Faber Music's Privacy Notice

Contents

  1. General
  2. Maintenance and Storage of Information
  3. Marketing Policy
  4. Faber Music's Use of Information:
    1. Information collected for Email Newsletter Sign-ups
    2. Information collected for polls, surveys, promotions, and competitions
    3. Information collected for E-Commerce Orders
    4. Information collected for Payment Processing
    5. Information collected when individuals contact us
    6. Forums, chat rooms, blogs, and message boards
  5. Disclosure to Third Parties
  6. Your Rights in Relation to Your Personal Data:
    1. The right to receive information
    2. The right to access your data
    3. The right to rectify your data
    4. The right to erase your data
    5. The right to restrict processing
    6. The right to withdraw consent
    7. The right to data portability
    8. The right to object to automated individual decision-making or profiling
    9. The right to lodge a complaint with the Information Commissioner's Office ("ICO")
  7. How to Unsubscribe/Opt Out/Withdraw Consent
  8. Third party sites
  9. Cookies and Google Analytics
  10. Security
  11. Policy Changes
  12. Contact Details

1. General: Faber Music (“Faber”, “the company”, “we”, “us”) is committed to protecting your privacy. We take our responsibilities regarding the security and legitimate use of your personal information very seriously, and work hard to ensure that we comply with the Data Protection Act (“DPA”) 1998, General Data Protection Regulation (“GDPR”) (EU) 2016, and Privacy and Electronic Communications Regulations (“PECR”). The purpose of this Privacy Notice is to inform you, as a visitor to our website:

  • What information we need about you;
  • The specific purposes and legal grounds for processing it;
  • How we process it;
  • The safeguards we use to ensure it is protected;
  • How long we need to keep it for;
  • Whether we disclose it to any third parties, or transfer it out of the European Union; and,
  • About your rights regarding our use of that information.

It is not our policy to employ a dedicated Data Protection Officer as, at present, the scale of personal data processed by Faber Music is not significant enough to meet this requirement. However, we have nominated a Data Protection Supervisor. If you have any concerns, questions or comments about this Privacy Notice, or the website, you can contact the data protection supervisor by following the instructions set out in section 12 below.

Please click this link to read a copy of Faber Music’s full Privacy Policy.

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2. Maintenance and Storage of Information: Your information is collected and stored on servers which are owned and maintained by or on behalf of Faber and its group companies. We may keep your information for a reasonable period for the purposes set out in this Privacy Notice.

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3. Marketing Policy: We want to tell people who are interested in Faber Music about what we do. We have various different forms of marketing communications and are dedicated to ensuring that wherever we are using personal data we are always compliant with the DPA, GDPR and PECR.

Definitions:

  • 'Marketing' means the promotion by Faber (and its group of companies) of news, information, products and services related to the business, our composers and their music;
  • 'Email Marketing' means the electronic delivery of correspondence via email straight to your Inbox; and
  • 'Direct Mail Marketing' means the posting of physical newsletters, magazines, catalogues etc. to a postal address via a third party mail delivery service (eg. Royal Mail).

In order to ensure that your personal information is processed fairly and lawfully, we will endeavour to:

  • Provide you with a privacy notice;
  • Obtain your consent wherever necessary;
  • Make ‘opting in’ instructions specific and transparent, and include a form of positive action (eg. a checkbox, or subscribe button) so that consent is given knowingly and freely;
  • Offer a clear and genuine choice regarding whether or not your details may used for marketing purposes;
  • Wherever possible, to record when and how we got consent, and exactly what it covers, and maintain our records to ensure your personal data is accurate and up to date;
  • Delete any irrelevant or excessive personal information in our records
  • Ask for consent before passing details to third parties for marketing, and name those third parties;
  • Only collect personal data for specified purposes;
  • Only use the information for the purposes that you have consented to;
  • Make certain that the news, information, products and services we are marketing are the same or similar to those that you originally consented to receive marketing for;
  • Specify our methods of communication (eg. by email or post);
  • Provide opportunities for you to manage the way in which we communicate with you, eg. links to unsubscribe from direct marketing activities and instructions on how to access, rectify, erase or restrict your personal information;
  • Have procedures for dealing with inaccuracies and complaints;
  • Respond to your requests positively and promptly, and confirm that we have done so in writing;
  • Not use bought-in marketing lists unless we have proof of consent;
  • Include our company name, address and telephone number in the content of our correspondence; and
  • Keep a record of anyone who opts out in order to ensure they are no longer included in communications.

