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SOFAR SOUNDS

PRIVACY POLICY FOR WEBSITE USER, MEMBERS AND ADDITIONAL GUESTS 

Dated: 24 May 2021

PLEASE READ THIS POLICY CAREFULLY 

Protecting your personal information is very important to Sofar Sounds (“Sofar Sounds” “our”, “us” or “we”).   This privacy policy will inform you as to how we look after your personal data in accordance with the Data Protection Act 2018, the UK and EU General Data Protection Regulation.

This policy applies to: (i) visitors to the website who have not created an account on the Sofar platform (“Users”), (ii) individuals that sign-up (or have already registered) as members with us (“Members”); and (ii) additional guests whose ticket(s) have been purchased by a Member (“Additional Guests”).  This policy sets out the basis on which personal data about Users, Members and Additional Guests will be processed and applies to activities occurring on or in connection with our website, https://www.sofarsounds.com/ (“Website”).  This privacy policy supplements other notices and privacy policies on the Website and is not intended to override them.

This policy does not cover the processing of personal data of hosts or performers.  Please refer to our ‘Privacy Policy For Hosts’ or our ‘Privacy Policy For Performers’ for details of how we process personal data in this respect.  

Our Website may contain links to third party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

Identity and contact information of the Data Controller

Sofar Sounds Limited is the controller and responsible for this website. Sofar Sounds Limited is a company incorporated and registered in England and Wales (company number 07561876) with its registered office at 5th Floor Roundhouse, 212 Regents Park Road, London, United Kingdom, NW1 8AW.

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to privacy@sofarsounds.com.

Personal information we may process about Users, Members and Additional Guests

We may collect, use, store and transfer different kinds of personal data which we have grouped together follows:

  • Member Data, which includes the first name, last name, email address, social media profile, gender, year of birth, phone number and hometown of a Member.
  • Additional Guest Data, which includes the first name, last name and email address of each Additional Guest. 
  • Transaction Data, which includes details about payments to and from a Member and other details of services a Member has purchased from us.
  • Technical Data, which includes a User’s or Member’s internet protocol (IP) address, login data, browser type and version, unique phone ID (if using our app), time zone setting and location used to access the Website.
  • Profile Data, which includes a Member’s password, which events they have applied to attend, which events they have attended, how often a Member attends events, how much a Member has paid and Members’ preferences, feedback and survey responses.
  • CCTV Data which include images taken by the CCTV in operation at events.
  • Event Data, which include professional recordings of such events by us or our service providers.

A breakdown of the personal data we may process is set out in the table below. Please note that third parties may collect personal data directly.  For example, payment processors such as Stripe Inc. collect financial data (such as payment card details) when payment is made to us on or through the Website. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from personal data but is not considered personal data in law as this data does not directly or indirectly reveal identity. For example, we may aggregate Technical Data to calculate the percentage of users accessing a specific section of our Website. However, if we combine or connect Aggregated Data with personal data so that it can directly or indirectly identify an individual, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

It is important that the personal data we hold is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

How personal data are collected

We may obtain personal data in three main ways:

  • Direct interactions.  Personal data may, for example, be provided us when an individual completes forms on our Website.  This included personal data provided to us when an account is created.  
  • Automated technologies.  Personal data may be collected automatically (such as the automatic recognition of IP addresses or placement of cookies on a device).
  • Third parties.  We may receive personal data from various third parties as set out below:
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If you fail 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 tickets to an event). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

International transfers

We share personal data within the Sofar Sounds group of companies. This may involve transferring your data outside the UK. Sofar is a UK based company and therefore when you submit your personal data to us it will leave your country of residence to arrive in the UK.

Many of our external third parties are also based outside the UK so their processing of personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring personal data out of the UK.

Disclosure of your information

We may also disclose your personal information to third parties in the following circumstances:

Purpose of disclosure and third party(s) to which disclosure might be made

Use Justification

If you request we do so.

You have provided your consent.

If Sofar Sounds or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets.

Legitimate interests (i.e. to dispose of our business).

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Sofar Sounds, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person.

We may disclose your personal information to third parties, the courts and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where we are compelled or believe it is reasonable to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime. 

Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person.

Alternatively, legitimate interests (i.e. to cooperate with law enforcement and regulatory authorities).

Data retention – how long will we use your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Member and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Your rights

You have various rights in relation to your personal data. All of these rights can be exercised by contacting us at privacy@sofarsounds.com.  

You have the following rights in relation to your personal data:

Rights

Details

Right of access

You have the right to obtain from us confirmation as to whether your personal data are being processed, and, where that is the case, access to such personal data. 

Right to Rectification

We will use reasonable endeavors to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete. 

Right to erasure / ‘Right to be forgotten’

Asking us to delete all of your personal data will result in us deleting your personal data without undue delay (unless there is a legitimate and legal reason why we are unable to delete certain of your personal data, in which case we will inform you of this in writing).

Object to processing

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 on 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 information which override your rights and freedoms.

Right to restriction of processing

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 it to establish, exercise or defend legal claims. (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

We will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.  

Where you request us to rectify or erase your personal data or restrict any processing of such personal data, we may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right, for example to comply with its legal obligations. 

Children under the age of 16

The Website is not aimed at children under 16 years of age.  We do not knowingly collect personal information from children under 16.  If you are under 16, please do not use our services or provide any information to us through the Website.  If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 16, please contact us at privacy@sofarsounds.com.

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, we will notify you, by email, or by means of a notice on our home page.  Your continued use of the Website will be deemed acceptance by you of the privacy policy.  The date the privacy policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Dated: 24 May 2021