ONLINE PRIVACY NOTICE

Project Melody Music Limited (“we”, “us”, “our”) respects your concerns about privacy.

This Online Privacy Notice (the “Notice”) applies to all personal data we may collect about you at www.projectmelodymusic.com (the “Site”).

The Notice describes the types of personal data we obtain, how we use the personal data, and with whom we share it. We also describe the rights you may have and how you can contact us about our privacy practises.

As a data controller we are responsible for processing your personal information collected through the Site.

1. How We Obtain Information About You

We may collect personal data that you choose to provide to us through the Site, including, but not limited to, your first and last names, physical address, e-mail address, or telephone number.

Information may be provided by you in circumstances such as when you:

• Make purchases on the Site;
• Sign-up to a feature that we offer on the Site and you provide your personal data in connection with that feature;
• Attend an event that we or one of our business partners has organised.

When you visit our Site, we also may collect certain information by automated means using technologies such as cookies, non-cookie-based tokens, web server logs, tracking pixels, and web beacons.

Cookies are files that websites send to your computer or other Internet-connected devices to identify your browser uniquely or to store information or settings in your browser. Your browser may tell you when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Site and may not be able to purchase products that use a “shopping cart.”

Where permitted by law, we may acquire personal data about you from third parties. This may include personal data shared between our affiliates and business partners and publicly-available profile information (such as your preferences and interests).

We may also collect personal data in other contexts that we will notify you of at the time.

2. Information We Obtain and our Legal Basis for Processing

Information That You Provide to Us

Personal data that you provide directly to us will be apparent from the context in which you provide it, for example:

• If you register on the Site (for example to sign up to our newsletter) you will generally provide your full name, email address, email subscription and communication preferences. Our legal basis for processing your personal data in this way is that processing is necessary for the performance of a contract to which you are a party;
• If you make any purchase(s) you will generally provide your full name, email address, telephone number, postal and billing address and payment details. Payments are processed by our payment provider to whom you will supply your payment details directly. We will not store your payment card information. Our legal basis for processing your personal data in this way is that processing is necessary for the performance of a contract to which you are a party.

Information That We Collect Automatically

Our web servers may log information such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to our Sites and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the Site, such as which pages you visit.

To control which web servers collect information by automated means, we may place tags called “web beacons” — small files that link web pages to particular web servers and their cookies. We may also collect information from your browser, such as your browsing history, and use it in conjunction with data gathered from forms and e-mails to help us understand and respond to your needs.

Where the information gathered is completely anonymised, the information will not constitute personal data. Where your personal data is not in an anonymous form, our legal basis for processing your personal data in this way, is that it is in our legitimate interest to continually evaluate that personal data in operating and improving our business (and to ensure that the products and services we provide are relevant to the market) that is not overridden by your interests, rights and freedoms to protect personal data about you.

Information That We Obtain From Third Parties

Information that we collect from third parties will generally consist of publicly-available profile information (such as your preferences and interests), for example from public social media posts.

3. How We Use Information That We Obtain

We may use personal data that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about products and future events, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal data about you. If you make a purchase on our Site, we also collect personal data because it is necessary for us to enter into a contract with you.

In addition to the uses above, we may also use the personal data you provide on our Site to:

• operate, evaluate, and improve our business;
• develop new products and services;
• advertise and market our products and services;
• determine the effectiveness of our advertising and marketing;
• analyze our products, services, and websites;
• administer the Site;
• segment and personalise the marketing communication that you have viewed on the Site.

We may also use the information to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.

Although we do not currently use your data for direct marketing we do reserve the right to do so for administrative purposes.

Other Uses of Information

In addition to the uses described above, we may use personal data that you provide to us or that we collect for other purposes. Where that is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal data and our legal basis for doing so.

4. Information We Share

We do not sell or otherwise disclose personal data that you provide to us or that we collect on our Site, except as described here. We may share personal data you provide to us or that we collect on the Site with:

• Our business partners;
• A named third party where you have given consent; or
• Service providers that perform services on our behalf.

We may share personal data with service providers that perform services on our behalf such as payment service providers, analytics providers, hosting providers and advisers. All our service providers will have entered into legally binding agreements requiring them to use or disclose personal data received from us only as necessary to perform services on our behalf or comply with applicable legal requirements.

In addition, we may disclose personal data about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity; and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

5. How Long We Keep Information

The time period for which we keep personal data depends on the purpose for which it was collected. In all cases we keep it for as long as necessary to fulfil the purposes for which it was collected. We will then delete the personal data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).

Subject to any applicable legal requirements, we typically retain personal data as follows:

• Personal data you provide to us when you make a purchase through our Site: we keep this personal data in order to process and deliver your purchase, and then we store it securely for seven years.
• Personal data collected for analytics purposes: we keep this personal data for such period of time necessary for us to carry out the analytics. We anonymise personal data used for analytics, immediately.

6. Your Rights and Choices

If you are located in the European Economic Area (“EEA”) or Switzerland, you may have the following rights in relation to personal data that we hold about you:

• To request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
• To request that we rectify or update your personal data that is inaccurate, incomplete or outdated.
• To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
• To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;

You may contact us by e-mail or as described in the “How to Contact Us” section below to exercise your rights described above.

You also have the right to lodge a complaint with the data protection supervisory authority in your country.

7. Updates to Our Online Privacy Notice

We may update this Notice periodically and without prior notice to you to reflect changes in our personal data practises or relevant laws. We will post the updated version online and indicate at the top of the notice when it was most recently updated.

8. How to Contact Us

If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose your personal data, or if you would like us to update information we have about you or your preferences, you may contact us at:

Project Melody Music Limited
C/o Jayes Collier llp
Ealing Studios
Ealing Green
London
W5 5EP