Privacy Policy and Personal Data Processing

The controller responsible for processing personal data is:

In this policy, the controller may also be referred to as “Latitude Music Group”, “Latitude” or the “Controller”.

This Privacy and Personal Data Processing Policy clearly explains how Latitude processes personal data relating to:

• Visitors to the website.
• People interested in programmes and services.
• Musicians who submit an application.
• Participants in musical and professional preparation programmes.
• Clients, suppliers, instructors, partners and collaborators.
• People who contact Latitude by email, forms, WhatsApp, Zoom, social media or other authorised channels.

Processing will be carried out in accordance with the Constitution of Ecuador, the Organic Law on Personal Data Protection of Ecuador, its General Regulations and other applicable rules.

This policy applies to personal data processed through:

• The Squarespace website.
• Google Forms.
• Google Workspace and corporate email.
• WhatsApp, Zoom and social media.
• Meetings, interviews, lessons and auditions.
• Documents, photographs, videos and audio files submitted by applicants.
• Banking institutions located in Ecuador.
• National and international companies and agencies involved in cruise-ship music entertainment.

4.1. Identification data

• Full name, date of birth, age and nationality.
• Country and city of residence.
• Identity card, passport or another document where necessary.
• Physical or electronic signature.

4.2. Contact data

• Email address, telephone number and WhatsApp number.
• Home address where necessary.
• Social-media usernames or profiles.

4.3. Professional and artistic data

• Instrument or musical speciality, education and experience level.
• Professional and artistic history and participation in groups or projects.
• Repertoire, genres, sight-reading, improvisation, interpretation and performance skills.
• CV, biography, references, photographs, videos, audio recordings and portfolios.
• Audition material, results, observations and evaluations.
• Availability to travel or work abroad and language proficiency.

4.4. Immigration and availability data

• Travel availability and potential embarkation dates.
• Passport validity and availability to obtain visas or permits.
• Countries where the data subject may legally work.
• Documents requested by agencies, cruise lines or potential employers.

Latitude will only request information that is necessary for each stage of the process.

4.5. Financial, banking and billing data

• Information required for billing, payments, receipts and refunds.
• Name or business name, tax identification and billing address when provided.

Latitude does not store banking passwords, security codes or online-banking credentials.

4.6. Technical and browsing data

• IP address, device, browser, operating system, date and time of access.
• Pages visited, interactions, cookies and approximate location inferred from the IP address.

4.7. Special-category data

Latitude does not routinely request sensitive, biometric, genetic, medical or criminal-background information. If an agency, cruise line or potential employer requires such information, the data subject will be informed and specific authorisation will be requested where required.

Personal data may be obtained:

• Directly from the data subject through web forms or Google Forms.
• By email, WhatsApp, Zoom or social media.
• During meetings, interviews, lessons, simulations or evaluations.
• Through CVs, photographs, videos, audio files or documents.
• Through banking platforms used to process payments.
• Through cookies and technologies used by Squarespace.
• From partner companies or agencies where there is a lawful basis for the disclosure.

6.1. Responding to enquiries

• Answer enquiries and provide information about programmes, services, requirements and prices.
• Arrange meetings, interviews or information sessions.
• Follow up with interested individuals.

6.2. Managing applications

• Receive and organise applications.
• Confirm that applicants are at least 18 years old.
• Evaluate experience, preparation, CVs and artistic material.
• Arrange interviews and auditions, communicate outcomes and assess suitability for professional opportunities.

6.3. Providing preparation services

• Manage enrolment, schedules, lessons, tutoring, masterclasses and audition simulations.
• Evaluate performance and provide feedback.
• Prepare CVs, profiles, videos and other professional materials.
• Record progress, manage payments and issue invoices.

6.4. Managing professional opportunities

• Present profiles to national and international cruise-entertainment companies and agencies.
• Share CVs, photographs, videos, audio recordings and audition materials.
• Arrange auditions and facilitate communication with agencies, cruise lines or potential employers.
• Follow up on selection processes and global professional opportunities.

6.5. Administrative and legal compliance

• Formalise agreements, issue receipts, process payments and manage refunds.
• Maintain administrative and accounting records.
• Respond to authorities and manage claims or disputes.

6.6. Marketing communications

With express authorisation, Latitude may send information about programmes, calls for applications, opportunities, workshops, events, educational content, news and promotions. This authorisation is voluntary and separate.

6.7. Security and service improvement

• Protect platforms and prevent fraud or unauthorised access.
• Analyse statistics, improve user experience and assess campaigns and forms.
• Maintain backups and security logs.

Consent

Consent may be used to manage applications, send marketing communications, share profiles, retain information for future opportunities, use materials for promotional purposes and process special-category data where necessary. Consent may be withdrawn at any time without affecting prior lawful processing.

Pre-contractual steps or performance of a contract

Processing may be necessary to respond to requests, evaluate applications, complete enrolment, provide services, manage payments, prepare applications and perform agreements.

Compliance with legal obligations

Latitude may process data to comply with tax, administrative, accounting, judicial or regulatory obligations.

Legitimate interests

Latitude may protect its systems, prevent fraud, improve services or defend legal claims where the processing is necessary and proportionate and does not override the rights of the data subject.

Forms may identify required fields. Failure to provide required information may prevent Latitude from processing an application, evaluating a profile, contacting an applicant, completing enrolment, providing a service, issuing an invoice or presenting a professional application.

