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.
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Information you give us
This is information about you that you give us by:
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:
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).
We may use personal data held about you in the following ways:
Information you give to us
We will use this information:
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:
Information we collect about you from third party sources.
We will use this information:
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.
We share your personal data with:
We will also disclose your personal data to third parties:
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.
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:
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:
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.
If you are located in the EEA, you have a number of rights in relation to how we process your personal data. These include:
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.
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.
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.
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.
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:
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.
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.
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.
Copyright © 2021 Songtrust. All rights reserved. Songtrust and the microphone logo are registered trademarks of ST Music LLC.