Privacy & Policy

1. Introduction

We at SKUFLER, Ltd. are concerned about privacy issues as they are very important and may affect your legal rights. So, we want to familiarize you with the data collection process we use, how we interfere with your mobile phone, what data we collect and how we disclose them if it is necessary. By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

This Privacy Policy is related only to SKUFLER Service and SKUFLER, Ltd. It does not apply to any information or data you collect by any Third Party integrated in our Application, which shall instead be governed by Third Party’s terms and policies.

This Privacy Policy will remain in full force and effect even if you select not to use the SKUFLER Service, terminate or cease your account with us or if your account has been suspended or deactivated by us for any reason. We may retain your information provided to us even after the closure or suspension of your account.

All collected information will be stored to our server as long as it is necessary by the applicable laws and in order to meet all legal requirements.

2. Age Limit

Our Users, in order to enjoy SKUFLER Service must be 18 or older, or be 13 or older and have their parents or guardian’s consent to the Agreements. We promise not to collect any information or data from anyone under age of 13 and to make available to this age group any of our Services and products.

In the event it comes to our knowledge that we have collected information of a person under 13 years old, we will take all necessary actions to terminate that person’s account and delete all provided information.

Apart of being of the eligible age to use our Service you have to:

1. Entitled to enter in a binding Agreement with us and not to be barred from doing so under any applicable law or other legal restriction
2. Be resident of the country where we offer the SKUFLER Service

By creating an account with us you are committed that all information you have provided during our registration is true, valid and you promise to keep it that way at all times.

3. Your consent to us

It is very important for us to clarify with you that using SKUFLER Service you are consenting to the following very important issues:

• you understand and you accept that we use cookies, technologies and various functions to offer you the best experience using our Service
• we may transfer your provided information to other location, outside of the country you live and you have created your account
• we will collect, use and share your information for commercial and advertising purposes
• we may make available to the public your information if we are forced to do so by any applicable law and/or other legal instruction

You acknowledge and consent that SKUFLER, Ltd. is the data controller and as such it is entitled to act accordingly in any of the above cases.

4. What we collect

We collect personal information from you and your Contents in order to give you a personalized and feature-rich use of our SKUFLER Service.

In particular:

• Personal information: we collect and store the following personal information: name, email address, mobile phone number, profile photo/image, location/country.
• User Content: while chatting, creating, sharing, uploading and storing your Contents to SKUFLER Service we may collect any personal information contained in your works.
• Metadata: we will collect metadata associated with User Contents. Namely any metadata added to Users Contents may be keywords posted with a photo or video, geographical information, comments, names or any other type of data not mentioned herein. The metadata may be accessible and searchable from others if you share the User Content with others or on Third Party social media sites.
• Your contacts: with your prior consent we may request access to your contacts available on your mobile in order to invite them to join the SKUFLER Service, to join the chat function, to send them invitations and in general to promote the SKUFLER experience

We may require access to specific services/functions on your mobile device in order to offer you a complete SKUFLER experience and in order our Service to be fully operational. Specifically, we may require access to:

• your photos and your phone camera(s)
• your microphone

Important Note: we will use your device’s microphone ONLY for songs/music recognition in order to facilitate you to create your Content(s). We will NOT use your microphone for any other purpose.

In order to recognize you in our system we may create a unique device or User ID.

We may also receive some of your personal information from our partners and affiliates in the event you have a valid account with them. We use both session cookies and persistent cookies.

In the event you decide to purchase other Users Content(s) you may be redirected to a Third Party’s application for the conclusion of the transaction. It is hereby agreed that any information you provide to such Third Party, it is provided by you to them at your own discretion and in full understanding of the transaction process.

We would like to clarify with you that we will delete and we will not accept any sensitive personal information (e.g., Social Security Number, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) you send to us or you disclose through SKUFLER Service or in any other way (electronically or via mail) to us.

5. Information about cookies and other technologies

We may use cookies – like most websites and mobile applications – to identify your device when visiting our website or any other technologies (i.e. pixel tags, mobile device identifiers) to recognize your device when you run the SKUFLER Application or in general you use our Service.

