7Wallace Music Limited’s Website Privacy Policy
At 7Wallace Music Limited, we are committed to respecting your privacy and protecting the personal information that we obtain and hold about you and others.
This Website Privacy Policy (“Policy”) explains how we will process the data relating to you that you provide us when you visit our website at 7wmusic.com(“Website”), or that we may collect from others about you when you visit our Website, our social media sites or in relation to any query or communication that you may send to us.
1. Introduction and General Terms
7Wallace Music Limited, a company registered under company number 08960712 with registered address at 10 Queen Street Place, London, EC4R 1AG (“7W”, “we”, “us” or “our” in this policy), works closely with emerging and upcoming talent to produce scripted and non-scripted film, television and digital content (“Services”).
Where we decide the purpose or means for the processing of the personal data that you provide when using our Website, we are the “data controller” for the purposes of the General Data Protection Regulation 2016 (“GDPR”) and the UK Data Protection Act 2018.
Our Website may contain hyperlinks to third party websites, such as links to our Facebook, Instagram, Twitter and other social media sites. These websites operate fully independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our Website is not an endorsement. Should you use any of these websites, such use is at your own risk and we would recommend that you review their respective privacy policies.
2. How We Use Your Personal Data
Contacting Us (Your Enquiries and Requests)
If you contact us via our Website ‘Contact’ webpage about our Services, to make an enquiry (such as in relation to project work or employment in our company or for any other purposes, the webpage asks you to provide a limited amount of personal information about yourself, such as your name, email address, subject (e.g. purpose of your message) and your message or enquiry. We will use this information to respond to your enquiries, for example:
· In line with the legitimate interest we have in promoting our business, we will process your enquiries to reply to your query, including providing you with information about the Services we offer.
· We may also respond to your enquiries or requests by taking steps in relation to your specific query or request, such as providing materials about some of our diversity and inclusion initiatives and opportunities, the festivals which we support and are involved in, or entering into an agreement to provide you with our Services.
You are under no obligation to provide us with any details, but if you choose to not provide us with relevant information, we may not be able to respond and/or provide the assistance that you request.
Mailing List
If you ask to be added to our mailing list, we will keep you updated with information on news, updates, new projects via email. If you would like to be removed from that list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive.
In line with the legitimate interest we have in promoting our business, we will use the email address you gave us via our Website to provide you with this information.
There may also be circumstances where we will ask you for your prior consent in respect of our use of your personal data or where we may rely on an alternative lawful basis to process your personal data in which case you will be notified at the time.
Information obtained from Third Parties
We may obtain and store personal information about you that we collect from third parties (including our talent, booking and PR agents, trade bodies, forums or community groups) or social media websites (such as Twitter, LinkedIn, Facebook and/or Instagram) for the legitimate interest of carrying on our business. We do so to enable us to improve our communications and reach out to the optimum audience in order to make our initiatives and projects a success for 7W, our partner organisations and supporters and for the undiscovered talent that we seek to support.
If we do receive any personal information about you from these third parties, including the social media platforms, we will not process your information for the purposes of direct marketing unless you have provided your consent or it is otherwise lawful for us to do so.
If you would like us to delete the personal information that we have received about you from these social media sites, please email us at DPO@7wmusic.com. If you do not want us to receive further information about you from these sites, you should contact the sites directly to turn off the ‘follow’ setting.
We may occasionally collect special categories of personal data (i.e. more sensitive personal data) about you. If and when we do so, we will ensure that we do so under a lawful basis which may require obtaining your prior consent to collect (and share) this information.
How You Use our Website (Analytics & Cookies)
Our Website uses cookies and other similar mechanisms to collect log and analytical information, such as your internet protocol (IP) address, location and browser type, to help us to analyse how visitors use the Website.
