Privacy Policy


Subshare Limited is committed to protecting and respecting your privacy.

This Privacy Notice shows you what personal information we collect from you and how we make use of it, and keep it secure. It is meant to be read alongside our Subshare Terms of Use. Those Terms relate to your use of our website and our mobile platform of creative music makers.

We can change this Notice at any time, so you should check this page frequently to see any updates. By using our platform in our “Subshare”, “Ripple” and/or “Neptune” streams and by registering with Subshare you agree to be subject to everything in this Notice. Questions, comments and requests regarding this Notice are very welcome. Please write to us at Kemp House, 160 City Road, London, EC1V 2NX or

Our Privacy Notice was last updated on 25 May 2018 to align our data protection practices with new data privacy laws in the United Kingdom, which came into effect on that date.

Please read the following carefully to understand our views and practices regarding your information and how we deal with it:

Who are we?

We are Subshare Limited, a company registered in England and Wales under number 10556905. Our registered address is Kemp House, 160 City Road, London, EC1V 2NX.

We provide a dynamic digital website (Site) and, through our Site, a mobile platform (Platform) offering creative and innovative ways for a community of music makers to collaborate in a collective music production process.

Who are you?

You might be:

  1. a visitor to our Site or our Platform;
  2. a person who corresponds with us and provides personal information to us in the course of making enquiries about the services we offer by email or through our Site or our Platform;
  3. a user of our Platform looking to collaborate with other users to produce music;
  4. an expert working in music education looking to provide guidance to assist others to produce music. We call these people “Educators”;
  5. a visitor to our Platform who downloads, streams or otherwise obtains access to music and content.

How do we collect information from you?

We will collect information about you that you have given us when:

  1. You send information to us through our Site or our Platform or by corresponding with us (for example, by email);
  2. You register as a user on our Platform;
  3. You send information to other users through our Platform;
  4. You upload Submissions or Completed Works to our Platform.

What type of information is collected from you?

Information which must be provided

When you register as a user you will need to provide us with:

  • your full name;
  • your credit or debit card details;
  • your bank account details;
  • your address and postcode; and
  • your date of birth.

If you choose, you may use PayPal instead of providing us with your credit or debit card details and your bank account details.

You will need to create a username (which doesn’t need to be your real name) and password. You should not share your password with any other person.

Alternatively, you may register and log in using your Facebook or other social media accounts (Social Media Accounts). If you do so, your Social Media Accounts will ask your permission to share your first name, last name, email address. We need this information to verify your identity. If you do not allow Social Media Accounts to share this information with us you will not be able to use our Platform.

This information is collected by Social Media Accounts and is provided to us under the terms of Social Media Accounts’ privacy policies. You can control the information provided to us by Social Media Accounts by changing the privacy settings in your Social Media Accounts.

If you register with your Social Media Accounts you will have the option of posting your Submissions or Completed Works and links to your favourite tracks on your timeline and your friends’ newsfeeds. We will not make any posts on your Social Media Accounts without your permission. Where a suggestion to post to your Social Media Accounts is made, you will be required to confirm that you wish to make the post.

Information which may be provided if you choose to do so

If you choose you may also add from your Social Media Accounts your email address, website address, birthday, “likes”, “friends” list and location to your profile. You also have the option of adding a photograph or artwork to your profile to identify you to other users. You may also allow your Social Media Accounts to share your photos if you would like to use them on our Platform.

Information collected automatically

We will collect some information automatically to enable us to improve our Site and Platform. This information includes your IP address, actions you take on our Site or our Platform, the length and frequency of visits to our Site or our Platform, you following or unfollowing other users and you posting comments.

You may also allow us to collect information on your location, websites you have visited and your “likes” on your Social Media Accounts to improve the music suggestions we make to you.

We collect information on how much you have made in sales which will be displayed on your dashboard and your profile. The dashboard is not visible to other users. Any information displayed on your profile is visible to any visitor to our Platform.

How is your information used?

If you pay for a subscription or an Educator’s feeback or to download music your name, address, postcode and credit or debit card details will be used to process and collect the payment.

You also have the option of making these payments through PayPal. In this case, you would be directed from our Platform to the PayPal app or website to make the payment.

If you are an Educator who has given feedback, we will use your bank details to pay you your fee unless you have chosen to be paid using PayPal.

Where you use PayPal to pay or receive money on our Platform, PayPal will provide us with your name, email address and billing address. This is governed by PayPal’s own privacy policy which is available on their website. You should read this if you have any questions regarding using PayPal on our Platform.

We may use your information to:

  • arrange distribution of royalties from any Completed Works you are part of;
  • register your ownership of a certain percentage of a Completed Work or subshare;
  • view your transactions;
  • contact you where you have breached the Terms of Use;
  • ensure that our Site and our Platform are presented in the most effective way for you and your computer;
  • provide you with technical support;
  • provide you with information you request from us or which we feel may interest you, where you have consented to be contacted for such a purpose.

