PRIVACY POLICY
Last updated on 4th October 2024.
Introduction
Please take the time to read this privacy policy, which contains important information about the way in which we process and protect personal data.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a copy of the policy here.
1. IMPORTANT INFORMATION AND WHO WE ARE (paragraph 1)
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)
3. HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)
4. HOW WE USE YOUR PERSONAL DATA (paragraph 4)
5. DISCLOSURES OF YOUR PERSONAL DATA (paragraph 5)
6. INTERNATIONAL TRANSFERS (paragraph 6)
7. DATA SECURITY (paragraph 7)
8. DATA RETENTION (paragraph 8)
9. YOUR LEGAL RIGHTS (paragraph 9)
10. CONTACT DETAILS (paragraph 10)
11. COMPLAINTS (paragraph 11)
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (paragraph 12)
13. THIRD PARTY LINKS (paragraph 13)
1. IMPORTANT INFORMATION AND WHO WE ARE
This privacy policy gives you information about how we collect and use your personal data through your use of our websites (including https://songpact.com/ and https://app.songpact.com/) and our sub-domains, including any data you may provide when you register with us, subscribe to our service, purchase a product or service, sign up to our newsletter, or report a problem with our website.
This websites are not intended for children and we do not knowingly collect data relating to children.
IF YOU DO NOT AGREE WITH THIS POLICY, DO NOT ACCESS OR USE OUR SERVICES OR INTERACT WITH ANY OTHER ASPECT OF OUR BUSINESS.
Controller
This policy is issued on behalf of the Songpact Group so when we mention “we”, “us” or “our” in this policy, we mean all the companies and businesses that make up the Songpact Group from time to time, including their respective parent companies and subsidiaries. This includes Songpact Ltd.
For the purpose of the Data Protection Act 2018 and the UK General Data Protection Regulation (UK Data Protection Legislation), Songpact Ltd of 59 St Martin’s Lane, London, United Kingdom, WC2N 4JS will be the data controller and shall be responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights in accordance with paragraph 9 below, please contact the DPO using the information set out in the contact details in paragraph 10 below.
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, middle name(s), last name, any previous names, any professional names, username or similar identifier, title, job title/role, date of birth and gender.
- Contact Data includes billing address, home address, registered office address, email address and telephone numbers.
Financial Data includes bank account and payment card details (processed by Stripe). - Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Songpact Group’s online services and its websites.
- Profile Data includes your username and password, details of the products and/or services used by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you interact with and use our website, products and services, including content you viewed or searched for, length of visit to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
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.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, secure messaging or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our websites;
- subscribe to our services or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our websites and services, we will also collect Technical, Transaction and Usage Data. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We will also receive personal data about you from various third parties as set out below:
- Technical Data is collected from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe Payments UK Ltd. based inside the UK or its affiliates outside the UK.
- Identity and Contact Data is collected from data brokers or aggregators.
- Identity and Contact Data is collected from publicly available sources such as Companies House in the UK.
4. HOW WE USE YOUR PERSONAL DATA
Legal basis
The law provides that we are only allowed to process your personal data (which includes storing it and sharing it with other companies) if we have a legal basis for doing so. We will always rely on one or more of the following legal bases for processing your personal data:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that the platform can include that address in the documents it generates. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal or regulatory obligations: We may use your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Direct marketing
During the sign-up process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at customercare@songpact.com.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations for updates to our Terms of Service, checking that your contact details are correct.
Cookies
We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website.
Our website may from time to time use cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data to third parties in limited circumstances, including.
.
- When we use sub-contractors, vendors and service providers to assist us in meeting business or operating needs, such as hosting our websites, communicating with users, delivering and improving our services, e-mail communication, invoicing and payments, customer support services and analytics. These service providers may only access, process or store your personal data pursuant to our instructions and to perform their duties to us, and in accordance with applicable laws and regulations.
- To third parties to whom we may choose to (or may prospectively) sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If Songpact is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your personal data to a third party as part of or in connection with that transaction. Upon such transfer, the privacy policy of the acquiring entity may govern the further use of your personal data. In all other situations your data will still remain protected in accordance with this privacy policy (as amended from time to time).
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example to the police, the courts, or any relevant regulatory body), or in order to enforce or apply our terms of business and other agreements.
Where necessary to protect the rights, property, or safety of us, users of our websites, or others.
When you have given us your explicit consent to share your personal data.
We may disclose your personal information to our affiliate companies. We may also share data with organisations with which we are working jointly.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We transfer and share your personal data within the Songpact Group, and your information may be stored and processed in the UK, Australia and/or any other countries or jurisdictions where the Songpact Group has facilities.
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK, we will ensure that a similar degree of protection is afforded to it by putting in place a contract with the data recipient incorporating standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8. DATA RETENTION
How long will we keep your personal data?
We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 (Your Legal Rights) below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using our contact details (paragraph 10 below).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. CONTACT DETAILS
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO in the following ways:
Email address: DPO@songpact.com
Postal address: 59 St Martin’s Lane, London, United Kingdom, WC2N 4JS
11. COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using our contact details in paragraph 10 above.
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review and may change it from time to time. If we do so, the latest version will always be made available on our websites and will become effective immediately.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
13. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
