Privacy Policy
About this Notice
This notice ("Privacy Notice") explains how Broadway Licensing ("we", "us" and "our") uses the personal information of our customers, prospective customers and users of our websites ("you" and "your").
This Privacy Notice applies to any information that can be used to identify you ("Data"). We are committed to protecting the confidentiality of your Data and complying with applicable data protection laws.
This Privacy Notice is intended to be clear and easy to understand, but please contact us using the details at section 2 if you have any queries.
We may make changes to this Privacy Notice from time to time, including where necessary to reflect any changes in the ways in which we process your Data or any changes to data protection laws. Any updates to this Privacy Notice will be posted on our websites.
Contents
1. WHO WE ARE
2. CONTACTING US
3. WHAT DATA WE COLLECT
4. HOW WE USE YOUR DATA
5. HOW WE SHARE YOUR DATA
6. HOW LONG WE KEEP YOUR DATA FOR
7. SECURITY
8. YOUR LEGAL RIGHTS
1. WHO WE ARE
We are Broadway Licensing Global, LLC also doing business as Dramatists Play Service, Inc., BLG Theatrical, LLC, Stageworks Media, LLC and Broadway on Demand, LLC a company registered in Delaware under company number, 2309280021 with its registered office at 440 Park Avenue South, 11th Floor, New York, New York 10016. We are known as 'Broadway Licensing Global' and/or ‘Broadway Licensing‘ and operate a business licensing theatrical works and selling scripts and other materials in relation to the same under this name as well as the names 'Dramatists Play Service' and 'Playscripts', which we refer to as 'Imprints'.
This Privacy Notice applies to how we use your Data in connection with our business activities under each of the Imprints mentioned above, including the following websites:
• https://broadwaylicensing.co.uk/
• https://www.broadwaylicensing.com/
• https://www.dramatists.com/
• https://www.playscripts.com/
• https://www.broadwayondemand.com/
• https://www.licensecursedchild.com/
• https://www.licensecursedchild.co.uk/
• https://www.bwaybookclub.com/
• https://www.thescenenews.com/
Data protection laws apply to our use of your Data and we are a 'data controller' for the purposes of these laws.
2. CONTACTING US
If you have any questions or complaints regarding this Privacy Notice or how we use your Data, please contact us at:
Email: dataprotection@broadwaylicensing.com
Address: 440 Park Avenue South, 11th Floor, New York, NY 10016, United States
3. WHAT DATA WE COLLECT
3.1 Data you provide
We collect Data from you directly when you:
3.1.1 access, use or interact with our websites or social media channels;
3.1.2 correspond/interact with us via email, phone, social media or other channels;
3.1.3 make any enquiry or complaint, or request technical support or other customer care support;
3.1.4 take steps to enter into an agreement with us in connection with the licence of theatrical rights or purchase of related materials, and otherwise in the course of the performance of that agreement; and
3.1.5 participate in surveys, competitions or questionnaires or provide us with a review or feedback.
The Data may include the following categories of information:
3.2. Data we collect from other sources
We may also collect certain Data about you from other sources, including publicly accessible sources. This may include:
• Research Data from our third-party service providers who we engage to carry out market research;
Research Data from our third-party service providers who we engage to carry out market research;
• Usage Data from third-party providers of analytic services, such as Performics Inc., Google Analytics, Shopify, and ThinkBig LLC;
• Identity Data, Contact Data, Organisation Data, Performance Data and Correspondence Data from publicly available sources such as LinkedIn or company websites, or from an organisation that is associated with you and provides such Data in the course of doing business with us;
• Identity Data and Transaction Data from third-party service providers (including third party platforms) where necessary for the performance of our contract with you; and
• Identity Data, Contact Data and Marketing and Communications Data from third-party service providers for marketing and business development purposes.
3.3 Sensitive Data
In limited circumstances, the Data we collect about you may include 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) and data relating to criminal convictions and offences (including terrorist offences and fraudulent activity ("Sensitive Data"). Except where we need to process your Sensitive Data to comply with a legal obligation, we will only process this kind of Data where you have chosen to provide us with it and on the basis of your explicit consent.
