Global Master Rights Privacy and Cookies Policy
Your privacy and the protection of your Personal Information is important to Global Master Rights. In processing your Personal Information, both offline and via our website and portal we operate in compliance with applicable data protection legislation, including the General Data Protection Regulation (GDPR).
Information we may collect from you
In order to better provide you with our numerous services, Global Master Rights (and the vendors we hire to perform business functions on our behalf) may collect several categories of information from you and about you (“Personal Information”):
- Contact Information: We may collect your first and last name, email address, mailing address, and company name; for use of our client portal, we will collect and store your password.
- Client Personal Information: categories of Personal Information processed for our clients may include name, current address, telephone number, email address, bank account beneficiary name, bank account number (IBAN / RTN), SWIFT / BIC code, tax residency, tax number date of birth, country of birth, city of birth, gender, copy of passport, copy of proof of address, artist aliases and names of relevant rightsholders.
- Correspondence Information: We collect any content you share with us when you send email requests or inquiries, submit forms or transmit other information by email, telephone or letter.
- Location Information: We collect information about your general location, using your zip code or postal code and IP address.
- Internet and Network Activity Information: If you use our website, we may gather certain information about you based upon where you visit our website. Any such information is compiled and analyzed on both an individual and an aggregate basis. This information includes information about what site you came from, what site you visit when you leave us, your interaction with the pages you visit on our website (such as what areas of the websites you visit and for how long), what browser you are using, and your IP address. If you access our site from a mobile device, we sometimes collect a device identifier.
Purposes and Legal Basis for Using Your Personal Information
We use the above categories of Personal Information for the following purposes:
- If you are a client, we use Personal Information in order to provide the services and meet our obligations under our contract with you.
- We use your Personal Information to deliver information to you and to contact you regarding administrative notices. We use contact information to communicate with you and to respond to your inquiries, feedback, or other matters related to our relationship with you. We also use Contact Information for account set-up and access purposes.
- All categories of Personal Information are also used to resolve disputes, troubleshoot problems and enforce our agreements with you.
- We use Internet and network activity as necessary to protect our company, our customers, and our clients. We may also use this Personal Information to protect our websites or our services, as well as to detect and investigate activities that may be illegal or prohibited (such as cyberattacks or fraudulent transactions).
- We use some categories of Personal Information to enhance the operation of our website, statistically analyze website use, improve our services, and customize our website’s content, layout, and services.
- Where we have your consent, we may also send you marketing communications (for example, email newsletters). You can withdraw this consent at any time by contacting us using the email address under the “Contact Us” section below.
We use information as otherwise disclosed or permitted by law, or as we may notify you.
Disclosure of Your Information
We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (“Group”).
Global Master Rights does not sell, trade, or rent Personal Information to others. We do provide some of our services through contractual arrangements with affiliates, service providers, partners and other third parties and, as a result, share the categories of Personal Information described above under the following circumstances:
- We share your Personal Information with vendors who perform services on our behalf (“service providers”). We may share each category of Personal Information with vendors who provide technology services, help us manage and operate our websites, provide analytics and search engine support, investigate and prevent data incidents, and audit our business and financial statements. Any service provider processing activities will be performed only under a valid legal contract in writing clearly defining the scope and nature of processing. Such a contract may be based, in whole or in part, on applicable certification procedures or on the implementation of standard contractual terms recognized by local legal or regulatory authorities.
- We share your Personal Information with authorized neighbouring rights societies (CMO’s) (applicable only to client Personal Information). If you are a client who has entered into an agreement with us, we will share client Personal Information with societies authorized to collect and pay neighbouring rights royalties to the extent necessary to facilitate royalty collections in accordance with our agreement.
- We may share your information if we think we must do so in order to comply with the law or to protect ourselves, our customers and others. Occasionally we may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities. We will disclose person information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. Subject to all local laws and regulations, we fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
We may share Personal Information for other reasons we may describe to you from time to time, as permitted by law.
The data that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us, a member of our Group or for one of our suppliers. Countries outside the UK or the EEA may not have laws that provide the same level of protection to your Personal Information as laws within the UK or the EEA. Where this is the case, we will put in place appropriate safeguards to ensure that such transfers comply with applicable data protection laws. Where required, we implement Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions.
We take appropriate technical and organizational security measures with regard to the processing of Personal Information, against loss or any form of unlawful processing (such as unauthorized access, corruption, alteration or disclosure of Personal Information). In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know and who will only process your Personal Information on our instructions.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, to the full extent you are empowered to do so under local law or regulations, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the website cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
We will retain your personal data for as long as you use our services (including our website) and for a reasonable time thereafter, in order to be able to deal with any claims or queries you may have in relation to our services. If you do not use our services, we may still retain your Personal Information for as long as we are legally able to do so in order to deal with any further queries you may have in relation to our services. If you would like us to delete the information, please contact us using the details in the “Contact Us” section below and we will respond in a reasonable time and manner. Please note that we may also be required to retain certain information by law.
You can always contact us if you have any questions regarding this policy. In addition, you have to the following rights regarding your Personal Information:
- The right to access/right to know. You have the right to request information about the purpose, categories, recipients (or categories of recipients), and period of storage (where possible; if not, any storage criteria) of your Personal Information; your right to lodge complaints with the appropriate authorities; information about any automated analysis; and information of safeguards on any international transfer, in addition to any other information required to be provided under local law or regulation.
- The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. We encourage you to promptly update your Personal Information if it changes.
- The right to erasure/deletion. At your request we will delete your Personal Information if any of the so-called “right to be forgotten” conditions set forth in the GDPR applies, or if any similar conditions are met under equivalent local laws or regulations. It may be impossible to completely delete your information without some residual information because of backups.
- The right to restrict processing. We will restrict our processing of Personal Information if you tell us that it is inaccurate, if you are entitled to request deletion but prefer restriction, if we would otherwise delete it but you need it for legal reasons, or if you are in the process of verifying our “legitimate interests” for processing your Personal Information (if those interests are the sole legal basis on which we are doing so).
- The right to data portability. You have rights to obtain and reuse your Personal Information for your own purposes across different services and platforms. California residents can request a copy of your Personal Information in a readily accessible format.
- The right to object. You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes. Where you object to processing for direct marketing purposes, the Personal Information shall no longer be processed for such purposes.
- The right to withdraw consent. You have the right to withdraw your consent to the processing of Personal Information at any time by email or other written notice to the address set forth in the “Contact Us” section below. You understand that withdrawal will not affect the legality of our treatment of your Personal Information while your consent was in place.
You are always free to decline our cookies if your browser permits, but some parts of our website may not work properly in that case. You can decline mobile tracking through the settings on your mobile device. In addition, when you access the website from different devices, we may correlate both devices with your account, so that we can provide a more seamless experience to you as a user of the website or client portal.
Modification of this Privacy and Cookies Policy
If you would like to file a complaint about our use of Personal Information, please send an e-mail with the details of your complaint to email@example.com. We will review and respond to any complaint we receive.
You may correct your Personal Information and exercise your privacy preferences by writing us at:
Please include your name, address, and/or email address when you contact us. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Information and whether you have an account with us.