1.1 At Blokur ("we"/"us"/"our") we respect your privacy and are committed to protecting your Personal Information (as defined below in paragraph 3.1). We have created this Privacy Notice to let you know what information we collect when you visit the website http://www.Blokur.com(the "Website") and use the services available (collectively, the "Blokur Services") or what we collect from third party sources, why we collect this information and how the collected information is used. It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the 'Your rights' section.
2.1 This Privacy Notice forms part of and should be read in conjunction with our Terms & Conditions and any additional applicable terms on the Blokur Services. We may periodically make changes to this Privacy Notice and will notify you of these changes by posting the modified terms on the Website. We recommend that you revisit this Privacy Notice regularly. If we are going to use Personal Information in a manner materially different from that stated at the time of collection, we will notify you by posting a notice on the Blokur Services.
3.1 "Personal Information" means information that may be used to identify an individual, including, but not limited to, first and last name, business or other physical address, email address, phone number, other contact information, website usage preferences, and your feedback regarding the Blokur Services. You may be asked to provide Personal Information when you sign up to use the Blokur Services. This information is held by us on secure servers based in the UK and may also be held on our behalf by third party cloud storage providers. In addition, when you interact with the Blokur Services, our servers may keep an activity log unique to you that collects certain administrative and traffic information including: source IP address used to connect your computer to the internet, browser type and version time of access, date of access, web page(s) visited, software crash reports and type and version of browser used and operating system or platform.
3.1.1 In addition to information which we collect about you from your use of, or inputting of information into this website, we may hold other information about you, such as your contact details, repertoire records, correspondence with us and documents which support your claims (e.g. proof of identity, proof of ownership of works).
3.1.2 We may also obtain information about you from third party sources, such as other publishers and collecting societies and agencies which may provide us with information regarding your repertoire.
3.2 Means of Collecting and Processing Data
We may automatically collect certain data and receive Personal Information about you where you provide such information through the Blokur Services or other communications and interactions with us. We may also receive information about you that is held by Third Parties such as Music Labels, Publishers and collecting societies or other publically available sources.
3.3.1 We use Personal Information to:
184.108.40.206 deliver the Blokur Services; this includes fulfilling a contract with you, or to take steps at your request prior to entering into a contract with you: this is relevant where you become a Blokur licensee. The steps taken may include:
verifying your identity;
taking payments from you (if applicable);
communicating with you in the course of fulfilling our contract with you; and
providing our services to you (such as administrative services and reconciling rights);
220.127.116.11 provide user support (including processing any complaints or enquiries made by you);
18.104.22.168 provide you with information regarding products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes as set out in paragraph 3.4);
22.214.171.124 notify you about changes to the Blokur Services; and
126.96.36.199 for any other purpose related to the operation of the Blokur Services.
3.4 Passing on Your Data to Third Parties
3.4.1 You may choose to receive promotional communications, either by indicating your communications preferences when you sign up to any Blokur Services or products and where any such option is made available to you, via the Website or otherwise.
3.4.2 Where you have consented to receive promotional information, we may also use your Personal Information (including your email address and phone number) to provide you with information regarding any products, services and promotions offered by us that may be of interest to you.
3.4.3 Wherever we rely on your consent, you will always be able to withdraw that consent. You have an absolute right to opt-out of us processing your personal data for direct marketing purposes, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us or by amending your communication preferences in your profile settings. Please note that if you do opt-out of receiving marketing emails you will still receive non-marketing emails and notifications from Blokur which contain essential information about your Blokur registration or licence to use the service including updates regarding rights information where you are an interested party, and any fundamental changes to how we operate as a company.
3.4.4 We may employ other companies and individuals to perform functions on our behalf, for example analysing data, providing marketing assistance, and product development. They may have access to personal information required to perform their functions, but are not permitted to use it for other purposes. They must process the personal information in accordance with this Privacy Notice.
3.4.5 We will not sell, lease or share your Personal Information except as set forth in this Privacy Notice.
3.5 LEGAL BASIS FOR PROCESSING PERSONAL DATA
In relation to the headings mentioned in the section above (“PERSONAL INFORMATION USE”), our legal basis for processing personal data is:
3.5.1 Making our Services available to you
Legal Basis: Contractual Necessity. We will not be able to provide you with your products or services if you do not provide us with this data.