3.4 Failing to provide Data
Where we need to collect your Data by law, or under the terms of an agreement we have with you, and you fail to provide that Data when requested (or fail to consent to the processing of that Data, if necessary), we may not be able to do business with you and/or such failure may result in a breach of the contractual obligations between us. We will notify you at the time if this is the case.
3.5 Changes to your Data
It's important that the Data we hold about you is accurate and current. Please let us know if your Data changes or if you become aware that any Data that we hold about you is not accurate.
4. HOW WE USE YOUR DATA
4.1 General Uses
The Data we collect and how we process it depends on the nature of our relationship with you. We will only use your Data where we are allowed to by law, including the requirement that there must be a 'lawful basis' for any processing.
Most commonly, we will rely on the following lawful bases to process your Data:
• Contract: in order to perform an agreement we have or are about to enter into with you;
• Legal obligation: to comply with an applicable law or regulation;
• Legitimate Interests: for the purposes of legitimate interests pursued by us or a third party. Where we rely on legitimate interests as the lawful basis, we will ensure that your interests and fundamental rights and freedoms are not overridden by our interests; and/or
• Consent: we may also process your Data where we have your consent. You have the right to withdraw your consent at any time and if you wish to do so, you should contact us using the details at section 2. The withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds.
4.2 Specific purposes and lawful basis
We have set out in the table below the legal basis on which we process your Data including, where relevant, a description of the applicable legitimate interests we rely on. Please note that we may process your Data for more than one lawful basis depending on the specific purpose for which we're using your Data.
4.3 Changes to how we use your Data
We'll only use your 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 we need to use your Data for an unrelated purpose, we'll notify you (which may be by way of update to this Privacy Notice) and explain the legal basis which allows us to do so.
4.4 Children's Data
Although our websites are not directed at children under 13, we recognize that certain features may appeal to a range of ages. We require parental consent, through a permission form (sent by regular mail or e-mail), before we ask for any Data from visitors we know are under 13.
In addition, even after a parent has given their permission, we allow parents to review, amend, or delete any Data their children have provided, and to prohibit further collection. For US residents under 13, we have special privacy procedures in place to ensure compliance with the Children’s Online Privacy Protection Act.
5 HOW WE SHARE YOUR DATA
5.1 Who we share your Data with
We won't share any of your Data with third parties except as set out in this section or as otherwise notified to you or agreed between us from time to time. We may share your Data with:
• the holder of the underlying rights in the works that you have licensed from us or intend to license from us. When you apply for a licence, you authorise us to share the Identity Data, Contact Data, Organisation Data and Performance Data included in your application with the rightsholder and their authorised representatives. This is necessary for us to be able to licence the relevant rights to you;
• our group companies (including our subsidiaries, ultimate holding company and its subsidiaries) and partnered companies for the purposes outlined in this Privacy Notice;
• third-party service providers who we engage to provide services that facilitate our business, for example, in relation to our IT and cloud-based systems and payment service providers. This includes Verio (website hosting), Argano and Word Press (website build), Contentful (content management system), Microsoft AX (database functionality) and any similar or replacement third parties from time to time. In all cases, such parties are required to keep your Data confidential and secure and use it solely for the purpose of providing the specified services to us;
• third parties that we engage to serve and track ads on our websites, to measure the effectiveness of advertising, and to provide advertisements about goods and services that may be of interest to you, such as Performics Inc., Google Analytics and ThinkBig LLC;
• our legal counsel and other professional advisers including accountants and auditors;
• in the event that our business or any part of it is sold or integrated with another business, with our advisers and those of the prospective purchaser; and/or
• with law enforcement agencies and other government departments or competent authorities where required to do so by law or regulation (such as in connection with an investigation of fraud or other legal enquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws or any agreement with us), or if we reasonably consider that this is necessary to help prevent or detect fraud or other crimes or to protect our rights, property, or safety, or that of our customers or others.
We will not share the Data of children we understand to be under the age of 18 with third parties under any circumstances unless we are legally required to do so.
5.2 International transfers
From time to time, it may be necessary for us to transfer your Data internationally. In particular, your Data may be processed on the servers of third parties identified above that are based outside of the UK or EEA.
If you are based in the UK or EEA (or your Data is otherwise subject to the data protection laws of either of these jurisdictions), we will not transfer your Data outside of the UK or EEA (as applicable) unless:
• the laws of that country provide your Data with a level of protection equivalent to that under UK/EEA law (known as an ‘adequacy decision'). A list of countries that have received an adequacy decision from the UK government is available here and includes countries within the EEA and various other jurisdictions (in some cases subject to certain requirements); or
• the transfer is done using legally approved safeguards, such as standard contractual clauses or binding corporate rules, or otherwise in accordance with data protection laws (e.g., where you have consented to the transfer or the transfer is necessary for the performance of a contract we have with you).
6 HOW LONG WE KEEP YOUR DATA FOR
As a minimum, we need to store your Data for as long as is necessary to enable us to fulfil the purpose for which we collected it. Once the relevant purpose is complete, we may continue to retain your Data in accordance with our retention policies, copies of which are available on request.
When determining the relevant retention periods, we will take into account factors including:
• our business relationship with you;
• our legal obligations to retain certain records for specified periods of time;
• the statute of limitations and any existing or potential disputes between us; and
• guidelines issued by relevant supervisory authorities.
7 SECURITY
7.1 Security measures
We use appropriate technical and organisational security measures to help protect your Data against loss and unauthorised access, which include procedures to deal with any actual or suspected data breaches. We will notify you of any such breaches where we are legally required to do so.
The pages of our websites are secured via HTTPS SHA-256 Transport Layer Security (TLS). This protocol encrypts all data between your computer/device and our websites and helps us to protect the security of your Data. All emails you receive from us are sent from a TLS enabled SMTP server. However, please note that any transmission is at your own risk as we cannot guarantee the security of any data transmitted via the internet.
It is important that you keep secure and confidential any login credentials that you create for the use of our websites. You are responsible for maintaining the security and confidentiality of such credentials. You should notify us immediately if you become aware that the security or confidentiality of your login credentials has been compromised.
7.2 Links to third party websites
Our website may link or redirect to other websites, social media accounts or other content which is not under our control. Unless otherwise stated, such links or redirections are not endorsements of such websites or representation of our affiliation with them in any way and such third-party websites are outside the scope of this Privacy Notice.
If you access such third-party websites or platforms, please ensure that you're satisfied with their respective privacy notices before you provide them with any Data. We cannot be held responsible for the activities, privacy policies or levels of privacy compliance of any website or platform operated by any third party.
8 YOUR LEGAL RIGHTS
You may have various rights under data protection laws in relation to the Data we hold about you depending on which laws apply to you.
8.1 Your rights in connection with your Data
Under certain circumstances, you may be entitled to:
• object to us processing your Data where we do so on the basis of a Legitimate Interest and you believe your own rights and interests outweigh those interests;
• request access to a copy of the Data we hold about you (commonly known as a "data subject access request") to enable you to check that we are processing it lawfully.
• request correction of any inaccurate or incomplete Data we hold about you;
• request erasure of your Data;
• request a restriction of the ways in which we process your Data;
• request the transfer of your Data to another party in a machine-readable, commonly used and structured format. This right only applies where we process your Data on the basis of Consent or Contract and the processing is carried out by automated means.
For further information, or to exercise any particular right, please contact us using the details at section 2.
Please note that in most cases these rights are not absolute and are subject to exceptions or qualifications under data protection laws. For example, even if you request that we delete your Data, we may be required to retain certain elements of it for accounting and record keeping purposes or to comply with our legal and regulatory obligations.
We will aim to respond to your request within one month of receipt. In some cases, we may require more time to respond to your request and we will notify you about this at the time.
8.2 What we need from you
We may need you to provide us with further information to help us process your request and/or to confirm your identity to protect against your Data being incorrectly disclosed. We will not be able to fulfil your request until you provide us with this information.
