Privacy Policy

This Privacy Policy explains how The Sanctuary of Fragility (“we”, “us”, or “our”) collects, uses, discloses, stores, and otherwise processes personal information in connection with:

𑇐 the official website of The Sanctuary of Fragility;

𑇐 Google Analytics and cookies or similar technologies;

𑇐 embedded YouTube content;

𑇐 forms operated through Tally or another form provider;

𑇐 email and other direct communications;

𑇐 General Cover Notifications;

𑇐 Metadata Requests;

𑇐 Collaboration, Commercial Use, and Special Permission Enquiries;

𑇐 permissions, confirmations, agreements, complaints, and disputes; and

𑇐 links to external platforms, stores, and services.

For the purposes of this Privacy Policy, “personal information” means information relating to an identified or reasonably identifiable individual.

This Privacy Policy is primarily based on the personal-data-protection laws applicable to the operation of The Sanctuary of Fragility in Thailand. Additional rights or obligations may apply where another law applies to a particular person, activity, or processing operation.

2. Person Responsible and Contact Information

The Sanctuary of Fragility is responsible for determining why and how personal information described in this Privacy Policy is processed.

The Sanctuary of Fragility

An independently operated creative project based in Thailand

Privacy contact: privacy@thesanctuaryoffragility.com

Questions, concerns, requests, or complaints concerning personal information may be sent to the email address above.

The Sanctuary of Fragility may provide additional identifying or administrative information where reasonably necessary or required by applicable law, a competent authority, or a formal legal process.

3. Information Collected Through the Website

The official website of The Sanctuary of Fragility is created and hosted through Google Sites.

The website does not currently provide:

𑇐 user accounts;

𑇐 membership registration;

𑇐 public comments;

𑇐 discussion forums;

𑇐 direct messaging between visitors;

𑇐 newsletter registration; or

𑇐 an independent payment or checkout system.

Visitors may generally view the website without directly providing personal information to The Sanctuary of Fragility.

However, Google Sites, Google Analytics, YouTube, browsers, network providers, security systems, and other technical providers may automatically process information such as:

𑇐 Internet Protocol address;

𑇐 browser type and version;

𑇐 device type;

𑇐 operating system;

𑇐 language settings;

𑇐 approximate geographic location;

𑇐 date and time of access;

𑇐 pages viewed;

𑇐 referring or destination pages;

𑇐 interactions with website functions or embedded content;

𑇐 cookie or similar-technology identifiers; and

𑇐 security, diagnostic, and technical information.

The Sanctuary of Fragility does not control every technical process, cookie, system log, server, data centre, or infrastructure decision made independently by those providers.

4. Google Analytics and Cookies

The Sanctuary of Fragility uses Google Analytics to understand how visitors use the website and to improve its organisation, accessibility, content, and performance.

Depending on the configuration and the visitor’s settings, Google Analytics may process information such as:

𑇐 the number of users and visits;

𑇐 session and interaction information;

𑇐 pages viewed;

𑇐 approximate geographic location;

𑇐 browser and device information;

𑇐 referral information;

𑇐 events or actions performed on the website; and

𑇐 cookie or similar-technology identifiers.

The Sanctuary of Fragility uses analytics information primarily in aggregated or statistical form and does not intend to use Google Analytics to identify individual visitors by name.

The Sanctuary of Fragility does not intentionally provide names, email addresses, form responses, confidential information, or other directly identifying information to Google Analytics.

Cookies or similar technologies may also be used by:

𑇐 Google Sites;

𑇐 Google Analytics;

𑇐 YouTube;

𑇐 embedded-content providers;

𑇐 security and technical-service providers; and

𑇐 other services accessed through or linked from the website.

These technologies may be used for:

𑇐 essential website operation;

𑇐 security and fraud prevention;

𑇐 preferences;

𑇐 media playback;

𑇐 analytics and measurement;

𑇐 technical diagnostics; and

𑇐 functions provided by the relevant service.

