We take your privacy very seriously. Horus Music Limited and our subsidiaries and affiliates collect and process some Personal Data about you. Under the GDPR (General Data Protection Regulations) we are required to provide you with certain information about how and why we collect, hold and process and in some cases transfer your Personal Data. This policy outlines:
- What data we collect.
- Why and how we collect this data.
- Your rights as an individual with regards to your data.
- Who we share this data with.
- How long we keep this data.
THE PERSONAL DATA THAT WE COLLECT
The Personal Data that we collect may include your name, date of birth, address, email address, post/zip code, phone number, country, Skype username, IP Address, Time zone and social media usernames/profiles. We collect this Personal Data from you when signing up to using our service and/or by entering this data on your MyClientZone profile. We also collect some of this data when joining our mailing list so we can keep you up to date with any news or updates to our services. We also collect Personal Data from third party partners such as Western Union and PayPal. We always ensure that we have a lawful basis for processing any Personal Data we collect. In this case, the lawful basis for processing this data is; to carry out our contractual obligations in order to distribute your audio and/or video releases or pay you any due royalties, as a legal requirement or by getting your expressed consent to collect this Personal Data.
HOW WE USE YOUR PERSONAL DATA
We are committed to using your Personal Data responsibly and lawfully. We use your Personal Data to:
- Process any orders and/or releases you submit to us quickly and efficiently;
- Transfer your releases (together with any personal information contained in the metadata and accompanying materials) to various platforms around the world;
- Collect subscription fees from you;
- Provide you with a report on sales and usage;
- To administer our site and internal operations;
- Pay you any due royalties, process payments and issue self-billing invoices;
- Ensure we deal with any queries you may have in an efficient and timely manner; and
- Send you; any updates on our services, information you have shown interest in or new services we have added.
As with most websites when you access our web pages certain information will be recorded by us, such as your IP address, browser type and information about web pages you have visited (see Cookies section below, for further information). This information is processed to work out how much use of the website is made by different users.
We like to keep you up to date with our news and activities. We may do this by sending you information by email, social media, post, telephone call or text message. In order to do this we operate a database that contains your Personal Data.
We currently only use email and social media for marketing.
We use MailChimp for our mailing list management which does track who opens emails and who clicks on what links within the emails we send out: https://mailchimp.com/
All marketing is done in-house and no third party companies are used to reach out to clients or potential clients.
We use Facebook Ads and Google Ads to market (but do not share any personal details with them).
When doing marketing campaigns (trying to get promotion for clients) we share release data and sometimes Personal Data such as name and email addresses.
If you would like to unsubscribe from any mailing list you have previously opted into then you can select the ‘unsubscribe’ option at the bottom or top of any newsletter we send. Alternatively, you can also contact us to remove you from any mailing list.
If you should apply for a job with Horus we will need to ask you for certain Personal Data and use it to assess your suitability for employment. You do not have to provide us with all Personal Data we request but if you do not it may affect your job application if you decide not to. Any Personal Data you provide us with as part of your job application will only be used for the purpose of progressing your application, or to fulfil legal requirements. We will not share any of the information you provide during the recruitment process with any third party for marketing purposes.
We may need to use the services of a recruitment agency from time to time, in particular, for temporary staff and senior staff. In this instance the recruitment agency will transfer personal details to us.
Transfers of Personal Data Outside of the EEA
We may pass Personal Data to other organisations within or outside of the EEA who are contracted to provide services to us where the transfer is necessary for the provision of those services. Some of these countries may not have the same level of data protection as the UK. Whenever we transfer your Personal Data outside of the EEA, our procedure for dealing with this is to ensure a similar degree of protection is afforded to it by ensuring one of the following safeguards are implemented:
- Checking whether the particular country to which Personal Data is being transferred to has been ‘deemed to provided an adequate level of protection’ for Personal Data by the European Commission;
- By putting contracts in place to ensure the 3rd party is aware of its responsibilities under the General Data Protection Regulations;
- Transferring Personal Data to the United States to an entity if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the US.
Security of Personal Data
We take technical and administrative steps to protect all of the Personal Data we hold. Only authorised employees and contractors have access to your Personal Data. Although we do our best to protect your Personal Data no system on the internet is 100% safe.
