Privacy Policy

Last updated: April 2024

Contact Details

Postal address:: FAO Legal,
Music Publishers Association Limited,
3rd Floor,
107 Gray's Inn Road,
London,
England,
WC1X 8TZ
Email:: [email protected]
Telephone number:: 020 3848 7410

Who we are

Music Publishers Association Limited (MPA, we, us, or our) takes your privacy very seriously. This Privacy Policy gives you information about how MPA collects and uses your personal data through your use of www.mpaonline.org.uk (Website), including any data you may provide when you register with us, sign up to our newsletter or purchase a service.

Our Website is not intended for children and we do not knowingly collect data relating to children.

MPA is the controller and responsible for your personal data.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the information set out in the paragraph below.

Email: [email protected]

Telephone number: 020 3848 7410

Types of personal data collected

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, and title.
Contact Data includes billing address, delivery address, email address and telephone address.
Transaction Data includes details about payments to and from you and other details of services (e.g., event tickets) you have purchased from us.
Technical Data includes internet protocol address, your login data, browser types and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our Website.
Profile Data includes your username and password, purchases or orders made by you, and your marketing preferences.
Usage Data includes information about how you interact with and use our Website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific Website feature in order to analyse general trends in how users are interacting with our Website to help improve it and any related service offering.

We do not actively 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. However, in some circumstances, we may collect or process information, from which it is possible to infer sensitive personal information about you, for the purposes specified in this Privacy Policy.

How is your personal data collected

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
– apply to be a member;
– sign up to any of the events we offer or purchase services;
– request to receive our newsletter; or
– give us feedback or contact us.
Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
Technical Data is collected by our analytics provider Google Analytics.
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe.com.

Use of personal information

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:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: Where it is necessary to conduct our business and pursue our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Legal obligation: Where we need to comply with a legal or regulatory obligation.
Consent: Where we have obtained your consent for a specified purpose, for example if you subscribe to our newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use the various categories of your personal data, and which of the lawful bases (set out above) we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
To register you as a new member	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep a record of all authorised users)
To process and deliver any order from you including to manage payments, fees and charges	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to provide the events and services requested by you)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) 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 exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our Website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about events that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) (b) Consent having obtained your prior consent to receiving direct marketing communications.
To carry out market research through your voluntary participation in surveys		Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

We will not keep your personal data for longer than is necessary. We will delete your personal data within a reasonable time after the end of the provision of the relevant services, and delete copies unless storage of data is required by applicable law or regulation. We may keep your personal data for the duration of any statutory limitation period to the extent necessary. In some circumstances you can ask us to delete your data: please see the paragraph on ‘your legal rights’ below. If you require further information, please contact us.

Direct marketing

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email.

You have the right to withdraw consent to marketing or change your communication preferences, at any time by following the opt-out links within any marketing communications sent to you or by contacting [email protected].

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or member service purposes.

Use of cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.

Disclosures

We will only disclose personal information to the Mechanical-Copyright Protection Society (MCPS) and the Printed Music Licensing Limited (PMLL), government bodies, law enforcement agencies and future owners of our business, as well as service providers we engage to process data on our behalf.

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 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.

International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as UK law. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have a right to:

Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
Object at any time to the processing of your personal data for direct marketing purposes (see the ‘direct marketing’ paragraph above for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us under the ‘contact details’ paragraph below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in certain circumstances.

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.

We try to respond to all legitimate requests within one (1) 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.

Contact details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: [email protected]
Postal address: FAO Legal, Music Publishers Association Limited, 3^rd Floor, 107 Gray’s Inn Road, London, England, WC1X 8TZ

Your right to complain to the ICO

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to MPA’s Privacy Policy

We keep our Privacy Policy under regular review. This Privacy Policy may be updated from time to time so you may wish to check it each time you submit personal information to us. The date of the most recent version will appear on this page.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new email address.

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