235 Music Publishing Limited (“235MPL”) is a London based music publishing company.
It is fundamental to our business that we collect and manage data about our clients and others. We are committed to the safe keeping of your information and, of course, compliance with data protection laws. As such, we therefore act as a “Data Controller”.
This privacy notice details how we collect, manage, process, store and share information about you as a result of you visiting our website, as a client or prospective client or in connection with a client matter or for other activities, such as marketing and hospitality. We also explain how you can control use of your data.
If you have any feedback or questions about our use of your data, please contact our Data Privacy Manager at firstname.lastname@example.org or you can write to 14 Basing Hill, London, United Kingdom, NW11 8TH.
235 Music Publishing Limited is a private limited company, company number 11593006 with its registered office at Elsley Court, 20-22 Great Titchfield St., London W1W 8BE.
While using our website, we may ask you to provide us with certain personally identifiable information (“personal data”). Personally identifiable information may include, but is not limited to: Email Address, Contact Information, Cookies and Usage Data.
Sources of information
We may be given or obtain personal information from a number of sources, such as:
- Information you give us about yourself
- Information you give us about others
- Information others give us about you to allow us to do our work
Why do we need personal information?
The main reason for asking you to provide us with or give us permission to obtain your personal data from other sources, is to allow us to run our business and enable us to carry out our contractual obligations to others.
The following are some examples of what we may use your information for:
- Establishing your identity
- Requesting and obtaining advice from third parties;
- Responding to complaints or allegations involving us
- Fulfilling statutory obligations
Who can access personal information?
Our data protection regime has been established to ensure secure and lawful processing of your personal data. We will not sell or rent your information to any other person or organisation or share your information with third parties for marketing purposes.
As a general rule, we will only use your information within 235MPL, but in running our business (whether directly or in the administration of our systems), we may need to disclose some information to third parties e.g. to:
- Contracted suppliers, such as information technology providers and services
- Providers of identity verification
- Statutory bodies or actors involved in law enforcement or regulation e.g. for the prevention of financial crime and terrorism, where there is an emergency and we think you or others are at risk.
In the event that any of your information is shared with third parties, we will require them to maintain strict confidentiality, to operate according to our instructions where appropriate and not to use your personal information for their own purposes, unless you have expressly consented to them doing so.
Some uses of your personal data may require your specific consent, in particular if we are processing special category or sensitive personal data. If so, we will contact you separately to ask for your consent, which you will be free to withdraw at any time.
How do we protect your personal data?
We recognise that your information is valuable and we will take all reasonable steps to protect it while it is in our care.
We have systems in place to protect personally identifiable data from loss, misuse, alteration or destruction. We also impose confidentiality obligations on internal and external parties to protect the confidentiality of all personal information and to ensure compliance with data protection laws.
We employ computer and digital data safeguards such as firewalls and data encryption and we enforce physical access controls to our offices and files to keep data safe.
How long will we keep information for?
Your personal information will be retained, in computer and/or manual files, for as long as necessary to fulfil the purpose for which the information was collected; or as required by law; or as long as detailed in any contract you may have with us (of which this privacy statement may form part). e.g.
- As long as necessary to carry out our contractual obligations to you;
- For a minimum of 7 years from the conclusion of a contractual relationship, to bring or defend complaints or claims
What are your rights?
Under the UK General Data Protection Regulations (UK GDPRs), you are entitled to access your personal data (this is the ‘right to access’). If you want to make an information request, please apply in writing to our Data Protection Officer, or contact the person dealing with the matter.
If you request access to your personal data, you are entitled to a copy of the data we hold on you – such as your name, address, contact details, date of birth, information regarding your health etc. You are necessarily entitled to the documents that contain the data.
We will endeavour to provide you with the personal information to which you are entitled within 30 days unless there are legitimate reasons for doing so and unless your request is exceptional in some way, there will be no cost to you.
In addition to the entitlement to access your data, you may have the following rights:
- The right to be informed: this is fulfilled through this privacy notice and our explanation about how we use your personal data.
- The right to rectification: you are entitled to have your personal data amended if it is inaccurate or incomplete.
- The right to erasure / ‘right to be forgotten’: you have the right to request the deletion or removal of your personal data where:
- The use or storage of personal data is no longer necessary for the purpose for which it was originally collected;
- Consent is the lawful basis for holding your data and you withdraw your consent;
- You object to the processing and there is no overriding legitimate interest for it to continue;
- The personal data was unlawfully processed; or
- You object to the processing for direct marketing purposes
- The right to object: you have the right to object to processing based on legitimate interests and direct marketing. This right applies as follows:
- We must stop processing personal data for direct marketing purposes if you object
- Otherwise your objection must be based on grounds relating to your particular situation
- We must stop processing your personal data unless:
- We can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms; or
- The processing is for the establishment, exercise or defence of legal claims.