Further details on how your personal information might be used can be found in section 4 of this Privacy Notice and in our wider Privacy Policy.

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4. Faber Music's USe of Information: In order to make use of various services provided through the website (such as the forums, blogs, email newsletters, competitions, polls, or to order a product) you will need to provide us with certain information about yourself. You will be granted an opportunity to give your explicit consent for us to communicate with you in the future, to select how we use your information for marketing purposes and also to manage your preferences to make certain our communications are always relevant to you. We will only use your information in accordance with your instructions and as set out in this Privacy Notice or if we are required to do so by any law or other regulatory or government authority, to enforce the terms of use or to enforce our rights, or to protect the safety of others. In particular, we may collect and use personal information for the purposes of investigating and, if necessary, removing any content about which we receive complaint. For more information regarding the lawful basis for processing your personal data please visit the ICO website.

Types of information kept by Faber Music:

  1. Information collected for Email Newsletter Sign-Ups: We use a two-step, double-opt in process when individuals subscribe to receive newsletters. At the first stage we collect email address. At the second stage a confirmation email is sent to the email address you have provided, containing a unique link which individuals have to actively click to confirm their explicit consent to receiving communications from us. If this link is not clicked on we will not market to that individual. Consent can be withdrawn at any time by following the instructions under section 6 of this Privacy Notice.

    We provide our newsletter(s) to you free of charge, unless otherwise stated. From time to time the newsletters may contain promotions or advertisements relating to goods or services provided by us or our group companies and associated third party publishers whose products we distribute. Customer data is only used for direct marketing purposes where explicit consent has been given by the customer in line with EU GDPR regulations.

    We use Constant Contact as our third party email marketing provider to process and store all personal data provided to us by individuals in relation to Email Newsletters. A limited number of key marketing staff have password protected access to this cloud-based service. To view the Constant Contact privacy policy go to https://www.constantcontact.com/uk/legal/privacy-statement.

    We only store your personal details for as long as you wish to be contacted by us.

  2. Information collected for polls, surveys, promotions and competitions: If you wish to take part in any poll or survey run through this website, we will only use and store your information for the purposes specified in the poll or survey. We may also disclose non-personal, aggregated information we collect through the poll or survey to third parties.

    If you wish to take part in any promotion or competition run through this website, we will only use and store your information for the purposes specified in the promotion or competition, to make sure you are eligible to enter the promotion or competition, to contact you if you have won a prize and for publicity purposes.

  3. Information Collected for E-commerce Orders: If you ask us to provide goods or services to you, we will use your information to provide those goods or services to you in the most efficient way and to monitor our provision of those goods or services. To purchase a product from our website you will first need to create an Account on our E-Commerce platform. We offer Accounts so that regular customers can quickly log in and continue shopping without needing to re-supply certain details such as addresses. When an individual creates a new account we collect the following mandatory information:

    • Account Username
    • Email address
    • Account Password (encrypted)

    In addition to the basic registration we also provide an Opt In tickbox which you can use to actively provide consent to receive marketing communications from us. When this box is checked we will flag your account to acknowledge that consent has been given freely and explicitly. Consent can be withdrawn at any time by following the instructions under paragraph 6 of this Privacy Notice.

    When a customer places an order on our website we collect and process additional information for the purposes of fulfilling orders:

    • Full Name
    • Company name (if applicable)
    • Billing and delivery address
    • Phone number (so that we can respond in a timely manner if there is an issue with your order)

    This information is passed via a secure, SSL-protected electronic feed into Faber Music’s central fulfilment system, or our E-Partners digital fulfilment system for digital products, both of which are stored within Faber’s secure servers and web databases in the United Kingdom, and maintained by a limited number of key staff.

    We only store order details for a minimum of six years plus the current HMRC tax year in order that we may adhere to mandatory accounting regulations.

  4. Information Collected for Payment Processing: It is our policy never to capture or store any bank card details belonging to our customers within our own systems or servers. All transactions that take place on our websites are processed through two layers of third party processor security: 3D-secure cardholder identification (Verified by Visa) and the Secure Hosting (Monek) payment gateway service - both of which are PCI compliant. To view the privacy and data protection policies of our third party payment processors and security certificate issuers please visit their websites listed below:

    Secure Hosting keep personal data for 13 months, in line with their PCI DSS requirements. To read their Privacy Policy and Personal Data Retention policy visit https://monek.com/gdpr-docs/

  5. Information collected when individuals contact us: when you contact us by email, through our website, by mail or by telephone we retain your information for as long as it takes to respond and deal with your enquiry. In some cases it is necessary for us to retain personal data in order to facilitate ongoing business communications and to fulfil ongoing business contracts.

