We are Brendan Mills Music Limited (a company registered in England under company number 10118242) whose registered office is at 3-4 Bower Terrace, Tonbridge Road, Maidstone, Kent, United Kingdom, ME16 8RY.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number [and company details]
- [Information to enable us to check and verify your identity, e.g. your date of birth]
- your billing information, transaction and payment card information
- Contact forms collect information to enable us to provide quotations for sale, answer general queries and monitor our sales and marketing efforts to report return on investment.
- Your Name
- Your email address
- Your company
- Your telephone number
- How you heard about us
- The industry you work in
- What your enquiry is about
- Information you actively give us, such as these details are collected and stored when you register your enquiry with us, when you correspond with us using on line forms and questionnaires, we can then provide products/service based on the enquiry.
- Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit aboutcookies.orgor www.allaboutcookies.org.
- You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note in a few cases some of our website features may not function because of this, we would recommend you leave them turned on in order to get the most from our website.
- Analytics – e.g. how visitors use our website
- We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.
- Google – http://www.google.com/intl/en/policies/privacy/
- IP addresses – or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. We do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
- Internet Based Advertising – Google adwords, Facebook, Instagram and Twitter advertising services are tracking codes installed on our website so that we can manage the effectiveness of our campaigns. We do not store any personal data within this type of tracking.
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or us||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, services or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts|
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at [insert contact details for marketing opt-out]
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
- [updating your marketing preferences on our [insert link to preference centre]]
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- third parties we use to help deliver our services to you, e.g. payment service providers, our performers and suppliers, and delivery companies;
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- [credit reference agencies;]
- our insurers and brokers; and
- our bank.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Where your personal information is held
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information, for example:
- Marketing data: We will hold your data for a period of 6 years with a review every 3 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that; and
- Contracted Services: We will hold your data for 7 years in line with our regulatory requirements.
For further details on this please contact us (see ‘How to contact us’ below).
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- with your and our service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
We will ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on [insert date] and last updated on [insert date].
We may change this privacy notice from time to time—when we do we will inform you via [insert mechanism for informing the data subject of changes to the notice, eg our website or other means of contact such as email].
How to contact us
If you wish to contact us, please send an email to firstname.lastname@example.org, write to 3-4 Bower Terrace, Tonbridge Road, Maidstone, Kent, United Kingdom, ME16 8RY or call 0207 183 1453.