FRONT ROW MUSIC – PRIVACY POLICY

Introduction

This is the privacy notice of Front Row Music. In this document, “we”, “our”, or “us” refer to Front Row Music and its associated franchises. Our company numbers are 07526772, 08903465, 10958633, 11351805, 09208165, 10296850, 11197374 registered in England and Wales.

  • This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
  • We take seriously the protection of your privacy and confidentiality. We understand that all our clients and students are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
  • We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
  • Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
  • The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
  • Except as set out below, we do not share, or sell, or disclose to a third party, any information we collect.
  • This policy explains how we collect data, how we use and store information and what it means for you. We also have specific Terms and Conditions when signing up to lessons, which you should read as well.
  • Data Storage: We keep customer records for 10 years from the point of last communication for tax purposes.

What information do we collect?

  • Directly with us
    We collect personal information each time you deal with us, for example when you register yourself or your child for our lessons, purchase an instrument, make an enquiry (in person, by email, through the website, over the phone or otherwise), make a payment, respond to questionnaires or updates, provide us with feedback, or otherwise provide your personal details, we collect the information you provide.
  • From website interaction with us
    We collect non-personal data such as IP addresses, details of pages visited and files downloaded from our website. Website usage information is collected using cookies. See the section on Cookies below.
  • Information from third parties
    Although we do not disclose your personal information to any third party (except as set out in this notice), we may sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.No such information is personally identifiable to you.
  • Where you give your permission to other organisations
    We may collect information that you make available on, for example, Twitter, Facebook, LinkedIn or similar organisations. You may wish to check their privacy policy to find out more information on how they will process your data.
  • From publicly available data
    We may collect information from Companies House for example, and information published in articles, newspapers or blogs.
  • Sensitive data
    Where you provide the information directly, we may collect sensitive personal data, including but not limited to, religious beliefs, or physical or mental health.

What do we do with it?

  • Basis of processing your data
    1. The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
  • Contractual obligation: when you pay for our service or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
    We may use it to:

    1. Provide you with our services;
    2. Provide you with updates and resources;
  • Sell or recommend products to you;
  1. Contact you about any changes to our service;
  2. Provide you with suggestions and advice on products or services.

We process this information on the basis that there is a contract between us. We will continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract (see our Terms & Conditions).

  • Consent: By signing yourself or your child up to our lessons through our sign-up slips or online web form, you have given us consent to collect and process the personalinformation you provide. You are free to change your preferences at any time by contacting us by telephone, post or email as shown in the below section.
    1. In situations when there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies (see the below section on Cookies for more information).
    2. Sometimes you might give your consent implicitly, such as when you send us an email to which you would reasonably expect us to reply.
    3. Except when you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
    4. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
      We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us at office@frontrow-music.com. However, if you do so, you may not be able to use our services further.
  • Legitimate Interest: We may process information on the basis that there is a legitimate interest, either to you or to us, of doing so. When you have requested we teach you or your child, we may rely on our legitimate interest in order to collect the information we need to provide this service. Where we process your information on this basis, we do so after having given careful consideration to:
    • Whether the same objective could be achieved through other means;
    • Whether processing (or not processing) might cause you harm;
    • Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.

For example, we may process your data on this basis for the purposes of:

  • Record-keeping for the proper and necessary administration of our business;
  • Responding to unsolicited communication from you to which we believe you would expect a response;
  • Protecting and asserting the legal rights of any party;
  • Insuring against or obtaining professional advice that is required to manage business risk;
  • Protecting your interests where we believe we have a duty to do so.
  • Legal obligation: We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
  • Processing of requests / payments / calls to action

Personal information given to us is collected and stored on a secure web application, Upscale, which is used solely by our staff and tutors. All data stored on Upscale is secure and encrypted. Information on physical slips or otherwise, is locked in a secure filing cabinet in our office.
We may use the personal data we collect to:

