This privacy notice will inform you as to how we look after your personal data when you visit the Richer Unsigned website and/or choose to participate in our free music promotion or music streaming services.
Please note our website is not intended for children and we do not knowingly collect data relating to children under the age of 16.
2. How we use your personal data
2.1 In this section we have set out:
(a) the general categories of personal data that we may process
(b) the purpose for which we may process personal data; and
(c) the legal bases of the processing
2.2 We may process data about your use of our website and services (usage data). The usage data may include your location, browser type and version, operating system, referral source, length of visit, page reviews and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 When you choose to upload music content for promotional and streaming services onto our platform or sign up to any of our services, we may collect “profile data”. The profile data may include your name, e-mail address, contact telephone number, band name, band image, soundtrack URL, track title and music genre. This data may be processed for the purpose of supplying the requested services. The legal basis for this processing is the performance of a contract between you and us and/or taking e steps at your request to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and services.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (promotions data). The promotions data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.5 We may process information contained in or relating o any communication that you send to us (“correspondence data”). The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for the purpose of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business risks.
2.8 We may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interest of another data subject.
2.9 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with promotion or streaming services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. Who do we share your information with?
3.1 We may share your profile data with e-commerce music streaming platform providers such as Soundcloud, Spotify, Deezer and Music Glue for the purposes of promoting your music.
3.2 We may share your profile data with third party music promoters, such as Cambridge Audio, for the purposes of arranging and hosting promotional events.
3.3 In the instances of ticket purchases for an event we may provide your name and contact information to the venue or associated booking agent to allow then to confirm your identity or facilitate your entry into the event.
3.4 We may disclose your profile data, promotions data and correspondence data to our suppliers or subcontractors insofar as reasonably necessary for the purposes of sending you the relevant notifications and/or newsletters and for the purposes of communicating with you.
3.5 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out of court procedure.
3.6 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another data subject.
4. How long do we keep your information for?
4.1 In Section 4 we set out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or these purposes.
4.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on following criteria:
(a) The period of retention of Profile data and consent data will be determined on the length of time you wish to remain a registered user of our services.
4.4 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another individual.
5. Marketing & Promotional Offers
5.1 You will receive marketing or promotional e-communications from us only if you have given us your consent to do so.
5.2 We will not pass on your details to any third party for the purpose of direct marketing unless we obtain your prior consent to do this.
5.3 You may opt out of any marketing or promotional communications by emailing firstname.lastname@example.org or by clicking on the unsubscribe link contained in each e-communication.
6. Data Security
6.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
6.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Transferring your data
7.1 All data collected by www.RicherUnsigned.com is located on secure severs in the EEA.
9. Amendments to this Policy
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy
9.3 This policy was last updated on the 4 June 2018.
10. Your rights
10.1 In this Section 10, we have summarised the rights that you have under data protection law.
10.2 Your principal rights under data protection law are:
- a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which over ride your rights and freedoms.
- e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
10.3 If you wish to exercise any of the rights set out in this Section 10, please contact us using the contact information provided in Section 13, our details.
10.4 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.6 We try to respond to all legitimate requests within 28 days from confirmation of requester’s ID. Occasionally it may take us longer than 28 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10.7 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
11. Third Party websites
11.1 Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
11.2 We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
12. Updating Information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. Our details
13.1 This website is owned and operated by Richer Sounds plc, registered in England and Wales under registration number 4870030, and our registered office is at Richer House, Hankey Place, London, SE1 4BB
13.2 You may contact us by email at email@example.com or by post to the postal address given above. Please mark correspondence for the attention of Richer Unsigned.