Visitors may manage or limit cookies through any controls provided by the relevant service, browser, or device. Blocking some cookies may affect analytics, embedded media, or other website functions.

5. Embedded YouTube Content and External Services

The website may contain embedded YouTube videos.

When a visitor opens a page containing an embedded YouTube player or interacts with that player, Google or YouTube may receive technical and usage information and may use cookies or similar technologies according to their own policies and settings.

The website may also link to external services, including:

𑇐 social-media platforms;

𑇐 music and podcast platforms;

𑇐 video platforms;

𑇐 public profiles;

𑇐 stores and marketplaces;

𑇐 payment and download services;

𑇐 external documents; and

𑇐 other websites.

When a visitor follows an external link, the destination service may independently collect and process information under its own privacy policy and terms.

The Sanctuary of Fragility does not control the independent privacy, security, account, payment, transaction, delivery, or data-handling practices of external services.

Where a purchase is completed through an external store or marketplace, that service will ordinarily process checkout and payment information. The Sanctuary of Fragility may receive order, customer, licence, support, or transaction information made available to a seller and may use it for the relevant sale, support, accounting, rights, record-keeping, or legal purpose.

6. Information Submitted Through Forms and Email

The Sanctuary of Fragility currently uses Tally as its third-party form provider.

The Sanctuary of Fragility may replace Tally or use another form provider in the future for operational, technical, security, accessibility, cost, or administrative reasons. The provider used for a particular form may therefore change.

Depending on the relevant form, communication, or request, The Sanctuary of Fragility may collect the following categories of information.

6.1 Identity and Contact Information

This may include:

𑇐 artist name;

𑇐 performer name;

𑇐 professional or public-facing name;

𑇐 project, company, or organisation name;

𑇐 contact name;

𑇐 email address;

𑇐 preferred contact information;

𑇐 public account, channel, page, profile, portfolio, or website; and

𑇐 public links supplied by the sender.

A legal name is not generally required unless it becomes reasonably necessary for a permission, agreement, business relationship, legal obligation, rights matter, or dispute.

6.2 Role and Authority Information

This may include:

𑇐 the sender’s role;

𑇐 whether the sender acts for themselves or another party;

𑇐 the person, artist, project, company, label, agency, brand, organisation, client, sponsor, or other party represented; and

𑇐 information concerning authority to submit a request or act for another party.

6.3 Cover, Release, and Metadata Information

This may include:

𑇐 the song being covered;

𑇐 publication or release status;

𑇐 proposed titles;

𑇐language and lyric version;

𑇐 performers and contributors;

𑇐 backing-track or instrumental source;

𑇐 vocal, synthetic-voice, and artificial-intelligence information;

𑇐 intended platforms and territories;

𑇐 publication and release dates;

𑇐 distributor information;

𑇐 metadata fields;

𑇐 artist-profile mapping;

𑇐 monetisation;

𑇐 licensing arrangements;

𑇐 Content ID, fingerprinting, claims, and rights-management settings;

𑇐 artwork and visual-material information; and

𑇐 other information relevant to the proposed cover or release.

6.4 Collaboration, Commercial-Use, and Permission Information

This may include:

𑇐 project title, type, description, and development stage;

𑇐intended audience;

𑇐 parties involved;

𑇐 clients, brands, sponsors, commissioners, funders, or organisations;

𑇐 requested materials, rights, participation, or services;

𑇐 proposed adaptation, translation, remixing, sampling, synchronisation, or artificial-intelligence use;

𑇐 proposed credits and public presentation;

𑇐 platforms, distribution methods, territories, and availability;

𑇐 commercial or non-commercial context;

𑇐 budget or compensation information voluntarily supplied;

𑇐 requested scope, deliverables, and timing;

𑇐 previous or existing use; and

𑇐 other non-confidential information reasonably necessary to assess the enquiry.

