PRIVACY POLICY

SONGTRUST® PRIVACY AND COOKIES POLICY

Last updated: January 10, 2023

ST Music LLC (d/b/a Songtrust), its affiliates and subsidiaries (collectively, “Songtrust”) respect your concerns about privacy. This Online Privacy Notice (the “Notice”) applies to personal data we collect on Songtrust.com (the “Site”) and in relation to providing music rights management and publishing services (the “Services”) to our customers. The Notice describes the types of personal data we obtain, how we use the personal data, with whom we share it and the choices available to you regarding our use of the information. We also describe measures we take to protect the security of the information, the rights you may have and how you can contact us about our privacy practices.

ST Music LLC is the entity responsible for the collection of personal data on the Site and through our Services.  For more information, please see the “How to Contact Us” section below. 

Click on one of the links below to jump to the listed section:

• Personal Data We Collect

• How We Use Personal Data We Collect

• Information That We Collect Automatically And How We Use It

• Interest-Based Advertising

• Third-Party Analytics Services

• Information We Share 

• Data Transfers

• How We Protect Personal Data

• Data Retention 

• Your Rights And Choices

• Children’s Privacy

• Links To Third-Party Services 

• Updates To Our Online Privacy Notice

• How To Contact Us

Personal Data We Collect

The types of personal data we collect and process include:

• Identification and contact information, such as your name, telephone number, postal and email address, country, government-issued ID information (if needed for verification);

• Personal characteristics, such as photo, age and gender;

• Financial information such as income and tax-related information, and any payment details that you may provide to us;

• Other information you choose to provide to us (see below).

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

• If you register for an account with us;

• If you fill out a form on our Site, such as the “Contact Us” form;

• If you complete our online surveys; 

• If you enter into transactions with us;

• If you provide us with feedback about the Site or our Services;

• If you correspond with us by phone, email or otherwise; or

• If you sign up to receive electronic marketing communications from us.

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

Each form on our Site varies in the information required and collected. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information within fields that are not required.

While the personal data you choose to provide is voluntary, certain personal data may be necessary to provide you with the relevant product or service.  If you choose not to provide certain information, this may affect my ability to provide you with certain products or services.   

How We Use Personal Data We Collect

We use the personal data you provide on our Site for the following legitimate business purposes:

• To set up an account for you, including to verify your identity in connection to setting up your account;

• To respond to any enquiry you should make, or contact you if necessary;

• To perform market research and customer surveys, and determine the effectiveness of our advertising and marketing; 

• To comply with our legal and regulatory obligations such as for anti-money laundering, financial and credit checks, audit requirements, conduct fraud monitoring, prevention and detection activities and ID verification activities. This may include automated checks of personal data that you provide about your identity against relevant databases, contacting you to confirm your identity, or making records of our communications with you for compliance purposes;

• To operate, evaluate, and improve our Services and business (including administering the Site; developing new products and services; enhancing, improving and analysing our products and services; managing our communications; analysing our customer base and Site; performing data analytics; and performing accounting, auditing and other internal functions); 

• 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 or other 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 Site;

• To provide you with information about other products and services we or our subsidiaries or affiliates offer; and

• To exercise our rights and remedies and defend against legal claims, protect against, identify and prevent fraud and other criminal activity, claims and other liabilities, and comply with and enforce applicable legal requirements, relevant industry standards and or policies.

FOR EEA (European Economic Area) ONLY

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. In accordance with applicable law, we take reasonable measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms, which we are happy to explain upon request.

Where required by applicable law, we will obtain your consent to send you marketing communications about products and services launches, offers and promotions, and invite you to events and surveys.

Where we have a contract with you, we process your personal data as necessary to perform our contractual relationship with you, provide our products and professional services and manage our customer relationship, including: 

• 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 process and fulfil any transaction or order you make with us; and

• Offering legal support and managing contracts, orders and deliveries.

We may also use the information in other ways for which we provide specific notice at the time of collection.  To the extent required by law, such notice will also describe our legal basis.

Information That We Collect Automatically And How We Use It

When you visit our Site, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits. 

We may use these automated technologies on our Site to collect information about your equipment, browsing actions, and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Site; (3) tailor the Site around your preferences; (4) measure the usability of our Site and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.

Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all of the features of our Site. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

For more information on our use of cookies and similar technologies, click here to review our Cookie Policy.   

Interest-Based Advertising

On our Site, we may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. You may see our ads on other websites because we use third-party ad services. Through these ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track your online activities over time and across multiple websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The information ad services may collect includes data about your visits to websites that serve advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Sites and on third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts. 

The Site is not designed to respond to “do not track” signals from browsers.

To learn how to opt out of interest-based advertising, please visit www.aboutads.info/choices and http://www.networkadvertising.org/choices/. In the EU, please visit www.youronlinechoices.eu. 