Additional information and consent to receive marketing communications are optional. Data subjects must provide truthful, accurate, complete and current information.

Latitude's programmes, services and application processes are intended exclusively for people who are at least 18 years old. Applications from minors are not accepted.

Forms may require applicants to confirm that they are adults. Where there is reasonable doubt, Latitude may request documentation to verify age.

Where necessary and supported by a lawful basis, personal data may be disclosed to:

• National and international music-entertainment companies and agencies.
• Agencies specialising in the recruitment of musicians for cruise ships.
• Cruise companies, cruise lines, producers, musical directors and audition managers.
• Potential international employers.
• Instructors and evaluators associated with Latitude.
• Squarespace, Google Workspace, Google Forms, WhatsApp and Zoom.
• Banking institutions established in Ecuador.
• Technology suppliers, accountants, lawyers and professional advisers.
• Public, administrative, tax or judicial authorities where legally required.

Because Latitude operates internationally, personal data may be stored, processed or disclosed outside Ecuador, including when:

• Squarespace, Google Workspace, Google Forms, WhatsApp or Zoom are used.
• Information is stored on servers located outside Ecuador.
• Profiles are presented to international agencies, companies, cruise lines, producers or employers.
• Professional cruise-ship opportunities are managed worldwide.

International transfers will be made in accordance with Ecuadorian law. Where required, specific authorisation will be obtained before a profile or professional material is shared internationally.

Applications and audiovisual material

Applications, CVs, photographs, videos, audio recordings and other applicant materials will be retained for a maximum of one year from the date of submission or the end of the evaluation or selection process, as applicable.

They may be kept longer where the data subject authorises this, a process remains active, a contractual relationship exists, or retention is required for legal obligations or claims.

Clients and programme participants

Information required to provide services will be retained during the contractual relationship and afterwards for the period needed to comply with legal, accounting and contractual obligations or manage claims.

Billing and accounting

Invoices, receipts and accounting records will be retained for the periods required by Ecuadorian law.

Marketing and consent records

Marketing data will be retained until consent is withdrawn. Evidence of consent may be retained for as long as needed to demonstrate legal compliance.

Latitude applies reasonable administrative, organisational, physical, legal and technical measures to protect data against unauthorised access, loss, alteration, destruction, improper disclosure, fraud or unauthorised processing.

• Role-based access and permission controls.
• Strong passwords and two-factor authentication.
• Protection of forms and documents.
• Backups and updates to devices and applications.
• Confidentiality commitments and supplier review.
• Secure-deletion and incident-response procedures.

No electronic system can guarantee absolute security, despite the application of reasonable safeguards.

Access

To know whether Latitude processes personal data and obtain information about that processing.

Correction and updating

To request correction or updating of inaccurate, incomplete or outdated information.

Deletion

To request deletion where the purpose has been fulfilled, the retention period has expired, consent has been withdrawn or another legal ground applies.

Objection and restriction

To object to processing or request its temporary restriction in the circumstances established by law.

Portability

To request personal data in a structured and interoperable format or request its transfer where applicable.

Withdrawal of consent

To withdraw consent for one or more purposes.

Automated decision-making

To request information or human review where a decision with legal or similarly significant effects is based solely on automated processing.

Requests may be sent to dataprivacy@latitudemusicgroup.com with the subject “Personal data rights request”.

The request should include:

1. The data subject's full name.
2. An email address or other response channel.
3. A clear description of the right being exercised.
4. Identification of the relevant data or processing activity.
5. Supporting documents where necessary.
6. Evidence of authority where the request is made by an authorised representative.

Latitude may request additional information strictly necessary to verify identity. Requests will be handled within the time limits established by Ecuadorian law.

Where a data subject believes that their rights have not been properly addressed, they may submit a complaint to Ecuador's Superintendence for Personal Data Protection in accordance with the procedures made available by that authority.

Artistic materials submitted with an application may be used to evaluate a profile, carry out simulations, provide feedback, prepare professional materials, present applications and coordinate auditions.

Latitude will inform participants before recording a lesson, meeting, interview, Zoom session or audition.

Recordings may be used to evaluate performance, provide feedback, prepare professional materials, retain audition evidence, share materials with an authorised company or agency and improve internal processes.

Recordings connected with applications will be retained for a maximum of one year and will not be used for advertising without separate authorisation.

The Squarespace website may use cookies to operate securely, remember preferences, analyse traffic and performance, and integrate forms, videos or third-party services.

Strictly necessary cookies may be used for technical operation. Where analytics, advertising or personalisation cookies require consent, visitors may accept, reject or configure them through the preference mechanism provided on the website.

Latitude uses third-party services including Squarespace, Google Workspace, Google Forms, WhatsApp, Zoom and banking institutions established in Ecuador.

Each provider may process information under its own privacy policy, terms and security measures. Users are encouraged to review those policies when using the relevant services.

Latitude Music Group will not make decisions producing legal or similarly significant effects for applicants based solely on automated processing. Human involvement will form part of the evaluation of profiles and audition materials.

Latitude may update this policy to reflect changes in its services, processing activities, platforms, relationships with agencies or companies, legal requirements or security practices.

The current version will be available on the website and will show its last-updated date. Where a change materially affects the purposes or conditions of consent, the data subject will be informed and fresh authorisation will be requested where required.

For questions, requests or concerns about this policy or personal-data processing: