SleeveFM, Inc. - Privacy Policy

Effective Date: January 1st, 2025

Last updated: May 28, 2026

1. Introduction

SleeveFM, Inc. ("SleeveFM," "we," "us," or "our") is committed to protecting your privacy and respecting your rights. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform, website, and services (collectively, the "Service").

By accessing or using the Service, you consent to the collection, use, processing, and disclosure of your information in accordance with this Privacy Policy and any applicable laws.

2. Information We Collect

We may collect the following types of information:

a. Personal Information: When you register for an account, use the Service, or communicate with us, we may collect personal information such as your name, email address, payment information, and other details you provide.

b. Usage Information: We collect information about your interactions with the Service, including your IP address, browser type, device information, pages visited, and other usage data.

c. Cookies and Tracking Technologies: We use cookies, web beacons, and similar tracking technologies to enhance your experience on Sleeve, improve the performance of our Service, and provide essential functionalities. These technologies help us understand how users interact with our platform, identify and fix issues, and optimize their experience.

We use the following types of cookies:

• Essential Cookies: Necessary for the operation of the Service, maintaining your session, and providing basic functionalities.
• Product Analytics Cookies: Used to gather insights into how our platform is used, helping us improve functionality and user experience. We use PostHog for product analytics.
• Error Tracking Cookies: Used to detect, report, and fix bugs or technical issues, ensuring stability and reliability. We use Sentry for error tracking.
• Payment Processing Cookies: Necessary for handling transactions and ensuring secure payments. We use Stripe for payment processing.

We do not use cookies for marketing, advertising, or profiling purposes. We do not sell your personal information or share it with third parties for cross-context behavioral advertising.

By using Sleeve, you agree to our use of cookies and similar technologies as described above. For more information on how we use these technologies, please refer to our Cookie Policy.

3. How We Use Your Information

We may use the information we collect for various purposes, including to:

• Provide, operate, and maintain the Service;
• Process transactions and send you related information, including purchase confirmations and invoices;
• To enable interactions between artists and fans, such as fan subscriptions and artist communications;
• Communicate with you, including sending updates, promotional materials, and other information;
• Personalize your experience on the Service by presenting content, products, and offers tailored to you;
• Monitor and analyze trends, usage, and activities to improve the Service;
• Detect, prevent, and address technical issues or security concerns.
• To comply with legal obligations, enforce our Terms, and protect our rights.
• To support features such as artist websites, fan subscriptions, newsletters, and fan relationship management.
• To operate AI-assisted features (for example, EPK drafting and onboarding pre-fill) by retrieving publicly available information about you from third-party sources and sending it, together with your prompts and inputs, to third-party AI providers. See Section 5 for the providers, and Section 3.9 of our Terms of Use for how these features work.

4. Legal Bases for Processing (if required under law)

If you are located in the European Economic Area (EEA), the United Kingdom, or other applicable jurisdictions, we process your personal data under the following legal bases:

• Contractual necessity – To provide the Service to you;
• Consent – For marketing communications and optional features (e.g., newsletters);
• Legitimate interests – For platform maintenance, analytics, and fraud prevention;
• Legal obligation – To comply with applicable laws and legal processes.

5. Sharing Your Information

We may share your information with:

1. Service Providers: We may share your information with third-party service providers who perform services on our behalf, such as payment processing, data analysis, and customer support.
2. AI Providers: When you use an AI-assisted feature on Sleeve (for example, the EPK builder or onboarding pre-fill), we may send your inputs, prompts, and publicly available information about you to third-party AI providers (currently Anthropic) to generate drafts. These providers process your inputs under their own terms and do not use the content you upload to Sleeve to train their models. The list of providers may change; we will keep this Privacy Policy updated.
3. With Artists (for fans): If you subscribe to or support an artist, we may share limited information (such as your name and email address) with that artist for the purpose of delivering content, rewards, or communications. Artists are independent data controllers and are solely responsible for how they use fan information.
4. Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
5. Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

6. Your Rights and Choices

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

• Access – Request a copy of the personal data we hold about you;
• Correction – Request correction of inaccurate or incomplete data;
• Deletion – Request deletion of your data, subject to legal limitations;
• Objection/Restriction – Object to or restrict processing in certain circumstances;
• Data Portability – Receive your data in a structured, machine-readable format;
• Withdraw Consent – Where processing is based on consent, you may withdraw it at any time.
• Promotional Communications – You can opt out of receiving promotional emails from us by following the instructions in those emails or by contacting us directly.

To exercise these rights, please contact us at privacy@sleeve.fm. We may verify your identity before responding.

