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Privacy Policy
CONTENTS
1. Introduction
2. What is ?
3. Explaining the legal bases we rely on
4. When do we collect your personal data?
5. What sort of personal data do we collect?
6. How and why do we use your personal data?
7. How we protect your personal data
8. How long will we keep your personal data?
9. Who do we share your personal data with?
10. Where your personal data may be processed
11. What are your rights over your personal data?
12. How can you stop the use of your personal data for direct marketing?
13. Contacting the Regulator
14. If you live outside the UK
15. Any questions?
1. Introduction This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
2. Col Canto Associates is a sole trader business providing choral music advocacy and website site listings. Its maintains British Choirs on the Net, Concertfinder and Choirsite websites. It also administers the British Choirs on the Net Choral Conductors facebook group. This document will refer to British Choirs on the Net of which Concertfinder and Choirsites are a subset.
3. Explaining the legal bases we rely on The law on data protection, based on the General Data Protection Regulation and formerly the Data Protection Act, sets out a number of different reasons for which a company may collect and process your personal data, including:
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. You are free to opt out of receiving these requests from us at any time by contacting us.
- To confirm that we have carried out your instruction such as posting a job vacany, concert promotion, choir listing, etc.
- For promotion of our services and choral related products and services your choir may have an intertest in, including the quarterly 'Chorister' newsletter and third party mailings. You are free to opt out of receiving these requests from us at any time by contacting us at philliptolley@colcanto.co.uk.
Consent In specific situations, we can collect and process your data with your consent.
British Choirs on the Net uses
'soft opt-in' methods to collect and store email contact information. This
means;
- We only collect email addresses from
organisations / choirs that are already listed on our site or have
requested to be listed on the site or to do business via our website. We
also used publically availabe email contact details from choir websites.
- Any marketing mailshots that are related to
British Choirs on the Net itself or companies which provide choral/choir
related services and general information about forthcoming choir related
events.
- We provide an opt-out or unsubscribe
mechanism for those who do not wish to receive marketing mailings.
- We do not buy-in or sell mailing lists or
contact information on third parties.
- We will only hold email contacts details while they remain relevant and will delete or amend them upon request. We are reliant on listed choirs and third party suppliers to keep us up to date on any changes to email contats or website address changes.
- You can unsubscribe from the mailing list
at any time by sending me an email with the words 'unsubscribe 'choir name' plus your
email address.
Please remember however that the mailing are for you choir membership and
unsubscribing will apply to the whole choir.
- When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations. If you have asked us to send out a mailing on behalf of your choir or organisation then we will require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business, such as invoicing and subsciption advertising, and which does not materially impact your rights, freedom or interests
4. When do we collect personal data
- We collect personal data when you request that your choir be added to the database of choirs on British Choirs on the Net
- We also collect personal date when you request that we add your concert details to Concertfinder
- We collect personal data when you request that we advertise a choral vacancy on your behalf
- When you engage with us on social media.
- When you contact us by any means to make enquiries
- When you or your company become subscription advertisers on the website(s)
- When you request a mailing on behalf of your choir or organisation
5. What sort of personal data do we collect?
- For a choir listing on the website we request the name and location of the choir, a small desciption of the choir and either a webiste address or contact email address. Of that information only the email address is classed as personal data and then only if the email address can identify a specific individual.
- For event listings on Concertfinder we collect information about the concert listings (date, venue, repertoire and cost). We also collect and publish online personal details where it is necessary to enable people to purchase tickets or seek further information about a concert.
- For subscription advertisers we collect all the necessary personal information to enable us to advertise the subscribers business and to enable us to invoice the company. This data may include names, addresses, telephone and bank details.
- For choirs who host their websites via Choirsites we collect and publish personal data as required by the choir concerned to enable them to advertise the contact details of their choir.
- For mailings we collect and publish whatever personal data that we have been authorised to publish by the originator of the mailing. Originators of mailings need to be very clear on which part of the mailing text is for publication and which part is simply part of the mailing request. We also collect and store personal information required to enable us to invoice choirs or organisations who have requested use of the mailing service. This personal data may include bank details
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
- Copies of documents you provide us or signed contracts .
6. Here’s how we’ll use your personal data and why:
- To perform any contract we’ve agreed with you. If we don’t collect your personal data during this process, we won’t be able to provide the required services and comply with our legal obligations.
- To respond to your queries or complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business from fraud and other illegal activities. We’ll do all of this as part of our legitimate interest.