6.5 Links, Supporting Materials, and Communications

This may include:

𑇐 public or view-only links;

𑇐 published cover links;

𑇐 portfolios;

𑇐 project summaries;

𑇐 pitch decks;

𑇐 treatments;

𑇐 scripts or excerpts;

𑇐 storyboards;

𑇐 demos;

𑇐 screenshots;

𑇐 distributor-field information;

𑇐 metadata and licensing references;

𑇐 email correspondence;

𑇐 attachments; and

𑇐 follow-up communications.

6.6 Administrative and Case Records

The Sanctuary of Fragility may create or retain records including:

𑇐 the date and nature of a submission;

𑇐 administrative notes;

𑇐 review status;

𑇐 requests for clarification;

𑇐 reasons for closing or declining a matter;

𑇐 metadata supplied or confirmed;

𑇐 permissions offered, granted, limited, withdrawn, or declined;

𑇐 agreed conditions;

𑇐 material changes;

𑇐 complaints;

𑇐 suspected misuse, impersonation, or fraud;

𑇐 completed agreements;

𑇐 rights-related action; and

𑇐 dispute or legal records.

7. Information Required and Consequences of Not Providing It

Some information requested in a form or communication is necessary for The Sanctuary of Fragility to:

𑇐 identify and contact the sender;

𑇐 understand the relevant cover, release, request, enquiry, or project;

𑇐 determine whether the correct form or process has been used;

𑇐 assess eligibility under the applicable policies;

𑇐 confirm metadata;

𑇐 evaluate a proposed permission, collaboration, commercial use, or agreement;

𑇐 verify authority, rights, ownership, or licensing where relevant;

𑇐 maintain an appropriate record; or

𑇐 comply with a legal or contractual requirement.

Required fields will ordinarily be identified through the relevant form or instructions.

If required information is not provided, is incomplete, cannot be verified, or is materially inaccurate, The Sanctuary of Fragility may be unable to:

𑇐 receive or process the submission;

𑇐 contact the sender;

𑇐 assess the proposed use;

𑇐 confirm metadata;

𑇐 consider a permission or collaboration;

𑇐 proceed with an agreement;

𑇐 provide a response;

𑇐 maintain the matter as active; or

𑇐 continue the relevant process.

The Sanctuary of Fragility may request clarification, return the submission for correction, place the matter on hold, decline the request, or close the matter.

Providing optional information is voluntary. A sender should provide only information that is relevant and reasonably necessary.

8. Purposes and Legal Grounds for Processing

The Sanctuary of Fragility may process personal information to:

𑇐 operate, maintain, secure, and improve the website;

𑇐 understand general website use;

𑇐 receive and administer forms, notifications, requests, and enquiries;

𑇐 determine whether a form or process is appropriate;

𑇐 assess whether a proposed use falls within the applicable policies;

𑇐 contact the sender;

𑇐 request clarification or corrected information;

𑇐 review cover, release, metadata, collaboration, commercial-use, and permission matters;

𑇐 confirm metadata;

𑇐 evaluate, prepare, administer, perform, amend, suspend, or terminate a permission or agreement;

𑇐 verify authority, identity, rights, ownership, licensing, or relevant facts;

𑇐 maintain records of notifications, communications, confirmations, decisions, permissions, and agreements;

- administer and protect copyrights, recordings, metadata, credits, claims, and other rights;

𑇐 prevent or investigate fraud, impersonation, misleading association, duplicate submissions, abuse, or unauthorised use;

𑇐 manage security concerns, complaints, disputes, or legal claims;

𑇐 comply with applicable law, court orders, and lawful authority requests; and

𑇐 establish, exercise, or defend legal claims.

Depending on the circumstances and applicable law, personal information may be processed because:

𑇐 the sender has requested that The Sanctuary of Fragility take steps concerning a notification, request, enquiry, permission, collaboration, or proposed agreement;

𑇐 processing is necessary to enter into, perform, or administer an agreement;

𑇐 processing is necessary to comply with a legal obligation;

𑇐 processing is necessary for legitimate interests that do not improperly override the rights of the individual;

𑇐 processing is necessary to establish, exercise, or defend legal claims;

𑇐 the individual has provided consent for a specific purpose; or

𑇐 another lawful ground applies.