We may send messages to all users to notify you:

  • of an update to our Site or our Platform;
  • of new services we are offering;
  • that our Site or Platform is experiencing problems.

We may also send messages to seek your comments on our Site or our Platform.

We will send automatic email notifications where there has been activity on your account (including, among other activities, where you have subshared or where you have received a new request for feedback). You have the option of turning off these notifications. Please go to settings when accessing your account.

Grounds for processing

We are able to process your personal information in pursuance of our contract with you at your request to provide the services on our Site or our Platform.  We may also do so in order to operate our business, protect the security of our systems and other users or otherwise fulfil our other legitimate interests (except where our interests are overridden by your privacy rights).  Where we rely on your consent to process your personal information, you have the right to withdraw such consent whenever you wish.  Where we rely on our legitimate interests to process your personal information, you may have the right to object to our processing.

Who has access to your information?

We will not share your information with third parties for marketing purposes.

Your profile is public and will be visible to any other user of our Site or our Platform.  This includes any information you have added to your profile, your Submissions, subshares and Completed Works you are part of and money earned. Your profile can be anonymous if your username is a nickname, your profile image is not a photograph of you and you do not add any information which could identify you.

Your username and profile image may appear in the newsfeed of recent subshares and Completed Works and when you upload your Submissions to our Site or our Platform your profile image will appear next to the song.

When you begin a subshare, request feedback from an Educator through Ripple or provide advice through Ripple, we will only share the information which is publicly visible on your profile with the other user or users you connect with. If you choose to share other information, we are not responsible for protecting that information.

If you listen to Completed Works or Submissions , the user who has uploaded that Submission or users who took part in the Completed Work will receive a notification that you listened to the Submission or Completed Work.

Our Site and our Platform may contain links to other websites run by other organisations (including, but not limited to, Paypal and YouTube). This Privacy Notice does not apply to these other websites and you should ensure you read the privacy policies of those websites to understand how they will deal with your information. We cannot be held responsible for the way the owners and operators of these sites use your information, even if you accessed the sites through a link on our Site or our Platform.

In some circumstances, we have a legitimate interest in transferring your personal information to third parties as follows:

  • if we buy or sell any business or assets to a third party, or as part of a business restructuring or organisation;
  • if we have a legal duty to disclose or share your data;
  • in order to enforce or apply the Subshare Terms of Use or this Notice;
  • to protect the rights, property or safety of Subshare Limited and the users of our services;
  • if we need to disclose the information to help resolve a complaint or investigation that arises from your use of our Site or our Platform.


Our Platform is not designed for use by anyone under the age of 16 without the permission of a parent or guardian and such person acting as guarantor on the account. Please see the Terms of Use for full details.

If you are under the age of 13, or if you are giving us information about somebody under the age of 13, please ensure you have your/his/her parent’s permission before you give us the information.

How you can access and update your information

You have the right as an individual to manage the personal information we hold about you and make amendments to it if this is necessary.  If you notice that the information we hold about you is no longer correct, please let us know on, by writing to us at Kemp House, 160 City Road, London, EC1V 2NX. You can also update your account information when you sign in to your account.

You have the right to ask for a copy of the information Subshare holds about you and to receive it from us within 30 days. Please contact us on the details above to make this request.

Your additional rights

You have the following rights:

  • to withdraw any consent you might have given to Subshare to receive marketing communications and general information about our services.
  • to object to Subshare using your personal information, even if we rely on our legitimate interests to make use of it.
  • to erase your personal information or restrict its use.
  • to complain to the Information Commissioner as the relevant United Kingdom supervisory authority regulating data privacy matters (if you need to make a complaint, the content details for the Information Commissioner are as follows:-

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF (telephone: 0303 123 113,

Security precautions in place to protect the loss, misuse or alteration of your information

We take steps to ensure any personal information you give us is treated securely. We take all appropriate technical and organisational measures to ensure the integrity and security of the personal information we hold. We use Microsoft Azure encryption to protect your information.

All credit and debit card details are transmitted using Secure Socket Layer (SSL) encryption. Subshare also complies with the Payment Card Industry Security Standards. Your card details will be stored as long as you are a user of our Platform.

Where we have given you or you have chosen a password which enables you to access our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.


We will also collect information on search terms, location, searches you have made elsewhere on the internet and pages you have visited on Facebook and Instagram and may analyse this information in order to ensure our search function provides the most accurate results possible for you and to improve the search function on our Site and Platform.

You may choose not to allow us to do this. If you would like to do so, please contact us on the details above.

Use of cookies

We use cookies to distinguish you from other users of our Site or our Platform. This helps us provide you with a good experience when you use our Platform or browse our Site and also helps us improve our Site and our Platform. You can choose to switch off cookies in your browser settings but if you do you may notice a loss of functionality when using our Site or our Platform. You are welcome to contact us if you want any more information about the cookies we use.

Version 8     4 June 2018