PRIVACY POLICY
Please read the Music Circles Privacy Notice carefully to understand how we use your personal data. The Music Circles Privacy Notice defines the basis for processing any personal data you provide to us, or we collect from you when you use our website or make an enquiry with us.
This website is operated and managed by Music Circles. This Privacy Policy explains how we use and protect your personal information. You express your consent to this Privacy Policy by using our Site. If you have any questions about this Privacy Policy or the website, please contact us.
Music Circles is the registered controller for the purpose of the Data Protection Act and GDPR. This website privacy notice describes how the controller protects and makes use of the information you give to us when you use this website.
This policy is updated from time to time. The latest version is published on this page.
When you provide personal information to us it will only be used in the ways described in this Privacy Policy.
This Privacy Policy describes how we handle your personal information for our services available through this website (the “Site”) and mobile applications (the “Apps”). By using this Site, Apps, or by registering as a member of our marketing list, you accept the terms of this Privacy Policy, and in doing so, you expressly consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.
Introduction
You can browse the Site or Apps without telling us who you are or revealing any personal information about yourself. Once you give us your personal information, you are not anonymous to us. If you choose to provide us with personal information, you consent to the transfer and storage of that information to our servers located in the United Kingdom. Where sensitive data is stored, it is held in an encrypted form, only readable by programs that are themselves protected by password and by access point. As a visitor to the site we collect information about you, in order to:
- Respond to general enquiries,
- Provide information relating to your account
- Communicate with you about events and promotions
- Keep you updated with changes to related regulations
- Collect information via our website to better understand how visitors use it
- Inviting you to participate in research studies and/or market research activities with your prior consent
What data we gather
To ensure we are able to respond to our members, we will collect the following personal information, please note that this is not an exhaustive list:
- Email address, physical contact information;
- Credit/debit card information (held within the payment gateway and bound by their PCI compliancy);
- Transactional information and bank details based on your activities on the Site – Delivery, billing and other information you provide to purchase or deliver an item, (held within the payment gateway and bound by their PCI compliancy);
- Community discussions, chats, dispute resolution, correspondence through the Site, and correspondence sent to us;
- Computer sign-on data, statistics on page views, traffic to and from the Site, and ad data; and
- Other information, including your IP address, Browser, Operating System, Domain Name and Time and other standard web log information.
How we use this data
Below is a list of all the ways that we may use your personal information, and specific reasons we rely on to use this information.
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Marketing to you
At Music Circles, we want our customers to know about our exciting services, offers and products that we think you would be interested in, which we call ‘marketing’.
We can do this by looking at your purchase history and personal information to see which products services and offers you might be particularly interested in, which is also known as ‘profiling’ for marketing purposes. You have the right to ask us to stop marketing to you at any time. If you have a preference to receiving marketing through the post or via email, please let us know.
We only market to you if you have given your consent, or if there is a ‘legitimate interest’. Marketing to you under legitimate interest will mean that we have established that there is a commercial or business reason to market to you which must be fair to you, so we can’t just send you any marketing material.
If you do not want us to collect or process personal data from our websites or mobile apps, you have the right to prevent future processing.
As standard, we will contact you to confirm your choices regarding the use of your personal data in line with changes in the regulation, law, or business changes and we have a specific set of marketing preferences in your Music Circles account that you can update at any time.
Surveys, questionnaires & competition entries
From time to time, we may invite you to take part in Surveys, Questionnaires or a Competition. These will obviously take different forms, but will all involve the capture of answers and other personal information – typically name and email address. Competition entries will be made available to our operational staff so that winners may be selected. Other information will be made available in summary form to our operational and marketing staff. Such information may be made available to business partners, particularly where a third party is organising or sponsoring the event. If this is the case, you will be made aware of the arrangement and in what form your data is to be passed on.
Contact information
When entering into a sales transaction we require certain contact information. This extends your membership record to include your Name, Address and Telephone Number.