- With your consent, we will use your personal data, as part of our mailing list, to keep you informed by email about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
- To send you relevant, personalised communications by email in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
- You can unsubscribe from the mailing list
at any time by sending me an email with the words 'unsubscribe 'choir name' plus your
email address.
Please remember however that the mailing are for you choir membership and
unsubscribing will apply to the whole choir. You can also amend the details of the person receiving this information.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. You are free to opt out of receiving these requests from us at any time by contacting us.
7. How we protect your personal data
- We know how much data security matters to all our clients. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. Our computers and mobile devices are all password protected. We regularly monitor our systems for possible vulnerabilities and constantly review our security.
8. How long will we keep your personal data?
- Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. If you request to unsubscribe to future mailings your data will deleted completely and a record of your unsubscription retained. Equally if the data changes, for instance the name of the choir contact changes, we will amend the email details accordingly. Her Majesty's Revenue and Customs (HMRC) requires us to keep records of contracts, payments and invoices for 7 years. We will therefore normally hold information of any contracts for this long.
9. Who do we share your personal data with?
- We do not share your personal data on the mailing list with other choir, advertisers or other third parties.
- To protect privacy all mailing are sent blind so that
no choir gets a listing of all other choirs emails the mailing has been sent to.
- The mailing lists is not
available for sale and we do not purchase mailing lists.
- On Facebook there are a limited number of administrators who look after the British Choirs on the Net Choral Conductors. They authorise membership and then the members self publish.
- We may, in exceptional circumstances, share personal data with legal or law enforcement authorities - for instance in fraud or money laundering enquiries.
10. Where is personal data stored
- Personal data is stored on a local computer at the home of the owner/adminirator of British Choirs on the Net and backed up to a secure facility that hosts the websites on behalf of the administrator. Computers are backed up regularly and virus protected.
- Data
collected about internet visitors to the British Choirs on the Net and
Concertfinder websites is anonymised data, in that it is not in a form that
can identify individuals. It can just count the number of visits to each
page to enable the content and the flow of information around the website to
be improved and tailored.
11. What are your rights over personal data. An overview of your rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- The right to deletion, for example when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as a change of choir contact information or the closure of a choir).
- That we stop using your personal data for direct marketing via email.
- You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact us at philliptolley@colcanto.co.uk. If we decide not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
- Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. You can unsubscribe from the mailing list
at any time by sending me an email with the words 'unsubscribe 'choir name' plus your
email address.
- Where we rely on our legitimate interest In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
- Direct marketing You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
12. How can you stop the use of your data for direct marketing
- You can stop direct marketing communications from us by sending me an email with the words 'unsubscribe 'choir name' plus your
email address.
Please remember however that the mailing are for you choir membership and
unsubscribing will apply to the whole choir. On Facebook you can remove yourself as a member of the British Choirs on the Net Choral Conductors Group.
13. Contacting the Regulator
- If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
- You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
- If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
14. If you live outside the UK
- British Choirs on the Net Mailing List is a contact list of UK based Choirs. We also list International Choirs on the website do do not currently have a mailing list of Internation Choirs. We do however have third party advertisers who are based outside the UK and we hold personal data to enable us to deal with and invoice these companies.
- By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes. Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK. By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes. This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK. We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
15. Any Questions?
- We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. If you have any questions that haven’t been covered, or if you wish to unsubscibe please contact us at philliptolley@colcanto.co.uk
- Please note that this is a home based business with no additional staff so requests for information may take a little longer that larger businesses with dedicated Data Protection officers
This notice was last updated on May 2018.
British Choirs on the Net uses
'soft opt-in' methods to collect and store email contact information. This
means;
-
We only collect email addresses from
organisations / choirs that are already listed on our site or have
requested to be listed on the site or to do business via our website. We
also used publically available email contact details from choir websites.
- Any marketing mailshots that are related to
British Choirs on the Net itself or companies which provide choral/choir
related services and general information about forthcoming choir related
events.
- We provide an opt-out or unsubscribe
mechanism for those who do not wish to receive marketing mailings.
- We do not buy-in or sell mailing lists or
contact information on third parties.
- We will only hold email contacts details while they remain relevant and will delete or amend them upon request. We are reliant on listed choirs and third party suppliers to keep us up to date on any changes to email contats or website address changes.
You can unsubscribe from the mailing list
at any time by sending me an email with the words 'unsubscribe 'choir name' plus your
email address.
Please remember however that the mailing are for you choir membership and
unsubscribing will apply to the whole choir.
Phillip Tolley
philliptolley@colcanto.co.uk
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