Last Amended: May 25, 2018
1. Information collected
We collect your personal and non-personal information (the “Information”) in two ways: (i) Information that you provide; and (ii) Information that is automatically collected. Your provision of personal information is completely voluntary. We do not collect personal information unless you submit that information to us.
Categories of personal information we may collect include:
- Identity Data, which includes name or other similar identifies.
- Contact Data, which includes address, email address, and telephone numbers.
Additionally, we may collect certain other types of information that, along with identity and contact data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:
- Financial Data, which includes credit card, debit card, bank account, or other payment details.
- Transaction Data, which includes details about payments to and from you.
- Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information;
- Profile Data, which includes your username and password, your album and release information, accounting statements and other reports, and preferences.
- Usage Data, which includes information on how you use the Site and any third party sites linked to from the Site.
- Marketing and Communications Data, which includes your preferences in receiving marketing from us.
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAINS TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
1.1. Information you provide
1.2 Information automatically collected
We may automatically receive, collect and record information such as (i) actions and searches you perform while interacting with the Site or using the Services; (ii) Internet Protocol addresses; (iii) operating systems; (iv) the time, frequency and duration of the actions, visits and uses of the Site and Services; and (v) analytics thereof. Some of the ways in which we or the Site may collect are further described below:
- Internet-Based Advertising: We may engage third-party vendors to use your information in connection with their own information to deliver targeted advertising to you when you visit the Site or other websites. Cookies, described above, may be used in this process.
- Clickstream Data: As you use the Internet, a trail of electronic information is left at each website you visit. This information, sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. For example, clickstream data can tell the type of computer and browsing software you use and the address of the website from which you linked to the Site. The Site may collect and use clickstream data as a form of aggregate information to anonymously determine how much time users spend on each page of the Site, how users navigate through the Site and how we may tailor the Site to better meet the needs of users. The information often will be used to improve the Site and Services. The collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any personal information.
- Location Data: The Site may location information, including as provided by a mobile or other device interacting with the Site (including through beacon technologies) or associated with your IP address, where we are permitted by law to process this information.
2. Use of the Information
Subject to the section titled “Additional EU Disclosures,” we use information held about you to perform the Services and for other purposes outlined below. Specifically, we use your information for a variety of purposes (the “use” or “treatment”), including:
- To identify you when you use the Site and Services;
- To provide, operate, improve and optimize the operation of the Site and Services;
- To customize the Site and Services;
- To perform under the contract we are about to enter into or have entered into with you;
- To communicate with you, send you emails, technical messages, marketing campaigns messages, security alerts, updates. terms and conditions and policies updates, and notices;
- To provide technical support; and
- To comply with a legal or regulatory obligation.
Subject to the section titled “Additional EU Disclosures,” we may also use your Information by sharing or disclosing all or part of it with certain third parties:
- If it is necessary to provide, operate, improve or optimize the operation of the Site or Services;
- If it is required by the applicable law and regulations or requested by an authority such as a court, the government or law enforcement officials;
- In order to investigate suspected fraud or other violations of any law, rule, regulation, or the policies of the Site.
- As required to our affiliated companies, assignees, officers, employees, contractors, partners, shareholders or licensees; or
- In connection with a merger, acquisition, or corporate restructuring of ONErpm.
3. Third-Party Links and Social Networking Services
The Site may integrate with various social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with the Site, we are doing so merely as an accommodation and, like you, are relying on those third party services to operate properly and fairly.
You should be aware that Information which you voluntarily include and transmit online in a publicly accessible blog, social network, or otherwise online may be viewed and used by others. We are unable to control such uses of your Information, and by using such services, you assume the risk that the Information provided by you may be viewed and used by third parties.
