SongbookFM — Privacy Notice

Zeneszöveg.hu Kft. · Version: 1.0 · Effective: 13 October 2026 · The Hungarian text governs; this English version is a translation.

This summary for SongbookFM is part of the full Privacy Notice of Zeneszöveg.hu Kft.; once the full document is published, the full document governs.

1. What this notice covers

SongbookFM is the music streaming service of Zeneszöveg.hu Kft. This notice covers the following surfaces:

• songbook.fm — landing page, listening without signing in, registration;
• app.songbook.fm — the web radio;
• tv.songbook.fm and the SongbookFM TV apps (LG, Samsung);
• the embedded SongbookFM player on zeneszoveg.hu pages and on websites that embed it with our permission;
• the SongbookFM mobile app — once released.

2. The controller

3. What data we process, why, on what legal basis and for how long

Legal bases under GDPR Article 6(1): (a) consent, (b) performance of a contract, (c) legal obligation, (f) legitimate interest. You can object to processing based on legitimate interest (section 7).

Retention — general rule. Unless stated otherwise for an activity: (1) we keep identifiable data for as long as the account or the contract exists and for 5 years thereafter — to the extent necessary for establishing, exercising or defending legal claims (the limitation period under section 6:22 of the Hungarian Civil Code); accounting records for 8 years (section 169 of Hungarian Act C of 2000 on Accounting); where the law or the purpose justifies a shorter period, the shorter period applies; (2) after that, we pseudonymise the data — without name, e-mail address or other contact details — and keep it for statistical, historical and royalty-accounting purposes for up to 20 years, with the safeguards of Article 89(1) GDPR (pseudonymisation, restricted access); (3) anonymised, aggregated data from which you can no longer be identified may be kept without time limit.

Own history. Your own history linked to your account (for example your listening history) is kept for as long as the account exists, even if you do not use it for a long time. If the account ends other than at your request (for example because the Provider terminates it or because it has not been used), we keep it for 5 years from the end of the account, so that it is available again if the account is reactivated. If you ask for your account to be closed or for these data to be erased, we erase them, except for what we must keep by law (for example listening data needed for royalty accounting, in pseudonymised form).

3.1. Playback and listening data

• Purpose: playing the music, keeping your queue and settings, enforcing the daily free allowance and the entitlements of your subscription, and the listening statistics needed for royalty accounting.
• Data: a random device identifier that the app creates itself (not the device's hardware identifier); the client type and version; which recording you listened to on which station, when and for how long, your skips, your queue; with an account, your saved stations.
• Legal basis: (b) contract; listening statistics: (f) legitimate interest (measuring and improving how the service works); royalty accounting: (c) legal obligation.
• Retention: playback sessions for at most 1 year after they expire; listening data for 5 years from your last use — for data linked to an account, from the closure of the account — then pseudonymised for up to 20 years, then only in aggregate (general rule); the "Own history" paragraph also applies to the listening history linked to your account.

3.2. Protecting the free allowance and the music

• Purpose: preventing the free allowance from being circumvented; protecting the music and filtering out mass, automated downloading. If you sign in, the use generated on the device until then is linked to your account, so that signing in does not grant a new allowance.
• Data: where protecting the allowance requires it, on the songbook.fm landing page and in the TV app, a pseudonymised hash derived from your IP address; a log of issued playback keys (session, recording, time); flags for unusual use.
• Legal basis: (f) legitimate interest (protecting the free allowance and the copyright-protected music).
• Retention: the hash, the key log and the flags for as long as the security purpose requires, at most 1 year.

3.3. Embedded player on zeneszoveg.hu and other sites

• Purpose: playback on zeneszoveg.hu pages and on other websites that embed it with our permission, enforcing the daily allowance, statistics.
• Data: the embedding page, the recording played and for how long, the device class (mobile or desktop), a pseudonymised visitor hash derived from the IP address and browser data; if you are signed in to zeneszoveg.hu, the identifier of your zeneszoveg.hu membership.
• Legal basis: (b) contract; the allowance and statistics: (f) legitimate interest (enforcing the allowance, measuring the service).
• Retention: listening data for 5 years from last use, then pseudonymised for up to 20 years, then only in aggregate (general rule); the visitor hash for as long as the security purpose requires, at most 1 year.

3.4. Songbook account (registration on songbook.fm)

• Purpose: creating the common Songbook account, signing in, proving acceptance of the Terms, protecting the account and operating the service.
• Data: e-mail address, password (if you set one), display name, subscription tier; the time and IP address of the e-mail confirmation, of sign-ins and of accepting the Terms, and the version of the Terms accepted; data of the signed-in device (operating system, app version, device name); with Google or Apple sign-in, the account identifier from that provider.
• Legal basis: (b) contract; protecting the account: (f) legitimate interest (preventing abuse); proving acceptance of the Terms: (f) legitimate interest (establishing legal claims) and (c) legal obligation.
• Retention: until the account is closed, then under the general rule; sign-in sessions until they expire (at most 90 days); one-time codes until they are used or expire; the log of sign-ins and code requests (with IP address) for as long as the security purpose requires, at most 1 year, then anonymised; acceptance of the Terms for 5 years after the account is closed.