Third Party Analytics Services

We may use third-party analytics services on our sites, such as Google Analytics.  The information we obtain through our sites may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.  To opt-out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

Information We Share

We share personal data we obtain about you with:

• members of our group, including affiliates and subsidiaries of our group
• our trusted third party service providers that perform services on our behalf and our business partners (or allow access to or collection of personal data by such third parties), in particular marketing service providers, ad-tech services, analytics providers, IT and data hosting providers, customer service and order delivery services, providers of fraud prevention services and ID verification services, and credit card processing or payment service providers. 
• accountants, attorneys, and consultants who need the information in order to provide services in connection with the delivery of our Services, Songtrust’s management, administration, or legal and tax responsibilities.
• 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 reorganisation, dissolution, or liquidation. 
• With your consent, we also may share information with third parties whose products and services we think may interest you or in connection with co-promotions, sweepstakes or contests in the Site.

FOR EEA ONLY

Many of our service providers are based outside of the EEA, such as in the U.S. We require service providers by contract to process personal data only on our behalf and to implement measures to protect the security and confidentiality of personal data.

Data Transfers

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries such as the U.S., we will protect that personal data as described in this Notice.

We will comply with applicable legal requirements by providing adequate protection for the transfer of personal data to data recipients in countries outside of the EEA, the United Kingdom and Switzerland. To the extent that these data recipients are in countries that have not been recognized by the European Commission or relevant body as providing an adequate level of data protection, we ensure that appropriate safeguards aimed at ensuring such a level of data protection are in place, including by entering into the European Commission’s EU Standard Contractual Clauses (“SCCs”) and, where applicable, the UK Addendum to the EU SCCs, with the data recipients. To obtain a copy of the safeguards we have put in place, please contact us as indicated below.

How We Protect Personal Data

We maintain administrative, technical and physical safeguards designed to protect the personal data we obtain against accidental, unlawful or unauthorised access, destruction, loss, alteration, disclosure or use. 

Data Retention 

To the extent required by applicable law, we keep the personal data you provide for the duration of our relationship, plus a reasonable period to comply with the applicable statute of limitations or if otherwise required under applicable law, unless a shorter retention period is required by applicable law.

Your Rights And Choices

Depending on where you are located and subject to applicable law, you may have the following rights in connection with the personal data we process about you:

• The right to access and obtain a copy of your personal data;

• The right to correct inaccuracies in information we have about you;

• The right to object to the processing of your personal data on grounds relating to your particular situation;

• The right to have your personal data “erased” or to restrict the processing of such information; or

• Where you have given us your consent, the right to withdraw consent for future processing of your information.

FOR CALIFORNIA RESIDENTS ONLY:

• The right to information about the collection, selling, sharing or disclosing personal data; and

• The right to opt-out of the sale of personal data.

The right to request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances.  You can tell us at any time not to send you marketing communications by e-mail by  clicking on the unsubscribe link within the marketing emails you receive from us, or by sending an “opt out” request to the address indicated on such email.  You may also request not to be contacted by us in connection with any new services, updates, news, or events by contacting us as described below.

If you wish to exercise any of these rights, complete this webform, and we will respond to your request in a reasonable time.  You may have the right to file a complaint with a supervisory authority if you are not satisfied with our response.

Children’s Privacy

Our Site is designed for a general audience and is not directed to children. In connection with the Site, we do not knowingly solicit or collect personal data from children under the age of 16. If we learn that we have collected personal data from a child under age 16 without parental consent, we will either seek parental consent or promptly delete that information. If you believe that a child under age 16 may have provided us with personal data without parental consent, please contact us as specified in the How To Contact Us section of this Online Privacy Notice.

Links To Third-Party Services 

For your convenience and information, our Site may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Songtrust, we are not responsible for these third parties’ information practices.

California Residents Only

We register your songs worldwide for the collection of your royalties. This information may include your name, national origin, track numbers, label information, and author and performer information. This personal information is shared consistent with the specific purpose under the agreement entered into between Songtrust and the rights management organisations worldwide, and thus does not constitute a “sale” of personal information under the CCPA. 

We do not otherwise sell, lease, or licence your personal information beyond what is incorporated into your music.  Please note that a “sale” of Personal Information does not include those instances when such information is part of a merger, acquisition, or other transaction involving all or part of our business. If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or other business transaction, we may transfer your Personal Information to a third party as part of that transaction. If such a transaction materially affects the manner in which your Personal Information is processed, we will notify you of such change prior to its implementation. 

Updates To Our Online Privacy Notice

We may update this Online Privacy Notice from time to time and without prior notice to you to reflect changes in our personal data practices. We will indicate at the top of the policy when it was most recently updated.

How To Contact Us

You can update your preferences, ask us to remove your information from our marketing lists, submit a request or ask us questions about this Online Privacy Notice or our practices by emailing us at privacy@songtrust.com or writing to us at:

ST Music LLC (Songtrust)

Attn: Legal Department

Address: 155 Avenue of the Americas, 

New York, NY 10013

United States

If you are based in the EEA, the United Kingdom or Switzerland, the Songtrust entity responsible for the processing of your personal data is the entity with which you have a direct relationship. Please contact your Songtrust representative or contact us at: Prinsengracht 581, 1016 HT, Amsterdam, the Netherlands (0031 20 620 4785) or privacy@downtownmusic.com.

If you are based in California, you may contact us on our online privacy request for or on privacy@songtrust.com.