Radio Latte Privacy Policy
Effective date: 2026-05-14
This Privacy Policy is a working draft for lawyer review.
1. Controller
Radio Latte is provided by RBN SPC LTD, company registration number HE403962, VAT number CY10403962Q, with registered office at Makariou 228, 3030 Limassol, Building A, office 714, Limassol, Cyprus.
For privacy questions, contact: legal@radiolatte.com
2. Personal Data We Collect
We may collect:
- account data: email address, login codes, session identifiers, account status;
- business and venue data: business name, venue trading name, venue address, country, venue type, operating hours, contact name if provided;
- billing data: Stripe customer ID, subscription ID, plan, payment status, invoice metadata, billing country, VAT ID if provided;
- playback and service data: active session state, device label, IP address, stream heartbeat, playback events, errors, current venue/channel settings;
- support data: emails, messages, attachments, and issue details you send us;
- website and security data: IP address, browser/device data, request logs, cookie/session data, abuse-prevention logs.
We do not intentionally collect payment card numbers. Payments are processed by Stripe or another payment provider.
3. How We Use Data
We use data to:
- create and manage accounts;
- authenticate users with magic links or codes;
- provide streaming access;
- issue venue license certificates;
- process payments, renewals, invoices, tax, and subscription status;
- enforce one-active-stream and anti-abuse controls;
- provide support;
- improve catalog quality and service reliability;
- maintain security, fraud prevention, and logs;
- comply with legal, tax, accounting, and dispute obligations.
4. Lawful Bases
For GDPR purposes, we rely on:
- contract: to provide the service, subscriptions, account access, playback, billing, and license certificates;
- legitimate interests: to secure the service, prevent abuse, understand service reliability, respond to support requests, and improve the product;
- legal obligation: for tax, accounting, payment, and compliance records;
- consent: for non-essential cookies, marketing emails, or analytics where required.
5. Cookies and Similar Technologies
We use essential cookies or local storage for login, sessions, checkout, security, and service operation.
We should not use non-essential analytics, advertising, or tracking cookies unless a consent mechanism is in place and this policy is updated.
See the Cookie Policy for details.
6. Sharing and Subprocessors
We may share personal data with service providers that help us operate Radio Latte, including:
- hosting, edge, database, object storage, and security providers;
- payment processors;
- email delivery providers;
- customer support tools;
- analytics providers if later added;
- professional advisers where needed;
- authorities or third parties where legally required or necessary to protect rights.
The current draft subprocessor list is maintained separately.
7. International Transfers
Some providers may process data outside your country or outside the European Economic Area. Where required, we use appropriate safeguards such as adequacy decisions, standard contractual clauses, or equivalent transfer mechanisms.
This section must be finalized after vendor contracts are confirmed.
8. Retention
We keep personal data only as long as needed for the purposes described above.
Draft retention targets:
- login codes: about 10 minutes, plus short security logs;
- session records: up to 90 days or until logout/revocation;
- subscription and invoice records: as required for tax/accounting/legal obligations;
- venue license records: for the active subscription and a reasonable dispute period;
- playback/security logs: normally 12 to 24 months unless needed for security, dispute, or legal reasons;
- support emails: normally up to 24 months after last contact unless needed longer.
Retention periods must be finalized before launch.
9. Your Rights
Depending on your location, you may have rights to:
- access personal data;
- correct inaccurate data;
- delete data;
- restrict processing;
- object to processing;
- receive a portable copy;
- withdraw consent;
- complain to a data protection authority.
To exercise rights, contact legal@radiolatte.com.
10. Security
We use reasonable technical and organizational measures to protect personal data, including access controls, secure cookies where applicable, provider security controls, and limited access to operational systems.
No online service can be guaranteed completely secure.
11. Business Customers and Staff
If you provide personal data about staff or other business contacts, you are responsible for ensuring that you have a lawful basis to provide it and that those individuals receive appropriate privacy information.
12. Children
Radio Latte is a business service and is not intended for children.
13. Changes
We may update this Privacy Policy from time to time. The latest version will be posted on the website with an updated effective date.
14. Contact
Privacy contact: legal@radiolatte.com
Legal entity: RBN SPC LTD
Company registration number: HE403962
Registered address: Makariou 228, 3030 Limassol, Building A, office 714, Limassol, Cyprus
VAT number: CY10403962Q