Privacy Policy

 

Top Floor Music Limited Privacy policy (v1.0)

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Here at Top Floor Music Limited we understand that protecting your personal information is of utmost importance. This privacy policy explains how we collect, use and store your information and how we ensure your information is secure.

We are a Data Controller, which means that we determine the purposes and the means of processing your personal information. We are registered directly with the Information Commissioner’s Office (ICO) and our registration number is Z9722822.

This privacy policy will apply to you if you provide your personal information to us, even if you decide not to go ahead with any product or service we offer. We provide a range of products and services and your personal information may be used differently depending on the product or service requested by you. You can find this information easily within the ‘How we use your personal information’ section below.

If you’ve any questions about how we may use your personal information you can contact us.

If you click on a link that takes you to a third-party website that is not ours, we will not be responsible for how they use your personal data. You should read their own privacy policy to understand how they may use your personal data.

Last update: 01/09/2024

•          What personal information do we collect?

•          How do we collect your personal information?

•          How we use your personal information

•          Who do we share your personal information with?

•          Social media

•          International transfers

•          Security

•          How we may contact you about the products and services we provide you

•          Your rights

•          How long do we keep your personal information for?

•          How we may contact you about other products or services we may offer

•          Other types of advertising

•          Contact us

•          Updates to this privacy policy

•          Cookies

 

 

1. What personal information do we collect?

The information we collect from you will depend on the product or service you apply for or the service that we provide to you. We will only collect information that we genuinely need, or where we're required to collect the information to enable us to perform our legal or contractual obligations necessary to provide you with the products or services, where we have a legitimate interest to do so, or where we have your permission.

This will likely include the collection of:

•          your personal details (e.g. name, date of birth);

•          address details;

•          contact details (e.g. phone number, email address);

•          special personal information;*

•          financial information / payment details;

•          information on how you use our website(s) and products and services.

Special Personal Information

Data protection law defines some personal information as “sensitive data” or “special categories of data”. This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect, for example, when applying for 3rd party services, such as ‘SYNC’, or where it may help us to provide a better service to you. Where we need to collect and process this type of data about you, we will ask for your explicit consent for us and any other third party to process this sensitive data as set out in this privacy policy, unless we have a legal obligation to process this type of data.

Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.

Information about other people

If you provide personal information about someone else, for example, if you have multiple artists within the band, you must do so with the permission of the other person(s). If you enter into a service jointly with another person, your personal information and any information about the service provided to you will be shared with the other person.

The personal information about the other person will be used in the ways as described in this privacy policy.

2. How do we collect your personal information

We can collect your information in a number of ways.

•          When you make an application or enquiry to us either by phone, email, our website, by a third party or by any other means;

•          Information received from a third party, for example where you have previously agreed for your information to be shared with us, or if you have been introduced to us by another company.

•          When you participate in market research, competitions and promotions provided by us, or on our behalf.

•          By adding reviews or interacting with us using social media such as Twitter/X or Facebook etc.

•          When we may need to obtain up to date information about you to meet our legal or regulatory obligations.

•          Where you have given permission for your information to be provided to us.

3. How we use your personal information

We can only use your personal information where it falls into one or more of the following categories:

•          it is necessary to fulfil a contract we have with you;

•          you have provided your consent;

•          we have a legal or regulatory obligation to do so;

•          it is necessary to carry out a task which is in the public interest;

•          it is necessary to protect your vital interests; or

•          it is in our legitimate interest to do so and it is not against your rights.

How we will use your personal information will depend on the product or service being provided to you. You can select from the products below to see how your personal information will be used specifically to be able to provide you with the product or service. If you decide not to go ahead with any of the services we provide we will still process your personal information we have collected for the purposes set out in Other Purposes for Processing your Personal Information.

PR Campaigns

Your details have been incorporated either for provision of, or to be in receipt of, Press Releases and campaigns run by Top Floor Music Limited.  To help us to do this, we will be required, under these terms and conditions and therefore to fulfil our obligations with you, to process your personal information, for example:

•          providing you with regular email updates/announcements;

•          sending you physical copies of releases and/or merchandise

•          passing on your information to selected 3rd party PR outlets for the benefit of promotion

•          setting up and processing payments with third parties such as your PRS/PPL, SYNC licensees.

