Privacy Policy

1. Introduction and Data Controller

1.1 Who We Are

This Privacy Policy explains how A.T.O.H. International e.K. (“we,” “us,” “our,” or “TIP-DJ”) collects, uses, stores, and protects your personal data when you use the TIP-DJ platform and services (the “Service”).

We are committed to protecting your privacy and being transparent about our data practices. By using TIP-DJ, you acknowledge that you have read and understood this Privacy Policy.

1.2 Data Controller Information

A.T.O.H. International e.K.

Meiendorfer Rund 47
22145 Hamburg
Germany

Data Protection Contact: info@tip-dj.com
Customer Support: info@tip-dj.com

If you have questions about how we handle your data or wish to exercise your privacy rights, contact us using the details above.

2. Data We Collect

We collect different categories of data depending on how you use TIP-DJ. All data collection is necessary to provide the Service.

2.1 DJ Account Holders - Data Collected

When you create a DJ account on TIP-DJ, we collect the following categories of data:

Identity Data:

• Email address
• Username
• Stage name / Professional name
• Phone number (optional)

Payment Data:

• Stripe Connect account information (bank details, business registration)
• Payout history and earnings records

Profile Data:

• Bio / Professional description
• Profile photo or avatar
• Performance history (dates, venues, set times)

Audio Data (Requires Microphone Access):

Audio Recording and Microphone Access: When you start a DJ set session, TIP-DJ will request access to your device's microphone via a standard browser permission prompt. By granting microphone access, you consent to audio being captured and processed for song verification purposes as described in this section. If microphone access is denied, song verification will not function and tip payouts dependent on verification cannot be processed.

• Live set recordings: Audio captured from your device's microphone during DJ sets where requests are accepted
• Acoustic fingerprints: Unique digital signatures of songs created by ACRCloud for song verification purposes
• Duration: From set start time to set end time
• Frequency: Recorded for every DJ set where song requests are accepted
• Purpose: To verify that requested songs were played using automated audio recognition technology, and to power the real-time song request ranking system

Third Parties and Background Audio:

Please be aware that audio recording captures the full ambient sound of your performance environment. This may include background conversations of venue guests within microphone range, third-party performers or co-DJs present at the venue, and venue ambient noise and announcements. You are responsible for ensuring that all persons who may be recorded at your venue are appropriately informed of recording activity, in accordance with applicable local laws. In Denmark and other jurisdictions, transparency to venue occupants about recording is a legal requirement. We recommend displaying a visible notice at your venue when TIP-DJ recording is active.

Transaction Data:

• Tips received and payout amounts
• Dates and times of transactions
• Request acceptance/decline history
• Refund records

Technical Data:

• IP address
• Device type and operating system
• Browser type and version
• Device identifiers (where applicable)

Usage Data:

• Login history and timestamps
• Session activity (requests viewed, settings changes)
• Platform feature usage

2.2 Users Who Send Tips (Guests) - Data Collected

When you send tips or song requests through TIP-DJ, we collect the following:

Transaction Data:

• Tip amount
• DJ recipient
• Date and time of transaction
• Song requested (title, artist, key, BPM)
• Optional message or note with the request
• Request status (accepted, declined, expired, verified, refunded)

Payment Data:

• Card last 4 digits
• Card expiration month/year (stored by us; full card details managed by Stripe)
• Billing zip code (if provided)
• Name (if provided for guest tips; otherwise not required)
• Email address (if provided for guest tips; otherwise not required)

Technical Data:

• IP address
• Device type and operating system
• Browser type and version
• Device identifiers (where applicable)

Optional Data:

• Name and email (only if you choose to provide them for guest tips)
• Custom tip messages or notes

2.3 Data From Third Parties and Automated Collection

We may receive data from:

Payment Processors:

• Stripe: Transaction confirmations, fraud screening results, chargeback information, disputes

Automated Processes:

• Log files: Server logs recording access attempts, errors, and system activity
• Cookies and similar tracking technologies: Session management, analytics, authentication
• Analytics tools: General platform usage patterns, feature popularity, performance metrics

3. Legal Basis for Data Processing

Under GDPR, we process your data based on the following legal foundations:

3.1 Contract Performance (Legal Basis: Article 6(1)(b) GDPR)

We process data necessary to:

• Create and manage your account
• Process payments and tips
• Verify song playback using ACRCloud
• Calculate DJ payouts
• Provide customer support
• Send transactional emails (payment confirmations, refund notifications, payout updates)

3.2 Consent (Legal Basis: Article 6(1)(a) GDPR)

We process certain data based on your consent:

Audio recording for song verification: By granting microphone access via your browser when starting a DJ set session, you consent to audio being captured and processed for song verification purposes.

