2. Data Controller
3. What personal data do we collect?
By personal data we mean identifiable information about you. Generally, this is likely to include information such as your name, email address, correspondence address and your IP address if you access our website.
We may collect, use, store and transfer different kinds of personal data about you:
• Contact Data includes data such as your email address, telephone number, geographical address and billing address
• Identity Data includes data such as first name, last name, username or similar identifier, date of birth;
• Financial Data includes details you provide to us so that we can process your payments including bank account details, credit or debit card details;
• Transaction Data includes details of products you have purchased and payments made;
• Technical Data includes data such as internet protocol (IP) address, your login data, browser type and version, cookies, 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 our website and any communications we may send to you.
• Usage Data includes information about how you use our website such as information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to and through, pages you viewed or searches you made, page response times, download errors, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• Marketing Data includes your preferences in receiving marketing from us.
3a. Personal data you provide to us
From time to time you may provide to us personal data. This may be because:
•You access and interact with our website;
•You create an account on our website either as a user or a creator;
•You or your employer provides services to us;
•You apply to work with us as an employee or a consultant;
•You provide feedback or reviews to us;
•You respond to a survey or questionnaire or enter a promotion or competition;
•You sign up for our newsletter;
•You otherwise contact us including with queries, comments or complaints.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities. When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
3b. Personal data we automatically collect about you
When you use our website, we may automatically collect and store information about your Transaction Data, Technical Data and Usage Data for the purposes of research and analysis.
Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.
3c. Personal data we receive from others
If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, such as credit reference agencies and the electoral register, to try to confirm your identity.
We may also receive personal data about you from our third party service providers, including our payment service providers and our analytic service providers. Given the nature of our website, if you are a user who purchases content or services from a creator, then we may receive personal data about you from the artist, and if you are a creator who has sold content or services, then we may receive personal data about you from the user that purchased the content or services.
4. Legal basis for processing your personal data
• consent (where you choose to provide it);
• performance of a contract with you;
• compliance with legal requirements; and
• legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
|PURPOSE/ACTIVITY||TYPE OF DATA||LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST|
|To register you as a user or a creator and/or create your account|| Contact
|Performance of a contract with you|
|To manage your account including managing payments, and refunds||Contact
|Performance of a contract with you Legitimate interests (fraud-checking)|
|Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests|
|To administer and protect our business and this website (including improving and fixing our service, analysis, testing, system maintenance, support, reporting and hosting of data)||Technical||Necessary for our legitimate interests (for running our business security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure and understand the effectiveness of the advertising we serve to you||Contact
|Necessary for our legitimate interests (to analyse how customers use our website and manage our business accordingly)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To send you marketing information||Contact
5. do we share your data with?
Given the nature of our website, if you are a user who purchases content or services from a creator, then we may share your Identity Data with the creator. If you are a creator then you agree that any data within your profile will be available on our website for all users to view and consider.
For our legitimate interests, we may share any of personal data with our service providers, sub-contractors, consultants and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, group companies, accountants, auditors and lawyers.
We shall provide our service providers, sub-contractors, consultants and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.
If we need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety then in doing so, we may share your personal data with third party authorities and regulatory organisations and agencies.
6. Where we hold and process your personal data
Some or all of your personal data may be stored or transferred outside of the United Kingdom and/or European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.
Where your personal data is transferred outside the United Kingdom and/or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data.
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.
However, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.
You may consent to receive marketing email messages from us about our website and our services, website, events, sales and business. You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.
If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. If you still have an account with us, we shall continue to email you in relation to your account only.
9. Your rights
You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here
• Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
• Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
• Right to portability: You can request that we transfer your personal data to another service provider if you initially provided consent for us to use the personal data or where we used the personal data to perform a contract with you.
• Right to restrict or object to processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information. If you believe our processing impacts on your fundamental rights and freedoms. However, we may demonstrate that we have legitimate grounds to process your personal data not withstanding your rights and freedoms.
• Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws and when we respond to your request we shall notify you of any specific legal reasons that we have to retain your personal data
• Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account, if you have one.
We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive, and we may ask for identification from you before we can fully respond to your request.
10. Retention of personal data
Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
For the avoidance of doubt, we may use anonymous data, such as usage data for research or statistical purposes indefinitely without further notice to you.
What are cookies?
We also use pixels which are small blocks of code on web pages that do things like allow another server to measure viewing of a webpage and often are used in connection with cookies.
We also use other tracking technologies like web beacons (sometimes called tracking beacons or clear gifs) and local storage. These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our website or opened an email that we have sent them.
You can find more information about cookies at http://www.allaboutcookies.org/.
Cookies help us to operate our website and provide services to you. In particular, they can:
• make your online experience more efficient and enjoyable, including by recognising you when you return to our website and to customise the website according to your individual interests;
• enhance and customise your experience across our website including by speeding up your searches;
• enable us to perform research and carry out analytics; and
• deliver advertising and marketing that is relevant to you.
Third party cookies enable third party features or functionality to be provided on or through our website, such as advertising, interactive content and analytics.These third-parties are responsible for the cookies they set on our website and we have no control over them
What cookies do we use?
We use the following cookies:
• Operationally necessary cookies. These are cookies that are required for the operation of our website. For instance, cookies to enable you to log in to access our services;
• Performance cookies. These cookies allow us to track how our users use our website, the number of visits on each page, and behaviour on each page. This helps us optimise our website so you can find the things you are looking for and have the best experience possible.
• Functionality cookies. These cookies allows us to recognise you by name and create a more personalised experience for you.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you may have clicked. We will use this information to curate services and content based on your needs. This information may also be shared with third-party providers.
We also use Google Analytics to monitor how website is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to the system, where visitors generally came from, how long they stayed on the system, and which pages they visited. Google Analytics places several persistent cookies on your computer’s hard drive. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the relevant social media sites will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
What technical information do we collect about your device?
Wecollect the following information about the device you are using to access our website:
• the type of device you use;
• a unique device identifier, for example, your device's IMEI number;
• network information;
• your operating system;
• your IP address;
• the browser you are using and what version it is; and
• your time zone setting.
We collect usage data about your activities on our website, including:
• The full Uniform Resource Locators (URL) clickstream to, through and from our online properties (including date and time);
• The different types of services/products 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;
• any phone number used to call our customer service number.
How can you control cookies?
To change your cookie settings, or if you want to be notified each time a cookie is about to be used, you should amend the settings provided in your web browser to prevent us from storing cookies on your computer hard drive.
You can manage your cookie settings by following your browser's instructions. Here are some links that might be of assistance:
• Microsoft Internet Explorer
Last updated: 14 September 2020