Delivery information
When goods are to be delivered, we need to have delivery details, so we will require you to provide a Delivery Name, Address and Telephone Number. This information may also be shared with any courier company that we may use for the delivery of the goods.
Credit/debit card information
When paying for goods or services via credit card, we require you to enter your credit card number, expiration date, card type (MasterCard, Visa, etc.), card holder name and card security code. This information is entered directly on to a page hosted by our credit card payment processing provider, a PCI DSS Level 1 certified facility, who store these details in encrypted format and provide us with a ‘token’ that we store and use to refer to the card for transactional purposes. They also provide us with the first six and last four digits of the card number, the cardholder name, and the expiration date that we store to assist in identifying which card you wish to use in the future. We do not store the full credit card number at any time. Due to our use of the ‘token’ system, card information does not need to be made available to our Operational staff and it is not possible for any of our staff to obtain full credit card information.
Order information
When you place an order, we will keep a record of the type(s) of item(s) purchased, the quantity, pricing information and any delivery cost. For analysis purposes, we also store the date the order was placed and the date it was shipped. This information may be made available in summary, non-specific form to any of our business partners by way of analysis or the payment of royalties and/or licenses in the supply of such goods. At the end of placing the order, we may ask you to enter certain simple items of marketing information to help us develop our business. You may elect to not enter this information.
Use
Our primary purposes in collecting personal information are to allow for payment by credit or debit card while providing you with a safe, smooth, efficient, and customised experience. You agree that we may use your personal information to:
- Provide the services and customer support you request;
- Resolve disputes, collect fees, and troubleshoot problems;
- Prevent potentially prohibited or illegal activities, and enforce our Terms and Conditions of Sale and policies;
- Customise, measure, and improve our services and the Site’s content and layout;
- Tell you about targeted marketing, service updates, and promotional offers based on your communication preferences; and
- Compare information for accuracy, and verify it with third parties
Who We Share Your Personal Information With
Music Circles may need to share your information with other organisations:
- Service providers under contract who help with our business operations, such as fraud investigations, bill collection, order fulfilment, shipping, affiliate and rewards programs and co-branded credit cards;
- Other third parties to whom you explicitly ask us to send your information or about whom you are otherwise explicitly notified and consent to when using a specific service;
- Law enforcement or other governmental officials, in response to a verified request relating to a criminal investigation or alleged illegal activity – in which cases we will disclose name, city, telephone number, email address, User ID history, fraud complaints and purchase history; and If we legally segregate some or all of our business, your information may be transferred with the segregated business.
We may disclose personal information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property or safety.
Controlling information about you
We will never lease, distribute or sell your personal information to third parties unless the law requires us to.
Any personal information we hold about you is stored and processed under our data protection policy, in line with the Data Protection Legislation.
Where do we store your data?
Music Circles will not transfer your personal information outside of the EEA. If we are ever required to send your personal information outside of the EEA it would be for the following reasons:
- Comply with a legal duty.
Access to your information
You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all of your personal information please contact us via the details provided in the ‘contact us’ section.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
How to Get a Copy of Your Personal Information
You can access the personal information we hold by writing to us at hello@music-circles.com
If You Think Your Personal Data Is Incorrect?
If you think we may have information about you that is incorrect or wrong, you have the right to question and raise this with us. Please contact us if you want to do this, we will take reasonable steps to check its accuracy and correct it.
Your Rights to Stop Us Using Your Personal Information?
We may need to keep your data for legal or official reasons but you can inform us if you think that we shouldn’t be using it. You can object to us using your data or to have it deleted and removed if you think there is no reason for us to have it. This is now recognised as the ‘right to object’, the ‘right to erasure’ or the ‘right to be forgotten’.
We can sometimes limit the use of your data. This will mean that your data will only be used for specific things like legal rights and legal reasons. In this case, we will not use or share your information in additional ways while it is restricted.
