Privacy Policy
SENTRIC MUSIC GROUP PRIVACY POLICY
Welcome to the Sentric Music Group Limited’s(including all subsidiaries as defined by s1159 of the Companies Act 2006) (Sentric) privacy policy(Privacy Policy). Sentric is the data controller and responsible for your personal data (collectively referred to as "Sentric", "we", "us" or "our" in this privacy policy). Sentric is based in the United Kingdom and will primarily process your personal information in the United Kingdom, however, Sentric will transfer your data globally to facilitate your use of the Services (as defined below). Use of the Services indicates your consent.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel our Services to you.
This Privacy Policy applies to the information collected by Sentric about you in connection with your use of the Services (as defined below) both offline and online for (a) the websites located at www.sentric.com, www.sentriccreative.com/sentric-voices, and www.sentriccreative.com/makers-hub and all corresponding web pages and websites and through any interactive features, applications, widgets, blogs, social networks and other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device or other technology (Site); (b) the Sentric publishing dashboard at https://sentric.publishingdashboard.com/ (Publishing Dashboard) and (c) any other content, applications, features, functionality, information and services offered by us though the Site (collectively, Services).
This Privacy Policy will remain in full force and effect, even if your use of or participation in the Services or any particular service, feature, function or promotional activity offered through the Services terminates, expires, ceases, is suspended or deactivated for any reason. If you do not agree with this Privacy Policy, please do not participate in the Services or any features, activities or services offered through the Services. This Privacy Policy applies regardless of the device you use to access the Services and whether you are accessing the Services as a registered user or otherwise.
This Site, Appand our Services are not intended for children, and Sentric do not knowingly collect data relating to children.
The Services are not directed to people whose age: (i) is under the age of 13 years; (ii) or, makes it illegal to process their personal data; or (iii) requires parental consent to process their personal data. If you are under the age limit for use of the Services, please do not use the Service, and do not provide any personal data to us.
This Site and/or App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site and/or App, we encourage you to read the privacy policy of every website you visit.
- THE DATA WE COLLECT ABOUT YOU
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 (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 | Includes but is not limited first name, maiden name, last name, professional name, username or similar identifier, marital status, title, date of birth and gender. |
|---|---|
| Contact Data | Includes but is not limited to physical address, email address and telephone numbers. |
| Transaction Data | Includes but is not limited to details about payments (invoices and payee details), social security information, tax exemption or registration status/information, musical composition and master recording registration/release data and other details of Services you have received from us. |
| Technical Data | Includes but is not limited to internet protocol (IP) address, your login 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 you use to access the Services. |
| Profile Data | Includes but is not limited to our username, queries made by you, user preferences, feedback and survey/call to action responses. |
| Usage Data | Includes but is not limited to information about how you use our Site and/or App, products and Services. |
| Marketing and Communications Data | Includes but is not limited to your Identity Data and Contact Data (above) and your preferences in receiving marketing from us and our third parties and your communication preferences. |
| Contests, Sweepstakes and Surveys | To participate in certain Services-related promotions, including, but not limited to, contests, sweepstakes and surveys, there may be a separate registration process which may require the submission of both personal Information and additional Information (including your full name, email address, mailing address, telephone number, demographic or profile information, etc.). We will use the information you provide for the purpose of conducting the promotion (for example, to contact you if you have won). You may also have the opportunity to opt-in to receive special promotions or offers from third parties as a result of your use of the Services. Our Promotions will include specific terms and conditions and privacy statements that you should read at the time. |
| Identity Data | Includes but is not limited first name, maiden name, last name, professional name, username or similar identifier, marital status, title, date of birth and gender. |
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 or App feature. However, if 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 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). Nor do we collect any information about criminal convictions and offences.
- HOW IS YOUR PERSONAL DATA COLLECTED?