We take appropriate administrative, technical, physical measures and more to safeguard your Personal Data against, theft, loss, unauthorised access and misuse.
YOUR PERSONAL DATA RIGHTS
- Right to Rectification: If you believe any of your data we have is incorrect or out of date then please contact us to request this data is changed. You have the right to request us to rectify inaccurate information held abut you without undue delay.
- Right to Access: If you would like a copy of the data we hold on you then please contact us. We will require two forms of identification in order to process this request. If we do hold information about you we will give you a description of it, tell you why we are holding it, tell you who it could be disclosed to and let you have a copy of the information in intelligible form. This request can be made free of charge, in writing to the Data Protection Officer, details of which are below.
- Right to Object: If you would like to object to us processing your data or would like us to delete your data, and we don’t have a lawful reason to retain it, you can make a request for us to stop processing and/or delete this data by contacting us.
- Right to confirmation: If you would like to obtain from us confirmation whether or not Personal Data concerning you is being processed by us you can contact us at the email address below.
- Right to Erasure (right to be forgotten): you have the right to have the personal data we hold about you erased without undue delay, however if the processing is necessary for us to perform our service this may be difficult. If you would like to consider having your Personal Data erased please contact us on the email address below.
- Right to data portability: you are entitled to receive from us a copy of the Personal Data we hold concerning you in a machine readable format.
- Right to withdraw consent: where consent forms are the basis for processing, you have the right to withdraw your consent to the processing at any time.
In all cases above you can reach out to us at firstname.lastname@example.org or by using the “Contact Us” form on your MyClientZone Profile to make any of these requests.
GDPR requires that Personal Data is accurate. It is essential that you let us know if your contact details change. If we do not have the correct contact details, we cannot take responsibility for its accuracy.
WHO WE SHARE YOUR DATA WITH
We may need to share some Personal Data, which you provide to us, with a third party in order to process any releases or payments due to you and to assist us with our business operations. We may pass Personal Data to third parties in the following circumstances:
- Your Personal Data may need to be shared internally, for example, in order to deal with a query you may have, or in order to process a release;
- All metadata you provide to us (and accompany Materials such as Bio, photographs, videos etc) may be sent to any and all store partners in order for us to distribute your release(s), within the terms of our contract;
- We may need to share details with third-party partners such as Western Union, PayPal and Xero in order to process releases, payments, royalties and invoices. This is to enable us to carry out our contractual obligations;
- We use a third party provider to assist us with transmission of your releases (together with metadata and accompanying materials bio, photographs etc) to various platforms around the world. Currently, we are using Consolidated Independent www.ci-info.com;
- We use WordPress for our website https://en-gb.wordpress.org/;
- We use PayPal who deal with any purchases you make;
- We use Western Union Business Solutions for making royalty payments to clients.
- To suppliers (such as IT Service providers) who process information on our behalf;
- To independent suppliers who are under a contractual obligation to assist us with our business operations;
- Analytics and search engine providers that assist us in improvement and optimisation of our website;
- We use google ads and facebook ads;
- If required by our internal auditors;and
- We may also need to share your details with third parties to issue and resolve legal notices.
We do not sell your data to any third party companies under any circumstances.
HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
Your Personal Data will be retained by us for the duration that your MyClientZone profile is open and may be retained for a period after this time in order to carry out our contractual obligations or in accordance with any applicable legal requirements. This may include retaining data necessary; to meet our tax reporting requirements, to enable us to carry out our contractual obligations or for identifying, issuing and resolving any legal requirements.
Name and Address of the Controller
The Controller is Horus Music Limited and we determine the purposes and means of processing of the Personal Data. Horus Global has its registered office at 346 Loughborough Road, Leicester LE4 5PJ .Phone (0)116-2530203. Email email@example.com Website www.horusmusic.global.
Name and Address of the Data Protection Officer
The Data Protection officer is Nick Dunn.
You may contact our Data Protection Officer with any enquiries relating to Data Protection. Please use the following email address firstname.lastname@example.org.
Name and Address of the Lead Supervisory Authority
The lead supervisory authority overseeing is the Information Commissioner’s office, Wycliffe House, Water Lane, Cheshire, SK95AF, United Kingdom, Phone +44 (0) 3031231113.
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