We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, hengemusic.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
1.1 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 Site;
- “Cookie Law” – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003
2. What Does This Policy Cover?
3. What is Personal Data?
3.1 Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
3.2 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.
4. What Are My Rights?
4.1 Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 12 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 14 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 have. Please contact us using the details in Part 14 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 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).
4.2 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 14.
4.3 Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
4.4 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.
5. What Data Do We Collect?
- Email address;
- Telephone number;
- Business name;
- Payment information;
- IP address;
- Web browser type and version;
- Operating system;
6. How Do You Use My Personal Data?
6.1 Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, and/or because it is in our legitimate business interests to use it. Your personal data may be used for any of the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by following the unsubscribe link in marketing emails we send to you, or by contacting us via our contact form at https://hengemusic.com/contact-us/.
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
6.2 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 with information, news, and offers on Our products. 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 GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
7. How Long Will You Keep My Personal Data?
7.1 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 the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- We’ll only hold on to your information for as long as you are a customer. If you haven’t logged onto our website for three years, we will delete your personal data from our systems. If you’re subscribed to our email list, we’ll ask you if you want to re-subscribe three years after your original subscription date unless you have opted-out in the meantime.
- Where reasonably necessary or required to meet our legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms & Conditions, if you have purchased goods from Our Site, we may also keep hold of some of your personal data for up to seven years even after you have closed your account or it is no longer needed to provide the services to you.
8. How and Where Do You Store or Transfer My Personal Data?
8.1 We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows:
- We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
- Where we transfer your data to a third party based in the US, we ensure they subscribe to the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
8.2 Please contact us using the details below in Part 14 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
9. Do You Share My Personal Data?
9.1 We may share your personal data with third parties for the following purposes:
- We may disclose your account data to our suppliers and delivery agents insofar as reasonably necessary for the supply and delivery of your purchased orders.
- We may share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
9.2 In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
9.3 If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
9.4 If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
9.5 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.
10. How Can I Control My Personal Data?
10.1 In addition to your rights under the GDPR, set out in Part 4, when you submit personal data via Our Site, 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 marketing emails and at the point of providing your details when subscribing to our email list and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Can I Withhold Information?
11.1 To use all features and functions available on Our Site you will be required to submit or allow for the collection of certain personal data.
12. How Can I Access My Personal Data?
12.1 You can access most of your personal data, including your purchase order details held by us by logging into your account (if you’ve registered for an account on Our Site).
12.2 For a more detailed account of the personal data we hold 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 sent to the email or postal addresses shown in Part 14. We will respond to your subject access request within 28 days.
14. How Do I Contact You?
14.1 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:
Our website contact form: https://hengemusic.com/contact-us/.
Postal Address: 1 Burford Drive, Whalley Range, Manchester, M16 8FJ.
15.1 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.
16. Information About Us
16.1 Our Site is owned and operated by Merchant of Venus LTD.
Address: 1 Burford Drive, Whalley Range, Manchester, M16 8FJ.