6.1 Notice to California Residents (CCPA / CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (as amended by the California Privacy Rights Act). In the previous 12 months, we have collected the categories of personal information described in Section 2 (identifiers such as name and email; commercial information such as transaction history; internet activity such as usage data; and inferences drawn from that information). We collect this information for the purposes described in Section 3.

We do not sell your personal information, and we have not sold personal information in the previous 12 months. We do not share personal information for cross-context behavioral advertising.

In addition to the rights listed above, California residents have the right to:

• Know what personal information we collect, use, disclose, and (if applicable) sell or share about you;
• Delete personal information we have collected about you, subject to legal exceptions;
• Correct inaccurate personal information we maintain about you;
• Limit the use of sensitive personal information to purposes necessary to provide the Service;
• Non-discrimination for exercising any of these rights.

To submit a request, email privacy@sleeve.fm. You may also designate an authorized agent to submit requests on your behalf, subject to our verification of your identity and the agent's authority. We will respond within the timeframes required by law (generally 45 days, extendable by another 45 days where reasonably necessary).

To exercise these rights, please contact us at privacy@sleeve.fm. We may verify your identity before responding.

7. Data Retention and Security

We take reasonable measures to protect your information from unauthorized access, use, alteration, or destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee its absolute security. You are responsible for maintaining the security of your account credentials.

We retain personal information only as long as needed for the purposes described in this Privacy Policy, including to provide the Service to you, satisfy our legal and tax obligations, resolve disputes, and enforce our agreements. Concretely:

• Active accounts: We retain personal information for as long as your account is active.
• Closed accounts: When you close your account, we delete your personal information from our active systems within 90 days, except where we are required to retain it (for example, transaction records for tax purposes, which we typically retain for 7 years).
• Backups and caches: Information may persist in routine backups and content-delivery caches for a short period (typically up to 90 days) before it is purged on our normal cycle.
• Fraud, abuse, or legal claims: Where we have a good-faith need to investigate fraud, abuse, or violations of our Terms, or to defend or pursue a legal claim, we may retain relevant information for the duration of that investigation or claim plus any applicable limitations period.

8. Children's Privacy

Our Service is not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete that information.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your own, including the United States. These countries may have different data-protection laws than your jurisdiction.

Where we transfer personal data of users in the European Economic Area, the United Kingdom, or Switzerland to a country that has not been determined to provide an adequate level of data protection, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum, or another lawful transfer mechanism. By using the Service, you understand that your information may be processed in the United States and other jurisdictions, subject to these safeguards.

10. Third-Party Links and Services

The Service may contain links to third-party websites, platforms, or integrations (e.g., Spotify, Stripe). We are not responsible for the privacy practices or content of those third parties. We encourage you to review their privacy policies before interacting with them.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the Service. You are advised to review this Privacy Policy periodically for any changes. Your continued use of the Service after any changes to this Privacy Policy constitutes your acceptance of the new terms.

12. Sub-Processors

We use a limited set of third-party providers to operate the Service. Each one processes only the data needed to do its job.

Provider	Purpose	Data processed	Region
Stripe	Payments and Stripe Connect for artist transactions	Cards, billing info, names, email, transaction history	US (EU residency available)
Anthropic	AI-assisted content drafting (EPK, onboarding, bio drafts)	Prompts, publicly available artist info, draft outputs	US
PostHog	Product analytics	IP, page views, event data, user IDs	EU (Frankfurt)
Sentry	Error and performance monitoring	Stack traces, request metadata, occasionally user IDs in error context	US
Mailgun	Transactional and broadcast email	Email addresses, message content, delivery metadata	US (EU region available)
Resend	Transactional and broadcast email	Email addresses, message content, delivery metadata	US
Mux	Audio and video processing, storage, and delivery	Audio/video files, viewing metadata	US
Fly.io	Application hosting	All Sleeve data while on our application servers	US (EU regions available)
Heroku	Application hosting (specific services)	All Sleeve data while on our application servers	US

We will update this list when we add or remove sub-processors. For material additions (a new sub-processor that processes a new category of artist data), we will notify artists by email at least 14 days in advance unless we are required to act sooner for security, legal, or operational reasons. Continued use of the Service after a change takes effect signifies your acceptance of the updated list.

For questions about sub-processors or to request a Data Processing Agreement, contact us at privacy@sleeve.fm.

13. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

SleeveFM, Inc. 2810 N Church St #88777 Wilmington, DE 19802 United States

Email: privacy@sleeve.fm

By using Sleeve, you acknowledge that you have read and understood this Privacy Policy.