8.3 Fees
You will not have to pay a fee to exercise your rights. However, if your request is clearly unfounded or excessive or if you request multiple copies of the information, then we may charge a reasonable fee or refuse to comply with the request.
8.4 Data for marketing purposes
We use your Data to identify and notify you about products, services, events or competitions that we think may be of interest to you.
We will only send you marketing messages via email where you have consented to us contacting you in this way, or where the message relates to products/services that are similar to those that we have already provided to you. You have the right to stop us from sending you marketing messages at any time. You can do this by:
• contacting us using the details at section 2;
• following the instructions provided in the messages you receive from us. For example, by clicking the ‘unsubscribe’ link included in emails from us; or
• updating your marketing preferences on your website account insert link to preference centre.
We may ask you to confirm or update your marketing preferences if you continue to purchase products or services with us in the future, or if there are changes in the law, regulation, or the structure of our business.
8.5 Complaints
Please contact us using the details at section 2 if you are unhappy with how we have handled your Data.
If you are not satisfied with our response to your complaint or believe that we have not complied with data protection laws, you can make a complaint at any time to the Information Commissioner's Office (https://ico.org.uk/global/contact-us/).
[DETAILS OF CHANGES TO THIS PRIVACY NOTICE]
This notice ("Privacy Notice") explains how Broadway Licensing ("we", "us" and "our") uses the personal information of our customers, prospective customers and users of our websites ("you" and "your").
This Privacy Notice applies to any information that can be used to identify you ("Data"). We are committed to protecting the confidentiality of your Data and complying with applicable data protection laws.
This Privacy Notice is intended to be clear and easy to understand, but please contact us using the details at section 2 if you have any queries.
We may make changes to this Privacy Notice from time to time, including where necessary to reflect any changes in the ways in which we process your Data or any changes to data protection laws. Any updates to this Privacy Notice will be posted on our websites.
Contents
1. WHO WE ARE
2. CONTACTING US
3. WHAT DATA WE COLLECT
4. HOW WE USE YOUR DATA
5. HOW WE SHARE YOUR DATA
6. HOW LONG WE KEEP YOUR DATA FOR
7. SECURITY
8. YOUR LEGAL RIGHTS
1. WHO WE ARE
We are Broadway Licensing Global, LLC also doing business as Dramatists Play Service, Inc., BLG Theatrical, LLC, Stageworks Media, LLC and Broadway on Demand, LLC a company registered in Delaware under company number, 2309280021 with its registered office at 440 Park Avenue South, 11th Floor, New York, New York 10016. We are known as 'Broadway Licensing Global' and/or ‘Broadway Licensing‘ and operate a business licensing theatrical works and selling scripts and other materials in relation to the same under this name as well as the names 'Dramatists Play Service' and 'Playscripts', which we refer to as 'Imprints'.
This Privacy Notice applies to how we use your Data in connection with our business activities under each of the Imprints mentioned above, including the following websites:
• https://broadwaylicensing.co.uk/
• https://www.broadwaylicensing.com/
• https://www.dramatists.com/
• https://www.playscripts.com/
• https://www.broadwayondemand.com/
• https://www.licensecursedchild.com/
• https://www.licensecursedchild.co.uk/
• https://www.bwaybookclub.com/
• https://www.thescenenews.com/
Data protection laws apply to our use of your Data and we are a 'data controller' for the purposes of these laws.
2. CONTACTING US
If you have any questions or complaints regarding this Privacy Notice or how we use your Data, please contact us at:
Email: dataprotection@broadwaylicensing.com
Address: 440 Park Avenue South, 11th Floor, New York, NY 10016, United States
3. WHAT DATA WE COLLECT
3.1 Data you provide
We collect Data from you directly when you:
3.1.1 access, use or interact with our websites or social media channels;
3.1.2 correspond/interact with us via email, phone, social media or other channels;
3.1.3 make any enquiry or complaint, or request technical support or other customer care support;
3.1.4 take steps to enter into an agreement with us in connection with the licence of theatrical rights or purchase of related materials, and otherwise in the course of the performance of that agreement; and
3.1.5 participate in surveys, competitions or questionnaires or provide us with a review or feedback.
