ABC Creative Music Privacy Policy    23/5/2018


At ABC Creative Music we have never, and will never, buy or sell email addresses or personal data and the only email addresses we hold are those actively provided by schools and teachers signing up for trial courses or full subscriptions for our services. We have always, and will continue to, take child protection very seriously when dealing with storing or processing childrens' names for assesssment data, and any use of videos or photos containing children. We welcome the new legislation in the General Data Protection Regulation and see it as a way of refreshing and improving how we protect your privacy whilst continuing to inform you of, and provide our services.
Remember you can always manage your email marketing preferences at any time using the unsubscribe link in every email we send to you.

 

Our Privacy Promise To You


We promise:

  • To keep your data safe and private.
  • Not to sell your data.
  • To give you ways to manage and review your marketing choices at any time.
Please read the following to learn more about how we collect, store, use and disclose information about you when you interact with us, in any manner, via our website and/or our services.

HOW THE LAW PROTECTS YOU


As well as our Privacy Promise, the law protects your right to privacy – this section explains how that works.  Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside ABC Creative Music. The law says we must have one or more of these reasons:
  • To fulfil a contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of information that we gather when you are accessing or using our websites or services or when you contact us in any manner. We gather various types of information, including information that identifies you as an individual (“Personal Information”) as explained in more detail below.

WHAT INFORMATION DOES ABC CREATIVE MUSIC COLLECT?

a) INFORMATION YOU PROVIDE TO US:


When you sign up to use our website – we collect the personal information that you choose to provide for us e.g. your name, your email address, your school name, and in some cases your class and pupil names , or your children's names. We need this informationm to manage your subscription to give you access to our education websites, and for optional specific features should you choose to use them - eg an assessment module requiring a list of your children's names.
If you order a product through our website  – we collect the personal information that you provide to us, for example, your name, your email address, your address, as well as any other contact information you choose to provide us in connection with the delivery of services or products.

 

b) INFORMATION WE AUTOMATICALLY COLLECT:


When you use our website – we collect information via cookies and other similar technologies which may include saving cookies to users’ computers. We collect certain information related to your device such as your device’s IP address, referring website, what pages your device visited, and the time that your device visited our website.
For further information, please see our cookie policy.

 

HOW DO WE USE THE INFORMATION?


We use the information we collect via our services for a range of reasons, including:

  • to send you information to tell you about new courses and activities available on our education websites, information about downloadable apps or documents, or training or CPD opportunities in your area.
  • to set up a contact record in our data system;
  • to provide, operate and maintain the services;
  • to process and complete purchases and send related information including purchase confirmations and invoices;
  • to manage our customers’ use of the services i.e. respond to enquiries and comments, lost password requests, and provide customer service and support
  • to investigate and prevent fraudulent activities, unauthorised access to the services, and other illegal activities;
  • for any other purposes about which we notify customers and users.
  • for the purposes made clear to you at the time you submit your information – for example, to enable you to use or try out our online education resources by logging in
  • for administration and reporting purposes including (but not limited to) troubleshooting, performance analysis, statistical analysis and testing
  • to improve our website to ensure that content is presented in the most effective manner
  • to analyse customers use of our website for as part of our quality improvement and educational impact assessment activities;
  • as part of our efforts to keep our website safe and secure.

We may also use the information you send to us via our website and/or services, to communicate with you via email and possibly other means regarding products, services, offers, promotions and events we think may be of interest to you or to send you our newsletter.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You will always be able to opt-out of such communications at any time (see the “What choices do I have” section below).

HOW DO WE SHARE / DISCLOSE THE INFORMATION TO THIRD PARTIES?
We will not rent or sell your Personal Information to anyone under any circumstances.

We may process your personal information for our legitimate business interests e.g. direct marketing, data analytics and/or enhancing/improving our services (see ‘Legitimate Interests’ section below).
We do not transfer any information, personal or otherwise, outside the EEA (European Economic Area).
Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities such as the Police or security services.

LEGITIMATE INTERESTS


“Legitimate Interests” mean the interests of our companies in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well. For example, we may process your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
If you have any concerns you have the right to object to processing that is based on our legitimate interests.

IS PERSONAL INFORMATION ABOUT ME SECURE?


We use appropriate technical, organisational and administrative security measures to protect any information we hold from loss, misuse, unauthorised access, disclosure, alteration and destruction.  Unfortunately, no company or service can guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

WHAT CHOICES DO I HAVE?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of our services. You can opt-out of receiving promotional or marketing communications from us at any time by using the unsubscribe link in the marketing and promo email communications we send or by writing to us at . Tou can also stop the subscription to our websites, and any related non-promotional communication at any time by writing to us at

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
You can ask us to restrict the use of your personal information if:
  • It is not accurate.
  • It has been used unlawfully but you don’t want us to delete it.
  • It not relevant any more, but you want us to keep it for use in legal claims.
  • You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.
  • If you want to object to how we use your data or ask us to delete it or restrict how we use it or, please contact us.


CHILDREN


We do not knowingly collect or solicit personal information directly from anyone under the age of 16 but we do provide features and services where you may want to store information about children in the form of first names and education assessment data. We generally recommend only using first names for tracking children's assessment data when using all our online services, but even then make sure this data is only accessible to the holder of your user log in details or someone in the same educational establishment. We continuously monitor the security of this data and make assessments if the data in anyway can impact on child protection issues. If you are under 16, please do not attempt to register for our Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Information please contact us at .

We have a Child Protection Policy (available on request) and strictly follow current recommended practices on obtaining parental permission before using any photos or videos of children in any way. All of our staff are members of the PVG scheme.

LINKED WEBSITES


For your convenience, hyperlinks may be posted on our website that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the website. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy policy of each Linked Site that you visit to understand how the information that is collected about you is used and protected.

WILL ABC CREATIVE MUSIC EVER CHANGE THIS PRIVACY POLICY?


We are constantly trying to improve our website and services, so we may need to change this Privacy Policy from time to time. We will alert you to material changes by, for example, placing a notice on our website and/or by sending you an email when we are required to do so by applicable law. You can see when this Privacy Policy was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Privacy Policy.

WHAT IF I HAVE QUESTIONS ABOUT THIS POLICY?


If you have any questions or concerns regarding our privacy policy, please contact us at .