Who we are
We are an independent musical artist whose legal base is located in The Netherlands.
Our website address is: https://sleepsunderbeams.subscotia.net which aliases as https://sleepsunderbeams.online.
Subscotia is the name of the entity which deals with the management of our rights (Subscotia Music), releases and distributes our work (Subscotia Records) and produces all our work from our studio located in Hilversum, The Netherlands (Subscotia Sound).
Data Controller
The data controller responsible for the processing of personal data on this website is:
Entity: Subscotia (trading as Sleeps Under Beams)
Location: Hilversum, The Netherlands
Chamber of Commerce (KvK): 99867567 Registered under Subscotia
Contact Email: privacy@subscotia.net
What Personal Data We Collect and Why
We adhere to the principle of data minimisation under Article 5(1)(c) GDPR. We only collect personal data necessary to provide and secure this website and to distribute requested music updates.
Server Access Logs
When you visit the site, our web server (hosted by Hostinger Operations, UAB) automatically logs standard technical connection data:
- IP address
- Date, time, and timezone of access
- Requested resource (URI) and HTTP status code
- User agent string (browser type, operating system, device details)
- Referrer URL
- Legal Basis: Legitimate interests (Article 6(1)(f) GDPR). Processing is strictly required to ensure technical stability, prevent unauthorized access, mitigate DDoS threats, and maintain server security.
- Retention: Server log files are retained for security auditing for a maximum of 30 days and are automatically purged or anonymised, unless needed for specific incident investigation.
Newsletter Subscription
If you voluntarily subscribe to the Sleeps Under Beams newsletter:
- Data Collected: Email address, timestamp of opt-in, confirmation IP address, and subscription status.
- Legal Basis: Explicit Consent (Article 6(1)(a) GDPR). We use a double opt-in mechanism to confirm your request.
- Third-Party Processor: Email dispatches and subscriber lists are processed via Brevo (Sendinblue SAS, France). Brevo hosts data within the European Union.
- Retention: Your email is stored until you withdraw your consent. You may unsubscribe at any time using the direct link provided in the footer of every email.
Direct Communication
If you contact us via email:
- Data Collected: Your name, email address, and message contents.
- Legal Basis: Legitimate interests (Article 6(1)(f) GDPR) or performance of pre-contractual steps (Article 6(1)(b) GDPR) to reply to your inquiry.
- Retention: Inquiries are kept for as long as necessary to address your communication, then archived or deleted.
Cookies and Tracking Technologies
Technical Cookies: This site uses only essential, session-based cookies strictly necessary for core functionality and caching (e.g., WordPress session management). These do not require consent under Article 11.7a of the Dutch Telecommunications Act (Telecommunicatiewet).
Third-Party Tracking: This site does not run Google Analytics, Meta tracking pixels, or commercial tracking scripts.
External Media Links: Links to third-party platforms (such as Bandcamp, Spotify, YouTube, or Soundcloud) are outbound hyperlinks, not embedded trackers. Interacting with those links directs you to third-party domains governed by their respective privacy statements.
Data Processors and Transfers
We do not sell, rent, or trade your personal data. We use select data processors bound by Data Processing Agreements (DPAs) compliant with Article 28 GDPR:
- Web Hosting: Hostinger Operations, UAB (Lithuania / EU).
- Newsletter Infrastructure: Brevo (Sendinblue SAS, France / EU).
Data is processed within the European Economic Area (EEA). If any fallback technical transmission occurs outside the EEA, standard contractual clauses (SCCs) are applied to guarantee equivalence of protection.
Your Rights Under the GDPR
Under Articles 15 to 22 GDPR, you retain the following rights regarding your personal data:
- Right of Access (Art. 15): Request a copy of the personal data we hold about you.
- Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data.
- Right to Erasure (Art. 17): Request deletion of your personal data (“right to be forgotten”).
- Right to Restriction of Processing (Art. 18): Request that we restrict processing under specific legal conditions.
- Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format.
- Right to Object (Art. 21): Object to data processing based on legitimate interests.
- Right to Withdraw Consent (Art. 7(3)): Withdraw your newsletter subscription at any time with immediate effect.
To exercise any of these rights, contact us at privacy@subscotia.net. Requests will be handled within one calendar month as required by Article 12(3) GDPR.
Supervisory Authority
If you believe that our processing of your personal data infringes data protection legislation, you have the right to lodge a complaint with the competent supervisory authority:
Autoriteit Persoonsgegevens (AP)
Postbus 93374
2509 AJ Den Haag
The Netherlands