The Data may include the following categories of information:
| Categories of Data | Description of Data |
|---|---|
| Identity Data | Details necessary to identify you as an individual. This may include your name, address, date of birth, age, marital status, title, gender, nationality, country of residence and any details contained in copies of identification documents you provide us with. |
| Contact Data | Information necessary to contact you, such as your email address, postal address, telephone number, social media handles and other similar information in an email signature. |
| Organisation Data | Details about any organisation(s) you are connected to, including the name and corporate details of the relevant organisation and your current or historical interests, roles and associations with it. |
| Performance Data | Information we require to determine the necessary scope and terms of a licence you have requested from us. This may include the number of performances you intend to put on, the opening date, seating capacity, ticket price and information in relation to the relevant venue. |
| Transaction Data | Information necessary to process transactions between us, such as your bank details, account number, sort code, payment amount and any information contained in a payment reference. |
| Correspondence Data | Information which you provide in, or we learn about you from, any correspondence or communications with us, including any enquiries in relation to our products and details of any enquiries or requests for technical or customer support, or any information relevant to your relationship with us that you post online. |
| Record Data | Information relating to the history of your transactions with us and our records of communications with you, including electronic communications with our staff and recordings of phone calls. |
| Due Diligence Data | Information we are required to collect in order to comply with 'know your customer', anti-money laundering or other regulatory or internal policy requirements (such as information in relation to politically exposed personas and sanctions checks, your assets, sources of wealth, and/or income and/or financial dealings. |
| Usage Data | Information about how you use and interact with our websites, such as how often you access it, how long you spend on it and how you navigate around it, and your use of social sharing features such as 'likes', comments and links that you share (e.g. via Facebook Comment or Share). |
| Profile Data | Information relating to an account you have registered with us, such as your username, password, security word and hint, memorable word, your interests, account preferences, and items you have added to your cart. |
| Technical Data | Technical information relating to your use of our website, such as your device type, unique device identifier (e.g. an IMEI number, IDFA, IP, or MAC address), network information, operating system type, platform/browser type, time zone settings and location. |
| Cookie Data | Information we collect through cookies in use on our website. Please refer to our Cookies Policy for further information. |
| Marketing and Communications Data | Information in relation to your preferences for receiving marketing communications from us. |
| Research Data | Statistical information in connection with the delivery of our products, which may include information relating to email opening and clicks and information you provide in response to market research surveys. |
3.2. Data we collect from other sources
We may also collect certain Data about you from other sources, including publicly accessible sources. This may include:
• Research Data from our third-party service providers who we engage to carry out market research;
Research Data from our third-party service providers who we engage to carry out market research;
• Usage Data from third-party providers of analytic services, such as Performics Inc., Google Analytics, Shopify, and ThinkBig LLC;
• Identity Data, Contact Data, Organisation Data, Performance Data and Correspondence Data from publicly available sources such as LinkedIn or company websites, or from an organisation that is associated with you and provides such Data in the course of doing business with us;
• Identity Data and Transaction Data from third-party service providers (including third party platforms) where necessary for the performance of our contract with you; and
• Identity Data, Contact Data and Marketing and Communications Data from third-party service providers for marketing and business development purposes.
3.3 Sensitive Data
In limited circumstances, the Data we collect about you may include 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) and data relating to criminal convictions and offences (including terrorist offences and fraudulent activity ("Sensitive Data"). Except where we need to process your Sensitive Data to comply with a legal obligation, we will only process this kind of Data where you have chosen to provide us with it and on the basis of your explicit consent.
3.4 Failing to provide Data
Where we need to collect your Data by law, or under the terms of an agreement we have with you, and you fail to provide that Data when requested (or fail to consent to the processing of that Data, if necessary), we may not be able to do business with you and/or such failure may result in a breach of the contractual obligations between us. We will notify you at the time if this is the case.
