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CWORKS Data Privacy Notification

Version date: 01 Mar 2023

CWORKS Music takes your privacy very seriously. This privacy notice contains information about how we may collect and use your personal data, and about your data protection rights.

About This Notice

This privacy notice applies primarily to our dealings with our clients, their managers, or representatives.

This is our main privacy notice. Other, specific terms – such as the terms of your CWORKS Music engagement, or the terms of use for the CWORKS Music website– may also apply to your personal data, as well as containing other important information about your dealings with CWORKS Music.

We operate this privacy notice in accordance with the applicable provisions of the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (the “Data Protection Laws”). We reserve the right to update this privacy notice from time to time, so please check for changes or updates. This version of our privacy notice is effective from 1st January 2022.

For the purposes of this privacy notice, the data controller in relation to all CWORKS Music data processing matters is CWORKS Music Ltd, whose office address is 14-15 Newbury Street, London, EC1A 7HU.

The type of personal information we collect

We currently collect and process the following information:

  • Identity Data for example, name, title, date of birth and gender
  • Contact Data for example e-mail, telephone, and postal address details
  • Works Data including data relating to the creation and ownership of musical and lyrical works and their recordings
  • Royalty Data including data relating to accounting and financial flows associated with the exploitation of musical and lyrical works and their recordings
  • Financial Data including bank and payment details
  • Transaction data relating to your dealings with us and the services we have provided
  • Technical and usage data including details of your interaction with our website
  • Marketing and Communications data including your preferences relating to marketing communications from us and our third parties

We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.

Sources of personal data

Some of the personal information we collect is provided to us directly by you (or your representative) including data provided when you request information about our products or services, instruct us in relation to those products or services, use our web site or other digital channels, give feedback, or otherwise contact us.

We also collect personal data from third parties including Collective Management Organisations and from Public Sources such as Companies House.

Basis for using your personal data

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

1/ we have a contractual obligation. This means it is something you have asked us to do, and without using the data we would not be able to complete the task.

2/ we have a legal obligation. This means that we may use your personal data relating to compliance with general legal obligations (such as under company law, employment law, or the Data Protection Laws) or the direction or order of any court, tribunal, law enforcement authority or government agency.

3/ we have a legitimate interest. This means we will use the data where it facilitates the delivery of our services to you

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

The following lists the ways in which we may use your personal data :

  • Providing you with important information about CWORKS Music
  • Registering you as a new client
  • Processing and delivering services ordered by you
  • Managing our client relationship with you
  • Carrying out client satisfaction surveys and other research in order to monitor and improve our services
  • Conducting marketing activities (other than where the Data Protection Laws require consent for such activities)
  • Training and developing our staff
  • Keeping our records up to date and verifying the accuracy of the information we hold
  • Responding to queries and complaints
  • Complying with our legal and regulatory obligations, enforcing our contractual or other legal rights, and defending any legal claims against us
  • Taking appropriate steps to protect your personal data from accidental loss, destruction, or damage, or unauthorised or unlawful access
  • Prevention of theft, fraud, or other criminal acts
  • Compiling aggregated data for use in our systems on the basis that once aggregated such data will no longer contain data from which you can be identified

Sharing and transferring your personal data

Generally, we may share your personal data:

  • With third party service providers, agents, subcontractors, and other organisations for the purposes of providing services to us (including providers of legal or financial services, or providers of IT services such as cloud, hosting and email services), or providing services to you on our behalf
  • With relevant third parties when required by applicable law (such as when CWORKS Music is required to respond to court orders or legal process)

When we voluntarily share personal data with third parties, we only provide the information they reasonably require in relation to the purpose for which we are sharing it, and place obligations on those third parties such as requiring them to keep your personal data secure and only to use it in accordance with our agreement with them.

Transferring your personal data outside the EEA

In the course of using or sharing your personal data in accordance with this privacy notice, CWORKS Music may transfer your Personal Data to locations outside the European Economic Area (EEA), such as where it is shared with third party service providers, agents, subcontractors and other organisations, located worldwide.

When we transfer personal data outside the EEA, we seek to ensure that it will be protected appropriately. Typically, this is addressed through our contract with the data recipient under which the transfer takes place.

Keeping your personal data

We will not keep your personal data for longer than is necessary, bearing in mind the purposes for which we collect and use it (as described in this privacy notice).

In determining how long it is necessary to keep your personal data, we have regard to criteria including the following:

  • The nature of your relationship with us. Generally, we retain all the information we gather for you for the period you are a client with us, as this helps us to build up a data profile through ongoing searches of indirect data sources
  • CWORKS Music legitimate interests in relation to data processing
  • The length of time we reasonably need to retain system entries, documents, and other information (which may include personal data) for legal, financial or regulatory reasons.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

How to contact us or complain

If you have any queries or complaints about this privacy notice, you can contact us at either of the following. Please clearly state your query as being a data protection query, to help us deal with your query more effectively.

Email
privacy@cworksmusic.com

Phone
+44 (0) 203 633 8114

Address
14-15 Newbury Street
London
EC1A 7HU

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO's address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk