for pre-publication contact. Not published.
• Story content — the text of the submitted story or post.

Data collected through the Remix License application:

• Name, email, artist name, PRO affiliation, payment account handle (for identity verification only — not charged without further agreement), and creative description of the planned remix.

Data we do not collect:

• We do not use cookies beyond any that may be set by embedded third-party services (Formspree, Google Fonts).
• We do not collect IP addresses, device identifiers, or browsing behavior directly.
• We do not collect sensitive personal data such as racial or ethnic origin, health data, political opinions, or biometric data.
• We do not knowingly collect personal data from children under 13. Our services require users to be 18 or older.

3. How We Use Your Data — Legal Basis

Under GDPR and UK GDPR, we must identify a lawful legal basis for each purpose for which we process personal data. The following table describes our processing purposes and the legal basis for each.

• Responding to commission requests and service inquiries — Legal basis: Contractual necessity (Article 6(1)(b) GDPR). Processing is necessary to take steps at your request prior to entering a contract or to perform a contract with you.
• Communicating about a commission or service relationship — Legal basis: Contractual necessity (Article 6(1)(b)) and legitimate interests (Article 6(1)(f)). Our legitimate interest is fulfilling our professional obligations to clients and partners.
• Processing remix license applications — Legal basis: Contractual necessity (Article 6(1)(b)). Processing is necessary to evaluate and fulfill the license agreement.
• Reviewing and potentially publishing blog submissions — Legal basis: Consent (Article 6(1)(a)). By submitting a story you consent to TriGlobe reviewing it and contacting you regarding potential publication. You may withdraw consent at any time by contacting us.
• Maintaining records of commercial transactions — Legal basis: Legal obligation (Article 6(1)(c)) and legitimate interests (Article 6(1)(f)). We retain transaction records for tax compliance and business record purposes.
• Sending follow-up communications about services you have inquired about — Legal basis: Legitimate interests (Article 6(1)(f)). Our legitimate interest is following up on genuine service inquiries. You may opt out of any such communications at any time by replying to any email or contacting us directly.

4. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purpose for which it was collected or as required by law.

• Commission inquiries that do not result in a contract — 12 months from the date of the inquiry, then deleted.
• Executed contracts and commercial relationships — 7 years from the end of the commercial relationship, for tax and legal compliance purposes.
• Blog submissions not selected for publication — 6 months from submission, then deleted.
• Published blog posts — retained for the duration of the blog's existence. You may request removal at any time.
• Remix license applications approved — retained for the duration of the license plus 3 years for legal record purposes.
• Remix license applications declined — 6 months from the date of decline, then deleted.

5. Who We Share Your Data With

We do not sell personal data. We do not share personal data with third parties for marketing purposes. We share data only in the following limited circumstances.

• Formspree — our contact and commission forms are processed through Formspree, a third-party form processing service. Formspree receives form submission data and forwards it to our email address. Formspree's privacy policy is available at formspree.io/legal/privacy-policy.
• Google Fonts — our website loads fonts from Google Fonts. Google may collect limited technical data in connection with font serving. Google's privacy policy is available at policies.google.com/privacy.
• Google Translate — our website uses Google Translate to provide multilingual access to content. When the translation feature is used, page content and limited technical data is transmitted to Google's translation servers. Google's privacy policy is available at policies.google.com/privacy.
• Payment processors — Stripe, PayPal, and Venmo process music service payments under their own privacy policies. We do not receive or store full payment card data.
• Gumroad — processes digital product purchases for Build with TriGlobe products. Gumroad receives purchaser name, email, and payment information directly. TriGlobe receives order confirmation data only. Gumroad's privacy policy is available at gumroad.com/privacy.
• Legal compliance — we may disclose personal data if required to do so by applicable law, court order, or governmental authority.
• Business transfer — if TriGlobe Recordings is acquired or merges with another entity, personal data may be transferred as part of that transaction. We will notify affected individuals before any such transfer occurs.

All third-party service providers are contractually required to process personal data only as instructed and to maintain appropriate security measures.

6. International Data Transfers

TriGlobe Recordings is based in the United States. If you are located in the European Economic Area (EEA), the United Kingdom, or another jurisdiction with data transfer restrictions, your personal data will be transferred to and processed in the United States.

