Privacy Policy

This describes how LabelOS handles personal data. It is written against what the software actually does, so it names the processors that genuinely receive data and omits the ones it does not use. LabelOS is in internal testing; the items still marked open are completed before public launch.

Who is responsible

System Error MM GmbH, Lehrter Straße 49, 10557 Berlin, Germany, registered at Amtsgericht Charlottenburg (Berlin) under HRB 229014B. A data protection officer is not appointed. Contact for data protection questions: office@systemerrorworldwide.com.

What we process, and why

• Account data. Email address, name where you give one, and credentials handled by Supabase Auth. Needed to operate your account (Art. 6(1)(b) GDPR).
• Organisation data. Your label, its members and their roles, and the settings the organisation chooses. Needed to run the product for your organisation (Art. 6(1)(b)).
• Catalogue and money data. Releases, artists, contracts, imports, royalty periods, statements and payouts, including any payee bank and tax details you enter. Needed to provide the service (Art. 6(1)(b)) and kept where tax and commercial law requires it (Art. 6(1)(c)).
• Integrations you switch on. If an organisation connects Google Calendar and Tasks, the tokens and the data exchanged with Google are processed for that purpose (Art. 6(1)(a), withdrawable by disconnecting).
• Messages. Statement and notification emails are drafted in the product and, once live email is enabled, delivered through our own mail server in Germany, which processes recipient addresses and message content on our behalf.
• Technical logs. Server and access logs, including IP address, for security and fault diagnosis (Art. 6(1)(f)).
• If you ask for access. The email address you give on the waitlist, and the optional note about your label, so we can answer that request and write to you when a place opens (Art. 6(1)(b)). If you also ticked the box asking for news, we use the same address to send occasional LabelOS news: that is your consent, you can withdraw it at any time, and replying to any message takes you off that list (Art. 6(1)(a)).

We do not run product analytics, we do not profile you, and there is no automated decision-making. No payment card data reaches LabelOS: there is no payment processor integrated.

Cookies we set

LabelOS sets only the cookies the application needs to work: a session cookie once you sign in, so you stay signed in; a cookie recording the organisation an invitation or onboarding placed you in; a preference cookie remembering the language you chose; and, while you are connecting the Google integration, a short-lived cookie that secures that step. Your theme choice is not a cookie: it is stored on your membership and remembered in your browser. There are no advertising, analytics or marketing cookies, and no advertising network receives anything.

Where the data lives, and who else sees it

• Our own server infrastructure. The production instance runs PostgreSQL and Supabase Auth on infrastructure we operate, hosted by netcup GmbH in Germany.
• Cloudflare. DNS and the tunnel that publishes the application.
• Vercel. Hosting for the separate Vercel deployment of the same application. Its functions run in the Frankfurt region, inside the EU.
• Own mail server. Transactional and account email is delivered by the mail server we operate ourselves on a Hetzner server in Germany. No external mail processor is involved.
• Google. Only when an organisation connects the Google integration.

Open before public launch: the data processing agreement for each processor above. Email no longer involves a processor outside the EU.

How long we keep it

Account and organisation data are kept while the account exists. Financial records tied to payouts and statements are kept for the statutory retention periods, which under German commercial and tax law are six or ten years depending on the record (HGB § 257, AO § 147).

A deleted contract is only soft-deleted at first. Once its retention window has passed, a scheduled maintenance sweep removes the row from the database permanently.

Open before public launch: a stated retention period for logs, for closed accounts and for revoked integration tokens, which today follow our deletion of the underlying rows rather than a fixed number.

Your rights

You can ask for access to your data, correction, deletion, restriction of processing, and portability, and you can object to processing based on legitimate interests (Art. 15 to 21 GDPR). Some of this is available in the product itself: artists can export their data and request erasure from their portal, and administrators can export organisation data. You can complain to the supervisory authority for Berlin, the Berliner Beauftragte für Datenschutz und Informationsfreiheit.

Changes

This policy is updated when the product changes how it handles data. The current version is the one published here.