Where processing is based on consent, consent may generally be withdrawn for future processing. Withdrawal does not affect processing that was lawful before withdrawal and does not necessarily require deletion of information that The Sanctuary of Fragility remains legally permitted or required to retain.

The Sanctuary of Fragility does not use submitted personal information for unrelated direct marketing without an appropriate notice or another lawful ground.

9. Access, Service Providers, and Disclosure

Personal information submitted directly to The Sanctuary of Fragility is ordinarily accessible only to:

𑇐 the person operating The Sanctuary of Fragility;

𑇐 authorised team members or representatives who reasonably require access for the relevant purpose; and

𑇐 service providers whose systems are used to receive, transmit, store, secure, organise, or manage the information.

Relevant providers may include providers of:

𑇐 website hosting and publication;

𑇐 analytics;

𑇐 embedded media;

𑇐 forms;

𑇐 email;

𑇐 cloud storage;

𑇐 document management;

𑇐 security and URL inspection;

𑇐 technical support; and

𑇐 professional advice.

The Sanctuary of Fragility does not sell personal information.

Personal information may be disclosed or made available where reasonably necessary to:

𑇐 operate the website or relevant service;

𑇐 administer a form, notification, request, permission, agreement, or project;

𑇐 verify rights, authority, ownership, licensing, or metadata;

𑇐 communicate with a person or organisation identified in a submission;

𑇐 obtain legal, accounting, technical, security, or other professional advice;

𑇐 investigate fraud, impersonation, misuse, abuse, or unauthorised activity;

𑇐 respond to a platform, distributor, service provider, rights holder, or affected party;

𑇐 protect the rights or safety of The Sanctuary of Fragility or another person;

𑇐 comply with applicable law, a court order, regulatory requirement, or lawful authority request; or

𑇐 establish, exercise, or defend a legal claim.

The Sanctuary of Fragility will seek to limit disclosure to information reasonably necessary for the relevant purpose.

10. International Processing

The Sanctuary of Fragility is operated from Thailand.

Google, Tally, YouTube, email providers, cloud providers, analytics providers, and other service providers may operate systems, personnel, contractors, or infrastructure in Thailand, the European Economic Area, the United States, or other countries.

Personal information may therefore be transferred to, stored in, accessed from, or processed in countries outside the sender’s country.

The exact processing location may depend on:

𑇐 the provider used;

𑇐 the provider’s infrastructure;

𑇐 account and service settings;

𑇐 technical routing;

𑇐 backup arrangements;

𑇐 support operations;

𑇐 legal requirements; and

𑇐 changes made by the provider.

Where required and reasonably within the control of The Sanctuary of Fragility, appropriate measures will be taken concerning international processing or transfers.

11. Retention and Deletion

The Sanctuary of Fragility retains personal information only for as long as reasonably necessary for the purpose for which it was collected and for legitimate administrative, rights-management, security, record-keeping, contractual, and legal purposes.

Different information may be retained for different periods.

11.1 Submissions Closed Without Further Action

Where a submission is incomplete, unsuitable, duplicated, ineligible, withdrawn, or otherwise closed without further action, the complete form and related material may ordinarily be retained for approximately three to eight months after closure.

After that period, the complete submission may be deleted while a limited case record is retained where reasonably necessary.

A limited case record may include:

𑇐 the artist or contact name;

𑇐 contact details;

𑇐 date and general subject of the contact;

𑇐 outcome or closure status;

𑇐 a brief reason for closure; and

𑇐 information necessary to identify duplicate, abusive, misleading, fraudulent, or rights-related submissions.

11.2 General Supporting Materials

Links, attachments, full form responses, screenshots, drafts, and other supporting materials that are not required for a continuing legal, administrative, contractual, or rights-related purpose may ordinarily be deleted within approximately eight to thirty-six months after the relevant matter is completed or closed.

