Privacy Policy


Published: 23rd May 2018


We are committed to protecting and respecting your privacy. This Privacy Policy relates to our website at www.boosey.com or any related online or mobile service ("Site") operated from time to time by or for Boosey & Hawkes Music Publishers Limited ("B&H", "we", "us" or "our").

It explains how we collect, process and look after any personal information that we collect about you when you use the Site, including any data that you may provide when registering an account or purchasing products or digital content. Further details of how we use your information are set out in our Cookies Policy, which forms part of this Privacy Policy.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This Privacy Policy is provided in a layered format, so you can click through to the specific areas set out below.

By continuing to use the Site, you acknowledge our collection, storage and use of your personal information as described below.

The Site is not intended for children, and we do not knowingly collect any data relating to children.

Contents:
1. Important information and who we are
2. The data we collect about you
3. How we collect your personal data
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary
11. Changes to this Privacy Policy


1. IMPORTANT INFORMATION & WHO WE ARE

Controller

B&H is the controller and responsible for your personal data.

We have appointed a data privacy team to oversee any queries about this Privacy Policy. If you have any such queries, including any requests to exercise your legal rights in relation to your personal data, please contact our data privacy team using the following details:

Email address: dataprotection@boosey.com

Postal address: Data Protection Department, Boosey & Hawkes Music Publishers Limited, Aldwych House, 71-91 Aldwych, London WC2B 4HN, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Informing us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data change during your relationship with us.

Third-party links
The Site may contain links to other online or mobile sites. We are not responsible and accept no liability for the privacy practices or content of such sites.


2. THE DATA WE COLLECT ABOUT YOU

The term “personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
  • Identity Data include your first name, last name, user name or similar identifier, title, date of birth, gender and/or (if applicable) company name.
  • Contact Data include your billing address, delivery address, country of origin, email address and telephone number(s).
  • Transaction Data include details about payments to and/or from you and/or other details of products or digital content that you have bought from us.
  • Technical Data include your internet protocol (IP) address, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices that you use to access the Site.
  • Profile Data include your user name and (for registered users) password, purchases or orders made by you, and your interests, preferences, feedback and survey responses.
  • Usage Data include information about how you use the Site.
  • Marketing and Communications Data include your preferences in receiving marketing from us and (if relevant) third parties and your communication preferences.


We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but are not considered personal data in law, as such data do not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. If, however, we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this would include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract that we have with you and you fail to provide that data when requested, we may not be able to perform the contract that we have or are trying to enter into with you (for example, to provide you with products or digital content). If so, we shall notify you if this is the case at the time.


3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you, including through:

Direct interactions: You may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by post, email, phone or otherwise. This includes personal data that you provide when you:

- submit a contact form via the Site;
- send us any correspondence by post;
- send an email to any of our contact email addresses displayed on the Site;
- phone us through our switchboard;
- order any of our products or digital content;
- create a new account on the Site or upgrade your account;
- subscribe to receive our email newsletters;
- request marketing to be sent to you;
- enter a competition, promotion or survey; and/or
- give us some feedback.

Automated technologies or interactions: As you interact with the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites using our cookies. Please see our Cookies Policy for further details.

Third-party sources: We may receive personal data about you from various third-party sources as set out below:

- Technical Data from:


(a) analytics providers such as Google based outside the EU;

(b) social networks such as Facebook and Twitter based inside and/or outside the EU (which information we may receive indirectly via the above analytics providers); and

(c) search information providers such as Google based inside and/or outside the EU.

- Contact and Transaction Data from third-party providers of technical, payment, fulfilment and delivery services.

4. HOW WE USE YOUR PERSONAL DATA

We shall only use your personal data when the law allows us to do so. Most commonly, we shall use your personal data in the following circumstances:
  • where we need to perform any contract that we are about to enter into or have entered into with you (such as a contract for the sale of products or digital content via the Site);
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights and freedoms do not override our (or such third party’s) interests; and/or
  • where we need to comply with a legal or regulatory obligation.

Please refer to the Glossary to find out more about the types of lawful basis that we shall rely on to process your personal data.

We do not generally rely on consent as a legal basis for processing your personal data other than, if you agree to receive such communications, in relation to the sending of third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to such marketing at any time by contacting us
.

Purposes for using your personal data We have set out, in a table format, a description of all the ways that we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out in the table below.

To view our legal basis for processing data please Click Here

Marketing
We strive to provide you with choices regarding certain uses of personal data, particularly around marketing and advertising, where relevant.

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, digital content and offers may be relevant for you (which we refer to as “marketing”).

You may receive marketing communications from us if you have consented to receive those or if you have bought products or digital content from us (where we believe that similar items may be of interest to you) or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
We will never share your personal data with any third party outside the B&H group of companies for marketing purposes, unless you have given your express prior opt-in consent to do so.

Opting out
If, at any time, you would like us to stop using your personal information or to correct any factual inaccuracies, you can contact us by or post. Be sure to state "Opt-out" in the subject line, and to include your full name, registered user ID (if any) and email address in the message.

