This policy (together with the nkoda End User Licence Agreement and any other documents referred to on it) sets out:
- Child safety
- The information we collect about you
- How we use your information
- Our promotional updates and communications
- Who we share your information with
- Where we store your information
- Public forums
- Payment processing
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- Contact us
- General Terms and Conditions for Social Media Contests
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of applicable data protection law, (the "Data Protection Law"), the data controller is: nkoda Limited, c/o Leigh Saxton Green LLP, Mutual House, 70 Conduit Street, London W1S 2GF, contactable at email@example.com.
Protecting the safety of children when they use the Internet is important to us.
If you are under the age of 18, you confirm you have received permission from your parent or guardian before using the nkoda App or sending us personal data.
If you are under the age of 16 then your parent or guardian must consent on your behalf if and where we ask for consent in relation to the use of your information and the nkoda App will ask you for your parent or guardian's email address so that we can get this consent. We will need your parent or guardian to agree to you using the nkoda App before we can allow you to use it.
Information we collect about you
We will collect and process the following personal data from you:
Information you give us
This is information about you that you give us directly when you interact with us.
This is information about you that you provide to us when using the nkoda App or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the nkoda App, subscribe to our service, search for sheet music, place an order for sheet music, participate in any discussion boards or other social media functions available on or via the nkoda App, enter any competitions, promotions or surveys run via the nkoda App, submit a query, and when you report a problem with the nkoda App.
The information you give us may include your name, e-mail address and login and password details. You may also have the option of uploading a profile picture via the nkoda App. It is entirely your choice as to whether you do this as it may be accessible by and shared with others. We may also collect details of any transactions made by you via the nkoda App, including your credit/debit card details (where saved by you).
Information we collect about you from your use of the nkoda App: We will automatically collect information from you each time you use the nkoda App. This includes:
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from the nkoda App (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
Location data - we collect information through the nkoda App as to your real time location to provide location services where requested or agreed to by you, or to deliver content, or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the nkoda App.
Information we receive from other sources. This is information we receive about you:
- If you use any of the other websites or apps we operate or the other services we provide.
- From third parties we work closely with.
In this case we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected via the nkoda App. We will also have told you for what purpose we will share and combine your data.
We are working closely with third parties (including, for example, business partners, sheet music publishers, sub-contractors in technical, payment and delivery services, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
How we use your information
We use information held about you in the following ways:
Information you give us:
We will use this information to:
take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
- administering your account with us;
- verifying and carrying out financial transactions in relation to payments you make through the nkoda App;
- notifying you about changes to the nkoda App, this policy or the nkoda End User Licence Agreement;
provide you with information about our products or services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See 'Our promotional updates and communications' section.
ensure in our legitimate interests that:
- content from the nkoda App is presented in the most effective manner for you and for your device;
- we provide you with the information, products and services that you request from us or that may interest you, subject to your stated preferences.
Information we collect about you from your use of the nkoda App
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- to administer the nkoda App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to keep the nkoda App safe and secure;
- to improve the nkoda App to ensure that content is presented in the most effective manner for you and for your device; and
- to allow you to participate in interactive features of our service, when you choose to do so.
Information we receive from other sources
We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
In limited cases where consent is appropriate to and sought for specific processing, a separate consent notice will apply.
Our promotional updates and communications
Where permitted in our legitimate interests or with your prior consent where required by law, we will use your personal data for marketing analysis and to provide you with promotional update communications by email about our services.
You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to firstname.lastname@example.org.
Who we share your information with
We may share your information with selected third parties.
Our selected third parties may include:
- Organisations who support the services we offer through the nkoda App, in particular those providing website and data hosting services, fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions and will also be subject to the Data Protection Law.
- Analytics and search engine providers that assist us in the improvement and optimisation of the nkoda App.
- Business partners who jointly with us provide services to you and with whom we have entered into agreements in relation to the processing of your personal data.
- Payment processing providers who provide secure payment processing services. Your payment card details are not shared with us by the provider.
We may disclose your personal data to third parties:
- to enable us to enforce or apply our rights under this policy or any other agreements with you, or to protect the rights, property, or safety of nkoda Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime; and/or
- where required to do so by court order or where we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation.
Where we store your information
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law.
We may transfer your personal data outside the EEA:
- in order to store it;
- in order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services;
- where we are legally required to do so; and/or
- in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
The nkoda App may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and avoid posting any personal data.
How we protect your information
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the nkoda App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the nkoda App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
The nkoda App may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites. You should check the relevant policies before submitting any information to these sites.
How long we keep your information
We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
- You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section);
- to request that your personal data be moved to a third party in certain circumstances.
- You may opt out at any time from allowing further access by us to your location data by emailing email@example.com and requesting deletion of your account. You can also stop all information collection by uninstalling the App. You may use the standard un-install processes as may be available for your mobile device.
- Your right to withdraw consent:
Where the processing of your personal data by us, is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us firstname.lastname@example.org. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section.
You can also exercise the rights listed above at any time by contacting us at email@example.com.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).
Changes to this policy
General Terms and Conditions for Social Media Contests
- The Promoter of this competition is nkoda Limited.
- The competition is open to users of nkoda aged 12 years or over, except employees of nkoda and their close relatives and anyone otherwise connected with the organisation or judging of the competition.
- There is no entry fee and no purchase necessary to enter this competition.
- By entering this competition, an entrant is indicating his/her agreement to be bound by these terms and conditions.
- This competition is run across social media platforms owned by nkoda Limited.
- Only one entry will be accepted per person.
- Closing date for entry will be Dec 21 2018. After that date no further entries to the competition will be permitted.
- No responsibility can be accepted for entries not received for whatever reason.
- The rules of the competition and how to enter are as follows:
- The Promoter reserves the right to cancel or amend the competition and these terms and conditions without notice in the event of a catastrophe, war, civil or military disturbance, act of God or any actual or anticipated breach of any applicable law or regulation or any other event outside of the promoter’s control. Any changes to the competition will be notified to entrants as soon as possible by the Promoter.
- The Promoter is not responsible for inaccurate prize details supplied to any entrant by any third party connected with this competition.
- The prize is as follows: the prize is as stated and no cash or other alternatives will be offered. The prizes are not transferable. Prizes are subject to availability and we reserve the right to substitute any prize with another of equivalent value without giving notice.
- Winners will be chosen from all entries received and verified by the Promoter and or its agents.
- The winner will be notified by email and/or Direct Message on Twitter/Facebook and/or letter within 28 days of the closing date. If the winner cannot be contacted or do not claim the prize within 14 days of notification, we reserve the right to withdraw the prize from the winner and pick a replacement winner.
- The Promoter will notify the winner when and where the prize can be collected/is delivered.
- The Promoter’s decision in respect of all matters to do with the competition will be final and no correspondence will be entered into
- By entering this competition, an entrant is indicating his/her agreement to be bound by these terms and conditions
- The competition and these terms and conditions will be governed by English law and any disputes will be subject to the exclusive jurisdiction of the courts of England.
- The winner agrees to the use of his/her name and image in any publicity material, as well as their entry. Any personal data relating to the winner or any other entrants will be used solely in accordance with current [UK] data protection legislation and will not be disclosed to a third party without the entrant’s prior consent.
- Entry into the competition will be deemed as acceptance of these terms and conditions.
- nkoda will judge the competition and decide on the winner each week, which will be picked from all complete entries via social media channels and email.
- nkoda’s decision as to those able to take part and selection of winners is final. No correspondence relating to the competition will be entered into.