PRIVACY POLICY
Last updated 1st June, 2023
This privacy notice for Fate Sister Music Publishing Ltd (‘Company’, ‘we’, ‘us’, or ‘our’), describes how
and why we might collect, store, use, and/or share (‘process‘) your information when you use our
services (‘Services‘), such as when you:
Visit our website at http://www.fsmusicpublishing.com and http://www.fsmusicpublishing.co.uk, or any
website of ours that links to this privacy notice Download and use our mobile application, or any other
application of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and
choices. If you do not agree with our policies and practices, please do not use our Services. If you still have
any questions or concerns, please contact us at info@fsmusicpublishing.co.uk.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about
any of these topics by clicking the link following each key point or by using our table of contents
below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may
process personal information depending on how you interact with Fate Sister Music Publishing Ltd and
the Services, the choices you make, and the products and features you use. Learn more about personal
information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third
parties.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your consent. We process your
information only when we have a valid legal reason to do so. Learn more about how we process your
information.
In what situations and with which parties do we share personal information? We may share
information in specific situations and with specific third parties. Learn more about when and with whom
we share your personal information.
How do we keep your information safe? We have organisational and technical processes and
procedures in place to protect your personal information. However, no electronic transmission over the
internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise
or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat
our security and improperly collect, access, steal, or modify your information. Learn more about how we
keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law
may mean you have certain rights regarding your personal information. Learn more about your privacy
rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject
access request, or by contacting us. We will consider and act upon any request in accordance with
applicable data protection laws.
Want to learn more about what Fate Sister Music Publishing Ltd does with any information we collect?
Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION? 4. WHEN AND
WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services,
express an interest in obtaining information about us or our products and Services, when you participate
in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the
context of your interactions with us and the Services, the choices you make, and the products and features
you use. The personal information we collect may include the following:
names
phone numbers
email addresses
mailing addresses
contact preferences
billing addresses
debit/credit card numbers
job titles
usernames
passwords
contact or authentication data
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as
your payment instrument number, and the security code associated with your payment instrument. All
payment data is
stored by MemberPress. You may find their privacy notice link(s) here:
https://memberpress.com/privacy/.
All personal information that you provide to us must be true, complete, and accurate, and you must notify
us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but may
include device and usage information, such as your IP address, browser and device characteristics,
operating system, language preferences, referring URLs, device name, country, location, information
about how and when you use our Services, and other technical information. This information is primarily
needed to maintain the security and operation of our Services, and for our internal analytics and
reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. The
information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance
information our servers automatically collect when you access or use our Services and which we record
in log files. Depending on how you interact with us, this log data may include your IP address, device
information, browser type, and settings and information about your activity in the Services (such as the
date/time stamps associated with your usage, pages and files viewed, searches, and other actions you
take such as which features you use), device event information (such as system activity, error reports
(sometimes called ‘crash dumps’), and hardware settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also process your information for
other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact
with our Services, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may
process your information so you can create and log in to your account, as well as keep your account in
working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide
you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to
your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details
about our products and services, changes to our terms and policies, and other similar information.
To fulfill and manage your orders. We may process your information to fulfil and manage your orders,
payments, returns, and exchanges made through the Services.
To enable user-to-user communications. We may process your information if you choose to use any of
our offerings that allow for communication with another user.
To request feedback. We may process your information when necessary to request feedback and to
contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information
you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You
can opt out of our marketing emails at any time. For more information, see ‘WHAT ARE YOUR PRIVACY
RIGHTS?’ below.
To deliver targeted advertising to you. We may process your information to develop and display
personalised content and advertising tailored to your interests, location, and more.
To protect our Services. We may process your information as part of our efforts to keep our Services
safe and secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our Services to better
understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your
information to better understand how to provide marketing and promotional campaigns that are most
relevant to you. To save or protect an individual’s vital interest. We may process your information
when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid
legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to
provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil
our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases
we rely on in order to process your personal information. As such, we may rely on the following legal
bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e. consent) to use your
personal information for a specific purpose. You can withdraw your consent at any time. Learn more
about withdrawing your consent.
Performance of a Contract. We may process your personal information when we believe it is necessary
to fulfil our contractual obligations to you, including providing our Services or at your request prior to
entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to
achieve our legitimate business interests and those interests do not outweigh your interests and
fundamental rights and freedoms. For example, we may process your personal information for some of
the purposes described in order to:
Send users information about special offers and discounts on our products and services Develop and
display personalised and relevant advertising content for our users Analyse how our Services are used so
we can improve them to engage and retain users Support our marketing activities
Diagnose problems and/or prevent fraudulent activities
Understand how our users use our products and services so we can improve user experience
Legal Obligations. We may process your information where we believe it is necessary for compliance
with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency,
exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are
involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital
interests or the vital interests of a third party, such as situations involving potential threats to the safety
of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following
third parties. We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our
business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those
affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint
venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain
products, services, or promotions.
Other Users. When you share personal information (for example, by posting comments, contributions, or
other content to the Services) or otherwise interact with public areas of the Services, such personal
information may be viewed by all users and may be publicly made available outside the Services in
perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you
within our Services, and view your profile.
Offer Wall. Our application(s) may display a third-party hosted ‘offer wall’. Such an offer wall allows
third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance
and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be
displayed to you based on certain data, such as your geographic area or demographic information. When
you click on an offer wall, you will be brought to an external website belonging to other persons and will
leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall
provider in order to prevent fraud and properly credit your account with the relevant reward.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we
may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services, including our offer wall, may link to third-party websites, online services, or mobile
applications and/or contain advertisements from third parties that are not affiliated with us and which
may link to other websites, services, or applications. Accordingly, we do not make any guarantee
regarding any such third parties, and we will not be liable for any loss or damage caused by the use of
such third-party websites, services, or applications. The inclusion of a link towards a third-party website,
service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy
of data you provide to any third parties. Any data collected by third parties is not covered by this privacy
notice. We are not responsible for the content or privacy and security practices and policies of any third
parties, including other websites, services, or applications that may be linked to or from the Services. You
should review the policies of such third parties and contact them directly to respond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and how you can refuse certain
cookies is set out in our
Cookie Notice.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy
notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this
privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal
requirements). No purpose in this notice will require us keeping your personal information for longer
than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either
delete or anonymise such information, 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.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational and technical
security measures.
We have implemented appropriate and reasonable technical and organisational security measures
designed to protect the security of any personal information we process. However, despite our safeguards
and efforts to secure your information, no electronic transmission over the Internet or information
storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Although we will do our best to protect your
personal information, transmission of personal information to and from our Services is at your own risk.
You should only access the Services within a secure environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent
to such minor dependent’s use of the Services. If we learn that personal information from users less than
18 years of age has been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we may have collected from
children under age 18, please contact us at info@fsmusicpublishing.co.uk.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have
rights that allow you greater access to and control over your personal information. You may review, change,
or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws.
These may include the right (i) to request access and obtain a copy of your personal information, (ii) to
request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if
applicable, to data portability. In certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by contacting us by using the
contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your Member State data protection authority or UK
data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information
Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, you
have the right to withdraw your consent at any time. You can withdraw your consent at any time by
contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor,
will it affect the processing of your personal information conducted in reliance on lawful processing
grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing
and promotional communications at any time by clicking on the unsubscribe link in the emails that we
send, or by contacting us using the details provided in the section ‘HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?’ below. You will then be removed from the marketing lists. However, we may still
communicate with you — for example, to send you service-related messages that are necessary for the
administration and use of your account, to respond to service requests, or for other non-marketing
purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your
account, you can: Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information
from our active databases. However, we may retain some information in our files to prevent fraud,
troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with
applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you
prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose
to remove cookies or reject cookies, this could affect certain features or services of our Services. You may
also opt out of interest-based advertising by advertisers on our Services.
If you have questions or comments about your privacy rights, you may email us at
info@fsmusicpublishing.co.uk.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track
(‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage no uniform technology standard for
recognising and implementing DNT signals has been finalised. As such, we do not currently respond to
DNT browser signals or any other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your
personal information.
California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are
California residents to request and obtain from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to third parties for direct marketing purposes
and the names and addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like to make such a
request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you
have the right to request removal of unwanted data that you publicly post on the Services. To request
removal of such data, please contact us using the contact information provided below and include the
email address associated with your account and a statement that you reside in California. We will make
sure the data is not publicly displayed on the Services, but please be aware that the data may not be
completely or comprehensively removed from all our systems (e.g. backups, etc.).
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an
updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make
material changes to this privacy notice, we may notify you either by prominently posting a notice of such
changes or by directly sending you a notification. We encourage you to review this privacy notice
frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at info@fsmusicpublishing.co.uk
or contact us by post at:
Fate Sister Music Publishing Ltd 85 Great Portland Street London W1W 7LT
United Kingdom
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal
information we collect from you, change that information, or delete it. To request to review, update, or
delete your personal information, please fill out and submit a data subject access request.