AI-powered request ranking: TIP-DJ's song request queue is ranked in real time using an AI system that analyses what the DJ is currently playing and predicts which requests best fit the current set. This ranking is a core function of the Service. By using TIP-DJ, you consent to anonymized audio and request data being processed for this purpose. You may withdraw this consent at any time by emailing info@tip-dj.com, but doing so will disable real-time request ranking for your sessions.

You may withdraw any consent at any time without affecting the lawfulness of processing before withdrawal.

3.3 Legal Obligations (Legal Basis: Article 6(1)(c) GDPR)

We process data when required by law:

• Tax reporting and financial compliance (7-year retention)
• Money laundering prevention (AML/KYC requirements)
• Payment processor compliance (Stripe regulatory requirements)
• Response to lawful government requests

3.4 Legitimate Business Interests (Legal Basis: Article 6(1)(f) GDPR)

We process data for purposes where our business interests do not override your rights:

Fraud Prevention and Security:

• Detecting and preventing fraudulent transactions
• Protecting against unauthorized account access
• Monitoring for suspicious activity patterns (velocity checks, geographic anomalies)
• Protecting platform integrity and other users

Service Improvement and Analytics:

• Analyzing how users interact with the platform
• Identifying technical issues and bugs
• Understanding feature usage to guide product development
• Measuring service performance and reliability

Business Operations:

• Internal reporting and business planning
• Quality assurance and staff training
• Enforcing our Terms and Conditions
• Protecting our legal rights and defending claims
• Communicating platform updates and service announcements

Direct Marketing and Onboarding (for DJs):

• Contacting DJs sourced from trusted third-party partner platforms who have a lawful basis to share contact data with us, where those DJs have not opted out of such communications
• Sending onboarding emails to new DJs
• Sharing tips for maximizing earnings
• Notifying about feature updates and opportunities
• Promotional communications (only if you have not opted out)

You have the right to object to processing based on legitimate interests (see Section 8 - Your Rights).

4. How We Use Your Data

4.1 To Provide the Service

Account Management:

• Creating and securing your TIP-DJ account
• Authenticating your identity and managing access

Payment Processing:

• Authorizing, capturing, and processing tip payments
• Managing refunds and chargebacks
• Calculating DJ commissions and payouts
• Ensuring PCI-DSS compliance for payment data

Service Verification:

• Recording audio from DJ sets (via browser microphone access) to verify song playback
• Using ACRCloud to identify songs and create acoustic fingerprints
• Comparing requested songs against actual performance
• Determining payout eligibility based on the 75% confidence threshold (see Section 10)
• Resolving disputes about specific transactions

Real-Time Request Ranking:

• Analysing audio and request data in real time to rank incoming song requests by relevance to the DJ's current set
• Improving the ranking model based on anonymized session data

Transactional Communications:

• Sending payment confirmations
• Notifying about request acceptance/decline
• Sending refund notifications
• Sharing payout confirmations and earning reports
• Providing receipts and transaction history

Customer Support:

• Responding to your inquiries
• Investigating and resolving issues
• Providing technical assistance

4.2 To Improve the Service

Analytics and Optimization:

• Understanding which features users engage with most
• Identifying performance bottlenecks
• Tracking conversion and engagement metrics
• A/B testing to improve user experience
• Analyzing geographic and temporal usage patterns

Product Development:

• Identifying user needs and feature requests
• Prioritizing development efforts based on usage data
• Planning new features and services

4.3 For Fraud Prevention and Security

Transaction Monitoring:

• Detecting unusual payment patterns or amounts
• Identifying geographic inconsistencies
• Monitoring for velocity abuse (multiple rapid transactions)
• Identifying potential chargebacks or dispute patterns

Account Security:

• Detecting unauthorized access attempts
• Identifying compromised credentials
• Monitoring for suspicious login activity
• Implementing security alerts

Regulatory Compliance:

• Preventing money laundering and terrorist financing
• Complying with anti-fraud regulations
• Supporting law enforcement investigations (when legally required)

4.4 To Communicate With You

Service Updates:

• Announcing platform changes or maintenance
• Notifying about new features or feature updates
• Sharing important policy changes

Onboarding (DJs):

• Guiding new DJs through setup and best practices
• Sharing strategies for maximizing earnings
• Providing tips for engagement with Guests

Marketing (Optional):

• Promotional emails about new features
• Invitations to special events or partner opportunities
• Survey requests to improve the service
• You can opt out of marketing emails at any time

4.5 Use of Anonymized Audio Data for Service Improvement

TIP-DJ uses anonymized audio and request data for the following strictly limited purposes:

• Platform Analytics – analyzing anonymized music preference patterns (time of day, genre trends) to provide aggregate insights to DJs
• Audio Recognition Improvement – improving the accuracy of ACRCloud song matching for DJ-specific environments (transitions, remixes, overlapping tracks)
• Trend Analysis – identifying anonymized music trends and genre patterns at a population level
• Recommendation Algorithm – improving the song request queue by analyzing which songs perform well in which contexts, to better surface relevant suggestions to guests and DJs

What we will NOT do:

• Use audio data for purposes beyond those listed above without first obtaining fresh, specific consent
• Sell, license, or share audio data with third-party AI or research companies
• Publish, broadcast, or distribute raw DJ recordings in any form
• Upload DJ sets to any public platform (SoundCloud, Spotify, YouTube, etc.)

Opt-Out: You may withdraw consent for AI ranking and anonymized data use at any time by emailing info@tip-dj.com with subject line “Withdraw AI Research Consent.” We will confirm withdrawal within 5 business days. Note that withdrawing this consent will disable real-time request ranking for your sessions.

5. Who We Share Your Data With

5.1 Payment Processors

Stripe:

• Role: Payment processing, payout management, and fraud detection
• Data shared: Transaction details, card information (last 4 digits), payout amounts, account information
• Stripe acts as: A data processor (handling payments on our behalf) and an independent data controller (for their own fraud prevention and compliance)
• Stripe's Privacy Policy: https://stripe.com/privacy
• Data location: Servers in the United States and EU
• Transfer safeguards: Standard Contractual Clauses (SCCs) + Transfer Impact Assessment conducted

5.2 Service Providers and Data Processors

All service providers are contractually bound to process data only as instructed and in compliance with GDPR.

Infrastructure and Hosting:

• Google Cloud Platform – Cloud infrastructure, database hosting, server management. Data stored in Belgium, EU (europe-west1). DPA in place.

Audio Recognition and Verification:

• ACRCloud – Audio fingerprinting and song identification. Data shared: acoustic fingerprints and verification queries (no raw audio transmitted). Location: US-based servers. DPA in place. Transfer safeguards: SCCs + Transfer Impact Assessment conducted.

Email Services:

• IONOS – Transactional email delivery. Data shared: email addresses, transaction summaries. Location: Germany, EU. DPA in place.

Song Metadata and Search:

• Deezer – Song database, metadata (BPM, key, genre), search functionality. DPA in place.

5.3 Financial Institutions and Payment Networks

To process payments and payouts, your data flows through card networks (Visa, Mastercard, etc.), your bank or card issuer, and regulatory bodies for AML/KYC compliance. These entities are independent data controllers with their own privacy policies.

5.4 Regulatory and Legal Authorities

We may share your data when required by law with tax authorities, law enforcement (in response to valid legal requests), and regulatory bodies for payment compliance or AML investigations.

5.5 Business Transfers

If TIP-DJ is acquired, merged, or restructured, your data may transfer to the new owner. We will notify you of any such change. The new owner must comply with this Privacy Policy or provide notice of changes.

5.6 With Your Direction

DJ stage name, profile photo, and bio are publicly visible on the TIP-DJ platform. When a Guest sends a tip, the DJ sees the song requested, tip amount, optional message, and display name (if provided) or anonymized identifier. DJs do not see the Guest's full email address, payment card, or personal contact details.

5.7 Commercial Data Partners

Receiving Data from Partners

We may from time to time receive DJ contact information from trusted third-party platform partners operating in the DJ and music industry, where those partners have obtained appropriate consent or have a lawful basis to share such data. Where we receive such data, we will only use it to contact DJs about TIP-DJ's services and will handle it in full compliance with GDPR. You may opt out of such communications at any time by clicking unsubscribe or emailing info@tip-dj.com.