3.5.2 Managing and improving our day-to-day operations
Legal Basis: Legitimate Interests.
3.5.3 Personalising your Blokur experience
Legal Basis: Legitimate Interests.
3.5.4 Contacting and interacting with you
Where you give us consent we will send you direct marketing by email in relation to our services, news and events or other products and services provided by us, our affiliates and carefully selected partner organisations although these emails and/or SMS messages will always come from us.
Legal Basis: Legitimate Interests.
3.6 LEGITIMATE INTEREST
Where we have mentioned above our use of your personal data is based on our “legitimate interests”, these are:
to service our customers’ needs, including delivering our products and services;
to promote and market our products and services;
to service your account, manage complaints and resolve any disputes;
to understand our customers including their patterns, behaviours as well as their likes and dislikes;
to protect and support our business, colleagues, customers and shareholders;
to test and develop new products and services as well as improve existing ones.
3.7 Excluded Disclosures
3.5.1 We may pass on your Personal Information to any member of the Blokur Group, comprising of our subsidiaries, our holding company and its subsidiaries (as defined in section 1159 of the UK Companies Act 2006) for the purposes of providing the Blokur Services and dealing with administration (where applicable).
3.5.2 We may disclose your Personal Information to third parties:
188.8.131.52 in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets;
184.108.40.206 if Blokur or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets;
220.127.116.11 if required to do so by law, or if we believe in good faith that such action is necessary to: (1) comply with any legal process served on us or the Blokur Services or in circumstances where we are under a substantially similar legal obligation; (2) protect and defend our rights or property; or (3) act to protect the personal safety of users of the Blokur Services or the public.
We will not keep your personal data longer than we need to, how long this is will depend on several factors, including:
Why we collected it in the first place;
How old it is;
Whether there is a legal/regulatory reason for us to keep it;
Whether we need it to protect you or us.
6.1.1 You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
6.1.2 In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
6.1.3 These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
6.1.4 To exercise any of these rights, you can get in touch with us using the details set out at the end of this Policy. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. In the UK this is the Information Commissioner’s Office.
6.1.5 In order to register to use the Blokur Services, the provision of certain information is mandatory: if relevant data is not provided, then we will not be able to administer your account. All other provision of your information is optional. Where you do not provide optional information, we cannot specifically tailor our services to you for example, inform you about news or services relevant to you.
7.1 We reserve the right to conduct a security review at any time to validate your identity, the registration data provided by you and to verify your use of the Blokur Services for potential breach of the Terms and of applicable law. By accepting the Terms, you authorise us, our staff, affiliates, subsidiaries, agents and suppliers to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide to us in the course of using the Blokur Services, including, where necessary, the transfer of information outside of your country. Security reviews may include verifying the information you provide against third-party databases. In addition, to facilitate these security reviews, you agree to provide such information or documentation as we may request.
7.2.1 We store all of the Personal Information we receive directly from you and use reasonable measures to protect all Personal Information that is stored within our database. We also take steps to ensure that our agents, affiliates and suppliers employ adequate levels of security. For any additional information about the security measures we employ please email us at email@example.com.
7.2.2 The transmission of information via the Internet is not always completely secure. We take steps to ensure protection of your Personal Information but we can not guarantee the security of data transmitted to our site and any transmission is at your own risk.
7.3 We know how important it is to protect and manage your personal data. We have the following measures in place.
We apply physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data;
We protect the security of your information while it is being transmitted by encrypting it;
We use computer safeguards such as firewalls and data encryption to keep this data safe;
We only authorise access to employees and trusted partners who need it to carry out their responsibilities;
We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security;
Whilst we take appropriate technical and organisational measures to safeguard your personal data, it is important that you keep your login details and devices protected from unauthorised access.
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. If we do this we ensure that your privacy rights are respected in line with this Policy. The most common way we do this is to put in place a specific type of contract, or through an approved scheme such as the Privacy Shield.
7.4 Third-Party Practices
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to: Data Protection Officer, Blokur Limited, First Floor Rear Building, 34-35 Hatton Garden, London, EC1N 8DX
Copyright 2019 Blokur Limited.