TINPAN.AI PRIVACY POLICY

This policy explains what Tinpan Inc., a California corporation ("Tinpan," "we"), collects, why, who sees it, and your choices. One thing to understand up front: activity records are a core feature of Tinpan. Listens, bets, holds, brief entries, and submissions are logged and selectively disclosed between users by design. This policy explains how.

1. What we collect.

You provide:

• Account data: email address, login credentials or authentication information, handle, and settings.
• Contract Acceptance and Security Records: When you accept platform terms or the Submission Agreement, Tinpan records your account identifier, timestamp, version accepted, and IP address to establish legal assent and prevent fraud.
• Desk verification data: for desk verification, your real name, professional role, affiliation, and evidence of your connection to an artist. This is the most identifying information we hold; §5 explains its special handling.
• Songs and submissions: audio files, lyrics, titles, your authorship and rights attestations, and provenance information you supply — generation links, tool names, and timestamps, stored as you supplied them.
• Communications: messages you send us, requests (such as cross-bucket requests naming a target artist), and support inquiries.
• Payment information, if you buy paid features, processed by a payment processor (we do not store full card numbers).

Generated by your use:

• Listen logs: which account played which song, when, and for how long. This is a core platform record.
• Activity records: bets (with timestamps), holds, passes and pass reasons, shortlists, withdrawals, brief entries and withdrawals of them, notifications and their delivery status, and in-platform viewable history.
• Derived audio data: acoustic and musical information we compute from submitted audio, such as key, tempo, structure, similarity, and fit signals. Tinpan does not use submitted audio to identify a natural person, enroll a person's voice, compare a voice against an identity-linked template, or create or store voiceprints or other biometric identifiers, and we require service providers processing audio for us to follow the same restrictions.
• Technical data: IP address (from which approximate location may be inferred by our providers), device and browser information, and logs collected for security and operations.
• Cookies: cookies necessary to keep you signed in and operate the site. We do not use advertising cookies or pixel-based retargeting. Our hosting and database providers generate standard operational logs and telemetry used for security and performance; we do not run third-party advertising or behavioral analytics trackers.

From other sources: for desk verification we may consult professional and public sources (such as company sites, credits databases, professional profiles, and referrals from industry contacts) to confirm a claimed affiliation.

2. How we use it.

To operate the platform: hosting and streaming songs, enforcing sign-in and role-based access (a signed-out visitor sees only a masked preview; a signed-in member plays the 30-second clip or the full song; only a desk may place a hold), sorting buckets, running briefs, holds, and notifications, verifying desks, preventing fraud and bet manipulation, providing support, and maintaining the records described in this policy. To analyze audio for platform features such as similarity and duplicate detection, fingerprinting, feature extraction, and artist-fit matching. We may use platform data to improve search, ranking, matching, fraud detection, and recommendation systems.

We do not use your songs or demos to train models that generate music, lyrics, vocals, or other creative content; we do not provide them to third parties for that purpose; and we do not sell or license extracted audio features to third parties. Any vendor that processes platform audio on our behalf is contractually prohibited from using it to train models. We do not sell personal information and do not share it for cross-context behavioral advertising.

3. What other users see — the deliberate disclosures.

This section is a product rule, not just a notice; the interface is built to match it.

• Signed-out visitors to public bucket and brief pages do not see the song table. They see a masked preview of a few rows with identifying detail withheld, and must sign in to see titles, handles, counts, or to play anything.
• Writers are told when their song is heard, by the listener's role and verification tier (for example, "A&R — verified"); desk identity is masked to tier in that notification. When a desk places a Hold, the hold record identifies the holding desk — verified name, role, and affiliation — to the writer to enable deal communication. Desks are informed of this consequence before claiming a desk and before placing a Hold.
• Signed-in members see song titles, writer handles (or "Anonymous" where applicable), durations, play counts, and bet counts, and may play the clip or the full song. Desks additionally see, for songs on their claimed page, each song's attestations and provenance summary. Provenance packets are available only to the song's writer, the holding desk, the claiming desk, and Tinpan administrators.
• Pass reasons are private to the passing desk and Tinpan; they are never shown to writers or the public.
• Cross-bucket requests are visible to Tinpan administrators only; the writer is not notified unless Tinpan contacts them directly.
• Aggregate desk activity (such as "N songs heard this week") may be shown on bucket pages without identifying individuals.
• Tinpan administrators: Tinpan administrative personnel access unmasked verification files, backend records, and provenance packets strictly on a least-privilege, need-to-know basis solely for verifying identity, platform moderation, technical maintenance, customer support, safety, and legal compliance. Tinpan administrators are prohibited from using or disclosing nonpublic submission data or provenance records for outside personal or commercial purposes.

