Last updated October 22, 2026
Privacy Notice
This notice is provided by Unsigned Now LLC (“Unsigned”, “we”, “us”, “our”), operator of the Unsigned platform and website (the “Service”). It forms part of, and should be read alongside, our Terms of Service, our Cookie Notice and our Data Processing Addendum.
Who we are and how to contact us
Data controller: Unsigned Now LLC, 1021 E Lincolnway, Suite #10234, Cheyenne, Wyoming 82001, USA.
Privacy contact: info@unsigned.now
The personal data roles in the Service
The Service involves different groups of people, and our data-protection role differs for each. It is important to understand this split because it determines who is responsible for what.
If you are a user (a musician or artist). When you create an account, upload music and use the Service, we act as the controller of your account and User Content data. We decide how that information is handled in order to provide the Service to you.
If you visit our website. Whether or not you have an account, we act as the controller of information collected when you browse the Service, including through cookies you consent to. Our Cookie Notice explains those cookies and your choices.
If you are a recipient (an industry contact). We maintain a database of professional, business-role contact details for music-industry recipients (such as labels, A&R staff, DJs, curators and distributors), and we transmit user-initiated communications to them. In respect of that recipient data, we act as a controller, because we determine the sourcing, selection, matching and retention of those details. Our lawful basis and safeguards for this are set out below.
The user’s own role in outreach. When you review, edit and send a communication from your own account, you determine the content and the decision to make contact. To that extent you act as an independent controller of your own outreach. We are not your processor for that activity, and you are responsible for your communications as set out in the Terms of Service (clauses 7.2–7.4, 7.7).
Meta advertising tools. If you consent to marketing cookies, we and Meta Platforms Ireland Limited are joint controllers for collecting information about your visit through the Meta pixel and transmitting it to Meta. Meta is a separate controller for its own further use of that information. See “Who we share data with” below.
What personal data we collect
Data about users and website visitors
- Account data: name, email address, password credentials, and profile details you provide.
- User Content: music, audio, artwork and related material you upload, and derived data such as audio analysis and generated pitch/metadata content.
- Usage and outreach data: records of the drafts generated for you, the communications you choose to send, and the recipients you contact.
- Billing data: subscription status and payment information processed by our payment provider.
- Technical data: IP address and device and browser information, held in our security and server logs.
- Analytics data (only with your consent): a pseudonymous identifier, pages viewed, clicks and scrolling, session start and end times, device type, operating system and browser.
- Marketing data (only with your consent): the information the Meta pixel collects about your visit, such as pages viewed, a browser identifier and, if you arrived from one of our Meta adverts, an identifier for that advert click.
- Cookie choices: a record of the consent choices you make in our cookie banner.
Data about recipients
For recipients, we hold business and professional-role contact information only.
- Contact information: for example a professional or role-based email address (such as a submissions, demo or A&R address), the associated organisation or project, and any public submission link. We do not knowingly collect or use recipients’ personal (private, non-professional) email addresses, because outreach to individuals in a personal capacity is subject to stricter rules in the UK and most EU/EEA countries than outreach to business contacts.
- Technical data: IP address and device and browser information, held only in our security and server logs when you visit the Service.
Source of recipient data. Consistent with clause 7.1 of the Terms, recipient contact information is sourced from publicly available sources — including recipients’ own official websites, social-media and link-in-bio pages, public submission pages, and publicly indexed search results. We do not scrape or reproduce any third-party platform’s private member directory, and we do not store private contact data. The fact that information is publicly available does not by itself exempt it from data-protection law, which is why we set out our lawful basis and safeguards below and provide the transparency information required when data is obtained indirectly.
How we use personal data and our lawful bases
The tables below set out, for each purpose, the personal data used and the lawful basis under UK GDPR / EU GDPR Article 6. Where we rely on legitimate interests, you may ask us for a summary of the balancing assessment. Where we rely on consent, the cookie or similar technology involved also needs consent under PECR and the ePrivacy Directive, and nothing is collected until you give it.
