2. Data Controller, Data Controller’s Representative, Data Protection Officer
i. The Data Controller controlling the means of processing of your personal data and the purposes of such processing is:
Secure Arts Limited (trading as Cright)
Registered in UK with company number 04868437
Registered office address: 5 Technology Park, Colindeep Lane,
London, NW9 6BX.
Tel: +44 208 962 3000
ii. Where one of the Cright group companies is responsible for processing personal data outside the EU, Secure Arts Limited registered in UK is its EU representative.
iii. Cright’s data protection officer can be contacted as follows:
Tel: +44 208 962 3000 and ask for the DPO.
3. Purpose of the Processing and the Legal Basis for the Processing
We gather two types of information in the operation of this website:
1. Personal Data:
We collect information from you when you register on our site, place an order or fill out a form. This may be as an administrative user (any employee, agent or subcontractor of Cright’s record company customers who may use and access CRight Services to perform administrative functions) or as an end user (persons of our record company customers’ choosing throughout the World and who are authorized by our customers to access and use the Services, including radio stations, journalists, buyers, DJs, record label employees.) In most circumstances, Cright is Data Processor processing your Personal Data pursuant to a record company’s written instructions and it is the record company which is your Data Controller. In such circumstances, any queries that you may have in respect of your Personal Data may be directed in the first instance to the relevant record company.
When ordering or registering on our site, through the “Contact Us” pages or any other area where you may send emails, submit your CV, request newsletters / blogs or provide feedback, you may be asked to enter your: name, e-mail address or credit card information as appropriate. This information will only be used by us in accordance with the terms herein and you will be asked clearly to tick consent to our processing of necessary categories of Personal Data, for each contractually agreed purpose we are to provide. This will enable you to participate in interactive features of the Service and notifying you about changes to the Service. The provision of your Personal Data is voluntary. However, it is also necessary to enable us to fulfil our contractual obligations with record companies. Therefore if you do not provide us with the required Personal Data, we may not be able to provide you with the Service you requested.
2. Non-Personal Data:
We may collect information about your visit to and use of this site, including sales data, traffic data and related site information. This information helps us to evaluate and improve our site and may also be used for investment analysis purposes. As Non-Personal Data does not personally identify you, we may use it for any purpose.
4. Categories of Personal Data
4.1 With a few exceptions, this information is limited to the kinds of information that are necessary to complete a contract with us. We may ask you for your:
4.2 What We Use Your Information For
We, and the third party providers to you of User Files, collect information from you which may be used to:
|Process and administer your Personal Information and process transactions, fulfil your requests, orders and/or to provide other information you requested. Where you have subscribed to a third party service and we are providing that service or User Files to you on behalf of that third party, we shall process Personal Data in accordance with that third party’s instructions, as controlled by them and as agreed with you. We require this Personal Data in order to be able to complete our contractual obligations to them and in turn their obligations to you|
|Complete delivery of your order. We require this Personal Data in order to be able to complete our contractual obligations to you and to the record companies uploading User Files.|
|Retain order details for repeat orders and/or when you open an account with us and where you request us to do so|
|Personalize your experience|
|Improve our website and app and make the website and app easier for you to use|
|Improve customer service|
|To respond to your enquiries or comments submitted through our website|
|Send periodic emails (Please see Direct Marketing below)|
|Notify you about important news or blogs concerning our products, industry updates, events, promotions and competitions, reports and other information|
|Match Personal Data with third party data. Also, we may keep track of what portions of the website and app users are visiting and other user statistics, and aggregate this information to help us create a better experience for users of our website. This is all done in order to describe our products and services to prospective partners, advertisers, and other third parties, and for other lawful purposes.|
CRight may collect, use and disclose interactions by you with the uploaded content, for sharing with its record company customers
Promote our products and services on our website, app and third party partners’ websites
|Provide you with information about products and services that you request from us or, where you have consented to be contacted, for such purposes which we feel may interest you|
|To obtain your feedback|
|To permit applications for employment with us and related activities to such applications|
|Create statistical reporting regarding our web activities|
In addition, in order to carry out our lawful activities and for legitimate purposes, we may collect and process your Personal Data to:
Allow you to use interactive features on our website or applications
Retain a record of incoming and outgoing communications (e.g. email)
Protect the security and integrity of the website and app
Prevent and detect fraud or other prohibited or illegal activity
In response to a court order, request for cooperation from a law enforcement or other government agency
To establish or exercise legal rights
To bring or defend legal claims
For responsible corporate governance or as otherwise required or permitted by applicable laws and/or regulations
In circumstances in which we believe disclosure is appropriate in connection with fraud prevention and prevention of other illegal, or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations
To protect and defend the rights, property or safety of Cright and/or other companies in the Cright group, its/their investors and other clients, staff, and/or service providers.