11.3 General Cover Notifications

Core information from a General Cover Notification may be retained for as long as reasonably necessary to maintain evidence of:

𑇐 who submitted the notification;

𑇐 the relevant song and proposed use;

𑇐 the date and scope of the notification;

𑇐 relevant publication and contact information;

𑇐 principal facts affecting eligibility; and

𑇐 material changes later communicated to The Sanctuary of Fragility.

Non-essential supporting information may ordinarily be deleted within approximately eight to thirty-six months after it is no longer reasonably necessary.

11.4 Metadata Requests and Enquiries That Do Not Proceed

Where a Metadata Request or Collaboration, Commercial Use, and Special Permission Enquiry does not result in a confirmation, permission, collaboration, or agreement, the complete submission and non-essential supporting materials may ordinarily be deleted within approximately eight to thirty-six months after closure.

A limited case record may be retained where reasonably necessary to identify:

𑇐 who contacted The Sanctuary of Fragility;

𑇐 the general subject of the request;

𑇐 the outcome;

𑇐 the principal reason the matter did not proceed; and

𑇐 information necessary for rights administration, consistent decision-making, duplicate-request management, fraud prevention, or dispute handling.

11.5 Confirmations, Permissions, Agreements, and Disputes

Where a matter results in metadata confirmation, permission, a licence, a commission, a collaboration, an agreement, a complaint, a rights dispute, or a legal claim, relevant records may be retained for as long as the matter remains relevant and afterward for as long as reasonably necessary for:

𑇐 record keeping;

𑇐 rights administration;

𑇐 compliance with applicable law;

𑇐 performance or enforcement of an agreement;

𑇐 responding to complaints;

𑇐 establishing, exercising, or defending legal claims; and

𑇐 protecting The Sanctuary of Fragility and affected parties.

Information may be retained for longer where required or permitted by applicable law or reasonably necessary for an active or anticipated legal, contractual, security, or rights-related matter.

Deletion may include secure deletion, removal from active records, redaction, aggregation, or anonymisation.

Residual copies may remain temporarily in backups, logs, security systems, or provider-controlled infrastructure until overwritten or deleted according to the provider’s normal processes.

12. Information That Should Not Be Submitted

Unless expressly requested and reasonably necessary, users must not submit:

𑇐 passwords;

𑇐 account credentials;

𑇐 private API keys or access tokens;

𑇐 payment-card or financial-account information;

𑇐 government identification numbers;

𑇐 passports or identification documents;

𑇐 unnecessary health, biometric, religious, political, sexual-life, or criminal-history information;

𑇐 confidential trade secrets;

𑇐 information subject to a confidentiality or non-disclosure obligation;

𑇐 unlawfully obtained information;

𑇐 personal information relating to another person without appropriate authority or justification; or

𑇐 information unrelated to the relevant form, communication, or request.

If unnecessary, excessive, unsafe, restricted, or unrelated information is submitted, The Sanctuary of Fragility may delete, redact, restrict, disregard, or decline to review it.

Submitting information does not by itself create a confidentiality or non-disclosure obligation.

13. Security

The Sanctuary of Fragility takes reasonable administrative and technical measures appropriate to the nature of the information and the scale of the project.

These measures may include:

𑇐 limiting access;

𑇐 using passwords and multi-factor authentication where available;

𑇐 using reputable service providers;

𑇐 separating public information from restricted records;

𑇐 deleting unnecessary information;

𑇐 maintaining appropriate records;

𑇐 checking links before opening them;

𑇐 declining unsafe files or restricted links;

𑇐 using security, malware-analysis, or URL-inspection services; and

𑇐 reviewing access when operational arrangements change.

No online form, email, cloud-storage system, or electronic transmission method can be guaranteed to be completely secure.

Users remain responsible for following the applicable instructions and avoiding the submission of unnecessary or highly sensitive information.

14. Minors

The website may be viewed by the public, but the forms and direct submission processes are not directed at persons who are minors under the law applicable to them.

The Sanctuary of Fragility does not knowingly invite or accept form submissions or personal information directly from minors.