    • Email
      When an email is sent to any one of the contact email addresses displayed on the website this email is stored on internal servers and logged within our databases. We collect your email address and any other information you provide to us including contact details displayed within email signatures. We make sure your email is passed onto the most appropriate member of staff. We regularly clear our inboxes and email folders to ensure we are not holding onto personal data for longer than is necessary.
    • Contact Forms
      When a contact form is submitted through the website we collect all mandatory information required including name, email address and all information included within the message field. This information is stored on our internal servers within our web database.We make sure your form is passed onto the most appropriate member of staff. We regularly clear our inboxes and email folders to ensure we are not holding onto personal data for longer than is necessary.
    • Phone
      When we receive phone calls through our internal company switchboard we collect phone numbers and any relevant information provided to us during the call. Phone calls are never recorded.
    • Post
      When we receive communication by post we only store the minimum amount of information required for the purposes of carrying out a specific request as required by the sender. We have data archiving and destruction policies in place in relation to the security of physical documents containing personal data.
  6. Forums, chat rooms, blogs, message boards: Please be aware that when you post public information to any forums, chat rooms, blogs, or message boards on or through the website, that information can be accessed by the public and used to send you unsolicited communications. Faber Music Ltd accepts no responsibility for this.

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5. Disclosure to third parties: We work with a number of third party service providers who process personal data to allow us to run our business and to fulfil contractual obligations on behalf of our clients, B2B and B2C customers and website visitors. These may include:

  • Email Marketing Platforms
  • CRM Platforms
  • IT Service Providers
  • Telephone Providers
  • Email Service Providers
  • E-Commerce Order Fulfilment Partners
  • Server Hosting Providers

We will only share personal data with these third party service providers to fulfil our business obligations (i.e. website submission form requests), to carry out a contract (i.e. website order fulfilment) or where you have given explicit consent for us to process your personal data for marketing purposes (i.e. active opt-in newsletter sign-ups).

We will only pass your information on to associated third parties for the purpose of enabling them to send you information which may be of interest to you if you have indicated you are happy for us to do so in your marketing preferences. We never pass on your contact details to third parties without your permission. If any associated third party is organising and/or managing any promotion, competition, survey or poll run through the website on our behalf, we may disclose your information to that third party to enable them to do so but they will be prohibited from using your information for any other purpose, unless you have given them specific consent.

Please note that if you upload or post any information to a public part of the website, we may use it in accordance with our terms and conditions of use and it may be viewed and used by others.

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6. Your Rights in relation to your personal data: We want to make certain you understand your rights as a "Data Subject":

  1. The right to receive information, including:
    • the name and contact details of the organisation processing your data;
    • the purpose and legal basis for processing your data;
    • details of any recipients of your data;
    • details about whether your data will be transferred outside the European Union, and the safeguards put in place to protect it;
    • the period for which your data will be stored;
    • if the data was supplied to us by a third party, and not directly by you, details of the source;
    • details of any automated decision-making or profiling* related to the processing of your data;
    • details of whether your data will be used for any purpose other than the purpose for which is was originally collected.

    *‘Profiling’ means any form of automated processing of personal data where it is used to evaluate certain personal aspects relating to the individual, in particular to analyse preferences, interests, behaviour, or location.