  • Send you information regarding our lessons;
  • Contact you about your, or your child’s, lessons with us;
  • Keep you up to date on news and stories about our team and work;
  • Process payments;
  • Provide information on how best to practise or support your child’s practice;
  • Provide a personalised or customised service, such as personalised emails;
  • Keep records of your relationship with us, e.g. questions you have asked or complaints or comments you have made;
  • Classify clients by location/franchise area;
  • Analyse the personal information we collect about you and use publicly available information to aid our understanding of who uses our service;
  • Conduct market research
  • Applying for a job with us

Where you provide personal data and sensitive personal data when applying for a job with us, such as the information on your CV, we will process, store and disclose the personal data we collect to:

  1. Support the recruitment process;
  2. Enable you to submit your CV and apply online for jobs;
  • Answer any questions you may have;
  1. Use third parties to provide services such as references, qualifications, criminal referencing, checking services, verification of information you have provided and skills tests;
  2. Provide anonymised data to monitor compliance with our equal opportunities policy.
  • Sending a message to our team

When you contact us, whether by telephone, through our website, in person or by email, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address, so as to be able to track our communications with you to provide a high quality service.

  • Lodging a complaint

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

How and where we store your information

  • How long?

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

  1. To provide you with the services you have requested;
  2. To comply with other law, including for the period demanded by our tax authorities;
  • To support a claim or defence in court
  1. For researching, feedback and reporting on our service
  • Security
  • We ensure that we have in place appropriate technical controls to protect any personal data you provide. For example, we ensure that online forms and our web application, Upscale, are encrypted and our network is protected and routinely monitored.
  • We ensure that access to personal data is restricted only to those staff members whose job roles require such access and that suitable training is provided for these staff members.
  • We may make limited use from time to time of external companies to collect or process personal data on our behalf. When we do so, we carry out checks on these companies, put in place contracts to make sure our requirements are clear, and carry out periodic reviews. When we do use external companies, we remain responsible for the storing and processing of your personal data.
  • However, we need to remind you that despite all our efforts the internet cannot be guaranteed to be 100% secure, and that you submit data at your own risk.
  • Credit/debit card security
    If you use your debit or credit card to make a payment with us, whether for lessons, instruments, or for any other reason, online, over the phone or by mail, we will process your information securely in accordance with the Payment Card Industry Data Standard.
    We store information about your debit or credit card or other means of payment when you first provide it to us. We store this payment information in order to make repeat purchasing of goods and services easier in the future. We also store it to prevent fraud. We take the following measure to protect your payment information:

    1. We keep your payment information encrypted;
    2. We do not keep all your payment information so as to prevent the possibility of our duplicating a transaction without a new instructions from you, and to prevent any other third party from carrying out a transaction without your consent;
    3. Access to your payment information is restricted to authorised staff only;
    4. If we ask you questions about your payment information, we only show the last four digits of the debit or credit card number, so that you can identify the means of payment to which we refer.

We hold bank account details for the purpose of collecting direct debits in accordance with direct debit mandate rules.

  • Direct debit
    When you agree to set up a direct debit arrangement, the information you give us is passed to our own bank Santander via GoCardless for processing according to our instructions. We do not keep a copy.
    We are registered under the direct debit guarantee scheme. This provides for the customer’s bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.
  • Where we store your personal information
    We use cloud based systems to process data and therefore data may be processed outside of the EEA. We use the following safeguards with respect to data transferred outside the European Union:

    1. The processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing;
    2. We comply with a code of conduct approved by a supervisory authority in the European Union;
  • We are certified under an approved certification mechanism as provided for in the GDPR;
  1. Both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information

When we share your information

  • We do not share or swap your information with other business unless otherwise outlined in this privacy policy
  • Legal duty
    We may need to pass on information if required by law or by a regulatory body, or if asked for details by a law enforcement agency.
  • Our service providers and third parties
    Occasionally we may employ agents to carry out tasks on our behalf, such as fulfilling orders or processing payments. These agents are bound by contract to protect your data and we remain responsible for their actions.
    We may provide third parties with general information about users of our site, but this information is both aggregate and anonymous.
    Although we do not disclose your personal information to any third party (except as set out in this notice), we may sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.