A person who is a minor under the law applicable to them must not:

𑇐 submit a form operated by The Sanctuary of Fragility;

𑇐 provide personal information, documents, links, or supporting materials through a form;

𑇐 make confirmations requiring legal capacity; or

𑇐 enter into a permission, agreement, or similar process directly with The Sanctuary of Fragility.

Where The Sanctuary of Fragility reasonably believes that information has been submitted directly by a minor, The Sanctuary of Fragility may:

𑇐 stop processing the submission;

𑇐 decline or close the matter;

𑇐 delete the information;

𑇐 request appropriate involvement by a parent, guardian, or legally authorised adult where lawful and appropriate; or

𑇐 take another action required or permitted by applicable law.

15. Rights and Requests

Depending on applicable law and the circumstances, an individual may have the right to:

𑇐 ask whether The Sanctuary of Fragility holds personal information about them;

𑇐 request access to or a copy of relevant information;

𑇐 request correction of inaccurate or incomplete information;

𑇐 request deletion, destruction, or anonymisation;

𑇐 request restriction of certain processing;

𑇐 object to certain processing;

𑇐 withdraw consent where processing is based on consent;

𑇐 request transfer or portability where legally applicable; and

𑇐lodge a complaint with an appropriate authority.

Requests may be sent to:

privacy@thesanctuaryoffragility.com

A request should provide enough information to identify:

𑇐 the person making the request;

𑇐 the relevant form, communication, project, or matter;

𑇐 the information concerned; and

𑇐 the action requested.

The Sanctuary of Fragility may request reasonable information to verify the requester’s identity, authority, or connection to the relevant record.

Rights may be subject to limitations under applicable law. The Sanctuary of Fragility may retain or continue processing information where reasonably necessary for:

𑇐 compliance with law;

𑇐 record keeping;

𑇐 rights administration;

𑇐 performance or enforcement of an agreement;

𑇐 fraud prevention;

𑇐 protection of another person’s rights;

𑇐 confidentiality owed to another party; or

𑇐 establishment, exercise, or defence of legal claims.

A person who believes that their personal information has been processed unlawfully may contact The Sanctuary of Fragility first using the email address above and may also submit a complaint to the competent personal-data-protection authority where permitted by applicable law.

16. Automated Form Logic

The Sanctuary of Fragility does not currently use personal information to make decisions through a fully automated system that produces legal or similarly significant effects without human involvement.

Forms may use conditional logic to:

𑇐 end an ineligible submission;

𑇐 display relevant questions;

𑇐 direct a user to another form;

𑇐 prevent submission where a required confirmation cannot be made; or

𑇐 organise information.

Such form logic is an administrative screening tool and does not by itself constitute permission, metadata confirmation, approval, legal advice, or a final decision concerning a person’s rights.

17. Changes to This Privacy Policy

The Sanctuary of Fragility may update this Privacy Policy to reflect changes in:

𑇐 the website;

𑇐 forms;

𑇐 service providers;

𑇐 analytics;

𑇐 embedded media;

𑇐 project activities;

𑇐 retention practices;

𑇐 security measures;

𑇐 applicable law; or

𑇐 administrative procedures.

The current version will be published through an official webpage of The Sanctuary of Fragility.

The “Last Updated” date will indicate when the published Privacy Policy was most recently revised.

A change of form provider does not necessarily require replacement of the entire Privacy Policy. The relevant provider information may be updated while the general principles remain in effect.

Where a change materially affects how previously collected personal information is used, The Sanctuary of Fragility will take reasonable steps to provide an appropriate notice where required.

18. Contact

Questions, concerns, requests, or complaints concerning this Privacy Policy or personal information handled by The Sanctuary of Fragility may be sent to:

The Sanctuary of Fragility

An independently operated creative project based in Thailand

Email: privacy@thesanctuaryoffragility.com

Please do not include passwords, identification documents, financial-account information, or other unnecessary sensitive information in a privacy request.