Privacy & POLICY

Effective Date: 23 September 2026 Last Updated: 23 September 2026

1. Introduction

This Privacy Policy explains how Ice Cream Music Records Ltd (“Company”, “we”, “us” or “our”) collects, uses, stores, protects and discloses personal information in connection with icecreammusicrecords.com (the “Website”), including through enquiries, newsletter subscriptions, music and demo submissions, business communications and other interactions with the Company.

Ice Cream Music Records Ltd is a private limited company incorporated in England and Wales under company number 16774550, with its registered office at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

For applicable data-protection purposes, the Company will generally act as the data controller in respect of personal information processed through the Website and the activities described in this Policy.

2. Information We Collect

Depending upon an individual's interaction with the Company, we may collect names, professional or artist names, email addresses, telephone numbers, postal addresses, country or region, organisation and professional information, correspondence, attachments and other information voluntarily supplied by the individual.

Where music or demo material is submitted, we may additionally receive recordings, lyrics, titles, songwriter and composer details, contributor information, metadata, ownership information, links and related materials.

The Website may also generate technical information such as IP address, browser and device information, access times, referring information, security logs and information obtained through cookies or similar technologies.

The Website currently provides, among other functions, contact, demo-submission and newsletter facilities.

3. Purposes of Processing

We may process personal information for the operation, security and improvement of the Website; responding to enquiries; reviewing music and demo submissions; communicating with artists, writers, producers and business contacts; administering commercial and contractual relationships; managing intellectual-property and licensing matters; sending permitted communications; preventing fraud and misuse; maintaining appropriate business records; complying with legal obligations; and establishing, exercising or defending legal rights.

4. Lawful Basis

Personal information will be processed only where a lawful basis exists under applicable law. Depending upon the circumstances, this may include performance of a contract, steps taken at an individual's request before entering into a contract, compliance with a legal obligation, legitimate interests, or consent.

Where the Company relies upon legitimate interests, such interests may include operating and securing its business, responding to enquiries, administering commercial relationships, protecting intellectual property, preventing fraud and enforcing legal rights.

5. Music and Demo Submissions

Submission of music, demos, lyrics, artwork or other creative material does not, by itself, transfer or grant copyright, publishing rights, master rights or any other intellectual-property interest to the Company.

Any assignment, licence, publishing arrangement, recording agreement or other exploitation right must arise from a separate legally binding agreement.

The Company may process submitted material for evaluation, communication, rights verification and legitimate business purposes. Unless separately agreed, submission alone does not authorise commercial exploitation of the submitted work.

6. Marketing Communications

We may send marketing communications where permitted by law and, where required, only after obtaining the necessary consent.

Every applicable electronic marketing communication will provide an appropriate means of withdrawing from future marketing. An individual may also contact info@icecreammusicrecords.com to object to direct marketing.

The Company may retain limited suppression information where reasonably necessary to ensure that a valid marketing objection is respected.

7. Cookies and Similar Technologies

The Website may use cookies and other technologies for essential functionality, security, preferences, analytics and other lawful purposes.

Where applicable law requires prior consent, non-essential cookies or similar storage and access technologies will not be activated before the required consent is obtained. Users may amend their preferences through the Website's applicable consent mechanism.

8. Disclosure to Third Parties

Personal information may be disclosed where reasonably necessary to Website, hosting, information-technology, communications, security, cloud-storage, administration, analytics and other service providers; professional advisers; licensing or rights-management partners; relevant business counterparties; and courts, regulators, governmental authorities or law-enforcement bodies where disclosure is legally required or permitted.

Where appropriate, third-party processors will be subject to contractual and other safeguards required by applicable law.

9. International Transfers

Because the Company's activities and service providers may operate internationally, personal information may be processed outside the United Kingdom.

Where a transfer is legally restricted, the Company will use an applicable lawful transfer mechanism and appropriate safeguards, which may include an adequacy arrangement, the UK International Data Transfer Agreement, the UK Addendum or another mechanism recognised by applicable law.

10. Security

The Company maintains reasonable technical and organisational measures designed to protect personal information against unauthorised access, unlawful disclosure, accidental loss, destruction, alteration and misuse.

No electronic system or transmission method can guarantee absolute security. Where a personal-data breach creates a legal notification obligation, the Company will take the measures required by applicable law.

11. Retention

Personal information will be retained only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law.

Enquiries, submissions, communications, contractual records, rights-management records, accounting information and security information may therefore be retained for different periods according to their legal, commercial and operational requirements. Information that is no longer required will be securely deleted, anonymised or otherwise disposed of where appropriate.

12. Individual Rights

Subject to applicable legal conditions and exemptions, individuals may have rights to access personal information, request correction or erasure, request restriction of processing, object to certain processing, object to direct marketing, withdraw consent, request portability where applicable, and exercise other rights provided by data-protection law.

Requests may be submitted to:

Ice Cream Music Records Ltd 71–75 Shelton Street Covent Garden London WC2H 9JQ United Kingdom

Email: info@icecreammusicrecords.com

The Company may request reasonable information necessary to verify identity before fulfilling a request.

13. Automated Decision-Making

The Company does not ordinarily make decisions producing legal or similarly significant effects solely through automated processing.

Where this position materially changes, the Company will provide the information and safeguards required by applicable law.

14. Children and Young Persons

The Website is not specifically directed towards children. We do not knowingly seek unnecessary personal information from children.

Where a particular activity involving a child or young person requires additional safeguards under applicable law, the Company will apply those requirements.

15. Intellectual Property and Confidentiality

This Privacy Policy does not grant, transfer or assign any copyright, publishing right, master right, trademark, likeness right or other intellectual-property interest.

The confidentiality of unreleased music, commercial information or other sensitive material may additionally be governed by separate contractual terms, submission conditions or applicable law.

16. Legal Claims and Compliance

The Company may retain and process information where reasonably necessary to comply with law, respond to lawful authority, investigate suspected misuse, establish, exercise or defend legal claims, or protect the Company's legitimate rights and interests.

17. Changes to this Policy

The Company may amend this Privacy Policy to reflect changes in law, regulatory guidance, Website functionality, technology, services or business practices. The current version will be published on the Website with its effective and revision dates.

18. Complaints

Individuals are encouraged to contact the Company first so that the matter may be investigated and, where appropriate, resolved.

A complaint may be submitted to info@icecreammusicrecords.com or to the Company's registered office.

An individual may also lodge a complaint with the Information Commissioner's Office (ICO), the United Kingdom's independent data-protection supervisory authority, without first contacting the Company.

19. Governing Framework

This Privacy Policy is intended to operate in accordance with applicable United Kingdom data-protection and privacy legislation, including the applicable UK data-protection framework and the Privacy and Electronic Communications Regulations, together with any mandatory privacy requirements applicable to particular processing activities.

Nothing in this Policy shall exclude or restrict a mandatory legal right available to an individual.

20. Contact and Effective Date

Ice Cream Music Records Ltd Company Number: 16774550 Registered Office: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom Email: info@icecreammusicrecords.com Website: icecreammusicrecords.com

This Privacy Policy is effective from 23 September 2026. © 2026 Ice Cream Music Records Ltd. All rights reserved.