“Personal data” means any information relating
to an identified or identifiable natural person. Personal data
can be factual (for example, a name, address or date of birth)
or it can be an opinion about that person, their actions and/or
In order for SMG Music and Multimedia Limited (“Snapmuse”) to be able to provide you with the Service (as defined in the General Terms and Conditions - Website) as well as to be able to provide you with individualised offers regarding the Service and products available from Snapmuse, Snapmuse collects personal data from you.
For the purposes of the EU General Data Protection Regulation
(EU Regulation 679/2016) (the “GDPR”), Snapmuse is the data
controller with regard to the personal data described in this
“Data controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed, who/which make independent decisions in relation to the personal data and/or who/which otherwise control that personal data.
If you have any questions about this Policy or about our data protection compliance please contact us via the details provided below.
Snapmuse collect the following personal data from you in order to provide the Service:
We also collect, use and share aggregated data such as
statistical or demographic data for any purpose. Aggregated data
could be derived from your personal data but is not considered
personal data in law as this data will not directly or
indirectly reveal your identity. For example, we may aggregate
your usage data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect
aggregated data with your personal data so that it can directly
or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this Privacy
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
The type of personal information listed below is only collected in order to offer you additional features. We will never process any of the following information unless you have chosen to share it with us, or decided to opt out from the features:
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all
the ways we plan to use your personal data, and which of the
legal bases we rely on to do so. We have also identified what
our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer|| ||Performance of a contract with you|
|To process and deliver your order including: || |
|To manage our relationship with you which will
include: ||Registration information||
Performance of a contract with you|
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in contests, campaigns and/or surveys||Registration information||
Performance of a contract with you|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|| ||
Necessary for our legitimate interests (for running our
business, provision of administration and IT services,
network security, to prevent fraud and in the context of a
business reorganisation or group restructuring
Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|| ||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences|| ||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you|| ||Necessary for our legitimate interests (to develop our products/services and grow our business)|
PROMOTIONAL OFFERS FROM US
We may use your registration information, usage data, cookie data and widgets to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes.
You can ask us or third-parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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.
Where you ask to be unsubscribed from marketing communications we may keep a record of your email address and the fact that you have unsubscribed to ensure that you are not sent any further emails in the future.
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.
We may further share information with our music industry
partners, customers and other cooperation partners in order to
help them understand how the content is performing, with
marketing partners who help us with promotional efforts, and
with advertisers that allow us to offer services and promotional
communication and help us understand how the users interact with
We may also share information with analytical providers in order for us to analyse how our users use the Service and to improve their user experience.
We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also share information for the purpose of responding to legal process (e.g. a court order), if we believe in good faith that it is necessary to do so; to comply with requirements of mandatory applicable law; to protect the safety of any person; and to address fraud, security, or technical issues.
There are circumstances in which we will have to transfer your
personal data out of the European Economic Area
(“EEA”) for the purposes of carrying out the
services we provide to you. We share your personal data within
the Snapmuse group. This will involve transferring your data
outside the EEA. We may also use external third-party service
providers based outside the EEA so their processing of your
personal data will involve a transfer of data outside the
Where the need for such transfers arises we will always ensure that there are appropriate safeguards in place to protect your personal data such as:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
The Snapmuse Service is a social Service that offers the user many ways to find, enjoy and share content. You as a user may choose to share playlists, music or other content with other users who have subscribed for the Service. This information will, if shared, be publicly available to the user(s) you accept to share it with. You may change your settings and limit the information which you have made publicly available.
If you connect your account to a third-party application,
Snapmuse may automatically share your activity and
activity-related stories with that service, including the
content you consume. You understand and agree that such
information may be attributed to your account on the third-party
application and may be published on such service.
Snapmuse, and if applicable its cooperation partners, have taken
several safety measures in order to protect personal data from
loss, misuse, unauthorised access, disclosure, alteration or
destruction. Personal data collected from you and processed by
us will only be accessed by employees and companies that are in
need to process such information.
Snapmuse is committed to protect user information. Your password protects your user account, so you should use a unique and strong password, limit access to your computer and browser, and log out after having used the Service. However, even if we take data protection precautions, no security measures are completely secure, and we do not guarantee the security of user information.
Snapmuse may display advertisements from third-parties and other content that links to third-party websites. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. Snapmuse do not control and will not be held responsible for third-parties’ processing of personal data. We strongly advise that you carefully review the terms and conditions and privacy policies of all linked third-party websites. We also reserve our right to discontinue any and all links to our website from third-party websites, at any time, at our sole and exclusive discretion.
The Service offered by Snapmuse is not directed to children
under the age of 16. A person under the age of 16 will not be
able to register for an account or be able to use the Service
provided by Snapmuse. We do not knowingly collect personal
information from children under 16 unless prior consent has been
obtained from the holder of parental responsibility over the
If you are under the age of 16, do not use the Service and do not provide any personal information to us without providing us with parental consent first. If you are the holder of parental responsibility over a child under the applicable age limit and become aware that the child you are responsible for has provided personal information to Snapmuse, please contact us via the details provided below and you may request exercise of your applicable access, rectification, cancellation, and/or objection rights.
Under certain circumstances, by law you have the right to:
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
HOW TO MAKE A COMPLAINT
In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance:
|Contact||Data Protection Commission|
|Telephone||+353 57 8684800 / +353 761 104 800|
Data Protection Commission|
21 Fitzwilliam Square South
effective when posted. As your use of the Service is subject to
your acceptance of this Privacy Statement, and any amendments
thereto, please check back regularly.
You can contact us with any queries, complaints or requests to exercise your data protection rights using the details below:
|Contact||SMG Music and Multimedia Ltd|
|Post:||4th Floor, 7/8 Wilton Terrace, Dublin 2, Ireland|