PRIVACY 
POLICY

SONGTRUST® PRIVACY AND COOKIES POLICY

Last updated: March 22nd, 2019. Please note that this update does not change our personal data processing practices. We have updated our Privacy Policy to ensure you are fully informed about how we process your personal data, in light of transparency requirements introduced by the European Union’s General Data Protection Regulation (GDPR).

Thank you for visiting Songtrust.com (“Website”), which describes the terms through which we provide a rights management platform which allows for the administration of music publishing and related rights (the “Services”).

This privacy and cookies policy (“Privacy Policy”), together with our Terms of Use (which can be found at https://www.songtrust.com/terms) (“Terms of Use”), set out the basis on which any personal data we collect from you (“you”, “your”, or “user”), or that you provide to us, will be processed by us.

Please read the following information carefully to understand what data we collect, how that data is used and the ways it can be shared by us and you.

The data controller of your personal data is ST Music LLC, a Delaware (U.S.) limited liability company, which owns and provides the Services and with a principal office address at: 155 Avenue of the Americas, New York, NY 10013, U.S.A. (“Songtrust”, “we,” “our,” or “us”)

IF YOU DO NOT WISH FOR YOUR PERSONAL DATA TO BE USED IN THE WAYS DESCRIBED WITHIN THIS PRIVACY POLICY THEN YOU MUST NOT ACCESS OR USE THE WEBSITE OR USE THE SERVICES.

INDEX

1. INFORMATION WE COLLECT ABOUT YOU
2. HOW WE USE YOUR PERSONAL DATA
3. LEGAL BASIS ON WHICH WE PROCESS YOUR PERSONAL DATA (EUROPEAN ECONOMIC AREA (“EEA”) ONLY)
4. HOW WE SHARE YOUR PERSONAL DATA
5. WHERE WE STORE YOUR PERSONAL DATA
6. YOUR RIGHTS (EEA ONLY)
7. LINKS TO THIRD PARTY SITES
8. SECURITY
9. CHILDREN
10. COOKIES
11. CHANGES TO OUR PRIVACY POLICY
12. CONTACT US

1. INFORMATION WE COLLECT ABOUT YOU  

Information you give us

This is information about you that you give us by:

• registering for an account with us;
• filling in the ‘Contact Us’ form on the Website;
• completing our online surveys;
• entering into transactions with us;
• providing us with feedback about the Website or our Services; or
• corresponding with us by phone, e-mail or otherwise.

This may include personal data such as your name, email address, postal address, telephone number, gender, income information, and any payment details that you may provide us with.

Please be aware that we may also obtain this information from a third party representative acting on your behalf.

Information we collect about you through the Website

Each time you use the Website, we may automatically collect the following information, which may be considered to be personal data when combined with other information about you:

• technical information, including the Internet protocol (IP) address used to connect your computer or device to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• information about your visit, including the dates and times you use the Website, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, your geographical location when accessing the Website and any phone number used to call the contact phone number provided on our Website.

Such information may amount to personal data, particularly when it is combined with other data sets.

Information we collect about you from third party sources

We may obtain your name and email address from third party online sources in order to contact you directly in respect of our Services. Please refer to section 12 below for further information on how to stop receiving direct marketing emails from us.

Special categories of data

We do not collect any special categories of personal data about you (this includes 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). 

2. HOW WE USE YOUR PERSONAL DATA

We may use personal data held about you in the following ways:

Information you give to us

We will use this information:

• to set up an account for you;
• to respond to any enquiry you should make;
• to provide the Services, including registering, licensing and otherwise administering your musical works;
• to manage and administer your or your organisation's relationship with us, including accounting and payment, marketing and support services, and taking other steps linked to the performance of our business relationship;
• to provide you with information about other products and services we or our affiliates offer;
• to fulfil any order you make with us;
• to comply with our legal and regulatory obligations such as for anti-money laundering, financial and credit checks, audit requirements, fraud and crime prevention and detection, and record keeping. This may include automated checks of personal data that you provide about your identity against relevant databases, and contacting you to confirm your identity, or making records of our communications with you for compliance purposes;
• to protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
•      to notify you about any changes to the Services;
• to send you promotional correspondence from us, to enable you to participate in contests or receive special offers, or to enable you to make purchases through the Website;
• for our recruitment;
• to contact you, if necessary; and
• for any other purposes related to and/or ancillary to any of the above, or any other purposes for which your personal data was provided to us.