3.5 Changes to your Data
It's important that the Data we hold about you is accurate and current. Please let us know if your Data changes or if you become aware that any Data that we hold about you is not accurate.
4. HOW WE USE YOUR DATA
4.1 General Uses
The Data we collect and how we process it depends on the nature of our relationship with you. We will only use your Data where we are allowed to by law, including the requirement that there must be a 'lawful basis' for any processing.
Most commonly, we will rely on the following lawful bases to process your Data:
• Contract: in order to perform an agreement we have or are about to enter into with you;
• Legal obligation: to comply with an applicable law or regulation;
• Legitimate Interests: for the purposes of legitimate interests pursued by us or a third party. Where we rely on legitimate interests as the lawful basis, we will ensure that your interests and fundamental rights and freedoms are not overridden by our interests; and/or
• Consent: we may also process your Data where we have your consent. You have the right to withdraw your consent at any time and if you wish to do so, you should contact us using the details at section 2. The withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds.
4.2 Specific purposes and lawful basis
We have set out in the table below the legal basis on which we process your Data including, where relevant, a description of the applicable legitimate interests we rely on. Please note that we may process your Data for more than one lawful basis depending on the specific purpose for which we're using your Data.
| Purpose/Activity | Type of Data | Lawful Basis |
|---|---|---|
| Registration and customer relationship management Registering you as a new customer and managing and administering our business relationship with you |
Identity Data Contact Data Organisation Data Performance Data Correspondence Data Record Data Profile Data |
Legitimate interests (to operate our business, including creating and developing relationships with our customers) Consent (to the extent that the data comprises Sensitive Data) |
| Delivery of our products Performing our obligations to you in relation to the licensing of theatrical works and the sale of scripts and other materials in relation to the same. |
Transaction Data Correspondence Data Profile Data |
Legitimate Interests (to operate our business and fulfil our legal and contractual obligations to our customers) |
| Verification, fraud and crime prevention Carrying out due diligence, monitoring and screening. Carrying out verification, antimoney laundering and other similar sanctions checks. Detecting, monitoring, investigating and reporting fraud and criminal activity |
Identity Data Contact Data Organisation Data Performance Data Transaction Data Record Data Due Diligence Data |
Compliance with a legal obligation (to prevent fraud and verify your identity for anti-money laundering and other similar purposes) Consent (to the extent that the relevant assessments comprise Sensitive Data and the processing of such data is not necessary to comply with an applicable legal/regulatory obligation) Legitimate interests (to prevent fraud and other crimes and to maintain the integrity of our business) |
| Operation of our websites Operating and protecting our website and social media channels, (including troubleshooting, incident management and data breach management, data analysis, product and system testing, system maintenance, support, reporting and data hosting) |
Identity Data Contact Data Usage Data Profile Data Technical Data Cookie Data |
Legal Obligation (to implement appropriate security measures and monitor the operation of such measures) Legitimate Interests (to ensure the effective operation of our business through maintaining the integrity of our IT systems) |
| Development of our websites Improving our website, our apps, customer relationships and experiences |
Usage Data Profile Data Technical Data Cookie Data |
Legitimate Interests (to promote our business by improving the performance and user experience of our websites) Consent (to the extent required in respect of the relevant cookies) |
| Market research Carrying out market research and implementing any resulting insights |
Identity Data Contact Data Correspondence Data Organisation Data Performance Data Profile Data Marketing and Communications Data Research Data |
Legitimate Interests (to promote our business by developing our marketing strategy, improving our products and the experience of our customers) Consent (to the extent that you choose to provide us with Sensitive Data as part of our market research) |
| Marketing and advertising Marketing our products and services to you, including making suggestions and recommendations to you about products, services, events or competitions that that may be of interest to you. Delivering content and advertisements on our website that is relevant to you and measuring the effectiveness of the advertising we serve to you |
Identity Data Contact Data Marketing and Communications Data Profile Data Usage Data Technical Data Cookie Data |
Legitimate Interests (to develop our business by implementing effective marketing strategies) Consent (to the extent that we require your consent to use your Data for these purposes. This applies where we send you marketing messages over email, and where we use certain cookies for the purposes of serving and tracking ads on our websites) |
4.3 Changes to how we use your Data
We'll only use your 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 we need to use your Data for an unrelated purpose, we'll notify you (which may be by way of update to this Privacy Notice) and explain the legal basis which allows us to do so.