To opt out of email marketing communications, please use the unsubscribe link within the relevant email and follow the unsubscribe instructions.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

Change of purpose
We shall only use your personal data for the purposes for which we collected the data, unless we reasonably consider that we need to use such data for another reason and that reason is compatible with the original purpose. If you would like to get an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we shall notify you and explain the legal basis on which we intend to rely.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if and to the extent that this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table (link provided) in section 4 above.
  • Internal Third Parties as set out in the Glossary at section 10 below.
  • External Third Parties as set out in the Glossary at section 10 below.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We may share your personal data within the B&H group of companies, which may involve transferring your data outside the European Economic Area (EEA).

Also, some of our External Third Parties are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we strive to ensure that a similar degree of protection is afforded to such data by ensuring that at least one of the following safeguards is implemented:
  • transferring your personal data to a country, organisation or sector that has, at the time of transfer, been deemed to provide an adequate level of protection for personal data by the European Commission;
  • using specific forms of contract approved by the European Commission that give personal data the same protection it has within Europe; and/or
  • transferring data to a provider based in the US if such provider is part of the Privacy Shield, which requires it to provide similar protection to personal data shared between the Europe and the US.

For further details of such safeguards and for a full list of countries recognised as providing adequate protection, please see the European Commission’s website currently available at: https://ec.europa.eu/info/index_en.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

Our servers are securely located in the United Kingdom and are maintained by a limited number of users.

More generally, we have put in place appropriate security measures (including user authentication software and secure data-sharing feeds) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach, and we shall notify you and any applicable regulator of a breach where we are legally required to do so.

Security of payment processing

The Shop at Boosey.com No bank details entered on the Site are stored on our network servers. All card payments are processed through two layers of third-party payment processor security, 3D-secure cardholder identification (Verified by Visa) and the Monek (UPG) payment gateway service, both of which are PCI-compliant. We also have SSL certificates in place within our secure check-out, providing high-level internet security. Encryption is 256-bit using SHA256 with a 2048-bit RSA key. These are provided by GoDaddy.

To view the data privacy policies of our third-party payment processors and security certificate issuers, please visit their websites, as listed below:

The Boosey & Hawkes UK Hire Library
No bank details entered on the Site are stored on our network servers. All card payments are processed through third-party payment processor security using the Stripe payment system with data servers based in the US. If you are located in the EEA or Switzerland, Stripe complies with applicable laws to provide an adequate level of data protection for the transfer of personal data. Stripe is certified under the EU-US and the Swiss-US Privacy Shield Framework.

To view the Stripe Privacy Shield Policy, please visit the following link:
To view the Stripe Worldwide Privacy Policy, please visit the following link:

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected such data, including for the purposes of satisfying any legal, accounting or reporting requirements.

By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax purposes.

Customers’ invoices are stored for a minimum of six years after the end of the current tax year in which the invoice was raised.

In some circumstances you can ask us to delete your personal data: please see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
  • right of access to your personal data;
  • right to rectification of your personal data;
  • right to erasure of your personal data;
  • right to restriction of processing of your personal data;
  • right to portability of your personal data;
  • right to object to processing of your personal data;
  • right not to be subject to automated decision-making (including profiling); and
  • right to withdraw consent to processing of your personal data.

To find out more about these rights, please see section 10 below and the ICO’s website www.ico.org.uk.

If you wish to exercise any of those rights, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data are not disclosed to any person that has no right to receive such data. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we shall notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product/content and the best and most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a Contract means:
processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means:
processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

THIRD PARTIES

Internal Third Parties means:
other companies in the B&H group of companies (acting as processors), which are based in the EU and provide certain administration services to us.

External Third Parties means:
  • Service providers (acting as processors) based in the UK, EU and USA who help us to fulfil our contractual obligations and to operate our business, including those providing us with certain marketing and data-processing services (such as Dotmailer (UK and USA) and Zinfonia (USA), order fulfilment services (such as Music Exchange (Manchester) Limited, based in the UK), payment processors (such as GoDaddy (UK), Monek and Visa 3D-Secure and Stripe (USA) and IT and communication services (such as server-hosting, CRM-platform, email and telephony providers).
  • Professional advisers (acting as processors or joint controllers), including lawyers, bankers, accountants and insurers, who are based in the UK and provide their respective professional services to us.
  • HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers), which are based in the UK and may require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

In certain circumstances, you have the following legal rights in relation to your personal data:

Right of access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing such data.

Right of rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data that you provide to us.

Right to erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for our continuing to process such data. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Right to restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you would like us to establish the accuracy of such data; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Right to portability of your personal data to you or to a third party. If you so request, we shall provide you, or a third party that you have chosen, with a copy of your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you believe that it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

Right not to be subject to automated decision-making (including profiling) where that would have a significant effect on you. We do not in fact engage in such activities, so this right will not, in practice, be relevant in the context of your use of the Site.

Right to withdraw consent at any time where we are relying on consent to process your personal data. This will not, however, affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products, content or services to you. We shall inform you if that is the case at the time when you withdraw your consent.