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

Information we collect about you

We will use this information:

• to ensure that the Website operates effectively and for internal operations, including technical administration, troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to provide you with a better experience, to improve the quality, value, functionality and general user friendliness of the Website, and to analyse and understand how the Website is used;
• as part of our efforts to keep the Website safe and secure;
• to serve you with advertisements and other information appropriate to your interests, including making suggestions and recommendations to you about Services we and our carefully selected third parties may offer that may interest you; and
• to serve any aspect of the Website or the Services to you according to your preferences or and location.

Information we collect about you from third party sources.

We will use this information:

• to invite you to use our Services.
   

3. LEGAL BASIS ON WHICH WE PROCESS YOUR PERSONAL DATA (EUROPEAN ECONOMIC AREA (“EEA”) ONLY)

We will process your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means Songtrust’s interests in conducting and managing our business to enable us to give the best possible service to our clients and the best and most secure experience on our Website. 

We make sure 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 by law). 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you.

4. HOW WE SHARE YOUR PERSONAL DATA 

We share your personal data with:

• Any member of our group, which means our subsidiaries, our ultimate parent entity, and its subsidiaries.
• Our trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the Website, database storage and management, e-mail marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the Website, to the extent necessary to supply the Services to you.
• Selected third parties, including analytics and search engine providers that assist us in the improvement and optimisation of the Services.
• Government and law enforcement officials and private parties, where necessary to comply with the law or enforce any legal rights. For example, we may disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

We will also disclose your personal data to third parties:

• If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our users will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our clients, or others.

With your express consent, which we will always seek separately, we may share information with third parties whose products or services we think may interest you. We may also occasionally share information with business partners in connection with co-promotions, sweepstakes or contests on the Website.

5. WHERE WE STORE YOUR PERSONAL DATA  

To provide the Services, we share your personal data within the Songtrust and Downtown Music Publishing group. If you are located in the EEA, this will involve transferring your personal data outside of the EEA. Many of our external third parties are based outside of the EEA, so their processing of your personal data will involve a transfer of data outside of the EEA.

Wherever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details see here.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA. For further details, see here.
• Where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the USA. For further details, see here.

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

If you are located in the EEA, you have a number of rights in relation to how we process your personal data. These include:

• the right to access the personal data that we may hold about you;
• the right to rectify any inaccurate personal data that we may hold about you;
• the right to have your personal data erased in certain circumstances, for example, where it is no longer necessary for us to process your personal data to fulfil our processing purposes; or where you have exercised your right to object to the processing;
• the right to restrict the processing of your personal data where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;
• the right to object to the processing of your personal data which may be exercised in certain circumstances, for example, where we are processing your personal data for direct marketing purposes, or where your own legitimate interests outweigh ours; and
• the right to have your data ported to a new service provider if you no longer wish to use the Services.

You can exercise any of these rights any time by [contacting 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). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 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 will notify you and keep you updated.

6. YOUR RIGHTS (EEA ONLY)

If you are located in the EEA, you have a number of rights in relation to how we process your personal data. These include:

• the right to access the personal data that we may hold about you;
• the right to rectify any inaccurate personal data that we may hold about you;
• the right to have your personal data erased in certain circumstances, for example, where it is no longer necessary for us to process your personal data to fulfil our processing purposes; or where you have exercised your right to object to the processing;
• the right to restrict the processing of your personal data where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;
• the right to object to the processing of your personal data which may be exercised in certain circumstances, for example, where we are processing your personal data for direct marketing purposes, or where your own legitimate interests outweigh ours; and
• the right to have your data ported to a new service provider if you no longer wish to use the Services.

You can exercise any of these rights any time by [contacting 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). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 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 will notify you and keep you updated.

7. LINKS TO THIRD PARTY SITES

The Website may contain advertisements and links to other websites. The fact that we link to another site is not an endorsement, authorization or representation of our affiliation with that third party. Other sites may place their own cookies or other files on your computer and collect or solicit both personal data and other information from you under rules different from this Privacy Policy. We do not control other sites and cannot be responsible for your experience once you leave our Sites. Therefore, we strongly encourage you to carefully read the privacy policies, terms of use and other policies of other sites you visit.

