Privacy Policy

This Privacy Policy explains how comanager, Inc. collects, uses, discloses, and safeguards your personal information when you use the comanager platform. We are committed to transparency and to protecting your privacy rights.

This policy applies to all users of the comanager platform, including artists, managers, and collaborators. By accessing or using the platform, you consent to the practices described in this policy.

We collect information that you provide directly, information generated automatically through your use of the platform, and information from third-party sources when you connect external services.

• Account information: name, email address, profile picture, and authentication credentials.
• Artist and project data: artist profiles, release metadata, campaign details, and collaboration records you create.
• Usage data: pages visited, features used, interaction patterns, and workflow activity within the platform.
• Device and technical data: IP address, browser type, operating system, device identifiers, and session information.
• Communications: messages, feedback, and support requests you send to our team.
• Third-party integrations: data from services you connect to comanager, such as streaming platforms or social media accounts.

We use your information to provide, maintain, and improve the comanager platform, and to deliver a personalized experience tailored to your needs.

• Operate and deliver the core platform services, including AI agent features.
• Personalize recommendations, insights, and workflow suggestions.
• Analyze usage patterns to improve product performance and user experience.
• Communicate with you about updates, new features, and account notifications.
• Detect, prevent, and respond to security threats, fraud, and abuse.
• Comply with legal obligations and enforce our terms and policies.

We process your personal data based on one or more of the following legal grounds:

Consent: when you have given explicit consent for specific processing activities. Contract performance: when processing is necessary to fulfill our agreement with you. Legitimate interests: when processing is necessary for our legitimate business interests, provided those interests do not override your fundamental rights. Legal obligation: when processing is required to comply with applicable laws or regulations.

We do not sell your personal data. We share information only in the following limited circumstances:

• Service providers: trusted third parties that help us operate the platform, including hosting, analytics, email delivery, and customer support providers.
• Integrations: external services you choose to connect to your comanager account, at your direction.
• Legal requirements: when required by law, regulation, legal process, or governmental request.
• Business transfers: in connection with a merger, acquisition, reorganization, or sale of assets, with continued protection of your data.
• With your consent: when you explicitly authorize us to share information with a specific party.

We collect your mobile phone number only if you choose to provide it, and we confirm it with a one-time verification code before we send you anything. Providing a number is optional and is never required to use comanager.

If you opt in, we use your number only to send notifications about your own account, such as letting you know when your new Weekly Moves are ready. Message frequency varies, but you will receive at most one message per weekly edition.

• We never sell your phone number, and we never share it with third parties for their own marketing.
• Phone numbers and SMS consent are not shared with third parties for marketing purposes.
• Message and data rates may apply.
• You can stop messages at any time by replying STOP to any message, or by turning off SMS notifications in your profile settings.
• Reply HELP to any message for help, or contact us at legal@comanager.com.

Carriers are not liable for delayed or undelivered messages.

We retain your personal data only for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements.

When your data is no longer needed, we securely delete or anonymize it. You may request deletion of your account and associated data at any time through your account settings or by contacting our support team.

We implement comprehensive technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

• Encryption of data in transit and at rest using industry-standard protocols.
• Role-based access controls limiting data access to authorized personnel only.
• Regular security audits, vulnerability assessments, and penetration testing.
• Incident response procedures to quickly detect and address security events.
• Employee security training and confidentiality agreements.

While we strive to protect your data, no method of transmission or storage is completely secure. We encourage you to use strong passwords and enable two-factor authentication.

comanager may transfer and process your data in countries other than your country of residence. When we transfer data internationally, we ensure appropriate safeguards are in place, including standard contractual clauses or other approved transfer mechanisms, to protect your data consistent with this policy and applicable law.

Depending on your location, you may have the following rights regarding your personal data:

• Right of access: request a copy of the personal data we hold about you.
• Right to rectification: request correction of inaccurate or incomplete data.
• Right to erasure: request deletion of your personal data, subject to legal retention requirements.
• Right to restrict processing: request that we limit how we use your data in certain circumstances.
• Right to data portability: receive your data in a structured, machine-readable format.
• Right to object: object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: withdraw previously given consent at any time.

To exercise any of these rights, contact us at legal@comanager.com. We will respond to your request within the timeframe required by applicable law.

We use cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver relevant content.

Essential cookies are required for the platform to function properly and cannot be disabled. Analytics cookies help us understand how users interact with the platform so we can improve it. You can manage your cookie preferences through your browser settings.

comanager is not intended for individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 16, we will take steps to delete that information promptly.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by posting the updated policy on the platform and revising the effective date at the top of this page.

We encourage you to review this policy periodically. Your continued use of the platform after changes take effect constitutes acceptance of the revised policy.