| Direct interactions | This is Sentric’s primary source of data collection. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes (but is not limited to) personal data you provide when you: (i) apply to use our services; (ii) create an account on our Site and/or App; (iii) subscribe to our Service or publications; (iv) request marketing to be sent to you; (v) enter a competition, promotion or survey; or (vi) give us feedback or contact us. |
|---|---|
| Automated technologies or interactions | As you interact with our Site and/or App, we will 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 employing our cookies. Please see our Cookie Policy https://sentricmusic.com/cookies-policy/ for further details. |
| Third parties or publicly available sources | We will receive personal data including Identity Data, Technical Data and Contact Data about you from various third parties and public sources including (but not limited to) the below: (i) Performance, Mechanical and Neighbouring Rights registration and collection societies worldwide; (ii) Spotify; (iii) Google, Google Analytics (including Doubleclick); (iv) Meta; (v) Jaxsta; (vi) Twitter; and (vii) LinkedIn. |
| Direct interactions | This is Sentric’s primary source of data collection. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes (but is not limited to) personal data you provide when you: (i) apply to use our services; (ii) create an account on our Site and/or App; (iii) subscribe to our Service or publications; (iv) request marketing to be sent to you; (v) enter a competition, promotion or survey; or (vi) give us feedback or contact us. |
- HOW WE USE INFORMATION.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: (i) Contract, where we need to perform the contract we are about to enter into or have entered into with you; (ii) Legitimate Interest, 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; and (iii) Legal Obligation, where we need to comply with a legal obligation.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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). 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 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Purposes for which we will use your personal data
We have set out below a non-exhaustive list, in a table format, to provide examples of the ways 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.
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 grounds, we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact (c) Transactional (d) Technical (e) Profile | Performance of a contract with you |
| To facilitate provision of Services to you including: (a) Register musical compositions, master recordings, manage payments, fees and charges (b) Collect and recover money owed to you | (a) Identity (b) Contact (c) Transaction (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover monies due to you) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our Service terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this Site and/or App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant Site and/or App content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Site and/or App, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and/or App updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
- SHARING AND DISCLOSURE OF PERSONAL INFORMATION
General Disclosure. Sentric do not sell, rent, lease or disclose your personal information to third parties, except if you consent to such disclosure or as otherwise described in this Privacy Policy. Sentric reserve the right to use and/or share any aggregated and anonymised data we collect in connection with your access to and/or use of the Services. Other than as set forth in this Privacy Policy, we do not share your personal information with other third parties, apart from those acting as our agents in providing our Services to you, and which agree to use it only for that purpose and to keep the information secure and confidential. Also, please be aware that our affiliated companies, including all their respective business units, subsidiaries, affiliates and sites, entities into which our companies may be merged, or entities to which any of our assets, products, sites or operations may be transferred, may obtain from us and be able to use your personal information, but only as set out in this Privacy Policy.
Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- DATA SECURITY.
We have put in place appropriate security measures 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 also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We request that our third-party contractors and third-party service providers follow similar standards of security and confidentiality.
- DATA RETENTION AND DELETION.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By accessing, interacting with, launching, downloading, or otherwise using the Services and providing and/or making available your contact information, (a) you expressly choose to receive certain communications from us and certain third parties as described in this Privacy Policy, and (b) you expressly agree to the privacy practices described herein. You may change your privacy preferences (e.g., choose to cease receiving certain communications or ask us not to share your personal information with a particular third party) by sending an email to us at privacy@sentric.com detailing your privacy request. If you ask Sentric to stop using your personal information, we will honour that request while retaining a record of any personal information as necessary to comply with applicable law. You always have the right to access and correct the personal information you have provided and generally you may review, update or delete certain Information collected by the Services at any time by accessing your User Account as described herein.You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you and/or by contacting us at any time.
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 this Site and/or App may become inaccessible or not function properly. For more information about the cookies we use, please see https://sentricmusic.com/cookies-policy/.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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 could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and 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 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. We try to respond to all legitimate requests within one month. Occasionally it could 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.
- PRIVACY POLICY CHANGES
From time to time we may modify this Privacy Policy to reflect industry initiatives, third party requirements or changes in the law, our information collection and use practices, the features and functionality of the Services, or technology, and such modifications shall be effective upon posting. Your continued use of the Services after we post a revised Privacy Policy signifies your acceptance of the revised Privacy Policy. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If we materially change our practices regarding collection or use of your Personal Information, your Personal Information will continue to be governed by the privacy policy under which it was collected unless you have been provided notice of, and have not objected to, the change.
- ACCURACY
It is your responsibility to give us current, complete, truthful and accurate information, including personal information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information or personal information or you fail to update such information or personal information. We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy.
- CONTACT US
If you have any questions about our privacy practices or any of the terms or conditions of this Privacy Policy, please feel free to contact us at:privacy@sentric.com and/or by mail: Attn: Privacy Manager
Sentric Music Group Limited, 4th Floor, Walker House, Exchange Flags, Liverpool L2 3YL.
This Privacy Policy was last modified January 2023 and is effective immediately.