In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Website;
“Cookie” means a small text file placed on your computer or device by Our Website when you visit certain parts of Our Website and/or when you use certain features of Our Website. Details of the Cookies used by Our Website are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Our Website is owned by Hipgnosis Songs Fund Limited (the “Company”) and operated by The Family (Music) Limited (the “Investment Adviser”) as data controllers, a limited company registered in England and Wales with company number 11425132.
Registered address: 3rd Floor, 5 Chancery Lane, London WC2A 1LG
Main trading address: United House, 9 Pembridge Road, Notting Hill, London W11 3JY
VAT number: GB302748518
For any queries, please contact Andy Sheppard at:
Telephone number: +44 (0)20 3828 7664
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. By sending us an email, you are giving us consent to use your data, until such as time as you tell us not to.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for up to six months unless you ask us to delete it.
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
We will not share any of your personal data with any third parties. We may share your personal data within the Hipgnosis Group of Companies.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
You may access Our Website without providing any personal data at all.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
All Cookies used by and on Our Website are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Website may not function fully or as intended.
Certain features of Our Website depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following Cookies may be placed on your computer or device:
|AWSALBCORS||BrighterIR||7 days||Click here for further information on privacy at BrighterIR|
Our Website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Website is used. This, in turn, enables us to improve Our Website and the services offered through it.
The analytics service used by Our Website use the following Cookies:
|_ga||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||2 years||Click here for further information on privacy at Google|
|_gat||Used by Google Analytics to throttle request rate.||1 day|
|_gid||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||1 day|
|collect||Used to send data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.||Session|
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Name: Andy Sheppard
Email address: email@example.com
Telephone number: +44 (0)20 3828 7664
Postal Address: The Family (Music) Limited, United House, 9 Pembridge Road, London W11 3JY
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.