We never publicly display your email address. Your real name appears only in the desk contexts described above.

Submission means disclosure. Tinpan is a submission platform: when you drop a song, information about you and the submission is disclosed to other users as described here — including verified industry professionals, who are independent third parties, not Tinpan service providers.

4. Who else gets data.

Service providers that host and operate the platform on our instructions (cloud hosting, database, storage, audio processing, email delivery, and payment processing), bound by written agreements limiting their use of the data, including the no-training prohibition in §2. Professional advisers (lawyers, accountants) under confidentiality. Parties to a deal you approve, to the extent needed to paper it. Authorities when required by valid legal process or applicable law, and others when necessary to enforce our terms or protect rights and safety. Information may also be transferred as part of a merger, financing, acquisition, reorganization, or asset sale, subject to applicable law.

5. Retention.

We retain by category and criteria, not indefinitely:

• Account and profile data: while your account exists; deleted or de-identified within 30 days of account closure except as below.
• Desk verification: the fact, tier, outcome, and dates of verification are kept as account-security history; supporting evidence you submitted (documents, screenshots, correspondence) is deleted within 90 days after the verification decision unless needed for fraud prevention, an open dispute, or legal compliance.
• Routine technical and security logs: 12 months, then rotation.
• Submission, provenance, acceptance, listen, hold, withdrawal, and deal records: retained for 7 years after the later of withdrawal, last activity, or deal termination, reflecting provenance needs and legal limitation periods.
• Withdrawn songs: withdrawal promptly disables ordinary platform access. Backup copies persist until overwritten in the ordinary backup cycle (approximately 90 days); separate archival copies may be retained where reasonably necessary for provenance, legal compliance, or disputes.
• Account closure: personal data not needed for the purposes above is deleted or de-identified. Where activity records are kept for provenance continuity after closure, they are decoupled from your direct contact information and retained in pseudonymous form to the extent consistent with their record purpose.

A legal hold, active investigation, or legal requirement may suspend deletion for affected records until released.

6. Your rights and choices.

Whether or not a particular privacy law applies to Tinpan or to your request, Tinpan generally permits you to request access to, correction of, a portable copy of, or deletion of personal information associated with your account by emailing hello@tinpan.ai. We will verify the request and may retain information where reasonably necessary to provide the service, maintain security, prevent fraud, keep provenance and transaction records, comply with law, or establish, exercise, or defend legal claims; we will explain material limits on a request. In particular, audit logs, provenance packets, split attestations, and transaction records may be retained to defend against infringement, fraud, and contract claims. These voluntary practices do not represent that Tinpan is subject to a law that does not otherwise apply. Tinpan does not sell personal information and does not share it for cross-context behavioral advertising, and we do not discriminate against anyone for exercising privacy rights. Depending on where you live, applicable law may provide additional rights.

7. Automated processing.

Tinpan uses automated algorithmic processes to sort songs for discovery, filter fraudulent activity, and analyze acoustic compatibility (fit matching). Tinpan may derive private account-level signals from a member's activity, including an internal standing or rank reflecting demonstrated outcomes. These signals may be recalculated as additional activity and outcomes occur. They are not published as public rankings, shown to other members, used to increase the weight of a member's bets, or used to grant page, brief, or desk authority. They are not sold. Tinpan does not disclose the internal method by which they are calculated, which it may change at any time. These systems evaluate musical characteristics and platform engagement; they do not make decisions with legal or similarly significant effects concerning any individual (such as decisions about employment, credit, housing, insurance, or essential services).

8. Security.

We use administrative, technical, and organizational safeguards designed to protect personal information and to restrict access based on authorization, including access controls designed to restrict full-length audio to authorized accounts, encryption in transit and at rest, and logging. No system is perfectly secure; if a breach affects your personal information, we will notify you as required by law.

9. Children.

Tinpan is for adults (18+). You represent that you are at least 18 when you agree to the Terms of Service. We do not knowingly collect personal information from anyone under 18. If we learn that an account belongs to someone under 18, we will close it and delete associated personal information except where retention is permitted or required by law. Contact hello@tinpan.ai if you believe a minor has an account.

10. International users.

Tinpan is operated from the United States and is currently offered for the United States market. We do not currently target or intentionally offer Tinpan to individuals in the EEA or UK. Information may be processed in the United States and other countries where we and our service providers operate. If we begin targeting or intentionally offering Tinpan in the EEA or UK, we will implement applicable notices, rights processes, lawful transfer mechanisms, representative arrangements where required, and other compliance measures before doing so.

11. Changes.

We may update this policy; material changes will be notified in the product or by email with an effective date.

12. Summary table.

Contact: Tinpan Inc., Privacy · hello@tinpan.ai