4. Update and correction of the Information
You agree to immediately
request that we to update or correct the Information as soon as you notice that
the Information provided by you or automatically collected is inaccurate or
needs to be updated, rectified or deleted. You are responsible for any
inaccurate or not updated Information. You may at any time request us to delete
from our records and to remove from the Site, all or part of the Information,
provided that we may retain copies of Information as required by law, for our
internal record-keeping, accounting and reporting purposes, and as necessary to
provide the Site or Services. To make such correction, please send an email to firstname.lastname@example.org. All notices sent to this
email will be deemed received 24 hours after the email was sent, if no
"system error" or other notice of non-delivery is generated. If
applicable law requires that a given communication be "in writing,"
you agree that email communication will satisfy this requirement.
5. Access to the Information
You may have access to your Information collected by us by providing written request to email@example.com. You may access your personal data (or to exercise any of the other rights) free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
6. Data Security
We have put in place appropriate security measures to prevent information about you from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed; however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have put in place procedures to deal with any suspected data breach that will affect you and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data Retention
We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for your Information, we consider the amount, nature, and sensitive of the Information, the purpose for which we process your Information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data (see Request erasure below for further information). In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
8. Unsubscribing Choice
You may revoke the authorization granted herein on a prospective basis by sending an email to firstname.lastname@example.org
9. Children’s Information
The Site and Services are not intended for children under the age of 13. If we become aware that a minor has provided his/her Information, we will have the right to remove or delete such information and to make our best efforts in limiting the access of the minor to the Site and Services. If the minor’s parents become aware that their child is accessing the Site, using the Services and/or providing us with his/her Information, they shall immediately contact us at email@example.com.
10. Additional EU Disclosures
10.1. Our role as data controller and data processor
Verge Records International, Inc. acts as the data controller of your Information submitted through the Site. If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local supervisory authority. However, we encourage you to contact us first at firstname.lastname@example.org, and we will do our very best to resolve your concern.
10.2. Provision of personal data and failure to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we will not be able to provide Services to you.
10.3. Legal basis for our processing of your personal data
Below are the types of lawful basis that we will rely on to process your personal data:
- Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com.
- Performance of contract means processing your data as necessary to perform our obligations under any contract with you, including all actions required to fully render the Services under any contract.
- With implied or express consent means processing your data based on your consent, whether express or implied by your actions, such as to send you certain information, including marketing communications, to share your information with partners when you have requested we do that, or as otherwise agreed.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for the compliance with a legal or regulatory obligation that we are subject.
10.4. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider the need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required by law.
10.5. Collection of personal data from third party sources
We also collect data about you from various third parties and public sources:
- If you register for the Site or otherwise link to your Facebook, Twitter, or other social media sites, we will import your data from those social media sites.
- Your accounting statements and reports generated in connection with the Services we provide are based on data we receive from various third party platforms.
- As discussed above, we also obtain data through automated technologies (see section titled “Information Collected”).
10.6. Withdrawing your consent
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at email@example.com.
10.7. Use of your personal data for marketing purposes
We strive to provide you with choices regarding personal data uses, particularly around marketing and advertising:
- Marketing emails from us: We may use your Information to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have signed up on the Site or used the Services and, in each case, you have opted into receiving that marketing.
- Third-party marketing: We will get your opt-in consent before we share your personal data with any company outside of ONErpm for marketing purposes.
To see how you can opt out of marketing communications, please see section 6 titled “Unsubscribing Choice”
10.8. Rights of EU Data Subjects
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.
- Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need to establish, exercise, or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You may access your personal data (or to exercise any of the other rights) free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
To exercise your rights, please contact firstname.lastname@example.org.
11. Cross Border Transfers
12. California Policy
If you are a California resident this section applies to you. Under California law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of personally identifiable information, such as name, email address, and mailing address and the type of services provided to the customer that a business has disclosed to third party (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (ii) the names and addresses of all such third parties. To request the above information, please contact us at email@example.com. If you do not want your personally identifying Information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to firstname.lastname@example.org.
14. Contact Us
Verge Records International, Inc.
2005 Russell Street
Nashville, TN 37206