Last revision date: 17th May 2020
What does this policy cover?
This policy describes Sony/ATV Music Publishing, LLC and its affiliates’ use of your data. References in this policy to SATV, we or us shall mean Sony/ATV Music Publishing, LLC.
Please note that when you enter any sub-sites accessible through SATV Properties, such sub-sites may have their own specific privacy policies. Additionally, the properties of affiliated SATV companies, including some that are linked to/from the SATV Properties, may have different policies; therefore, please review the privacy policies on those properties if you visit them.
What information do we ask you to provide us?
With the exception of information related to establishing an account and login credentials for any of the SATV Properties, SATV does not generally require that you provide us with personal data in order to visit and use the SATV Properties. Please note that in order to participate in some activities, such as sweepstakes, contests and other promotions (collectively, “Promotions”) and social media, we may ask you to provide information that could reasonably be used to contact you or to identify you personally (such as your name, company name, title, e-mail address, mailing address and telephone number). SATV may also ask you to provide other information about yourself, which may include demographic information such as geographic region, age, etc., or certain information about your preferences and interests.
Therefore, the information that we collect from you and process may include:
- First name, last name, company name, and title
- Your log-in credentials for any of the SATV Properties
- Demographic information, geographic region etc.
- Your age/date of birth
- Contact information, such as email address, mailing address and phone number
- Your bank account details
- Marketing preferences, including any consents you have given us
We may offer opportunities to enter into Promotions, on our own or jointly with a third party. Such Promotions may require registration and the disclosure of both personal data and non-personal data. In the event that a Promotion is offered jointly with a third party, as a result of your participation in such Promotion, your personal data and non-personal data may be shared with such third party. This sharing will be disclosed to you at the time you provide your information. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other third parties connected to the Promotion to use your name, voice and/or likeness in advertising and marketing materials. Therefore always carefully read the rules of the Promotion before entering.
What information do we collect from you automatically?
In addition to any personal data or other information that you choose to provide to us via the SATV Properties, whenever you visit or interact with the SATV Properties, SATV may automatically collect certain information such as your IP address and/or another unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (“Device”) you use to access the SATV Properties and any referring property. (A Device Identifier is a number that is automatically assigned to your Device when you access a Website, mobile app or other digital property or its servers. The SATV Properties identify your Device by its Device Identifier).
SATV may also automatically collect information about your Device, such as the platform, operating system, or browser type for the Device you use to access the SATV Properties and any referring property.
Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the SATV Properties.
In addition, SATV, as well as certain third-party analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use the SATV Properties (“Usage Information”). Usage Information may include, in part, browser type, operating system, IP address, the content served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views.
Therefore, the information that we may automatically collect from you and process may include:
- Your IP address or another unique identifier, such as a Device Identifier
- Information related to your Device such as the platform, operating system, browser type, or physical location
- Your Usage Information such as the content served, the time at which the content was accessed and/or the time spent using the content, and the preceding content views
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
- As required for business purposes or to establish and fulfill a contract with you, for example if you license music from us or enter a Promotion. This may include verifying your identity, communicating with you and providing services relevant to our business.
- As required by SATV to enable our business and pursue our legitimate interests, in particular:
- we will use your information to provide services you have requested, and respond to any comments or complaints you may send us
- we monitor use of the SATV Properties, and may use your information to help us monitor, improve and protect our content, services and the SATV Properties, both online and offline
- we may use information you provide to tailor your experience on the SATV Properties or personalize our services for you
- to provide you with information about Promotions or other offerings that may be of interest to you
- to provide you with support and answer questions or other requests
- we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law
- we may use information you provide to investigate any complaints received from you or from others, about the SATV Properties or our services
- we may also use the information we collect to improve the SATV Properties and our content and services, for internal business purposes, and to contact you with regard to your use of the SATV Properties and, in our discretion, changes to any of our policies
- compliance with applicable laws and protection of SATV’s legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, and investigative purposes (including disclosure of such information in connection with legal process or litigation).
In addition, we may send you direct marketing in relation to our services, or other services provided by our affiliates and carefully selected partners. You will be able to opt-out of those materials by following the instructions in the communication.
Who will we share this data with, and where?
To Affiliates, Other SATV Companies and Third-Parties
SATV may share your personal data with companies affiliated with SATV (“Affiliates”)*, so that those Affiliates can (i) assist us with fulfilling your requests or improving our content, services or advertising; and/or (ii) contact you about other content, services or other offerings that may be of interest to you.
* Affiliates: meaning worldwide affiliate offices, agents and administrators that represent and work with SATV, such as sub-publishers, performance societies, licensees and local agents.
We may from time to time employ third parties to perform functions on our behalf, and thus, we may also share your personal data with third-party service providers that assist us with providing content, fulfilling your requests, improving our content, services or advertising, or otherwise performing services for SATV. As one example, if you access content or services that are published, developed or supported by an Affiliate or third party, your personal data may be shared with that Affiliate or third party for purposes related to that content or those services, including service administration and/or development. Additionally, we may share your information in order to host or operate the SATV Properties, for data analysis purposes, and for the administration of Promotions, such as in connection with winner selection and prize fulfillment.
When You Consent To Have Your Personal Data Shared or Otherwise Request That We Share Your Information
We may offer you the opportunity to consent to the sharing of your information with third parties, for example so you are able to receive information and/or marketing offers from third parties. Additionally, you may request, sometimes through your use of an interactive feature or third- party application, that we share personal data about you with a third party, and we will typically do so in those circumstances. If you consent or request to receive communications from third parties, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications.
We may share your personal data with Affiliates for internal reasons, primarily for business and operational purposes, including any corporate reorganization, restructuring or other corporate change. In addition, SATV or any of its assets, including the SATV Properties, may be sold, or other transactions may occur in which your personal data is one of the key business assets in the transaction. In such a case, your personal data may be one of the business assets we transfer. Hence, SATV reserves the right to disclose and transfer user information, including personal data, in connection with any activity and/or transaction described above.
Legal Protections and Law Enforcement
We may transfer and disclose information, including your personal data, (including Usage Information and Device Identifier (including IP address)), to third parties: (i) to comply with legal obligations; (ii) when we believe in good faith that the law requires it; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce our Terms & Conditions or other applicable policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of third parties, visitors to the SATV Properties or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies, in our discretion. Such disclosures may be carried out without notice to you.
Cookies & Other Tracking Technologies
Social Media Applications
Functionality on the SATV properties may permit interactions between third-party properties, such as enabling you to “like” or “share” content to third-party properties. If you choose to “like” or “share” content or to otherwise post information from or via SATV Properties to a third-party property, feature or application, that information may become public and the third-party property may have access to information about you and your use of the SATV Properties, including personal data.
You may also choose to participate in a third party application or feature (such as one of our Facebook applications or a similar application or feature on a third-party property) through which you allow us to collect and share (or the third party to share) information about you, including personal data. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. In addition, we may receive information about you if other users of a third-party property give us access to their profiles and you are one of their “connections,” or if information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third-party property or interactive service.
SATV uses commercially reasonable safeguards to help protect and secure your personal data, and we use reasonable efforts to obtain the agreement of our Affiliates and third-party service providers to take steps to protect the confidentiality, security, and integrity of personal data we share with them. However, no electronic data transmission or storage of information can be guaranteed to be 100% private and secure. Please be careful to avoid ‘phishing’ schemes, where someone may send you an e-mail that looks like it is from SATV asking for your personal data. You understand that any message or information you send to a SATV Property may be read or intercepted by others. SATV does not ensure or warrant the security of any information you transmit to us, and you use the SATV Properties and provide us with your information at your own risk.
How do we treat children’s personal data?
The SATV Properties are open to all individuals, though some Promotions may have age restrictions. We do not knowingly collect or permit the collection, storage or use of any personal data from anyone under 16 years of age.
For Residents of the United States
If you are a parent or guardian who knows or has discovered that your child under the age of 13 has submitted his or her personal data or other information without your consent, permission or authorization, upon request, we will promptly: (a) provide direct notice to you indicating what, if any, personal data of your child has been collected and how it has been used and/or disclosed; (b) remove your child’s personal data or other information from our database, cease the use of such information and direct any other party with access to such information to do the same; and (c) by notice to you, confirm compliance with the foregoing.
Access to your information and your rights
Notice to California Residents
Your California Privacy Rights: If you are a California resident, you have the right to receive: (a) information identifying any third party(ies) to whom SATV may have disclosed, within the preceding calendar year, your personal data for that third party’s direct marketing purposes; (b) a description of the categories of personal data disclosed; and (c) to obtain such information free of charge. To request such information, please write to us at Sony/ATV Music Publishing, LLC, 25 Madison Avenue, New York, New York 10010, Attn: Legal Department, or submit your request to: email@example.com. SATV will respond to these requests within thirty 30 days. Requests that come to SATV by other means may result in a delayed response.
For Residents of the European Economic Area (EEA)
How can you access your personal data and what are your rights?
If you would like a copy of the personal data that we store about you in our customer databases, please contact us using the details given in the “Contact us” section below.
This is in addition to your legal rights, including the right to access a copy of your personal data, the right to request the deletion or updating of any inaccurate personal data and the right to object, in some cases, to our processing of your personal data. You can exercise these rights by contacting us using the details given in the “Contact us” section below.
Where we are processing personal data based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.
You may also have, for some data processed by us, a right to data portability, i.e. the right to receive your personal data in a structured, commonly used machine-readable format and transmit your personal data to another data controller.
You can exercise these rights by contacting us using the details given in the “Contact us” section below. You may be asked to provide some proof of identification so that we can verify that it is you making the request.
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us or your local data protection authority.
Retention of personal data
We will only retain your personal data for as long as is reasonably necessary for the various purposes set out in this policy or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of information.