Effective 25th May 2018
For the purpose of the EU General Data Protection Regulation (EU) 2016/679, (GDPR), the data controller is Pure Solo Limited, incorporated in England and Wales with registration number 06107958 , whose registered office is at 12 Melcombe Place, London, NW1 6JJ, England ("Pure Solo" or "we").
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following information about you ("Personal Data"):
- information that you provide by filling in forms on the Site. This includes information about you (and your parent or guardian, if you are under 16) which you provide when registering to use the Site, posting material or requesting further services. We may also ask you for information when you enter a competition, prize draw or other contest sponsored by Pure Solo, enter a promotion, and when you report a problem with the Site;
- if you contact us, we may keep a record of that correspondence;
- we may ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
- details of transactions you carry out on the Site and of the fulfilment of your orders;
- details of your visits to the Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
- the recording and sharing on PureSolo is facilitated by a Browser Plugin (“Plugin”) which you download & install directly into your Web Brower. This Plugin may collect and send information about each of your sessions to help us identify issues, evaluate how the Plugin is used and provide the Service. Such information may include: the Plugin version number and unique identifier numbers that allow us to distinguish between different computers and different people using the Plugin; your username or company ID; the duration of your session; and the number of times you download any Content;
- the Plugin may collect and send additional information to help us better understand your music preferences, personalize certain content, recommend music to purchase or listen to, share playlists, and to automatically identify what CD is in your computer; such information may include the song playing, your playlists and what CD is in your drive;
- audio tracks that you buy from the Site through the Plugin may contain security systems, known as digital rights management (or "DRM"), which may track and send to us over the Internet play counts and other information to assist in providing the Service.
- we may ask you to provide a testimonial regarding your experience of the Service; you are free to do so or not, but if we wish to publish your testimonial on the Site (which may include information identifying you personally such as your name), we will obtain your permission before doing so.
In addition to the information which you may provide at our request, we may collect certain information automatically, including, but not limited to:
- the type of mobile device you use
- your mobile device unique ID
- the IP address of your mobile device
- your mobile operating system
- the type of mobile Internet browser you use, and
- other statistics ("Log Data").
Furthermore, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Service's functionality. These third party service providers have their own privacy policies addressing how they use such information and will also be compliant with the EU General Data Protection Regulation.
IP ADDRESSES AND COOKIES
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general Internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve the Site and to deliver a better and more personalised service.
They also enable us:
- to estimate our audience size and usage pattern and to monitor and improve the Site and the Service;
- to store information about your preferences, and so allow us to customise the Site according to your individual interests;
- to speed up your searches; and
- to recognise you when you return to the Site.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will always act with extreme care and in accordance with the General Data Protection Regulation.
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We will also ensure that such third party companies are compliant with the General Data Protection Regulation.
HOW WE USE YOUR PERSONAL DATA
We use the Personal Data we hold about you in the following ways:
- to ensure that Content from the Site is presented in the most effective manner for you and for your computer;
- to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- to carry out our obligations arising from any contracts entered into between you and us;
- if you place an order with us, we will send your credit card and billing information to your specified credit or debit card provider;
- we may use your personal information to ask for your feedback on the Services or to ask you to participate in surveys;
- to allow you to participate in interactive features of the Service, when you choose to do so;
- as part of our own internal analytics program
- to notify you about changes to the Service;
- if you are an existing customer, we may contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you; and
We may provide our advertisers with aggregate information about our users. We may also use such aggregate information to help advertisers reach a certain audience However, we do not disclose information that could be identified as belonging to specific individuals.
From time to time we may request permission to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. Such requests will be specific and will be one time requests.
In addition we may ask you to complete surveys or give feedback that we use for research purposes, although you do not have to respond to these.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985.
We may disclose your Personal Data to third parties as follows:
- in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
- if Pure Solo or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets;
- to third party data processors with whom we have a Agreement for the internal analysis of general data (for example Google Analytics), such data processors to be fully compliant with GDPR and unable to share data externally.
In the event of any of the transfers of information outlined above, your rights under the General Data Protection Regulation will not be affected.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
ACCESSING YOUR INFORMATION
The EU General Data Protection Regulation (EU) 2016/679 gives you the right to access all information we hold about you. Your right of access can be exercised in accordance with the Regulation by writing to us at firstname.lastname@example.org and any access request will be addressed within 30 days of receipt.
YOUR PROFILE AND PRIVACY SETTINGS
You can protect your privacy by using the privacy settings we offer on the Site. These settings allow you to make your profile accessible only to your approved list of contacts. However, please bear in mind that any personal information you choose to include in your profile, such as your email address, telephone number, videos, photographs and comments, you include at your own risk.
Any information which you post in any public areas of the Site, such as weblogs, message boards and forums, can be accessed by the general public. We recommend that you are careful about what personal information you reveal in these areas as you do not know who may read and use this information for their own purposes, including in order to send you unsolicited marketing communications.
While you can choose to make your profile accessible to people who are not registered with the Site, we advise you to be cautious about sharing your personal information with people that you do not know, and if you choose do so you should make sure that your profile does not include any personal contact information.
You can change any details in your profile and adjust your privacy settings at any time. If you need any assistance with this, please contact us.
LINKS TO THIRD PARTY SITES
The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. ‘Email A Friend’
We may from time to time operate an ‘Email a friend’ service. This is a referral service, designed to make it easy for customers to recommend the Site and related websites or offers to a friend, and is a two-step process. First, you send us your friend’s name and email address, and secondly, we contact the friend, telling them who we are, and inviting them to take advantage of a particular offer, or to visit the Site.
When we contact your friend, we always advise them of the name and email address of the friend who made the original referral. We will not use your friend’s details for any other purpose.
Otherwise you are not eligible to use the Service and must not attempt to register with the Site .
If we become aware that we have collected any personal information from any person under the age of 16 without the consent of their parent or guardian, we will delete this information as soon as possible.
You may cancel your registration with the Site at any time by notifying us using the contact details given on the contact us page on the Site.
When we receive notice of cancellation from you, we will endeavour to delete any of your Personal Data we hold as soon as possible, unless there is a legitimate reason for us to retain this information.
GOVERNING LAW AND JURISDICTION