8. CHILDREN

The Website is not intended for, and we do not knowingly accept collect personal data from, children under 13. If we become aware that a child under 13 has provided us with personal data, we will delete it from our files. If parents or guardians become aware that their minor children have provided us with personal data without their consent (or that we have otherwise collected or obtained such information), they should contact us at privacy@songtrust.com. We recommend that minors between the ages of 13 and 18 ask their parents for permission before using a credit card or providing any information about themselves to us or anyone else over the Internet.

9. SECURITY

We are very concerned about safeguarding the confidentiality and use of your personal data. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. All credit transactions occur in a secure area of the Website using Secure Sockets Layer software to process orders, which encrypts the information you input on the Website. In addition, all information is stored in a secure location behind a firewall with limited administrative access. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable. 

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to use it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Please be aware that any information or material you may enter in a publicly viewable portion of the Website, such as an online forum or comment section, chat room, or bulletin board, will be readily accessible to the general public. Therefore, you obviously should not enter any personal data (for example, your name, email or postal address, credit card details) or other information or materials that you would not wish to be publicly available and beyond the scope of this Privacy Policy. 

In the event of a personal data breach, we will notify you and any applicable regulator where we are legally required to do so.

10. COOKIES  

We use cookies to distinguish you from other users of the Website. This helps us to provide you with a smooth experience when you visit the Website, and also allows us to improve the Website.  A cookie is a small text file that can be placed on your computer or other device when using the Website.

First and third party cookies

We set cookies (first party cookies) on web pages, however, where we require additional information or services, we may also allow other companies to host cookies on our web pages (third party cookies). These partner companies have been carefully selected by us and are required to meet contractual obligations they have with us.

We may include social media features, such as the Facebook “like” button and widgets, such as the “share this” button. These features may collect your personal data and track your use of the Website. These social media features are either hosted by a third party or hosted directly in the Website. Your interactions with these features are governed by the privacy policy of the company providing such functionality. 

We use Google Analytics cookies to collect information and compile reports about how visitors use our Website, and we use this information to help us improve our Website. Google Analytics will collect your IP address, demographic and interests information.  For more information about Google Analytics, go to https://www.google.com/intl/en-GB/analytics/learn/privacy.html.  To opt-out of Google Analytics, visit:  https://tools.google.com/dlpage/gaoptout

What do we use cookies for?

The cookies on this Website consist of the following categories:

1. Strictly necessary cookies - these cookies are used for technical reasons and are necessary to enable the Website to operate efficiently so that you can navigate the Website with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Website may not operate effectively.
2. Performance cookies - these cookies are used to obtain statistics about the number of users of the Website and how such users interact with the Website. These cookies collect information that is aggregated and therefore cannot be used to ascertain an individual's identity. Such information allows us to continuously improve the Website to provide users with a better online.
3. Functionality cookies - these cookies are used to improve the functionality of the Website and make it easier to use. They help us to identify you as a repeat user of the Website and help us remember your preferences (for example, your choice of language or region), improving your user experience.
4. Marketing and analytical cookies - These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.

We may share information that we collected through cookies, in aggregated form, with carefully selected third parties for the purposes set out above, unless you disable or block cookies as set out below.

How do I control my cookie settings on my computer or device?

Please be aware that if you decide to disable or block cookies, parts of the Website may not function correctly, or at all.

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

You can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive information on how to manage cookies.

11. CHANGES TO OUR PRIVACY POLICY

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

12. CONTACT US 

Questions, comments and requests regarding this Privacy Policy should be addressed to privacy@songtrust.com.  

Any promotional e-mails you receive from us will include specific instructions on how to unsubscribe from our e-mail list, and you may unsubscribe at any time.  You may also send an email to us at privacy to update or correct the personal data we have on file for you or to be unsubscribed from all or any particular types of e-mailings.

California residents only

California residents may request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@songtrust.com or write to us at ST Music LLC, 155 Avenue of the Americas, New York, NY 10013, U.S.A. Attn: Client Success Team. California residents who have an established business relationship with us may also choose to opt-out of our disclosing personal data about them to third parties. If you do not want us to share your personal data with such third parties, please send us your name, address and phone number to privacy@songtrust.com.

EEA residents only

Should you have any concerns about how we handle your personal data, please contact us in the first instance.  We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to your national supervisory authority.