Privacy Policy

1. Introduction

We take your privacy very seriously and are committed to protecting your personal data. This Privacy Policy details how we, Novecore Ltd of 27 Old Gloucester Road, London, United Kingdom WC1N 3AX, (we, us) collect, use and process personal data. If you have any questions on this Privacy Policy or otherwise relating to how we process your personal data you can contact us at [email protected].

This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide personal data to us.

We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.

We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.

2. Whose personal data do we collect?

By personal data we mean identifiable information about you.

We may collect, use, store and transfer different kinds of personal data about you:

We do not knowingly collect data relating to children. Our website is intended for users aged at least 18.

We also do not actively collect special categories of personal data such as information relating to your race or ethnic origin, political opinions, religious beliefs of other beliefs of a similar nature, physical or mental health or condition, sex life and sexual orientation.

Personal data you provide to us

From time to time you may provide to us personal data. This may be because:

We shall process all such personal data in accordance with this Privacy Policy. Certain personal data is mandatory to be provided to us in order that we can fulfil your request, for example to start a plan, and we shall make this clear to you at the point of collection of the personal data.

All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.

When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.

Personal data we automatically collect about you

When you use our website, we may automatically collect and store information about your Technical Data and Usage Data.

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.

Personal data we receive from others

If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, such as credit reference agencies and the electoral register, confirming or otherwise, your identity.

We may also receive personal data about you from our third party service providers, such as our payment processing services and our IT service suppliers.

You authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship. Further, you authorize our service providers to provide the aforementioned information to us. See our Privacy Policy for how we treat your data.

We will only use your personal data where we have a lawful basis to do so. The lawful purposes that we rely on under this Privacy Policy are:

If you register and use our website, we shall use your personal data in order to provide the services to manage your plan in accordance with our Terms of Service.

We may from time to time need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.

We may also use your personal data for our legitimate interests including:

Who do we share your data with?

In accordance with our Terms of Service, we may share some personal data about you with music platforms in order to promote and sell your music. If you request that we create a VEVO account for you, we shall share your personal data with VEVO. Such third party platforms will process your personal data as a controller, and you should therefore consider the terms of their privacy policy too. We are not responsible for how platforms process your personal data. Please therefore consider the following privacy policies (this list is not exhaustive): Vevo Privacy Policy, Spotify Privacy Policy, Soundcloud Privacy Policy, Deezer Privacy Policy, Pandora Privacy Policy, iTunes Privacy Policy.

For our legitimate interests, we may also share your personal data with our service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, payment providers, accountants, auditors and lawyers. We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

If we may need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety then in doing so, we may share your personal data with third party authorities and regulatory organisations and agencies.

If we choose to merge, sell assets, consolidate or restructure, finance, or sell of all or a portion of our business by or into another company then the new owners may use your personal data in the same way that we do as set out in this Privacy Policy.

Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of the United Kingdom and/or European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.

Where your personal data is transferred outside the United Kingdom and/or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).

Security

We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.

However, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.

Marketing

You may consent to receive marketing email messages, including our newsletter, from us about our website and our services and business generally. You can choose to no longer receive such marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.

If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. If you still have an account with us, we shall continue to email you in relation to your account only.

Your rights

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You do also have the right to contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority.

Retention of personal data

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws.

In particular, we shall retain your personal data for as long as you access or use our website. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents.

Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

General

Our platform may contain links to third party websites, plug-ins and applications. We are not responsible for the content of such third party content, or their privacy statement. and if you provide any information to the third party, then you should check the third party website to find the applicable privacy policy.

If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

This Privacy Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts.

This Privacy Policy was last updated on 4 August 2020. You may contact us if you wish to review any previous version.