To find out more about Google Analytics and to learn how to opt out, please visit:
When you visit our Website, these analytics service providers may collect the following data, which will almost always be anonymised and aggregated before reporting back to us:
· number of visitors to our Website
· pages visited while at the Website and time spent per page
· page interaction information, such as scrolling, clicks and browsing methods
· websites where visitors have come from and where they go afterwards
· page response times and any download errors
· other technical information relating to end user device, such as IP address or browser plug-in
We process this information to understand how visitors use our Website, to evaluate and improve our Website, to make our Website more accessible and to compile statistical reports regarding that activity. For example, your IP address may be used to approximate the country from which you access our Website, and we would aggregate this information together so we know, for example, that visitors to our Website come from a specific territory. The information collected by data analytics is not used by us to develop a personal profile of you.
We or other companies may use cookies to suggest and deliver content which we believe may interest you. Some of our webpages may use plug-ins from other organisations (such as Google and Facebook). These other organisations may use information about your visit to our Websites on their pages. For more information on how these organisations use information, please read their privacy policies and/or terms and conditions.
The processing of any of your personal data is necessary for us to pursue our legitimate interests in improving our Website, and providing a better service and source of information to our Website visitors.
You can always choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
For further information about cookies and how to adjust your browser settings, please see:
· www.allaboutcookies.org/managecookies
All content you submit to us
If you send us objectionable content or otherwise behave in a disruptive manner when using our Website, we may process personal data included in your messages to respond to and stop such behaviour.
· We only process personal data in this way for the legitimate interests of ensuring that use of our Website is lawful, does not disrupt our systems, does not harass our staff or other individuals, and to enforce our legal rights and to comply with our legal obligations.
· Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
Where we process personal data in this way, we will hold that personal information on our systems for as long as is reasonably necessary to achieve these objectives.
3. Do We Share Your Personal Data with Anyone Else?
We keep your information confidential, but may disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this privacy policy, including for the performance of contracts and in line with our legitimate interests in regard to conducting our business as a film, television and digital content production company. If we provide your personal information to third parties, we shall only do so provided that they do not make independent use of the information and provide the same confidential treatment as we do.
We only permit them to process your personal data for specified purposes and in accordance with our instructions. All our third party service providers are required to take appropriate security measures to protect your personal information in line with our policies. Activities which are carried out by or in collaboration with third party service providers include talent provision, public relations, website hosting and our IT support.
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the information we hold may be included as part of that sale, in which case you will be notified via email and/or a prominent notice on the Website of any changes in ownership or use of your information, as well as any choices you may have regarding that information.
Except as provided above, we will not provide your information to third parties.
4. Your rights in relation to your personal data which we process
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests by you:
· for a copy of data we are processing about you and/or to have inaccuracies corrected;
· to restrict, stop processing, or to delete your personal data;
· for a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
· to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/
To make a request in relation to any of the aforementioned rights, please send your requests to DPO@7wmusic.comor write to our Data Protection Team at 10 Queen Street Place, London, EC4R 1AG.
5. Children
We do not use the Website to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at DPO@7wmusic.com.We will delete such information within a reasonable time.
6. Security
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Website and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal information with us, you accept the aforesaid and provide your information at your own risk.
7. International Data Transfers
Our servers are located in the European Union and the information that we collect directly from you will be stored in these servers. We may also transfer your personal data to members of our third party service providers, many of whom may be located outside of the EU, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EU.
There are agreements in place with all of our third party service providers, including our talent and PR agents in the United States, to ensure that those parties process personal data using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses.
If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this policy, please let us know by emailing us at DPO@7wmusic.com.
To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
8. Retention Periods or Criteria
We will hold your personal information on our IT systems or hardcopy files for as long as is necessary for the relevant purpose for which that personal information was obtained, or as otherwise described in this privacy policy.
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 requirements.
If you would like us to stop using or holding your personal information and/or would like to request its deletion, please email us at DPO@7wmusic.com.
9. Changes
This Policy may be updated from time to time. We will notify you of any changes by posting the new policy here and, where feasible, by letting you know by email.
10. Contact Us
Questions, comments and requests in relation to this Policy are welcome and should be addressed to DPO@7wmusic.com.
Last Updated: August 2018