The United States does not have an adequacy decision from the European Commission. However, we implement appropriate safeguards to protect your data in accordance with GDPR requirements including data minimization, purpose limitation, and security measures appropriate to the risk.

7. Your Rights Under GDPR and UK GDPR

If you are located in the EEA or the United Kingdom, you have the following rights regarding your personal data. We will respond to all rights requests within 30 days of receipt.

To exercise any of these rights, contact us at josh@trigloberecordings.com with the subject line "Data Rights Request." We will verify your identity before processing any request and will respond within 30 days. We will not charge a fee for handling data rights requests unless they are manifestly unfounded or excessive.

8. Your Rights Under CCPA — California Residents

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

• Right to Know — you may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the business purpose for collecting it, and the categories of third parties with whom it is shared.
• Right to Delete — you may request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Correct — you may request correction of inaccurate personal information.
• Right to Opt Out of Sale or Sharing — TriGlobe Recordings does not sell personal information and does not share personal information for cross-context behavioral advertising. This right is therefore not applicable to our current data practices.
• Right to Non-Discrimination — we will not discriminate against you for exercising any of your CCPA rights.

To exercise CCPA rights, contact us at josh@trigloberecordings.com with the subject line "CCPA Rights Request."

9. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, destruction, or damage. These measures include:

• SSL/TLS encryption on all website communications.
• Email communications protected by standard provider security measures through Zoho Mail.
• Form submissions processed through Formspree's secure infrastructure.
• Access to personal data limited to Joshua Cartwright as sole Member/Manager of TriGlobe Recordings LLC.
• No storage of payment card data on TriGlobe systems.

No method of data transmission over the internet is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected individuals and relevant supervisory authorities as required by applicable law.

10. Cookies and Tracking

The trigloberecordings.com website does not use first-party cookies for tracking, analytics, or advertising purposes. The Google Translate widget may set a language preference cookie when used — this cookie stores only your selected language and is not used for tracking or advertising.

Third-party services that may set cookies or collect data:

• Google Fonts — loaded from Google's servers when you visit the site. Google may collect limited technical data. You can block Google Fonts by disabling third-party resources in your browser.
• Google Translate — our website uses Google Translate to provide automatic translation into multiple languages. When you use the translation feature, Google may collect limited technical data including your IP address, browser type, and the page URL in connection with the translation service. Google may set cookies to remember your language preference across sessions. Google's privacy policy is available at policies.google.com/privacy. You can opt out of the translation feature by not using the language selector widget.
• Formspree — processes form submissions. Formspree may set session-related cookies in connection with form processing.
• Gumroad — processes digital product purchases for Build with TriGlobe products. Gumroad collects payment information, name, and email address directly from purchasers under their own privacy policy available at gumroad.com/privacy. TriGlobe receives order confirmation and delivery information from Gumroad but does not store payment card data. Gumroad may set cookies in connection with purchase processing.

We do not use Google Analytics, Meta Pixel, or any other behavioral tracking or advertising technology. We use Google Translate to provide multilingual access — this service may collect limited technical data as described above but is not used for behavioral advertising or profiling. If our tracking practices change materially we will update this policy and where required obtain your consent before implementing tracking.

11. Children's Privacy

TriGlobe Recordings' services are intended for individuals 18 years of age and older. We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13 without verifiable parental consent, we will delete that data promptly. If you believe we may have collected data from a child under 13, please contact us at josh@trigloberecordings.com.

12. Links to Third-Party Sites

Our website may contain links to third-party websites including streaming platforms, social media, and payment services. This Privacy Policy applies only to trigloberecordings.com. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before submitting any personal data.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or the services we offer. Changes take effect upon publication at trigloberecordings.com/privacy.html. The effective date at the top of this page will be updated with each revision. For material changes we will make reasonable efforts to notify affected individuals directly where we hold contact information.

We encourage you to review this policy periodically.

14. Contact and Data Rights Requests

For any questions about this Privacy Policy, to exercise your data rights, or to report a privacy concern, please contact us:

TriGlobe Recordings LLC
Joshua Cartwright, Member/Manager
josh@trigloberecordings.com
trigloberecordings.com

We will acknowledge all data rights requests within 72 hours and respond fully within 30 days. If you are dissatisfied with our response you have the right to escalate your complaint to the relevant supervisory authority in your jurisdiction.