1. INTRODUCTON

Welcome to the Privacy Notice of Sarm Music Village, and Music Bank.

Our group is made up of different legal entities, in particular, SARM Music Holdings Limited, SPZ Properties Limited, Music Bank (Hire) Limited and Horn Productions Limited. All companies have their registered and correspondence address at Sarm Music Village, 105 Ladbroke Grove, London, United Kingdom, W11 1PG. This privacy notice is issued on behalf of the whole group so when we mention SARM, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the SARM group responsible for processing your data. We are committed to protecting and respecting your privacy.

Where you have entered into an agreement with us, such as when you purchase a product or service with us, the controller (for the purposes of the General Data Protection Regulation) will be whichever group company is party to that agreement. The operator of the website sarmmusicvillage.com is SPZ Properties Limited. The operator of musicbank.org is Music Bank (Hire) Limited. (each a “Website” and together the “Websites”)

This privacy notice (“Notice”) (together with our Terms of Use, available for Sarm Music Village here and Music Bank here and any other documents referred to in it and any other contractual terms that may be in place between us and you) sets out the basis on which any personal data we receive from you, or that we gather in any other way, will be processed by us.  It applies to any data gathered due to your use of our Websites or otherwise as a consequence of any dealings we may have with you.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process data about you in the manner set out below.

You may give us information about you by filling in contact forms on our Websites or by filling in forms on paper and providing them or sending them to us at our premises, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you enter a competition, promotion or survey or when you report a problem with our facilities, services and Websites. The information you give us may include without limitation your name, address, e-mail address, phone number, financial and credit card information.

With regard to each of your visits to or use of our Websites we may automatically collect the following information about you or your devices:

  • technical information, including the type of device(s) you use, a unique device identifier, the internet protocol (IP) address used to connect your device(s) to the internet, network information, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform; 
  • information and details about your use of our Websites (including but not limited to traffic data; location data; weblogs and other communication data; the full Uniform Resource Locators (URL) clickstream to, through and from our Websites (including date and time); what you viewed or searched for; page response times, download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page)). 

We may receive information about you from other sources. We work closely with third parties (including, for example, credit reference agencies) and may receive information about you from them.

3. COOKIES

Like most websites and mobile applications, our Websites use cookies. A cookie is a small, often encrypted file of letters and numbers that we store on your browser, your computer, your mobile device or other device. They help us improve our Websites and your general experience on them.

We may use the information we obtain from the cookie in the administration of our Websites, to improve our Website’s usability and to help guide the targeting of advertising. We may also use that information to distinguish you from other users of our Websites and to monitor traffic on our Websites. 

If you do not want us to store cookies on your computer or other device for these purposes, you may change the settings on your internet browser to reject cookies. Please note that if you set your browser to reject cookies, you may not be able to use all of the features of our Websites and/or may be prevented from accessing certain parts of our Websites.

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

Cookie Name Purpose Duration (Expires after)
_utma Collects data on the number of times a user has visited the website as well as dates for the first an d most recent visit. Used by Google Analytics. 2 years
_utmb Registers a timestamp with the exact time of when the user accessed the website. Used by Google Analytics to calculate the duration of a website visit. Session
_utmc Registers a timestamp with the exact time of when the user leaves the website. Used by Google Analytics to calculate the duration of a website visit. Session
_utmt Used to throttle the speed of requests to the server. Session
_utmz Collects data on where the user came from, what search engine was used, what link was clicked and what search term was used. Used by Google Analytics. 6 months
NID Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads. 6 months
_ztt_session Session cookie placed by ztt records Session

If you continue to use our Websites, we will take that as your consent to the relevant cookies being stored on your computer or other device.

4. USES MADE OF THE INFORMATION

We will use the information you give to us:

  • to carry out our obligations arising from any contracts for studio, rehearsal space or equipment hire, or for any other purpose, entered into between you and us or in order to take steps at your request prior to entering into such a contract. This may include registering you on our records as a customer;
  • in accordance with our and/or your and/or others’ legitimate interests:
    • to facilitate, and if necessary, enforce any legal obligations you may owe to us, including under any contract between you and us (in accordance with our interests under the contract);
    • to notify you about changes to our services (in accordance with your and our interests, and the interests of other users of our services, to ensure that our services are used in the most effective manner and for maximum benefit);
    • as part of, or as reasonably necessary for the purpose of, any sale or purchase of any of our businesses or assets of which the provision or offering of goods or services to you forms part (in accordance with our interest, and the interest of any counterpart, to facilitate such sale or purchase).

We will use the information we collect about you from the use of our Websites, in accordance with our and/or your legitimate interests, in order to improve your experience of our Websites:

  • to administer our Websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • as part of our efforts to keep our Websites safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

We may combine the information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We do not use your personal data as part of any automated decision-making, including profiling, which produces legal or similarly significant effects concerning you.

5. DISCLOSURE OF YOUR INFORMATON

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (if applicable).