We continually strive to improve our website offerings based on the information and feedback we receive from you. Your information helps us to respond more effectively to your requests and support your needs. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
5. Your Rights in respect of your Personal Data:
This Privacy NoticePolicy is intended to provide you with information about what Personal Data Cright collects about you and how it is used. If you have any questions, please contact us at firstname.lastname@example.org. If you wish to confirm that CRight is processing your Personal Data, or to have access to the Personal Data we may have about you, please contact us at email@example.com.
You have various rights in respect of your Personal Data which can be summarised as follows:
- The right to be informed. Where Cright intends to collect your Personal Data, you have a right to consent or object to such collection for the intended purposes. In respect of each intended purpose you will be asked to tick box to indicate your consent to each intended purpose for processing of your Personal Data.
- The right of access. You may request to receive a copy of any Personal Data held by us, which personally identifies you. We may charge an administration fee to cover the cost of carrying out your request. We may ask you to verify your identity and for more information about your request.
- The right to rectification. We will correct or erase inaccuracies in the information we hold about you when we learn of the inaccuracy.
- The right to erasure. Personal Data may be erased if we do not have a legitimate reason for retaining the information.
- The right to restrict processing;
- The right to data portability;
- The right to object;
- Rights in relation to automated decision making and profiling. Cright does not carry out any automated decision making.
Please contact Cright in writing with any requests and provide verification that you are whom you say that you are.
You may withdraw your consent to your Personal Data being processed at any time (the opt out button is available next to the opt in button where you provided your consent). However, if you withdraw consent, we may not be able to provide you with the service you requested.
6. The Right to Lodge a Complaint with a Supervisory Authority
If you have a reason to complain about how your Personal Data has been controlled and processed by Cright, please in the first instance contact Cright and we shall endeavour to resolve your queries promptly. If you remain unsatisfied, you may lodge a complaint with:
Address: Information Commissioner's Office
Phone: +44 303 123 1113 or 01625 545 745
Please copy any such communication to us so that we can work to resolve any outstanding issues promptly.
7. Disclosure of Personal Data
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the product or Service requested.
We may also disclose Personal Data in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service, or may be causing injury to or interference with any of our rights or property, other users, or anyone else. We may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services. In addition, if we or our assets are acquired, your Personal Data will likely be transferred or disclosed in connection with such acquisition.
8. Direct Marketing
On occasion, we engage third parties to mail or send information to you, including items about products you may have purchased, or material from an event sponsor. We have a legitimate interest in processing of Personal Data for direct marketing purposes. We may send postal marketing about a new product; you may opt-out of this. In the context of a sale, we may have sought your consent for electronic marketing, but again you may opt out of this at any time by following the instructions in the marketing communication itself or by contacting us through this website.
9. Retention Period
We shall retain and store your Personal Data securely and for as long as necessary in order to fulfil our and our partners’ (where applicable) contracts with you. We shall then only retain Personal Data for as long as necessary to comply with our legal obligations under relevant law. After a transaction, your Personal Data (credit cards, financial information, etc.) will be kept on file in order to enable recurring billing depending on your subscription plan and thereafter until you Unsubscribe in your Accounts settings.
Where you have opened an account with us and requested that we retain your Personal Data, it shall be retained securely using appropriate technological and organisational measures whilst that account remains open, until you opt out of such storage and you request closure of the account.
For more information on where and how long your Personal Data is stored, and for more information on your rights of erasure and portability, please contact firstname.lastname@example.org.
10. How We Protect Your Information
We implement a variety of security measures to maintain the safety of your Personal Data when you place an order or enter, submit, or access your Personal Data. To help protect the privacy of data and personally identifiable information you transmit through use of this site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees privacy responsibilities.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers’ database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.
Our payment gateway provider is Level 1 PCI compliant.
11. Terms of Service and Cookies
11.1 Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website.
Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website.
13. Contacting Us
14. Access and Amend Your Information
In accordance with the Data Protection Acts, you may request to receive a copy of any Personal Data held by us, which personally identifies you. We may occasionally charge an administration fee to cover the cost of carrying out your request. We may ask you to verify your identity and for more information about your request.
We will correct or erase inaccuracies in the information we hold about you when we learn of the inaccuracy. Personal Data may be erased if we do not have a legitimate reason for retaining the information. You should include adequate information that you may have that will reasonably assist us in fulfilling your request(s). There is no charge for this service.
If you no longer wish to receive marketing-related e-mails from us, you may opt-out of receiving such marketing-related e-mails.
You should direct any requests relating to your Personal Data, or any other privacy questions, to security@Cright.com or to the address specified below:
Registered office address: 5 Technology Park, Colindeep Lane,
London, NW9 6BX.
Attention: Data Protection Officer
Once we receive your inquiry, we will comply with your request as soon as practicable and in any event within not more than 40 days of receipt of your request and verification that you are whom you say you are.