11. CHANGES TO THIS PRIVACY POLICY

We may at any time update or otherwise modify this Privacy Policy. We will notify you of any changes to our Privacy Policy by posting the modified Privacy Policy on the Site.

This version was last modified on the date noted below, and historic versions can be obtained by contacting us.

Last modified: 18 May 2018


COOKIES POLICY

This Cookies Policy relates to our website at www.boosey.com or any related online or mobile service ("Site") operated from time to time by or for Boosey & Hawkes Music Publishers Limited.

This Cookies Policy forms part of our Privacy Policy. It explains how we use cookies via the Site to distinguish you from other users and helps us to provide you with a good experience when you use the Site.

By continuing to use the Site, you acknowledge our use of cookies.

About cookies

Cookies are widely used to allow websites to function efficiently. A cookie is a small file of letters and numbers that (depending on your browser settings) is deposited on your computer, mobile phone or other smart device (each, a “device”) when you visit an online or mobile site, if you agree. The cookie may be sent back to that site when you visit again, and may then be used by the server to identify and track your use of the site.

There are two main types of cookies. A “session cookie” is a temporary cookie that only remains on your device until you leave a website. A “persistent” cookie is a long-term cookie that will be stored by your device until its set expiry date (unless you delete it before the expiry date).

How we use cookies

We use the following types of cookies:
  • Strictly necessary cookies: These are cookies that are required for the operation of the Site. They include, for example, cookies that enable you to log into secure areas of the Site or to use a basket on our online shop.
  • Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies: These are used to recognise you when you return to the Site. This enables us to personalise our content for you, to greet you by name and to remember your preferences.
  • Targeting cookies: These cookies record your visit to the Site, the pages you have visited and the links you have followed. We will use this information to make the Site and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them below:

Cookie: “Email”
Duration: 1 year
Purpose: The cookie does not contain any personal information about you, apart from your email address if you select the “Remember Me” option when logging into the Site.

Cookie: "bsid”
Duration: 1 year
Purpose: We create randomly generated basket IDs for “persistent” basket purposes.

Cookie: “cf_token”
Duration: Currently session only not persistent.
Purpose: This cookie is only created if you use one of the "Contact Us" forms on our Site, and contains a randomly generated value which is used to control spam messages submitted through these forms.

Cookie: “Affiliate”
Duration: 30 days
Purpose: If you reach our Site by following a link from a 3rd party Affiliate site, this cookie will contain a numerical value which we can use to identify the Affiliate referrer. It cannot be used to identify you.

We may introduce further types of cookie from time to time to improve your experience of the Site. If we do so, we shall update the list above to note any further main cookies used on the Site.

Managing cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If, however, you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of the Site.

To disable cookies in your chosen browser, you can click on the links below for instructions:

Disable cookies in Internet Explorer:
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

Disable cookies in Chrome:
https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en

Disable cookies in Firefox:
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Please be aware that disabling cookies could reduce your user experience and the relevance of information and content presented to you on the Site.

Third-party cookies

Our Cookies Policy does not cover any third-party online or mobile sites that are linked to the Site. If you click through to those sites, they may set cookies on your device. To understand which cookies are used by those third parties and how they use your data, please read their privacy and cookies policies. We accept no responsibility or liability for those third-party sites.

The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics measures how users interact with our Site content through the use of tracking cookies. As a user navigates between web pages, Google Analytics provides our Site with tags to record information about the page a user has seen, such as the page URL, time and date of visit, length of visit, country of residence and language settings.

The information generated by Google’s cookies about your use of the Site (including your IP address) is anonymous and will be sent to Google and held on Google’s servers in the USA in accordance with Google’s privacy policy (available at http://www.google.co.uk/intl/en/privacy/). Please note that Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

You can find out more information on how Google uses cookies at: http://www.google.com/intl/en/policies/technologies/cookies/

The Site also uses DotMailer, a marketing analytics platform provided by DotMailer Limited. The DotMailer platform uses web behavioural tracking to measure the Site activity of individual users subscribed to any one of our newsletter options. That allows us to send the most relevant information and content to those subscribers based on their Site activity.

Rejecting and deleting cookies

If you object to the use of cookies on the Site, most browsers can be configured to alert you to their use or to enable you to reject cookies. You can also delete cookies already stored on your device. To learn how to reject or delete cookies, we recommend that you consult the "Help" function of your internet browser or, for a mobile phone, your handset manual. Further information on rejection and deletion of cookies is provided on www.aboutcookies.org.

If, however, you decide to disable or delete any cookies, some services or features on the Site (especially interactive features) may not work properly. Disabling or deleting cookies may also affect your ability to use other websites.

Contact us

If you have any queries about our Cookies Policy or our use of cookies, please contact us at:

Email address: dataprotection@boosey.com

Postal address: Data Protection Department, Boosey & Hawkes Music Publishers Limited, Aldwych House, 71-91 Aldwych, London WC2B 4HN, United Kingdom

Changes to this Cookies Policy
We may at any time update or otherwise modify this Cookies Policy. We will notify you of any changes to our Cookies Policy by posting the modified Cookies Policy on the Site.

Last modified: 18 May 2018
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