In the event you don’t want us to collect your information with the use of cookies, please follow your browser’s procedure to decline cookies. However, not all features of the site or application may operate as intended, if cookies are disabled.

6. How we use the information we collect

Subject to the permission of the applicable laws, we may use the collected personal information for the following purposes:

1. to provide you assistance with any customer related service issues, to help us improve any administration issues of the site or the Service and ensure the technical functioning of the SKUFLER Application
2. to inform you for any updates related to our Service, products and functions
3. to communicate with you either directly or through our partners and Third Parties Services, for marketing and promotional purposes via emails, notifications, or other messages when we believe that it may be of your interest
4. to facilitate your immediate connection with your network community and our Service and site
5. with your consent, to participate from time to time surveys and performance evaluation of our Service aiming to improve and upscale our services
6. to protect our intellectual property & copyrights and to prevent fraud
7. to comply with laws, to any requests from government bodies or courts, or to respond to litigation
8. to facilitate and permit a merger, acquisition or sale of the whole or a portion of our assets
9. as otherwise specified in this Privacy Policy

7. Sharing information – What will be available to public

Your personal information will not be shared with Third Parties without your consent.

We will collect your personal information only for the scope described in Article 6 herein and we are committed to you that we will neither rent, nor sell your personal information to anyone for their own use.

We may use and disclose your personal information, in total or part thereof, if we are forced or required to do so under applicable laws, any regulation or by any competent legal authority if they consider it as necessary and in view of preserving the rights and interests of SKUFLER Ltd.

For the conclusion of a transaction and the execution of a payment through a Third Party’s application, your personal information may be shared with a Third Party application or service.

It will always be publicly available your name, your profile picture, who you follow and who follows you, your public playlists and your recent check-ins.

Your activity on SKUFLER Service will be publicly available. More specifically, any playlists you create or follow, the Contents that you post, create and upload, your top tracks and artists, your recent check-ins, etc. will be published to SKUFLER Service and will be accessible by all Users. As your Contents are publicly displayed, they will appear in any Third Party’s search engine results, along with your name and profile picture.

We clarify herein that we are not liable for the treatment of your personal information and/or other data submitted to Third Parties sites and applications while creating or if having an account therein. You agree and you understand that a Third Party application’s use of information collected from you is governed by the Third Party’s privacy policy terms and conditions.

We may share your personal information in the event we are informed that you have violated the intellectual property of the works of record companies, music publishers, songwriters, composers, performers, musicians, artists, radio stations and all other parties not mentioned herein, eligible to claim compensation for the said violation.

8. Third Party sites and links

As SKUFLER Service integrates Third Parties’ services and links beyond our control, the inclusion of the said links does not mean ratification of their linked sites/ services by us or by our affiliates. We are not responsible for the privacy, the advertisements information or other practices of any Third Parties and its affiliates links and services. Please advise their Privacy Policy Agreements in order to be informed how they collect and process your personal information.

9. Transfer of your data

Your personal information may be transferred to, and stored at any country where we engage service providers or we have offices. By using the SKUFLER Service and our webpage you consent to the transfer of your personal information to countries other than your country of residence. We will take all necessary precautions and reasonable steps to secure at any time that your personal information is secure and in accordance with this Privacy Policy.

10. Updates to this privacy policy

We may change this Privacy Policy from time to time and as we consider it necessary for the proper and secure operation of SKUFLER Service. Any changes will become effective when we post any revision of our Privacy Policy on our website and your use of the SKUFLER Service following these changes means that you acknowledge and you accept any revisions or updates.

11. Protecting Your Account

Please be sure you have created a unique and strong password to your SKUFLER account and your mobile phone in order to secure your Contents. We do take data protection measures and precautions but we cannot guarantee the complete safety of your account, therefore we strongly recommend the use of strong passwords and access limitation to Third Parties.

12. Contact us

For any information you may require or if you have any inquiries as regards the present Privacy Policy, please address your request to us via email at support@skufler.com or via postal email at

3, Christki Kompou, PETER’S HOUSE, Limassol, 3011, Cyprus

Attention to: SKUFLER, Ltd.