Who we are
Surge Content Limited ("Surge", "we", "us", "our") is a marketing company registered in England and Wales under company number 16415580, with its registered office at 167-169 Great Portland Street, London, England W1W 5PF.
We are the data controller for the personal data described in this policy.
For any question about this policy or about how we handle personal data, contact us at hello@surgemusic.io.
What this policy covers
This policy explains how we collect, use, share and protect personal data when you:
- visit surgecontent.io;
- contact us or submit an enquiry;
- work with us as a client, or as a contact at a label, management company, distributor or artist team;
- apply to work with us, or work with us as an employee or contractor;
- receive updates or marketing from us.
It also explains, in outline, how we handle personal data when delivering campaigns for our clients.
We do not knowingly collect personal data from children. Our website and services are directed at businesses and professionals in the music industry.
The personal data we collect
When you visit the website. Technical data including IP address, browser type and version, device type, operating system, approximate location derived from IP address, referring source, pages viewed, and time spent on the site. This is collected through cookies and similar technologies - see section 6.
When you contact us. Your name, email address, phone number where you provide it, company or artist name, job title, and the content of your message, including any campaign or release details you choose to share.
When we work with you as a client. Business contact details, correspondence, campaign briefs and assets, billing and payment details, and records of the services we have provided.
When you apply to work with us. Your CV, contact details, work history, portfolio or examples of previous work, right-to-work or contractor status information, and interview or assessment notes.
When we deliver campaigns. In the course of running campaigns we process publicly available social media information, including creator handles, public profile information, public post content and publicly reported engagement and performance metrics. Where individual creators, editors or contractors work on a campaign, we process their contact details, payment details and work records.
When you receive marketing from us. Your contact details and records of what we have sent you and whether you have opened or engaged with it.
We do not intentionally collect special category personal data (such as data revealing health, ethnicity, religion or political opinions) and we ask that you do not send it to us.
How we use personal data, and our lawful basis
| What we use it for | Lawful basis |
|---|---|
| Responding to enquiries and preparing proposals | Legitimate interests (responding to a request made to us); steps prior to entering a contract |
| Delivering campaigns and managing client relationships | Performance of a contract; legitimate interests where the contract is with a company rather than an individual |
| Invoicing, payment and credit control | Performance of a contract; legal obligation (accounting and tax records) |
| Managing contractors, editors and account operators | Performance of a contract; legitimate interests |
| Recruitment and assessing applications | Legitimate interests; steps prior to entering a contract; legal obligation (right to work) |
| Website analytics and improving the site | Consent (for non-essential cookies); legitimate interests |
| Sending business updates and marketing to industry contacts | Legitimate interests, or consent where required |
| Security, fraud prevention and protecting our business | Legitimate interests |
| Complying with legal, regulatory and tax obligations | Legal obligation |
Where we rely on legitimate interests, we have considered the impact on your privacy and are satisfied that our interests do not override your rights. You can ask us for more detail on that assessment at any time.
Marketing
We may send you information about our services if you have enquired about them, worked with us, or if you are a professional contact in the music industry and we reasonably believe the information is relevant to your role.
You can opt out at any time using the unsubscribe link in any email, or by emailing hello@surgemusic.io. Opting out of marketing will not stop us sending you communications relating to a campaign or contract we are delivering for you.
Cookies and analytics
Our website uses cookies and similar technologies. Some are strictly necessary for the site to function. Others help us understand how the site is used, or measure the performance of our advertising.
We use:
- Strictly necessary cookies - required for site security and core functionality. These do not require consent.
- Analytics cookies - to understand how visitors find and use the site, so we can improve it. We use Google Analytics.
- Advertising and measurement cookies - where we run paid campaigns, to measure their effectiveness. We use Meta Pixel, TikTok Pixel and LinkedIn Insight Tag.
Non-essential cookies are only set where you have given consent through our cookie banner. You can change or withdraw your preferences at any time via [COOKIE SETTINGS LINK], or by adjusting your browser settings. Blocking cookies may affect how parts of the site work.
Who we share personal data with
We share personal data with:
- Service providers who process data on our behalf, including cloud hosting and storage, email and productivity tools, project management and CRM systems, mobile device and account infrastructure providers, analytics providers, accounting software and payment processors. These providers act on our instructions under written contracts.
- Contractors and freelancers engaged to deliver campaign work, where access to the relevant information is necessary for their role.
- Our clients, where campaign reporting includes information about the work delivered.
- Professional advisers, including lawyers, accountants and insurers.
- Regulators, tax authorities and law enforcement, where we are required to do so by law.
- A buyer or successor, if we sell or reorganise all or part of our business.
We do not sell personal data.
International transfers
We work with clients, contractors and service providers in a number of countries, including the United States and countries in Europe, the Middle East and Asia. This means personal data may be transferred outside the UK.
Where we transfer personal data outside the UK, we make sure it is protected by one of the following:
- the country has UK adequacy regulations in place;
- the transfer is covered by the International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses; or
- another safeguard permitted under UK data protection law applies.
You can request details of the safeguards applied to a specific transfer by contacting us.
How long we keep personal data
We keep personal data only for as long as we need it.
- Enquiries that do not become client relationships: up to 24 months from last contact.
- Client records and campaign records: for the duration of the relationship and for 6 years afterwards, to meet contractual and legal requirements.
- Financial and tax records: 6 years from the end of the relevant accounting period.
- Recruitment records for unsuccessful applicants: up to 12 months, unless you agree to us keeping them longer.
- Marketing contact records: until you opt out, or until the contact is no longer relevant.
Where data is no longer needed, we delete it or anonymise it securely.
How we protect personal data
We use appropriate technical and organisational measures to protect personal data, including access controls, multi-factor authentication on business systems, encryption in transit, role-based access to client information, and contractual confidentiality obligations on staff and contractors.
No transmission over the internet is completely secure. Where we are legally required to do so, we will notify you and the ICO of a personal data breach.
Your rights
Under UK data protection law you have the right to:
- access the personal data we hold about you;
- rectification of inaccurate or incomplete data;
- erasure of your data in certain circumstances;
- restrict how we process your data in certain circumstances;
- object to processing based on legitimate interests, and to object to direct marketing at any time;
- data portability, where processing is based on consent or contract and is automated;
- withdraw consent at any time, where we rely on consent. This does not affect processing carried out before withdrawal.
To exercise any of these rights, email hello@surgemusic.io. We will respond within one month. We may ask you to verify your identity first. There is normally no charge.
Complaints
If you are unhappy with how we have handled your personal data, please contact us first so we can try to resolve it.
You also have the right to complain to the Information Commissioner's Office:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
ico.org.uk
Third-party platforms
Our services operate on third-party platforms including TikTok, Instagram, YouTube and Spotify. Those platforms are independent data controllers for the data they collect, and their own privacy policies apply. We have no control over how they process personal data.
Changes to this policy
We may update this policy from time to time. Where changes are significant, we will make that clear on this page and, where appropriate, notify you directly. The date at the top of this page shows when it was last updated.
Contact us
Surge Content Limited
167-169 Great Portland Street, London, England W1W 5PF
hello@surgemusic.io