We may share your information with partners and sub-contractors for the performance of any contracts we enter into with you including invoicing, payment processing, web-hosting and mailing services. If invoices are unpaid, we may share your data with third parties, such as debt collection agencies, for the purpose of enforcing our right to payment. We may share your information with suppliers of our IT systems and services for the purpose of ensuring the correct operation, or enhancing the operation of IT systems, or to ensure the safety and security of personal data. We may share your information with credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We may share information with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.  However, we do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. We may also share anonymous aggregate information with analytics and search engine providers that assist us in the improvement and optimisation of our Websites. 

We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers 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, and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Data shall be shared with third parties only to the extent compatible with the uses set out in part 4 of this Notice.

6. WHERE AND HOW WE STORE YOUR PERSONAL DATA

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. For example, we use our own secure servers to store all information you provide to us. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us via email or forms on our Websites; Any transmission is at your own risk. 

While we do not store your data outside of the EEA, the data we collect from or about you may be processed by staff operating outside the EEA who work for us or for a third party, for example by way of remote working. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Notice. 

We will store your data for as long as necessary to fulfil the purposes for which it is originally collected, as explained in this Notice, or any other lawful purpose subsequently communicated to you, and for other essential purposes such as complying with legal obligations and enforcing our rights, such as those arising under any agreement with you. The retention period may therefore vary for different types of data, and depending on how and why it was gathered. Criteria relevant to determine retention periods include:

  • If the data is necessary for the performance of a contract, we will retain it while performance under that contract remains active, and for a period thereafter in which that data may still be relevant to dispute resolution, enforcement of rights under the contract, or where additional connected contracts are likely to arise.
  • In certain cases we may be legally obliged to hold data for a certain period of time, or to delete the data at a certain time, including in accordance with the exercise of your rights as data subject as explained in this Notice.

7. YOUR RIGHTS

We do not use your personal data for direct marketing purposes unless you have purchased a similar product or service from us in the past, or have provided your consent to us or to a third party via which we have received the data. You have the right to ask us not to process your personal data for these purposes. 

The General Data Protection Regulation provides you with rights to:

  • request from us confirmation of whether or not your personal data is being processed and where that is the case, confirmation of the information set out in this Notice;
  • request from us a copy of your data that is undergoing processing, including, in relation to data provided to us by you, and which is processed by automatic means pursuant to a contract with you, or pursuant to your consent, a right to request that data in a structured, commonly used and machine readable format;
  • request that we rectify or complete your personal data, where it is inaccurate or incomplete for the purposes of our processing of the data;
  • request that we erase your personal data in the following circumstances:
    • the personal data is no longer necessary in relation to the purposes for which it is processed; 
    • you withdraw consent and there is no other legal ground for the processing; 
    • you successfully object to the processing pursuant to your right of objection explained below; 
    • the personal data has been unlawfully processed; 
    • the erasure is necessary for compliance with a relevant legal obligation that applies to us; 
  • request that we restrict the processing of your personal data in the following circumstances:
    • you contest the accuracy of the personal data, for a period enabling us to verify the same;
    • the processing is unlawful, but you request restriction rather than erasure;
    • we no longer need the data, but it is required by you in respect of legal claims;
    • you have objected to the processing, until such that that we verify that there are legitimate purposes that justify such processing;
  • object to any processing that is based on our, or a third party’s legitimate interests, upon which event we shall suspend processing until we demonstrate legitimate purposes that justify that processing. We may at all times continue to use data for the purpose of establishment, exercise or defence of legal claims; 
  • withdraw your consent for future processing (where the processing is based on that consent);
  • lodge a complaint with the Information Commissioner’s Office, which is the data protection supervisory authority in the UK.

We will comply with any valid request for information under the rights explained above within one month, though we may tell you that this period is to be extended by a further two months where necessary, taking into account the complexity and number of the requests. This will normally be provided free of charge. If the request is manifestly unfounded, excessive or repetitive we may charge a reasonable fee or refuse to action the request.

The provision of personal data to us is not a statutory requirement. The provision of certain information necessary for billing is a requirement of entering into contracts with us for provision of goods and services. Where the provision of data is a contractual requirement, or a requirement necessary to enter into a contract, we will make that clear as part of the process by which the contract is concluded, which may include by way of terms of the contract. These provisions will also make clear the consequences of failure to provide such data.

Where the data is not a contractual requirement, you are not obliged to provide the data, but if you do not do so, we may be unable to offer certain benefits and functionality to you. For example, if you choose not to allow the use of cookies, you may not be able to access parts of the Websites.

Our Websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our Websites are advertised).  If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these notices or for any personal data that may be collected through these websites or services. Please check these notices before you submit any personal data to these websites or use these services.

8. CHANGES TO OUR PRIVACY NOTICE

Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next use our Websites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of our Websites. Alternatively, please check back frequently to see any updates or changes to our Privacy Notice. 

9. CONTACT

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to Sam Beckleyat sam@spz.com.