Cookies

  • What are Cookies?

We collect data using cookies. A cookie is a text file that is sent from our website as soon as you visit the site. It is stored on your computer’s hard drive and helps us to identify your computer (not you) and collects information in an aggregate, anonymous way.
Cookies may be used to collect information about your visit to our website, for example traffic data, location data, device information, the date and time of your visit and the pages that you visit.
The use of cookies is an industry standard for most major websites.

  • Front Row Music’s use of Cookies on our website

To enjoy the Front Row Music website to the full, we recommend that you leave cookies turned on. If you turn off cookies then you may not be able to enter parts of the site. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. The cookie data that we collect we may use to:

  1. Track how you use our website;
  2. Customise the content on our website and to help to understand the visitor’s current and future needs;
  3. Record whether you have seen specific messages we display on our website;
  4. Process any requests, applications or payment you may make;
  5. Aid internal administration and analysis.
  • Managing Cookies

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose. Most browsers allow you to turn off the cookie function. To do this you can look at the help function on your browser.

  • Third party Cookies
    Front Row Music works with a number of third party suppliers who set cookies on our website to enable them to provide us with services. These are mainly used for reporting and advertising purposes so we can improve the way we communicate.

We use websites such as Youtube, Vimeo and Soundcloud to embed videos and music, and you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third party website for more information about their cookies and how to manage them.

We also use third party suppliers such as Facebook, Twitter and Google Analytics and these providers may use cookies. They may also use tracking pixels, which are commonly found in advertising to track the effectiveness of adverts.
As some of these services may be based outside of the UK and the European Union, they may not fall under the jurisdiction of UK courts. If you are concerned about this you can change your cookie setting (see above).

How we treat children’s information

  • When we collect children’s personal information, we make it clear that we require the parent/guardian’s permission in order to collect it. We do not actively seek to collect children’s data without this consent for a parent or guardian.
  • Information we collect on children will include their full name, year group, school, and any other personal information provided to us with consent. This information will only be used to allow us to provide the service that has been requested.
  • We treat this data in the same way as other data outlined in this policy.

Access to your personal information

  • At any time you may review or update personally identifiable information that we hold about you, by contacting our office team at office@frontrow-music.com

After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

  • Updating your details

We do appreciate it if you keep your details up to date. You can do so by contacting our office team at office@frontrow-music.com.

We may use Post Office address search, postcode lists or other available sources to confirm data that you provide us with, where, for example, we are unsure of what you have completed on a form.
We will not use these sources to create that you have chosen not to provide, for example, if you have left a telephone number blank; nor will we automatically update changes of address, we will normally only update your address when you tell us it has changed.

  • Removal of your information

You have the right to ask us to erase your personal data, to ask us to restrict our processing or to object to our processing of your personal data. If you wish us to remove personally identifiable information, you may contact us at office@frontrow-music.com. This may limit the service we can provide to you.

  • Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Complaints

  • If you are not happy with our privacy policy or if you have any complaint then you should tell us by email. Our address is office@frontrow-music.com

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

Changes to Front Row Music’s privacy policy

  • Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our service.

  • Review of this privacy policy

We may amend this policy from time to time to take account of changes to our processes or changes to data protection or other legislation. If we may any significant changes to this policy we will show this clearly on our website or will write to you directly. By continuing to use our service and out website, you will be deemed to have accepted these changes.
If you have any questions regarding our privacy policy, please contact us by:

Calling us on: 0161 282 8731

Emailing us on:office@frontrow-music.com

Writing to us at:
Front Row Music
1st Floor
76-80 Heaton Moor Road
Stockport
SK4 4NZ