Sharing Data with Partners

We may share your personal data including name, email address, and general location with carefully selected third-party partner companies operating in the DJ and music industry for marketing and commercial partnership purposes. We will only do this where you have given consent at registration or have not opted out where processing is based on legitimate interests.

Referral Tracking

We may share aggregated or pseudonymised referral performance data (e.g. number of sign-ups attributed to a partner, revenue generated) with commercial partners solely for the purpose of calculating referral compensation. No further personally identifiable information is shared with partners beyond a unique referral code linked to your sign-up.

Your Rights

You have the right to object to your data being shared with commercial partners at any time by emailing info@tip-dj.com with subject line “Opt Out of Data Sharing.” We will action this within 5 business days.

6. International Data Transfers

6.1 Primary Data Location (EU-Based)

Your data is primarily stored within the European Economic Area:

• Primary infrastructure: Belgium (Google Cloud Platform, europe-west1)
• Email services: Germany (IONOS)
• Song metadata: EU-based Deezer infrastructure

6.2 International Transfers (Outside EU)

Stripe (United States):

• Payment processing requires data transfer to US-based Stripe servers
• Safeguards: Standard Contractual Clauses (SCCs) + Transfer Impact Assessment

ACRCloud (International):

• Acoustic fingerprints transferred for song identification (no raw audio transmitted)
• Safeguards: Standard Contractual Clauses (SCCs) + Transfer Impact Assessment

6.3 Schrems II Compliance

Following the Court of Justice of the EU's Schrems II ruling (Case C-311/18), we have conducted Transfer Impact Assessments (TIAs) for all key third-country transfers (Stripe and ACRCloud). Where gaps were identified, we implemented supplementary safeguards including:

• Technical measures: End-to-end encryption in transit; pseudonymization of personal identifiers before transfer where technically feasible; only acoustic fingerprints (not raw audio) transferred to ACRCloud
• Contractual measures: Enhanced DPAs requiring recipients to notify TIP-DJ of government access requests and to challenge overbroad requests where legally permissible
• Organizational measures: Access restricted to personnel strictly necessary for the service; annual compliance reviews

You can request a copy of our TIA documentation by contacting info@tip-dj.com.

7. How Long We Retain Your Data

7.1 Data Retention Schedule

7.2 Account Deletion

When you delete your account, your personal data is anonymized, your transaction history is retained for 7 years in anonymized form for tax compliance, and pending requests are automatically declined and refunded. Anonymization is irreversible.

8. Your Privacy Rights

8.1 Your GDPR Rights

Right of Access (Article 15) – Request a copy of all personal data we hold. Response within one month.

Right to Rectification (Article 16) – Ask us to correct inaccurate or incomplete data.

Right to Erasure (Article 17) – Request deletion unless legally required to retain.

Right to Restriction (Article 18) – Ask us to limit processing while resolving a concern.

Right to Portability (Article 20) – Request your data in CSV or JSON format.

Right to Object (Article 21) – Object to processing based on legitimate interests, including marketing (absolute right).

Right to Withdraw Consent (Article 7(3)) – Withdraw consent for audio recording or AI use at any time without affecting prior processing.

Right to Lodge a Complaint (Article 77) – Contact your local data protection authority.

8.2 How to Exercise Your Rights

Through Your Account:

• Access / Portability: Settings > Privacy > Download My Data
• Rectification: Edit profile in account settings
• Erasure: Settings > Account > Delete Account

Via Email: Send to info@tip-dj.com with subject “GDPR Request.” Include your name, email, and description of your request. We will verify your identity and respond within one month.

8.3 Objecting to Specific Processing

• Marketing emails: Click “Unsubscribe” in any marketing email or go to Settings > Communication Preferences
• AI ranking / research use: Email info@tip-dj.com with subject “Withdraw AI Research Consent” – confirmed within 5 business days. Note this will disable real-time request ranking.
• Analytics: Contact us if you have specific concerns

9. Data Security and Protection Measures

9.1 Technical Measures

• Encryption in transit: TLS 1.2 or higher for all data between your device and our servers
• Encryption at rest: AES-256 for sensitive data (audio, payment information, personal identifiers)
• Access controls: Role-based access, multi-factor authentication options, activity logging
• Monitoring: Intrusion detection, regular security audits and vulnerability assessments

9.2 Organizational Measures

• All staff receive data protection training and are bound by confidentiality agreements
• Privacy-by-design and data minimization principles applied throughout
• Incident response procedures in place; affected users notified within 72 hours of a qualifying breach

9.3 PCI-DSS Compliance

We do not store full card numbers. Stripe handles full card details as a PCI-DSS Level 1 certified processor.