Users and website visitors
| Purpose | Data used | Lawful basis |
|---|---|---|
| Creating and administering your account; providing the Service | Account data, usage data | Performance of a contract (Art. 6(1)(b)) |
| Storing and analysing your User Content and generating draft pitch/metadata content | User Content, derived data | Performance of a contract (Art. 6(1)(b)) |
| Processing payments, trials and renewals | Billing data | Performance of a contract (Art. 6(1)(b)); legal obligation for tax/accounting (Art. 6(1)(c)) |
| Securing the Service, preventing abuse and enforcing the No-Spam policy | Account, usage, technical data | Legitimate interests (Art. 6(1)(f)) — protecting the Service and third parties |
| Service-related communications (e.g. transactional and account emails) | Account data | Performance of a contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f)) |
| Optional product-marketing emails to you, including measuring opens and clicks | Account data, email engagement data | Consent (Art. 6(1)(a)) and PECR consent where required |
| Analytics for product improvement (the “Statistics” option in our cookie banner) | Analytics data | Consent (Art. 6(1)(a)) and PECR consent |
| Measuring and delivering our adverts on Meta (the “Marketing” option in our cookie banner) | Marketing data | Consent (Art. 6(1)(a)) and PECR consent |
| Recording and proving your cookie choices | Cookie choices | Legal obligation (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f)) |
Recipients
| Purpose | Data used | Lawful basis |
|---|---|---|
| Maintaining a database of professional recipients so users can identify relevant industry contacts | Business-role contact data | Legitimate interests (Art. 6(1)(f)) — connecting artists with relevant professionals |
| Transmitting user-initiated context-sharing communications to recipients | Business-role contact data | Legitimate interests (Art. 6(1)(f)); see the section on PECR below |
| Securing the Service | Technical data | Legitimate interests (Art. 6(1)(f)) — protecting the Service |
| Handling recipient objections, removal requests and suppression | Business-role contact data | Legal obligation (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f)) |
More about our legitimate interests
Where we rely on legitimate interests, we have weighed our interests, and those of our users, against the rights and reasonable expectations of the people concerned.
Recipient database and communications. Our interest is in operating a service that connects independent artists with industry professionals in their professional capacity. We use only business/professional-role contact details. Recipients who publish a professional submission or contact address can reasonably expect to receive relevant, individually-directed submissions, and we provide an easy way to object and be suppressed at any time.
Contacting recipients — PECR and the ePrivacy Directive
Separately from UK/EU GDPR (which governs the use of personal data), the Privacy and Electronic Communications Regulations 2003 (PECR) in the UK, and national laws implementing the ePrivacy Directive 2002/58/EC across the EU/EEA, govern electronic communications and the use of cookies and similar technologies. Our approach is as follows.
Nature of the communications. Communications transmitted through the Service are user-initiated music context-sharing and outreach: an artist asks us to pass on their music and submission details to a relevant professional recipient. These communications are not sent to advertise or promote Unsigned’s own goods or services, and we do not include Unsigned product-marketing within them. On that basis we consider that they do not constitute “direct marketing” within the meaning of Regulation 22 of PECR.
Business recipients only. We direct communications to professional, business-role recipients, not to individuals in a personal capacity. Under PECR, the prior-consent rule in Regulation 22 applies to “individual subscribers”; communications to corporate subscribers fall outside it. We do not send communications to recipients who are individual subscribers (such as sole traders or private individuals) without an appropriate basis.
Sender identification and opt-out (Regulation 23). Every communication sent through the Service identifies the sender and includes a valid, cost-free means for the recipient to opt out of further contact, consistent with Regulation 23 of PECR. When a recipient opts out or asks to be removed, we suppress their details across the Service so they are not contacted again.
No tracking in communications. Communications sent to recipients contain no open-tracking pixels or click-tracking links.
Who we share data with, and international transfers
Service providers (processors). We share personal data with third parties that provide services to us, under written data-processing terms that require them to protect it and act only on our instructions. Our current sub-processors, by function, are:
- Hosting and infrastructure — application hosting, database and authentication.
- Payment processing.
- Email delivery and validation — transactional and outreach email, and email-address validation.
- Marketing email — sending product-marketing emails to users who have consented.
- AI processing — audio analysis and generation of draft pitch and metadata content.
- Monitoring and product analytics — error monitoring and product analytics (analytics only with your consent).
- Consent management — operating our cookie banner and recording your choices.
- Workplace and development tools — business email, document storage and code hosting.
- Software development and maintenance — an external development contractor that builds and maintains the Service and has access to production systems.
- Marketing services — an external marketing contractor that manages our advertising accounts, our tag manager and our marketing email platform, including the email addresses of people subscribed to our marketing emails. It has no access to our production database.
A full list of our sub-processors is available on request. We keep it current and update it when our sub-processors change.