3.5. Subscription and entitlements

• Purpose: providing and accounting for the entitlements of a subscription, coupon or promotion.
• Data: your SongbookFM tier (free, Basic, Premium), its source (subscription, coupon, promotion) and validity; for store purchases, the store's receipt.
• Legal basis: (b) contract; (c) legal obligation (accounting).
• Retention: 5 years after the account is closed, then under the general rule; accounting records for 8 years.

3.6. Audience measurement on the songbook.fm landing page

• Purpose: measuring the landing page and the steps of registration.
• Data: page-usage events (for example a page view, opening the registration window), device and browser data, IP address.
• Legal basis: (a) consent — measurement starts only after you consent.
• Retention: the measurement cookies until you withdraw your consent, at most 2 years; the measurement data at the web analytics provider for at most 14 months.

3.7. Server logs

• Purpose: operation, troubleshooting, defence against attacks.
• Data: IP address, time, requested address, browser data.
• Legal basis: (f) legitimate interest (security and operation of the service).
• Retention: for as long as the security purpose requires, at most 1 year, then anonymised.

4. Data stored on your device

The apps keep on your device (in the browser's local storage or in the app's storage) the device identifier, after sign-in your sign-in data, your settings and listening data not yet sent. These are necessary for the service to work, so they do not require consent; they disappear when you clear the browser or app data. The landing-page measurement (3.6) uses cookies; we place these only with your consent.

5. Who may receive the data

Our staff may access the data to the extent needed for their tasks. As processors we may use a network and security provider (for the traffic of registration and sign-in), an e-mail delivery provider (confirmation codes, system messages) and — only with your consent — a web analytics provider (3.6); we may transfer to them the data they need for their tasks.

Independent controllers: LG Electronics and Samsung Electronics for the TV app, Apple and Google for downloading the mobile app and for store purchases; Google and Apple when you sign in with them. Their own privacy notices apply to them.

6. Transfers outside the European Union

The network and security processor and the web analytics processor may also operate outside the European Union (in the United States); in that case the transfer takes place with appropriate safeguards, on the basis of the European Commission's adequacy decision (EU–US Data Privacy Framework) or, failing that, the standard data protection clauses. You can request information about the safeguards at dpo@zeneszoveg.hu. Otherwise we process the data in the European Union.

7. Your rights

You may request access and a copy, rectification, erasure, restriction and data portability. You may withdraw your consent at any time; this does not affect the lawfulness of processing before the withdrawal.

Right to object. You may object at any time, on grounds relating to your particular situation, to processing based on our legitimate interest (3.1 listening statistics, 3.2, 3.3, 3.4 account protection, 3.7) at dpo@zeneszoveg.hu. We then no longer process the data for that purpose, unless compelling legitimate grounds or the establishment of legal claims justify it.

How: write to dpo@zeneszoveg.hu, or by post to the registered office. We reply within one month at the latest; where necessary this may be extended by two months, and we will inform you of this within one month. It is free of charge; we may verify your identity. You can request deletion of your account and SongbookFM data by e-mail. We carry out your request across all our services.

When you use the service without signing in, we link your data only to a pseudonym from which we cannot identify you (GDPR Article 11). If you wish to exercise your rights regarding this data, include in your request the device identifier shown in the app. If you clear the app or browser data, the device gets a new identifier and the earlier data can no longer be linked to it.

8. Complaints and remedies

You can lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH; Falk Miksa utca 9–11, 1055 Budapest; postal address: 1363 Budapest, Pf. 9.; phone: +36 1 391 1400; ugyfelszolgalat@naih.hu; https://naih.hu), or with the supervisory authority of your place of residence in the European Union. You may also go to court; at your choice, you may bring the action before the regional court (törvényszék) of your place of residence or stay. We suggest you contact us first.

9. Do you have to provide the data?

No law requires it. Playback needs the device identifier and the listening data: without them SongbookFM does not work. An account needs an e-mail address; without an account SongbookFM can be used only to a limited extent. Consent to audience measurement is voluntary; if you do not give it, the page can be used in the same way.

10. Automated decisions

We make no decision based solely on automated processing that has legal effects on you. Flagging unusual use (3.2) may interrupt playback temporarily; you can then request human review at dpo@zeneszoveg.hu.

11. Children

An account may be created independently by a person aged 16 or over; under 16, the consent of a legal representative is required.

12. In the TV app

This part also appears on the TV "Privacy" screen.

What data is processed? A random device identifier (not the TV's hardware identifier), what you listened to and for how long, and — where protecting the allowance requires it — a pseudonymised hash derived from the IP address.

Why? Playback, the daily free allowance, protecting the music, royalty statistics (3.1, 3.2).

Who processes it? Zeneszöveg.hu Kft. For downloading the app, the LG or Samsung store is an independent controller.

Your rights: write to dpo@zeneszoveg.hu and include the device identifier shown on the TV. If you clear the app's data in the TV settings, the TV gets a new identifier and the earlier data can no longer be linked to it.

Full notice: scan the QR code or open songbook.fm/privacy

13. Changes

If this notice changes materially, we publish the change before it takes effect and notify registered users.

This summary for SongbookFM is part of the full Privacy Notice of Zeneszöveg.hu Kft.; once the full document is published, the full document governs. Terms of use for SongbookFM: SongbookFM Terms.