PRIVACY AND COOKIE POLICY

Last updated 4 June 2018


WHO WE ARE
This privacy and cookie policy explains the data protection practices of Sony Music Entertainment Denmark A/S. Sony Music Entertainment Denmark A/S, company number 12 25 94 84, Vognmagergade 7, 6. Sal, 1120 København K is data controller for the processing of personal data described in this privacy and cookie policy. Where we refer to "Sony Music", “Sony Music Entertainment” “us” or "we", we mean Sony Music Entertainment Denmark A/S (or any Sony Music Entertainment entity using your data in accordance with this policy).

We are committed to protecting and respecting your privacy and the following sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the text carefully to understand our views and practices regarding your personal data and how we will treat it.


KEY POINTS

  • We use personal data to allow you to use the features in the content, to process your registration, and to provide you with requested content related to our music and other offerings.
  • Our main and artist websites provide interactive features that engage with social media sites, such as Facebook and Twitter. If you use these features, these websites will send us personal data about you.
  • Most of our content is not designed for children. We do not knowingly collect personal data of children under the age of 13 and may ask for your age before you can sign up to newsletters or to use our content.
  • If you give us permission, we will send you news and promotional material about Sony Music, including our artists. You can change your mind about this at any time and ask us not to process your personal data for direct marketing purposes, including profiling related to direct marketing. You can ask us to stop processing this data at any time. This can be done by unsubscribing the service directly in the mail or by sending an email to supportdk@sonymusic.com. Learn more about your wider data protection rights and how you can exercise them below.
  • We disclose your personal data publicly when you post content via our websites or apps. We disclose personal data when you agree that we can share data with business partners or other Sony group companies. We also share data with artists where you consent to marketing and third parties we engage to process data on our behalf or when such sharing is required by law, or in certain other situations.
  • We may transfer certain personal data to the United States and to other countries outside the EEA. In such cases, Sony Music always ensures the correct legal basis for the transfers.
  • We use cookies and other tracking technologies to personalize content and advertising and to make our content function better. To learn about our use of tracking technologies see below.


A SPECIAL NOTE TO CHILDREN UNDER 13 YEARS OF AGE
YOU MUST BE 13 YEARS OF AGE OR OLDER TO REGISTER WITH OUR WEBSITE(S). PLEASE DO NOT REGISTER IF YOU ARE UNDER 13 YEARS OF AGE.


A SPECIAL NOTE TO PARENTS
We do not allow children under the age of 13 to register, and parents should supervise their children’s Internet activity and use the parental control tools that online services and software manufacturers offer, and which helps to ensure a child-friendly Internet environment. These tools can also prevent children from disclosing their name, address and other personal data without parental permission.


HOW WE COLLECT YOUR DATA

(a)        From you
In some cases, we collect and process personal data relating to you if you send such personal data to us by filling in forms on our websites or if you contact us. This includes, but is not limited to, data that you provide when you register to use (or become a member of) our websites, subscribe to services (e.g. newsletters), purchase downloads, forward materials or order additional services.

(b)       With the help of cookies and other tracking technologies
We also use technology on our websites to collect data that helps us improve your online experience. We refer to this technology as “cookies” in this policy, but it also includes all similar technologies, including web markers, log files, pixel tags, GIF’s, etc. Cookies are text files that contain small amounts of data that is downloaded to your device when you visit a website. Cookies then transmit back to the original website on each subsequent visit or to another website that recognises the cookie. Cookies are useful as they allow a website to recognise a user’s device. You can read more about our use of cookies below.

Sometimes, we receive data about you from third parties. For example, if you use a "like" or a "share" button for a feature on our websites or apps, then the third party will share data with us. If you participate in activities on other websites or apps - such as participating in a Facebook application - you may allow us to have access to personal data held by Facebook, or other site or app owners.

If we provide online services to a child where we need parental consent for this, we may ask for a parent's email address, in order to ask for consent.


HOW WE USE YOUR DATA
We use personal data collected via our services for the following purposes:

  • To fulfil a contract, or take steps linked to a contract, cf. Data Protection Regulation art. 6(1)(b);
    1. To process your registration on one of our websites or apps, or entry to any competition we run.
    2. To send you information about changes to our terms or policies.
  • Where this is necessary for purposes which are in our, or third parties, legitimate interests, cf. Data Protection Regulation art. 6(1)(f). These interests are:
    1. To provide you with access to content and features in the websites and apps.
    2. To send you information you have requested.
    3. To ensure the security of our websites and apps, by trying to prevent unauthorised, malicious activities or similar actions that may result in a security breach.
    4. To enforce compliance with our terms of use and other policies and to help other organisations (such as copyright owners) to enforce their rights.
  • Where you give us consent, cf. Data Protection Regulation art. 6(1)(a):
    1. Where you have given us your consent to receive marketing information
    2. Where you allow us to share your data with third parties so they can send you marketing, such as artists.
    3. Where you give us consent to place cookies and to use similar technologies.
    4. Where we need parental consent to provide online services to children under 13
    5. On other occasions where we ask you for consent, for a purpose which we explain at that time.
  • For purposes, which are required by law cf. Data Protection Regulation art. 6(1)(c):
    1. In response to requests by government or law enforcement authorities conducting an investigation.

 
HOW WE SHARE YOUR DATA
Subject to the other terms of this policy, we may share your personal data with the following parties:

  • Group companies
    We may share your personal data with our affiliated or group companies worldwide for the purposes listed above. Where you give your permission via the registration process, we will also share your personal data with other Sony affiliates for them to use for direct marketing.
  • Artists
    Where you have consented to direct marketing, we may also share your personal data with those artists (and their management companies) that you have expressed an interest in, who may then use your data to keep you updated with information about them.
  • Other third parties
    We may transfer, sell, assign personal data to third parties in connection with the sale, merger, consolidation, change in control, transfer of substantial assets, reorganisation or liquidation of Sony Music, or any part of it.

    We may share with others, at our discretion, certain aggregate statistical data about purchases and the use of our content, which data may include demographic data such as the age range and/or geographic location of groups of users. No personal data (such as names or email addresses) will be identifiable from such statistics.
  • In special circumstances
    We may disclose personal data in special cases when we have reason to believe that disclosing this data is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the rights or property of those described above in paragraph (a) or (b). We may also disclose your personal data if we in good faith believe that it is required by law.
  • Suppliers
    If you register for a promotion, such as a competition, prize draw or contest, which is administered by a third party, your personal data will be disclosed to the organiser for them to administer the promotion. This may also mean that your personal data will be included in a winners list.

    We share data with third parties who perform functions on our behalf, such as hosting or operating our websites and apps, sending e-mails, and carrying out data analysis.


INTERNATIONAL TRANSFER
The data that we collect may be transferred to, and stored at, a destination outside the EU/European Economic Area ("EEA"), e.g. the United States of America.  If any of our servers are located outside the EEA, if we transfer data to one of our Sony Music entities or if one of our service providers or suppliers is themselves located in a country outside the EEA,  , and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission,  data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. 

COOKIES AND OTHER TRACKING TECHNOLOGIES

What is a cookie?
Cookies are used in almost all websites today and are often necessary for the service and the performance of the website.

Cookies are text files containing small amounts of information, which are downloaded to your device (PC, tablet, smartphone, etc.) when you visit a website for the device to be recognised. Cookies can, among other things, be used to compile statistics about users' use of the website and to optimize the content of the page. A cookie is a passive file and cannot collect information from the user's computer or spread computer viruses or other malware. Some cookies are placed by other parties (so-called third parties) than the one in the address bar (URL) of the browser. It can be common content, but also analytics or embedded comments. This means that cookies are stored from other parties than the owner of the webpage. Cookies are useful because they allow a website to recognise a user's device. 

The information we collect may include IP-addresses, browser version, number of visits, which pages you access and your viewing preferences. Information on the cookies that we use can be found here:

http://tools.sonymusiccreative.com/privacy/SME_UK_CookieGrid.pdf

We use the following categories of cookies on our website:

Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like any shopping basket items cannot be provided. We don’t use these cookies to gather data about you that could be used for profiling, advertising or remembering where you've been on the internet.

Category 2: Performance Cookies
These cookies collect information on how visitors use our website. For example, which pages visitors go to most often, and if you get error messages from web pages. These cookies do not collect data that identifies you as a visitor. All data these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Category 3: Functionality Cookies
These cookies remember choices you make such as the country you visit our website from, language or the region you are in. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The data these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Category 4: Targeting cookies or advertising cookies
These cookies collect data about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign.  The cookies are usually placed by third party advertising networks with the website operator's permission.  They remember the websites you visit and that data is shared with other parties such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

Category 5: Social Media Cookies
These cookies allow you to share what you have been doing on the website on social media such as Pinterest, Facebook and Twitter. These cookies are not within our control.  This data may be linked to targeting/advertising activities. Please refer to the respective social media’s privacy policies for how their cookies work.

Cookies within the above Categories may include those shown on the table (http://tools.sonymusiccreative.com/privacy/SME_UK_CookieGrid.pdf) together with their respective website locations showing you how to opt-out of them.


Use of Web Beacons
Some of our web pages may contain electronic images known as web beacons, among other things, that allow us to count users who have visited these pages. Web beacons collect only limited data including a cookie number, time and date of a page view, and a description of the page on which the web page resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable data and are only used to track the effectiveness of a particular campaign.


Consent to Cookies
In order to place cookies on your device, we require your consent. Please note that if you continue to browse the website, you will be considered to have agreed to our use of cookies.

If you want to withdraw your consent by removing or avoiding cookies, please refer to the section below.

How are cookies removed/avoided?
You can withdraw your consent to our use of cookies at any time.

If you do not wish to receive cookies, you can change the settings in your browser so that it informs you when cookies are being placed, or you can reject all cookies. You can also delete cookies that have already been placed.

If you wish to restrict or block web browser cookies , which have been placed on your device, then you can do this through your browser settings. The Help function within your browser should tell you how.  However, please note that if you select such settings you may be unable to access certain parts of our website or certain content or functionality may not be available. It depends on your browser how you remove or avoid cookies. If you use a PC, cookies can be removed by using [CTRL]+[SHIFT]+[Delete]. If this does not work or if you use a MAC, please use the link for the browser you use below:

 Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.

If you would like to opt out of our or other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It means that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.


YOUR RIGHTS
Wherever we rely on your consent, you will always be able to withdraw that consent. This can be done by contacting us as specified below. If you withdraw your consent, we will stop processing your personal data, unless we are entitled to or obliged to continue processing or storing your personal data on any other basis, including under applicable legislation.

The withdrawal of your consent does not affect the legality of the processing that has taken place before the withdrawal.

You have the right to gain access to the personal data we process about you, with certain exceptions provided for by law. In addition, you may object to the collection and further processing of your personal data. You also have the right to rectification of your personal data or to ask us to limit the processing of your personal data.

Following your request, we will delete the personal data we have registered about you without undue delay unless we can continue the processing on another basis, for example, if the processing is necessary to determine a legal claim or if necessary to answer a request from you.

In certain circumstances, you may also request us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format, and request that we transmit the data to another data controller (data portability).

If you wish to make use of your rights as described above, you are welcome at any time to contact us as specified below.

In connection with your rights queries we ask that you provide us with sufficient information for us to process your query, including your full name and email address, in order for us to identify and respond to your request. We will reply to your query as soon as possible.


HOW DO I GET IN TOUCH?
We hope that we can satisfy queries you may have about the way we process your data. If you would like to opt out of direct marketing, please contact us via supportdk@sonymusic.com.

If you have complaints regarding the processing of your personal data please contact Legal & Business Affairs on persondata@sonymusic.com. You can also file a complaint with Datatilsynet, Borgergade 28, 5, 1300 Copenhagen K, phone 33 19 32 00, e-mail dt@datatilsynet.dk.


HOW LONG IS MY DATA STORED?

We will delete your personal data when we no longer need to process them to fulfill one or more of the purposes stated above. However, special laws, including our obligations and rights laid down in the Danish Bookkeeping Act and the Danish Limitation of Claims Act, may give us the duty or the right to store them for a longer time. The data can also be processed and stored for longer if they are anonymised.

Where we process data in connection with your registration to use our websites, we do this for as long as you remain an active user of our websites.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for the shortest period possible after this (to allow us to implement your requests). However, we will keep a record of your request for documentation purposes.

OTHER WEBSITES
Our website may contain links to other websites, which are outside our control and are not covered by this privacy and cookie policy. If you access other websites using the links provided, the operators of these websites may collect and process data from you in a way, which is different to how we do so.


CHANGES TO OUR PRIVACY AND COOKIE POLICY
We may modify, alter or otherwise update this privacy and cookie policy at any time. We will indicate any changes by updating the date at the top of the policy. We encourage you to review this policy from time to time.