Privacy notice
What Under Bridges Entity (Pty) Ltd, trading as Setdesk, does with personal information, and the rights you have over it under the Protection of Personal Information Act 4 of 2013.
Who is responsible
- Registered name
- Under Bridges Entity (Pty) Ltd
- Registration number
- 2016/469951/07
- Registered address
- 3rd on East, 47 127 East Road, Kempton Park, 1619, Gauteng, South Africa
- Information officer
- Joseph Mbedzi, info@underbridges.co.za
Two roles, and the difference matters
Setdesk holds two kinds of personal information and stands in a different relationship to each.
For the people who sign in and use the product, we are the responsible party. We decide what is collected and why.
For everybody a workspace stores inside it, promoters, venue contacts, artists, demo submitters, the workspace is the responsible party and we are its operator. The agency decides what to record about its contacts. We process it on their instruction, and we do not use it for our own purposes.
What is held
- Account details: name, email address, your password if you choose one (kept only as a salted hash), the public key of each passkey you add, and, if you turn on two-step sign-in, its authenticator secret and backup codes (encrypted)
- To sign you in and show who did what in a shared workspace. Source: you, when you sign up.
- Contact records: names, email addresses, phone numbers, organisations
- So bookings, advance sheets and invoices can reach the right person. Source: entered by the workspace, usually about promoters and venues.
- Artist details: stage name, legal name, contact details, fees and commission
- To run the diary and calculate what is owed. Source: entered by the workspace.
- Banking and tax details: account number, branch, VAT number
- So an invoice states where to pay. Source: entered by the workspace about itself.
- Signature evidence: signer name, email, IP address, browser, timestamp
- So a signed agreement can be shown to have been signed. Source: captured when somebody signs a contract.
- Promo activity: whether a link was opened, plays, how far a track was heard, feedback given
- So a label learns how a record is landing. Source: recorded as a recipient uses their private link.
- Guest lists: the names on a show's guest list, how many each brings, and a note for the door
- So the door at a show knows who to let in. Source: entered by the workspace or the artist on the show, and read by the promoter on the advance.
- Demo submissions: submitter name, email, and the audio sent
- So an inbound demo can be listened to and answered. Source: the person submitting.
Who else receives it
Each of these is an operator under POPIA. None of them is permitted to use the information for anything other than the service they provide to us.
Information leaving South Africa
It does. The database sits in Frankfurt, Germany, and several of the companies above operate from the United States. Section 72 of POPIA governs transferring personal information outside the Republic, and permits it where the recipient is bound by rules or a contract that give effect to protection substantially similar to POPIA.
We rely on the data processing terms of each company listed above. Where you need those terms for your own compliance, ask and we will provide them.
How long it is kept
Information is kept for as long as the workspace holding it keeps it. Deleting a contact, a booking or a campaign removes it.
Four things are removed on a schedule, by a job that runs daily. Older versions of a generated document are deleted 30 days after a newer version replaces them. The audio attached to a demo submission is deleted 90 days after the submission is passed on or its link expires; the record that it was sent remains. And any file left in storage with nothing referring to it, which is what deleting a booking or a workspace leaves behind, is removed after 7 days. The names on a show's guest list are deleted 30 days after the show; the number of places in the deal remains.
Two things are shorter lived by design. A sign-in code is stored only as a hash and expires after ten minutes. A signed-in session lasts thirty days, and each day you use it extends it. A password, if you choose one, is never stored: only a salted hash of it is. When you set one we check it against a public list of passwords seen in data breaches by sending the first five characters of its SHA-1 hash, which cannot be turned back into the password, to that list; nothing else about you is sent.
Your rights
Under POPIA you may:
- ask what personal information is held about you, and get a copy
- ask for anything inaccurate to be corrected
- ask for it to be deleted, where we are not required to keep it
- object to it being processed
- complain to the Information Regulator
You can delete your own account from Settings. That removes your sign-in, your seats in every workspace, your links to artist profiles, and any workspace you were the only member of, with everything in it. A workspace you leave keeps its own records: contracts, invoices, signatures and its audit log, which then refer to a former member rather than to you. The only owner of a workspace with other members has to hand it over first.
If a workspace holds information about you, ask them first: they decide what to keep. The product gives every workspace a way to export everything it holds about one contact, and to erase it, so they can answer you. If you cannot reach them, write to us at info@underbridges.co.za and we will help.
The Information Regulator of South Africa can be reached at inforeg.org.za.
How it is protected
Every table enforces row level security in the database itself, so a workspace cannot read another workspace's rows even if the application asks it to. Fees and money sit behind a further permission, so a member without money access cannot read them at any layer.
Files are never public. Every link to a document or a track is short-lived, addressed to one recipient, and can be revoked, which takes effect on the next request. Passwords, sign-in codes and share tokens are stored only as hashes, so a copy of our database does not yield a working password or link.
To help you and to keep billing right, Setdesk's own staff can see an account's name and address, its workspaces and roles, its plan and payments, what was sent and whether it arrived, and counts of what a workspace holds. They cannot see your bookings, contacts, contracts, fees, invoices or files, and every look and every change they make is recorded with who made it and why.
Changes
If this notice changes materially, the version at the foot of the page changes with it, and account holders are told before the change takes effect.