Further details on how we will use your personal information when you open an account, and under what basis we can use your personal information are set out below:

What personal data do we need to collect?

When you work with us, either directly or indirectly (as a recipient of our PR submissions) we will need to collect the following categories of personal information:

•          Personal information – such as your name so that we can correctly identify you, and where you work, so that we may be able to send you relevant information/content.

•          Contact details – so we can contact you and send you any relevant communications about your arrangement with us – either directly or indirectly.

•          PayPal or BACS information – so that we can set up and process payments.

•          Musical information – PRS/PPL/IRSC details as required depending on the nature of our working relationship

 

This is required to fulfil our contractual and legal obligations.

Who will the data be shared with?

We will share only relevant personal information with PR agencies, Booking Agents, Management Companies and SYNC Licensee’s (and agents thereof) in relation to your arrangements with Top Floor. We will do this as part of our contractual and legal obligations to check your identity; check your eligibility for services, and as part of our fraud prevention procedures.

We also use personal information to help us create groups of people which may then be used to help us understand our products and help tailor our marketing more appropriately.  If we work with a third party for these purposes a contract will be in place to ensure your personal data is used only for these purposes and is processed securely.

We will need to share your information with other banks, retailers or other third parties to allow us to set up any Direct Debits, regular payments or deal with any issues that may arise to fulfil our contractual obligations with you.

How long will your data be stored for?

For Artists - Whilst you continue to work with Top Floor, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations.  This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. 

After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.

Responding to complaints or enquiries

If you make an enquiry or complaint with us, we will use your personal information to investigate the complaint and deal with your enquiry. We have a legal and regulatory obligation to deal with your complaint appropriately.

Analysis Purposes

As part of our legitimate interest to develop our business and our products we will use your personal information to assess our performance as a business and for statistical analysis and machine learning. We will use as little personal information as we can to achieve this. We may also share this analysis or any personal data between third parties who provide us with analysis services. We also use personal information to help us create groups of people which may then be used to help us understand our products and help tailor our marketing more appropriately. If we work with a third party for these purposes a contract will be in place to ensure your personal data is used only for these purposes and is processed securely.

4. Who do we share your information with?

In addition to the companies, organisations and other third parties set out in Section 3; we may also share your personal information with the following organisations:

•          PR Contacts such as radio, media, television, SYNC and other associated companies for the promotion of your product to the marketplace.

•          Technology/Digital Service Providers who provide technology platforms, cloud services or other technology or digital services

•          Banks and finance companies that process transactions such as Direct Debits or card transactions (where applicable).

•          Advertisers and social media companies such as Facebook, Google and Twitter for our social media accounts or where we can contact you using your social media account.

These companies help us to provide our services to you. We will have a contract in place with any provider who directly provides us with such services to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place.

We may also share your personal information where we have your consent to do so or where we’re required to do so under a legal or regulatory obligation or court order, such as the police, local authorities or the courts.

5. Social Media

We use publicly available social media platforms to promote our services, to provide updates and to share any news and promotional updates. We may collect personal information from these social media platforms, for example, if you post a message on our Facebook page. By providing any of your information to us through these platforms, you should be aware that:

•          the social media web pages are publicly available, and you must not provide any personal or sensitive information on our pages that are accessible to the public. 

•          each social media platform will process any personal information you provide through the platform and will be processed in accordance with their own privacy policy. The privacy policies will be available to view on each social media platform.

6. International Transfers

We will only share your personal information outside the UK, where we have your consent; to comply with a legal obligation; or where we work with a business partner to enable us to provide you with our services, and they process information outside of the UK.

If we do share your personal information outside of the UK, we will make sure that it is protected in the same way as if it was being used within the UK to ensure appropriate safeguards are in place. This may include putting in place a contract with the business partner that means they must protect the personal data to the same standards as it would within the UK (this may include model clauses), or only share the data to a business partner outside the UK or in a non-EEA country where the privacy laws provide the same protection as within the UK or the EEA and where appropriate technical and organisational measures are in place to ensure the data is protected and secure.

More information on this can be found on the Information Commissioner’s Office website.

7. Security

We take the protection of personal information very seriously, and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:

•          Company security policies and standards.

•          Staff security awareness.

•          Role-based access controls to prevent unauthorised access to the information.

•          Encryption and anonymisation technology.

•          Anti-malware technologies.

