Privacy Policy

This Privacy Policy explains how personal data is collected and used when you visit https://harmonia-b2b.com, apply for access, or use the Harmonia for Business customer console and player apps (together, the "Service").

1.1. The controller of your personal data is Adekom PromMash LLP, BIN 141140004501, 1/66 Promyshlennaya St., Ust-Kamenogorsk 070004, East Kazakhstan Region, Republic of Kazakhstan ("we", "us").

1.2. For any privacy question or request, contact us at legal@harmonia-b2b.com.

1.3. The Service is a business-to-business service. Most of the personal data we handle belongs to people who represent our business customers and applicants, and to visitors of our website.

2.1. Application form. When you request access, we collect the details you enter, such as your name, business email, phone or WhatsApp number, company name, country, type of venue, number of locations and your message.

2.2. Account data. For approved customers: names, roles and email addresses of users who access the console, log-in details, account settings and a history of actions in the console.

2.3. Business and billing data. Company name, registration or tax number, billing address, contact persons, invoices, payment amounts and dates. We do not collect or store full payment card numbers; if card payments are added, card data will be handled directly by the payment provider.

2.4. Venue data. Addresses of your locations, zones, playback schedules and audio files you upload (ads and announcements).

2.5. Usage and playback logs. What was played, when and in which location (used for broadcast reports), player status, device and browser type, IP address and technical logs.

2.6. Support communications. Messages you send us by email, chat, phone or WhatsApp.

2.7. Website data. Cookies and similar technologies, IP address, browser and device information, pages visited, and the source of your visit (for example, campaign parameters or the referring website). See our Cookie Policy.

2.8. We do not intentionally collect special categories of personal data (such as health, religious or political data) or biometric data. The Service is not intended for people under 18.

3.1. Reviewing applications and contacting you about access, pricing and onboarding. Legal basis: steps taken at your request before entering into a contract; our legitimate interest in responding to business inquiries.

3.2. Providing the Service: creating and running accounts, playing music in your locations, scheduling your audio, issuing license certificates and broadcast reports, and providing support. Legal basis: performance of our contract with the customer; our legitimate interest in serving the people who work for our customers.

3.3. Billing and accounting. Issuing invoices, receiving payments, keeping financial records. Legal basis: performance of a contract; compliance with legal obligations.

3.4. Security and fraud prevention: logging access, detecting unauthorized use, investigating incidents and enforcing our Terms (including the limits of the music license). Legal basis: our legitimate interests.

3.5. Website analytics to understand how the website is used and improve it. Legal basis: our legitimate interests or, where required by law, your consent.

3.6. Product news and offers sent to business contacts. Legal basis: our legitimate interests or your consent, as required by the law that applies to you. You can unsubscribe at any time.

3.7. Legal compliance: responding to lawful requests from authorities, and establishing or defending legal claims. Legal basis: legal obligation; our legitimate interests.

4.1. We do not sell personal data. We share it only with service providers that process it on our behalf and under our instructions, to the extent needed for their work:

• cloud hosting, storage and backup providers;
• email providers (business email and email delivery);
• messaging services used to notify our sales team about new applications and to talk to customers who contact us by messenger;
• web analytics providers;
• banks and, when added, payment providers that process payments;
• professional advisers such as accountants and lawyers.

4.2. We may also disclose data when required by law, to protect our rights, or as part of a merger, acquisition or sale of assets, subject to appropriate confidentiality.

4.3. A current list of our main service providers is available on request at legal@harmonia-b2b.com.

5.1. We are based in the Republic of Kazakhstan, and our service providers may process data in other countries. This means your data may be transferred to and processed in countries outside your own, including countries that do not have the same level of data protection as the European Economic Area or the United Kingdom.

5.2. Where the law requires it, we protect such transfers with appropriate safeguards, such as standard contractual clauses approved by the European Commission, or rely on another lawful transfer mechanism. You can ask for more information at legal@harmonia-b2b.com.

• Applications that do not become customers: up to 3 years after our last contact.
• Account and venue data: for the duration of the subscription and up to 3 years after it ends. Uploaded audio may be deleted 30 days after the subscription ends.
• Billing and accounting records: for as long as required by tax and accounting laws, usually at least 5 years.
• Security and technical logs: up to 12 months.
• Analytics data: up to 24 months.
• Marketing contacts: until you unsubscribe or object.

After these periods, we delete or anonymize the data, unless we need to keep it longer to comply with the law or to resolve a dispute.

7.1. We use technical and organizational measures to protect personal data against unauthorized access, loss, alteration and disclosure. These include access control based on roles and least privilege, encrypted connections, regular backups, software updates and security logging.

7.2. If a personal data breach occurs, we investigate it, take steps to limit its effects, and notify the competent authorities and affected people where the law requires it.

8.1. Depending on the law that applies to you (including the EU and UK GDPR), you may have the right to:

• access the personal data we hold about you;
• have inaccurate or incomplete data corrected;
• have your data deleted;
• restrict how we use your data;
• object to processing based on our legitimate interests, including direct marketing;
• receive your data in a portable format and have it transferred to another provider;
• withdraw your consent at any time, where we rely on consent;
• lodge a complaint with a data protection authority in your country.

8.2. To exercise your rights, email legal@harmonia-b2b.com. We may ask you to confirm your identity. We reply within one month; if a request is complex, we may extend this as allowed by law and will tell you why.

8.3. Customers can also update their account details directly in the customer console.

9.1. Our website uses essential cookies, preference storage and analytics cookies. You can block or delete cookies in your browser settings. Details are in our Cookie Policy.

10.1. We may update this Policy. The current version is always available at https://harmonia-b2b.com/privacy-policy. If we make material changes, we will post a notice on the website or email our customers.

10.2. If you have questions about this Policy, contact us at legal@harmonia-b2b.com.