AI and model training. We use third-party AI processing services to analyse audio and generate draft pitch, metadata and related content. We use these providers through their APIs on no-training terms: your User Content and personal data are used only to provide the Service to you, and not to train or fine-tune their models. Our signed data-processing agreements with these providers back this up.
Meta (joint controller). If you consent to marketing cookies, the Meta pixel sends information about your visit, such as the page viewed and a browser identifier, to Meta Platforms Ireland Limited. We and Meta are joint controllers for that collection and transmission. We are responsible for obtaining your consent and for providing this information; Meta is responsible for its own further processing, described in Meta’s Privacy Policy, and for responding to rights requests about it. You can exercise your rights with either of us, and you can ask us for the essence of our joint-controller arrangement using the contact details above.
Recipients. When you send a communication, the content you approve (including your name, music links and message) is disclosed to the recipient you are contacting. Recipients are independent third parties.
International transfers. Unsigned is established in the United States, and personal data of UK and EU/EEA individuals is transferred to and processed in the US. Some of our service providers are based outside the US, the UK and the EEA: our software development contractor is based in Pakistan and can access personal data held in our production systems, and our marketing contractor is based in South Africa and can access our advertising accounts and the email addresses of our marketing-email subscribers. Where we transfer personal data outside the UK or EEA, we rely on appropriate safeguards under Article 46 UK/EU GDPR. In practice this means one of two mechanisms per provider: where a provider is certified under the EU-US Data Privacy Framework and its UK Extension, the transfer is covered by the corresponding UK and EU adequacy decisions; where a provider is not certified, or is in a country without an adequacy decision (such as Pakistan or South Africa), we rely on the EU Standard Contractual Clauses together with the UK International Data Transfer Addendum or IDTA. We retain these safeguards even where a provider is separately certified. You may request information about the safeguard applying to a particular transfer using the contact details above.
Your rights
Under UK GDPR and EU GDPR, individuals (users, website visitors and recipients) have the following rights, subject to conditions and exemptions:
- Access — a copy of your personal data.
- Rectification — correction of inaccurate or incomplete data.
- Erasure — deletion in certain circumstances.
- Restriction — to limit processing in certain circumstances.
- Portability — to receive certain data in a portable format.
- Object — in particular, an absolute right to object to direct marketing, and a right to object to processing based on legitimate interests (Art. 21).
- Rights relating to automated decision-making.
- Withdraw consent — where processing is based on consent, at any time. For cookies, analytics and marketing, use the Privacy settings link in the footer of every page; for marketing emails, use the unsubscribe link in any email.
Recipients: you can object to our processing of your details or ask to be removed at any time using the opt-out in any message we send, or by contacting our privacy contact above. We will action removal and add you to our suppression list within 30 days.
To exercise any right, contact us at info@unsigned.now. You also have the right to complain to a supervisory authority: in the UK, the Information Commissioner, ico.org.uk; in the EU/EEA, your local Data Protection Authority.
How long we keep personal data
We keep personal data only as long as necessary for the purposes described, then delete or anonymise it.
- User account and User Content: for the life of your account; the User Content licence ends when you delete the content or close your account (see Terms). We delete or anonymise this data within 30 days of account closure.
- Billing records: retained for 7 years to meet tax and accounting obligations.
- Recipient data: kept while it remains relevant to the Service and re-verified on an ongoing basis (bounce and validity checks). It is removed on request or when found invalid, and reviewed at least every 12 months.
- Analytics data: Google Analytics data is kept for 14 months; PostHog analytics data is kept for 12 months.
- Marketing data: the Meta pixel cookies last up to 90 days (see our Cookie Notice); Meta’s own retention is set out in Meta’s Privacy Policy.
- Cookie choices: 12 months.
- Security and server logs: 30 days.
- Suppression list: retained as long as necessary to honour opt-outs (this is a lawful reason to keep minimal data indefinitely).
Children
The Service is not directed to children. The minimum age of use is 18 years.
Security
We take appropriate technical and organisational measures to protect personal data, and we choose service providers that do the same. These measures include encryption of data in transit and at rest, multi-factor authentication on accounts that can reach personal data, access controls limiting who can access personal data, and due-diligence and written data-protection terms with our sub-processors. No system is completely secure, but we work to protect personal data proportionately to the risk.
Changes to this notice
We may update this notice from time to time. Where changes are material, we will take reasonable steps to notify you. The “Last updated” date at the top shows when it was last revised.