9.4 Limitations

No system is completely secure. If you believe your account has been compromised, contact us immediately at info@tip-dj.com.

10. Automated Decision-Making and Profiling

10.1 Song Verification System - How It Works

TIP-DJ uses an automated audio recognition system (powered by ACRCloud) to verify that DJs have played requested songs:

• When a Guest submits a song request and tip, the song title and artist are recorded
• During the DJ set, TIP-DJ captures audio via microphone and sends acoustic fingerprints to ACRCloud
• ACRCloud returns a confidence score (0-100%) for each song detected
• If the confidence score reaches 75% or above, the song is marked “verified” and the tip is released for payout
• If the confidence score remains below 75% throughout the set, the song is marked “unverified” and the tip may be withheld or refunded

Factors that can affect the score include microphone quality, background noise, DJ remixes or edits, and partial plays.

10.2 Your Right to Human Review

You have the right to request human review of any automated verification decision. If you believe a song was incorrectly marked as unverified:

• Contact info@tip-dj.com with subject line “Verification Dispute”
• Include the transaction ID, date, time, and song title
• A human reviewer will examine the audio record and ACRCloud confidence data within 10 business days
• We will explain the outcome and, if the decision was incorrect, correct the payout accordingly

We do not make any other decisions with significant legal or financial effect based solely on automated processing without the possibility of human review.

10.3 Fraud Detection Systems

Stripe automatically flags transactions based on risk signals. If a transaction is flagged or blocked, contact info@tip-dj.com and a human reviewer will examine the case and explain the reason for the block.

11. Consumer Rights and Dispute Resolution

11.1 Dispute Resolution

If you have a complaint about our Service that we have not resolved to your satisfaction, you may contact your national consumer protection authority or an applicable alternative dispute resolution body in your country of residence. We will cooperate fully with any such process.

Our contact for dispute resolution: info@tip-dj.com

11.2 Withdrawal Rights

TIP-DJ provides a digital service that begins immediately upon purchase (tip transaction). By initiating a tip payment, you expressly acknowledge that the digital service commences immediately and that your right of withdrawal is therefore excluded in accordance with Article 16(m) of EU Directive 2011/83/EU.

Where a tip is not verified (song not played), our standard refund process applies automatically - see our Terms and Conditions for full details.

11.3 Governing Law and Consumer Protections

This Privacy Policy is governed by the laws of the Federal Republic of Germany. However, if you are a consumer residing in another EU/EEA member state, you retain all mandatory consumer protection rights granted by the laws of your country of residence, regardless of this governing law clause. Nothing in this Privacy Policy limits or overrides those rights.

12. Third-Party Links and Services

The TIP-DJ platform may contain links to third-party websites and services (e.g., Spotify, Deezer, Stripe). We are not responsible for the privacy practices or security of third-party websites. Review the privacy policies of any third-party services before providing data.

13. Children and Age Restrictions

The TIP-DJ Service is not intended for anyone under 18 years old. We do not knowingly collect data from children. If you believe we have collected data from a child, contact us immediately at info@tip-dj.com and we will delete the data and suspend the account.

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our data practices, new features, or legal requirements. We will notify you of material changes by email (at least 30 days' notice) and by updating the “Last Updated” date. For changes requiring new consent, we will request this before your next transaction.

15. Contact and Complaints

A.T.O.H. International e.K.

Meiendorfer Rund 47
22145 Hamburg, Germany
Email: info@tip-dj.com
Subject: “Data Protection Request” or “Privacy Inquiry”
Response time: Within one month (up to three months for complex requests)

Supervisory Authority - Germany:

Bundesbeauftragte für Datenschutz und Informationsfreiheit (BfDI)
https://www.bfdi.bund.de
Email: poststelle@bfdi.bund.de

16. Summary: Your Privacy at a Glance

Last Updated: March 19, 2026