Privacy Policy

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 data@235musicpublishing.com or you can  write to 14 Basing Hill, London, United Kingdom, NW11 8TH. 

General 

This notice does not apply to any websites or web services linked to our website  or any website or web services that we provide you with links to at any time, as  we do not have control over them. See below for our Cookie Policy. 

About Us 

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. 

Provided information 

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. 

Children 

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  data@235musicpublishing.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. 

Overseas Transfers 

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. 

Your rights 

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 

We may use cookies to store and help track information about you to offer and provide a personal service through our website  (www.235musicpublishing.com). A cookie is a small text file sent to your device  that we use to store limited information about your use of the website. We may  use cookies to provide you with certain functionality and to personalise our  website content. Without cookies, this functionality would be unavailable. 

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. 

Enquiries 

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