4.4 Children's Data
Although our websites are not directed at children under 13, we recognize that certain features may appeal to a range of ages. We require parental consent, through a permission form (sent by regular mail or e-mail), before we ask for any Data from visitors we know are under 13.
In addition, even after a parent has given their permission, we allow parents to review, amend, or delete any Data their children have provided, and to prohibit further collection. For US residents under 13, we have special privacy procedures in place to ensure compliance with the Children’s Online Privacy Protection Act.
5 HOW WE SHARE YOUR DATA
5.1 Who we share your Data with
We won't share any of your Data with third parties except as set out in this section or as otherwise notified to you or agreed between us from time to time. We may share your Data with:
• the holder of the underlying rights in the works that you have licensed from us or intend to license from us. When you apply for a licence, you authorise us to share the Identity Data, Contact Data, Organisation Data and Performance Data included in your application with the rightsholder and their authorised representatives. This is necessary for us to be able to licence the relevant rights to you;
• our group companies (including our subsidiaries, ultimate holding company and its subsidiaries) and partnered companies for the purposes outlined in this Privacy Notice;
• third-party service providers who we engage to provide services that facilitate our business, for example, in relation to our IT and cloud-based systems and payment service providers. This includes Verio (website hosting), Argano and Word Press (website build), Contentful (content management system), Microsoft AX (database functionality) and any similar or replacement third parties from time to time. In all cases, such parties are required to keep your Data confidential and secure and use it solely for the purpose of providing the specified services to us;
• third parties that we engage to serve and track ads on our websites, to measure the effectiveness of advertising, and to provide advertisements about goods and services that may be of interest to you, such as Performics Inc., Google Analytics and ThinkBig LLC;
• our legal counsel and other professional advisers including accountants and auditors;
• in the event that our business or any part of it is sold or integrated with another business, with our advisers and those of the prospective purchaser; and/or
• with law enforcement agencies and other government departments or competent authorities where required to do so by law or regulation (such as in connection with an investigation of fraud or other legal enquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws or any agreement with us), or if we reasonably consider that this is necessary to help prevent or detect fraud or other crimes or to protect our rights, property, or safety, or that of our customers or others.
We will not share the Data of children we understand to be under the age of 18 with third parties under any circumstances unless we are legally required to do so.
5.2 International transfers
From time to time, it may be necessary for us to transfer your Data internationally. In particular, your Data may be processed on the servers of third parties identified above that are based outside of the UK or EEA.
If you are based in the UK or EEA (or your Data is otherwise subject to the data protection laws of either of these jurisdictions), we will not transfer your Data outside of the UK or EEA (as applicable) unless:
• the laws of that country provide your Data with a level of protection equivalent to that under UK/EEA law (known as an ‘adequacy decision'). A list of countries that have received an adequacy decision from the UK government is available here and includes countries within the EEA and various other jurisdictions (in some cases subject to certain requirements); or
• the transfer is done using legally approved safeguards, such as standard contractual clauses or binding corporate rules, or otherwise in accordance with data protection laws (e.g., where you have consented to the transfer or the transfer is necessary for the performance of a contract we have with you).
6 HOW LONG WE KEEP YOUR DATA FOR
As a minimum, we need to store your Data for as long as is necessary to enable us to fulfil the purpose for which we collected it. Once the relevant purpose is complete, we may continue to retain your Data in accordance with our retention policies, copies of which are available on request.
When determining the relevant retention periods, we will take into account factors including:
• our business relationship with you;
• our legal obligations to retain certain records for specified periods of time;
• the statute of limitations and any existing or potential disputes between us; and
• guidelines issued by relevant supervisory authorities.
