Privacy Policy

Privacy Policy

Effective date: August 14, 2019

Swindon Music Co-operative Limited (“us”, “we”, or “our”) operates the http://swindonmusiccoop.co.uk website (the “website” or “Service”).

Please note – this privacy policy applies only to this website (the “website” or “Service”) and does not cover information or data collection, storage and processing when communicating with Swindon Music Co-operative via direct email, postal mail or telephone, or as any part of the administration before, during and after applying for or receiving musical or other services from the Swindon Music Co-operative. For information on data processing by the Swindon Music Co-operative that is not part of this website, please contact the Data Controller via the details at the bottom of this Privacy Policy.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our website and the choices and rights you have associated with that data.

We use your data to provide and improve the Service. By using the website, you agree to the collection and use of information in accordance with this policy.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

— Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information is limited to:

  • Contact Form Data (your email address)
  • Invoice Payment Data (your email address, account reference and IP address)
  • Membership data (your first name, last name and email address)

— Tracking & Cookies Data

We use cookies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. We don’t currently use analytic or tracking technologies such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service, however we may do so in future. If we do add this functionality, this Privacy Policy will be updated to inform you of that fact.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies – We use Session Cookies to operate our Service.
  • Preference Cookies – We may use Preference Cookies to remember your preferences and various settings.
  • Security Cookies – We use Security Cookies for security purposes.

Managing cookies

— Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Use of Data

Swindon Music Co-operative Limited uses the collected data for various purposes:

  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in any interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues

Processing of Data

Cookies and Usage Data

The legal basis for processing Cookies and Usage Data is our legitimate interests, namely monitoring and improving our website and services. The source of the Personal Data is automated browser cookies and any usage or tracking technologies on our website.

Personal Data

 – Contact Form Data

The legal basis for processing Contact Form Data is consent, which is given at the time of submitting the contact form, and the source of the Personal Data is you. The data is stored and processed in order for us to respond to communications sent via the Contact page.

 – Invoice Payment Data

The legal basis for processing Invoice Payment Data is our legitimate interests, namely the proper administration of our website and business. The source of the Personal Data is you. The data is stored and processed in order to facilitate the proper administration of customer accounts and to allow linking payments to the correct customer account.

 – Membership Data

The legal basis for storing and processing Membership Data is consent, which is given at the time of submitting the registration form, and the source of the Membership Data is you. The data is stored and processed in order to facilitate the proper and secure access to restricted areas and functionality of the website to legitimate teacher-members of the Swindon Music Co-operative.

Important

As noted in the Information Collection and Use section, the only Personal Data we hold and process when you make an invoice payment is your email address, account reference and IP address. ALL other information is submitted to, and processed by, the Payzone secure server. We do not have store or process any of that information.

Retention of Data

Personal Data is retained under the following schedule:

  • Invoice Payment Data – this data (email address, account reference and IP address) is held for a period of 5 years after the payment has been made. After 5 years, the personal data will be automatically anonymised.
    The reason for this data retention is to be able to comply with our legal and regulatory requirements.
  • Contact Form Data – this data (email address), once processed by the server and sent, is not stored by our systems or server. Please note that the email address will be stored as part of the email header that is sent and will neccessarily be stored by the Swindon Music Co-operative’s email system which is not part of this website. For information on data retention concering emails, please contact the Data Controller using the contact details at the end of this Privacy Policy.
  • Membership Data – this data is held until such time as the account holder withdraws consent for storage and use of the data, or until such time as the account holder ceases to be a member of the Swindon Music Co-operative. Membership data will be anonymised within 4 weeks of either the account holder withdawing consent or ceasing to be a member of the Swindon Music Co-operative.

Transfer of Data

Whilst our website is hosted on UK based servers, your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Swindon Music Co-operative Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Swindon Music Co-operative will not share your data (Personal Data or Cookies and Usage Data) with any 3rd party.

GDPR

We have summarised the rights that you have concerning your Personal Data under General Data Protection Regulation (GDPR). Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Not all rights are absolute and can depend on the lawful basis for data processing as well as specific circumstances and situations.

Your principal rights under data protection law are:

(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

You may exercise any of your rights in relation to your personal data by written notice (postal or email) to us.

Any request to Swindon Music Co-operative to exercise your rights under GDPR will be responded to within a reasonable time and no longer than 28 days from Swindon Music Co-operative receiving your request.

Swindon Music Co-operative’s initial response may require you to provide proof of identity.

Swindon Music Co-operative’s final response will either be confirmation of the action requested along with relevant details or a rejection of the action along with justification.

- Data Access

You have the right to access the personal data we hold about you. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data to view.

- Data Rectification

You have the right to have any inaccurate personal data that we hold about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

- Data Erasure

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

- Restriction of Processing

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

- Objection to Processing

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

- Data Portability

You have the right to obtain your data in a suitable structured, commonly used and machine readable format when: the lawful basis for processing this information is consent or for the performance of a contract; and the processing is carried out by automated means (ie. excluding paper files).

- Right to Complain

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

- Right to Withdraw Consent

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Our Details

This website is owned and operated by Swindon Music Co-operative Limited.

Swindon Music Co-operative Limited is a registered company (number 03534393) and the registered address is Suite 16, Shaftesbury Centre, Percy Street, Swindon, England, SN2 2AZ 

You can contact us:

  • by post using the above address
  • using our website contact form
  • by telephone on 01793 554747
  • by email using info@swindonmusiccoop.co.uk (general enquiries)
  • by email using datacontroller@swindonmusiccoop.co.uk (data related enquiries)
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