•          Security monitoring.

•          Security testing.

•          Secure archiving and deletion.

•          Compliance with industry regulation and legislation.

8. How we may contact you about the products and services we provide you

To help us keep you up to date about the products and services that we provide to you and to ensure that you’re kept fully informed we may contact you by letter, telephone, email, text message, push notifications, social media or may send you messages by any other electronic means.

If you don’t want to be contacted in a particular way, then you can request this at any time by contacting us, but if we are providing a service to you, we do need to be able to send you communications. 

It is important that you keep us up to date when you change your contact details to ensure that we use your up-to-date contact information.

9. Your Rights

Access to your personal information

You have the right to request from us a copy of the personal information that we may hold about you. This is often called a “Data Subject Access Request”. You can request this information by contacting us as set out below.

Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing it where you have given your agreement.

Right to have your personal information corrected

If the personal information we hold about you is incorrect, you have the right to request that we correct this.

Right to stop or limit the processing of the information we carry out

You may request that your personal information is deleted or that we stop processing the information if we’re no longer entitled to process it. There may be occasions where we are unable to delete the information due to our legal or regulatory obligations. We will, however, discuss this with you if you request for your information to be deleted.

Portability

In some cases, you may be able to request for your information to be provided to yourself or another company in a format that can be processed electronically by yourself or the other company. If you want to request this, you’ll need to contact us.

10. How long do we keep your personal information for?

Whilst you continue to be our customer, we will keep a record of your personal information to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least six years, starting from the date when we are no longer providing you with a service. We will retain telephone calls for between one year and eighteen months from the date the call was made.

After this time we will delete the information or anonymise the information so that it cannot be linked back to you.

11. How we may contact you about other products or services we may offer

Where we have a legitimate interest to do so, we may contact you to let you know about other offers, products and services that we provide or that are provided by our third party partners (for example SYNC Agents and Licensee’s), which we think you may be interested in or that may benefit you. We may do this through post, emails, text messages, telephone, push notifications, social media or other electronic means.

You can easily let us know at any time if you would no longer like to receive these messages. You can contact us using the details below, emailing us at info@topfloormusic.co.uk or unsubscribing using the link or information within the message.

12. Other types of advertising

When you visit our website or similar websites, Google may use our advertisements promoting our products and services which, may appear on other third-party websites you visit across the internet for remarketing purposes, including cross-device remarketing. Google and other third parties will use cookies to tailor advertisements for website users based on their previous visit to our website. More information about cookies can be found below.

We do not have any control over the advertisements you see on other third party websites however you can request to opt out or customise these advertisements by using the Google Ads Preferences Manager.

13. Contact us

If you have any questions or queries about how we use your personal information you can contact us or our Data Protection Officer using the address or email below:

Data Protection Officer

Top Floor Music Limited

18 Griffin Close

Wimborne

BH21 2FE

Email: info@topfloormusic.co.uk

If you are not happy with how we process your personal information you should contact us. If you’re not happy with how we have dealt with your complaint, you have the right to make a complaint with the Information Commissioner’s Office. You can find their details on their website at https://ico.org.uk/.

14. Updates to this privacy policy

Any updates to this privacy policy will be found on this page. If we make any important or significant changes to the way, we may collect and use your personal information we will endeavour to notify you of this change.

15. Cookies

When using this website, some information may be collected automatically using 'cookies' or other similar technologies. These are small text files that facilitate the processing of your information and enable us to analyse how the website is being used. Some cookies are essential and are needed to ensure the website functions correctly, for example, to allow us to store the data you input during an application to allow for your application to be submitted. Other cookies may be non-essential, for example, to allow us to track the number of users to the website or for online advertising.

Why are cookies used?

Cookies can be used for a number of reasons, including:

•          enabling us to recognise your device so that we can remember your log-in details and settings

•          providing advertising that is relevant and more interesting to you by collecting statistical and behavioural data

•          monitoring traffic to our websites to understand how they are being used and to ensure there’s enough capacity to run fast

•          providing us with information about our website users, for example, which search engine a visitor used to find the website, how often they visit the website and how long they spend on the website.

You can turn cookies off. This won't stop a website from working, but it might mean it won't work as well as it could, or that you have to do the same thing more than once.

More information on the cookies we use can be found in the Cookie Settings.