7 SECURITY
7.1 Security measures
We use appropriate technical and organisational security measures to help protect your Data against loss and unauthorised access, which include procedures to deal with any actual or suspected data breaches. We will notify you of any such breaches where we are legally required to do so.
The pages of our websites are secured via HTTPS SHA-256 Transport Layer Security (TLS). This protocol encrypts all data between your computer/device and our websites and helps us to protect the security of your Data. All emails you receive from us are sent from a TLS enabled SMTP server. However, please note that any transmission is at your own risk as we cannot guarantee the security of any data transmitted via the internet.
It is important that you keep secure and confidential any login credentials that you create for the use of our websites. You are responsible for maintaining the security and confidentiality of such credentials. You should notify us immediately if you become aware that the security or confidentiality of your login credentials has been compromised.
7.2 Links to third party websites
Our website may link or redirect to other websites, social media accounts or other content which is not under our control. Unless otherwise stated, such links or redirections are not endorsements of such websites or representation of our affiliation with them in any way and such third-party websites are outside the scope of this Privacy Notice.
If you access such third-party websites or platforms, please ensure that you're satisfied with their respective privacy notices before you provide them with any Data. We cannot be held responsible for the activities, privacy policies or levels of privacy compliance of any website or platform operated by any third party.
8 YOUR LEGAL RIGHTS
You may have various rights under data protection laws in relation to the Data we hold about you depending on which laws apply to you.
8.1 Your rights in connection with your Data
Under certain circumstances, you may be entitled to:
• object to us processing your Data where we do so on the basis of a Legitimate Interest and you believe your own rights and interests outweigh those interests;
• request access to a copy of the Data we hold about you (commonly known as a "data subject access request") to enable you to check that we are processing it lawfully.
• request correction of any inaccurate or incomplete Data we hold about you;
• request erasure of your Data;
• request a restriction of the ways in which we process your Data;
• request the transfer of your Data to another party in a machine-readable, commonly used and structured format. This right only applies where we process your Data on the basis of Consent or Contract and the processing is carried out by automated means.
For further information, or to exercise any particular right, please contact us using the details at section 2.
Please note that in most cases these rights are not absolute and are subject to exceptions or qualifications under data protection laws. For example, even if you request that we delete your Data, we may be required to retain certain elements of it for accounting and record keeping purposes or to comply with our legal and regulatory obligations.
We will aim to respond to your request within one month of receipt. In some cases, we may require more time to respond to your request and we will notify you about this at the time.
8.2 What we need from you
We may need you to provide us with further information to help us process your request and/or to confirm your identity to protect against your Data being incorrectly disclosed. We will not be able to fulfil your request until you provide us with this information.
8.3 Fees
You will not have to pay a fee to exercise your rights. However, if your request is clearly unfounded or excessive or if you request multiple copies of the information, then we may charge a reasonable fee or refuse to comply with the request.
8.4 Data for marketing purposes
We use your Data to identify and notify you about products, services, events or competitions that we think may be of interest to you.
We will only send you marketing messages via email where you have consented to us contacting you in this way, or where the message relates to products/services that are similar to those that we have already provided to you. You have the right to stop us from sending you marketing messages at any time. You can do this by:
• contacting us using the details at section 2;
• following the instructions provided in the messages you receive from us. For example, by clicking the ‘unsubscribe’ link included in emails from us; or
• updating your marketing preferences on your website account insert link to preference centre.
We may ask you to confirm or update your marketing preferences if you continue to purchase products or services with us in the future, or if there are changes in the law, regulation, or the structure of our business.
8.5 Complaints
Please contact us using the details at section 2 if you are unhappy with how we have handled your Data.
If you are not satisfied with our response to your complaint or believe that we have not complied with data protection laws, you can make a complaint at any time to the Information Commissioner's Office (https://ico.org.uk/global/contact-us/).
[DETAILS OF CHANGES TO THIS PRIVACY NOTICE]
| Version | Date | Details of changes |
|---|---|---|
| 1.0 | 02/29/2024 | First published. |