You have the right to ask for your personal data to be restricted if you think:
- It is not correct.
- It you think it has been used unlawfully, but you do not it deleted.
- It is no longer relevant, but you want us to keep it for a legal claim.
- You are waiting for us to confirm if we are allowed to keep on using it but you have already asked us to stop using your data.
If you want us to stop using your personal data for any of the above cases, please contact us.
How You Can Withdraw Your Consent
You have the right to withdraw your consent at any time so please let us know if you wish to withdraw consent. It may not always be possible to provide certain products or services to you if you do but we can confirm this with you.
Formats for Sharing Data
From the 25th of May 2018, you have the right to obtain your personal information from us in a format that can be easily re-used or ask us to pass on your personal information in this format to other organisations.
Retention periods
We will not keep your information for longer than is necessary however there are some situations where some information may be retained for in line with legal and regulatory requirements or guidance.
Cookies
We use “cookies” (small files placed on your hard drive) on certain pages of the Site to reference information stored on our server, such as member details and any preferences, in order to improve your browsing experience. Cookies are also used to track user’s behaviour on our Site for analysis purposes, so that we may work towards offering a better service to our customers. Third party referrals to our Site, from either their web site, from a dedicated link elsewhere, or from a printed URL are recorded using a cookie, which enables us to pay any commissions due to the referrer for your visit to our Site. Cookies are stored in the server logs and their contents are stored in the Site’s database. Browsing behaviour, in anonymous form, may be made available to our Marketing and Operational staff and may be relayed to any business party in the interests of improving our services. We do not profile individual customers using cookies.
A few important things you should know about cookies are that:
- We offer certain features that are only available through the use of cookies;
- We use cookies to help identify you and maintain your signed-in status;
- Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session;
- You are always free to decline our cookies if your browser permits, although doing so may interfere with your use of the Site; and
- In the event that we host any third party content on this website, you may encounter cookies from third parties on certain pages of this website that we do not control.
Controlling cookies
You can use your web browser’s cookie settings to determine how our website uses cookies. If you do not want our website to store cookies on your computer or device, you should set your web browser to refuse cookies.
However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.
Email Communications
As a user of our products or services, we will send you support communications by e-mail. As long as you are happy for us to do so, we would also like to keep you posted on anything that’s happening at Music Circles which we think you might like to know about; whether it’s our latest product announcements, owner offers or upcoming events, we want to make sure you’re happy with the communications you receive from us.
You can find out how to update or change whether you would like to hear from us, or stop us contacting you, in the section below titled ‘How is this personal information used?’
Online interactions
We collect and handle information from all visitors to our website, whether you actively provide us with that information or merely browse our websites. The information we collect includes the internet protocol (IP) address of the device you are using, the browser software you use, your operating system, the date and time of access, the internet address of the website from which you link through to our website and information on how you use our websites.
We use this information so that we can see how long our website takes to load, how it is used, the number of visitors to the different sections of our website, and what information visitors look at most.
We also collect, and handle information about how you engage with our promotional campaigns and advertising online, outside of our own websites (for example, on Google, YouTube [or on social media]).
That information is, predominantly, collected through our use of cookies and similar technologies.
Social Media
The information we collect from social media and online sites sometimes includes personal information that has been put online and is publicly available. We make sure any information we use is properly credited to its source or is made anonymous.
These online and social media sites may have their own privacy policies explaining how they use and share your personal information. You should carefully review those privacy policies before you use these sites to make sure that you are happy with how your personal information is being collected and shared.
Our Use of Cookies and Similar Technologies
Cookies are pieces of data, normally stored in text files that we place on visitor’s computers to store a range of information, usually specific to that visitor or device being used. Should you choose, you can disable cookies from your browser and delete cookies currently stored on your computer.
