Privacy Notice

This privacy notice is provided to inform about how and why your personal data is used and to ensure that you are aware of your rights under data protection legislation.

The company

We are Sing Up and we are the Data Controller, our correspondence address is Sing Up Limited, Gateshead International Business Centre, Mulgrave Terrace, Gateshead, NE8 1AN, United Kingdom. We can be contacted on +44 (0) 204 566 9666 or [email protected].

The purpose for processing your data and our basis for doing so

When you register an account and access our platform, we process your personal data so we can provide you access to Sing Up, manage your account (including billing) and to maintain contact for service purposes. We also process personal data for the purposes of marketing, and usage data associated with your account, such as playlists, songs, and favourites.

The lawful basis we use to process this information is Article 6.1.f, legitimate interest. We have a legitimate interest in offering our services to our customers and the data we process is proportionate to the purpose and comprises name and contact / address details.

We record audio downloads and score unlocks to ensure royalties are paid. In addition, we will process your IP address to provide your regional geographical location. The lawful basis we use to process this information is Article 6.1.c, in compliance with a legal obligation under the UK’s Copyright legislation.

We use your data for the supply and shipping of items when you make a purchase from our online shop. We do this on the basis of Article 6.1.f - legitimate interest as we have a commercial interest in delivering our e-commerce.

If you upload your image into your account profile voluntarily, we will process that under the lawful basis of Article 6.1.a, consent. You can withdraw consent at any time by deleting your profile picture or contacting us. We do not require you to upload your image.

If you fail to provide the information that is required, we will be unable to provide our services to you.

Recipients of your data

As a general principle, we will not transfer your personal data to other recipients without your permission. There are some exceptions to this:

• It is possible, that we might be obliged to disclose personal information in response to a court order or other lawful obligation. Our lawful basis for this is Article 6.1.c – legal obligation.
• In the unlikely circumstance you do not pay your bills, we may pass your details to a debt collection organisation. Our lawful basis for this is Article 6.1.f – legitimate interest, as we have a legitimate interest in collecting our fees.
• Third party suppliers of items purchased via our e-commerce site or the Song Bank.

Data processed by third parties on our behalf

We use the services of other organisations in the processing of your data, this includes:

Web developers, payment providers, shopping fulfilment platforms, cloud-based email and document storage platforms and mailing houses. We use customer relationship management, video conference and sales and marketing platforms. We also utilise the services of an IT support company.

Those organisations that process personal data on our behalf are subject to a data processing contract as required by Article 28 of the UK GDPR. This ensures that your data is handled in accordance with the UK GDPR.

Transferring your data outside of the UK

We transfer personal data outside of the UK by virtue of our cloud hosted platforms. Where this occurs, we depend on EU / UK adequacy decisions or for a transfer to the USA and Australia, standard contractual clauses.

Retention periods

We will retain your data only for the time we require it for the purposes stated and / or where we have a legal obligation or other legitimate purpose. We will retain the personal data of our current customer contacts for 6 years for our accounting purposes. If you close your account, or when your account is closed after 2 years of inactivity, your personal data is anonymised on our system and only your purchase history (if available) is retained in an identifiable way until the 6 year deletion process takes place.

Your rights

The UK GDPR provides you with several rights in relation to the data we process of you. The rights relevant to our activities are:

• You have the right to get access to and copies of your personal data.
• You can ask us to rectify any inaccurate information we may be holding.
• You can request we restrict our processing of your data.
• You can ask us to erase your personal data where we process under a legitimate interest basis (although we may have to retain some for legal reasons).
• You have the right to object to processing we undertake under a legitimate interest basis.

If you want to exercise any of these rights, please contact us using the above contact details.

Children’s data and ‘Children’s Code’

Please note, when we act as a Data Processor for student data, we process the minimum of children’s data to provide access to the platform. We have reviewed the Student Area of the Sing Up platform (https://student.singup.org/) and our processes against the requirements of the UK Information Commissioner’s Office Age Appropriate Design Code (Children’s Code) as it can be applied to data processors. We are satisfied that we comply with the standards set within this important code.

Your rights - Complaints

You also have the right to lodge a complaint about our processing with a supervisory authority — the UK's Information Commissioner's Office.

The Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: +44 (0) 303 123 1113