  2. The right to access your data: If you would like to receive a copy of the personal data in our possession, we can arrange for an electronic copy to be sent securely to you. Our response time may vary depending on the extent of the information that you require, and we may need to verify your identity before sending anything out. One copy can be organised free of charge but we may need to charge for additional copies.
  3. The right to rectify your data: If you need to amend or update the personal data in our possession, we will arrange for this to be done promptly. Our response time will depend on the extent of the information that you require, and we may need to verify your identity before amending your records.
  4. The right to erase your data: If you wish us to completely erase the personal data in our possession, we will arrange for this to be done promptly. Our response time may vary depending on the extent of the information to be deleted. We may need to verify your identity before deleting your records. We will make you aware of any reason why we are legally obliged to retain the information.
  5. The right to restrict processing: If you have reason to believe that your personal data is inaccurate, unlawful, or no longer required, you can request that we restrict the processing and we will investigate the possibilities without delay. Our response time may vary depending on the extent of restrictions that you require, and we may need to verify your identity before making any restrictions.
  6. The right to withdraw consent: If you gave consent for your data to be processed by us, this consent can be withdrawn at any time. We will make you aware of any reason why we are legally obliged to retain the information.
  7. The right to data portability: You have the right to forward a copy of the personal data in our possession to another party, or to request that we do so on your behalf, so long as we currently store it in an electronic format. Our response time may vary depending on the extent of data that you require, and we may need to verify your identity before taking action.
  8. The right to object to automated individual decision-making or profiling: From time to time we may process personal data for direct marketing purposes. You have the right to object, at any time, to your data being included in a decision based on automated processing (eg. preference profiling) and we shall comply and remove your personal data from the relevant marketing list with immediate effect.
  9. The right to lodge a complaint with the Information Commissioner's Office ("ICO"): If you are concerned that your personal data is being treated illegally, you can report that misuse to the ICO. For information and contact details visit https://ico.org.uk/concerns/ or call (UK +44)(0)3031231113.
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7. How to Unsubscribe/Opt Out/Withdraw Consent: If, at any time, you wish to unsubscribe from an email newsletter, opt out of receiving marketing communications or withdraw consent for us holding and processing your personal information you may do so by i) following the unsubscribe instructions contained in the newsletter itself, or ii) following the unsubscribe instructions on our website, or iii) alternatively you can contact us by following the instructions set out in section 12 of this Privacy Notice.

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8. Third Party Sites: This website contains links to third party websites. We may, on occasion, disclose non-personal aggregated information to the owners or providers of those third party websites. We link to a wide variety of other websites and we display advertisements from third parties on the website. We are not responsible for the content or privacy policies of third party websites or advertisers, nor for the way in which information about their users is treated. In particular, unless expressly stated, we are not agents for those sites or advertisers nor are we authorised to make representations on their behalf.

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9. Cookies and Google Analytics: This website automatically gathers certain information such as IP addresses and the number and frequency of visitors to the site and individual web pages viewed. This is collected using cookies and is used by us for security and monitoring purposes, to manage the website, to track usage, to improve the website and to ensure it is as appealing to visitors as possible. Cookies are pieces of information that are stored by the browser on the hard drive of your computer. The cookie does not contain any personal information about you apart from your email address if you select the 'Remember Me' option when logging into the website. The website also uses cookies to enable us and any person who advertises to provide features such as remembering certain information about you and your preferences so that we and they can deliver targeted advertisements which will be of most interest to you.

Cookies can be deleted from your hard drive or you can configure your web browser so that it rejects cookies. To learn more about cookies and how to reject them, visit www.aboutcookies.org. Rejection of cookies will not prevent you from using most of the features on the website. If you experience any problems having deleted cookies, you should contact the supplier of your web browser.

We also include web beacons (also known as clear GIFs or web bugs) in our emails to track the success of our marketing campaigns. This means that if you open an email from us we can see which of the pages of our website you have visited. Our web beacons do not store additional information on your computer but, by communicating with our cookies on your computer, they can tell us when you have opened our email. If you object to web beacons, we recommend that you follow the instructions for deleting existing cookies and disabling future cookies above. We will still know how many of our emails are opened and we will automatically receive your IP address, a unique identifier of your computer or other access device; but we will not identify you as an individual.

Google Analytics: Google Analytics measures how users interact with our website content through the use of tracking cookies. All data is anonymised with no personal data linked to individual website visitors. As a user navigates between web pages, Google Analytics provides our website with tags to record information about the page a user has seen, for example the page URL, time and date of visit, length of visit, country of residence and language settings.

For more information on how Google uses cookies please visit: http://www.google.com/intl/en/policies/technologies/cookies/

To view the Google Privacy Policy page please visit http://www.google.com/intl/en/policies/

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10. Security: In accordance with our requirements under the DPA 1998 and GDPR (EU) 2016, we will adopt appropriate security procedures to help prevent unauthorised access to your information. Neither Faber Music Ltd nor any of its group companies shall be liable for any attempt to hack or crack or otherwise gain access to any part of this website including any of your information.

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11. Policy changes: By using this website you agree to the terms of this Privacy Notice and our terms of use. We may amend this privacy policy and the terms of use from time to time. If we do so, we will post an updated version on the website. You will be bound by the new terms upon your continued use of the website.

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12. Contact details: If you have any questions or concerns about this Privacy Notice or the website, or you wish to you exercise any of the rights outlined in section 5 above please write to us at: FAO Data Protection Supervisor, Faber Music Ltd, Bloomsbury House, 74-77 Great Russell Street, London, WC1B 3DA, United Kingdom. Alternatively send an email to dataprotection@fabermusic.com or call +44 (0) 2079085340.

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