This can be done, in Microsoft Internet Explorer, by selecting “Internet Options” and then selecting the “Privacy” tab under “Settings”. From here you can select to “Block Cookies”. If using Google Chrome, go to “Settings”, and then select “Advanced”. Under “Privacy & Security”, select “Content Settings” and then “Cookies”. You can choose to “Allow sites to save and read cookie data” or select which cookies you want to block. Please consult your online HELP menu for other browsers or devices or if you need any further support in blocking or removing cookies.
If you choose to block cookies, this may prevent the Website or Apps from working correctly or stop us being able to identify errors on the Website or Apps that you may experience. Unless you have changed your browser to refuse cookies, our website will issue cookies when you visit it.
The cookies used on our Websites have been categorised based on the guidelines found in the ICC UK Cookie guide. We use the following categories on our websites and other online services:
Category 1: Strictly Necessary Cookies
These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Category 2: Performance Cookies
These cookies allow us to monitor traffic sources and our Website performance. This data may be used to help optimise our websites and make them easier for you to use and navigate. These cookies are also used to let affiliates know if you came to our Website from an affiliate and if your visit resulted in the use or purchase of a product or service from us, including details of the product or service purchased. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Website or be able to monitor performance.
Category 3: Functionality Cookies
These cookies allow our websites to remember choices you make while browsing and can allow enhanced functionality or personalisation. They may also be used to keep track of what featured products or videos have been viewed to avoid repetition. The information these cookies collect will not personally identify you, and they cannot track your browsing activity on non Music Circles websites and apps.
Category 4: Targeting Cookies
These cookies may be set through our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser or internet device. If you not allow these cookies, you will experience less targeted advertising.
Category 5: Social Media Cookies
These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
Unsubscribe instructions
To unsubscribe from our mailing list simply click on the unsubscribe link at the bottom of any of our marketing emails and you will be opted out of all email communications.
Account Protection
Your password is the key to your account. Use unique numbers, letters, and special characters and do not disclose your password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify us and change your password.
Accessing, reviewing and changing your personal information
You can see, review and change most of your personal information by logging into the Site. Generally, we will not manually modify your personal information because it is very difficult to verify your identity remotely. You must promptly update your personal information if it changes or is inaccurate. Should you so wish, and upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on you’re a account activity and in accordance with applicable law. We do retain personal information from closed accounts in order to comply with law, prevent fraud, collect any monies owed, resolve disputes, troubleshoot problems, assist with any investigations, and take other actions otherwise permitted by law.
How we protect personal data
We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.
We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe. We only authorise access to employees who need it to carry out their job responsibilities.
Our procedures mean that we may request proof of identity before we share your personal information with you.
In the unlikely event that we do suffer a security breach, which compromises our protection of your personal information and we need to let you know about it, we will do so.
However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.
Third parties
Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. We will never sell personal information or share any personal information with third parties that are unrelated to us. Data that has been aggregated from information – so that it is expressed in a broad, non-personal manner – may be relayed to third parties from time to time in order to better serve our customers.
Linking to other web sites
Our site may contain links to other web sites. Please note that when you click on one of these links, you are clicking to another web site. We strongly advise you to read the Privacy Policy of these linked web sites as it may well differ from our own. Once you leave our website and enter another website, we cannot be responsible for the privacy or protection of any information you transmit or provide.
Accuracy of our Site
We make every effort to ensure the accuracy of our website, both in its operation and its content. If you discover any errors or omissions, please email the details to: hello@music-circles.com
Changes to our Privacy Policy
We reserve the right to change our Privacy Policy from time to time as the business evolves. Where a revision is made to the policy the revised policy will be posted to our Site. Such changes to our Privacy Policy automatically shall become effective immediately upon posting the changes on our website.
Contacting us
How to Make a Complaint
If you are unhappy or unsatisfied with why and how we have used your personal data, you can contact us by sending an email to hello@music-circles.com.
If you are unhappy with our response, you can contact the office or the Information Commissioner at:
Email: casework@ico.org.uk
Tel: 0303 123 1113
Website: https://ico.org.uk/global/contact-us