- The right to restrict processing: you have the right to request us to restrict or suppress your data. When processing is restricted, we can store your data but we cannot use it. This right only applies where:
- You contest the accuracy of the personal data and we must restrict the processing until we have verified the accuracy of the data;
- You object to the processing (if necessary for the performance of a public interest or purpose of legitimate interests), and we are in the process of considering whether our legitimate grounds override your right;
- Processing is unlawful and you request restriction; or
- If we no longer need the personal data but you need it to establish, exercise or defend a legal claim
- Rights to data portability: If you want to move, copy or transfer the electronic personal data that we hold about you to another organisation, please contact our Data Protection Officer (as above).
- Rights to object to automated decision-making: If you want to object to any automated decision making without any individual involvement that we undertake, and to the profiling of your data, please contact our Data Protection Officer (as above).
Likelihood of objection to processing of information
235MPL is not aware of any justifiable reasons that would constitute a legitimate reason for objecting or complaining about the way we process or control information.
Our website and services are not aimed at children. If you are a child and need further advice or explanation about how we would use your data, please email email@example.com
Complaints about the use of personal data
If you want to complain about how we have dealt with your personal data, please contact our Data Protection Manager (as above) and we will investigate.
If you are not satisfied with our response or believe we are unlawfully processing your personal data, you can complain to the Information Commissioner’s Office (ICO) via the official website.
None of the information that we collect, process or store is transferred outside of the UK unless necessary for the purposes of fulfilling our contractual or professional obligations to our clients and in circumstances where our clients have a legitimate expectation of our sharing such information in the manner it is shared.
How we collect personal data
The following are examples of how we collect your personal information:
- Asking you to provide it when we enter into a contractual relationship with you
- Asking you to provide it in connection with a job application or with your employment with us
- Following/liking/subscribing to our social media channels · Asking us a question or submitting any queries or concerns you have via email or on social media channels
- Posting information to our website or social media channels, for example if we offer the option for you to comment on, or join, discussions
Legitimate interest will be the legal basis for processing personal data of job applicants, employees, clients and business contacts. Relevant business communications may be sent to you by post, email, courier and digital communications platforms.
How we may use your details
The following are examples of how we might use your personal information for our legitimate business interests:
- Fraud prevention
- Network and information systems security
- Modifying or improving our services
- Identifying systems and communications usage trends
We may use your personal information for legitimate interests under a reasonable expectation that we can provide you with information you would expect to receive or that would benefit and enhance our relationship. This information will help us review and improve our services.
You have the right to object to this processing. If you wish to do so, please email our Data Protection Manager (as above).
Cookies and links to other websites
By using our websites you agree that we can place these cookies on your device.
We may also use analytics tools provided by Google, Inc. or other similar providers. The data collected enables us to understand aggregated user or visitor activity and how we might improve our website. This data is collected and used on an anonymised, aggregated basis only and does not enable any user or visitor to be personally identified.
In addition, we may also use marketing automation tools. These companies serve cookies to profile users or visitors’ interests and activity. We may use data collected through these cookies to serve users or visitors with information, new articles and advertising tailored to their specific needs and requirements.
You have the right to refuse or disable cookies served through our website although, if you choose to do so, some functionality might become unavailable to you. As the methods to do this vary from browser to browser, we suggest that you access your browser’s help menu for further information. We respect your right to choose whether or not to accept cookies.
Note: If you do not set your browser and e-mail settings to disable cookies, you will be indicating your consent to receive them.
If you want to find out more about cookies and clear gifs, you can visit www.allaboutcookies.org, an independent resource that explains what cookies and clear gifs are and how you might manage them. We are not responsible for, and have no control over, the content of this third party website.
Our website might contain links to other websites or web services. Once you have used any link to leave our site, you should note that we do not have any control over that other website. We can’t be responsible for the protection and privacy of any information that you provide while visiting any other s sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
If you have any questions about this notice or our privacy arrangements, please email our Data Protection Manager (as above).
This document may be subject to amendment.
Go to www.235musicpublishing.com.com/privacy for the most up to date version.
235 Music Publishing Limited
Elsley Court, 20-22 Great Titchfield St., London W1W 8BE