PRIVACY POLICY

SEMANTIC AUDIO LABS LTD

INTRODUCTION

Semantic Audio Labs Limited is the company which provides you with the Faders platform.

The purpose of Faders is to allow you to create or edit music or other audio inputs using the wide array of audio tools available on the Faders platform.

Some of the facilities of the platform are available to visitors and others are only available to those who create an account with us (“Creators”).

We at Semantic Audio Labs do not intend to collect much personal data about our Creators or the visitors to our platform but what data we do have to collect will be processed in accordance with this privacy policy.

We are committed to a policy of collecting and processing no more of your personal data than is strictly necessary for you to have the full benefit of the Faders platform and it is this policy that describes our relationship with you, the data subject.

This privacy notice was drafted with brevity and clarity in mind.

For further information contact us using the details given at the end of this policy or go to https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ for more information.

OUR POLICY

We at Semantic Audio Labs are committed to protecting your privacy and ensuring that personal information is collected and used appropriately, lawfully and transparently.

This Privacy Policy gives information about Faders and the way that we deal with the personal data of visitors to the platform and Creators.

In this policy we will provide you with the following information:

WHO WE ARE

Semantic Audio Labs Limited is a company incorporated in England & Wales under company number 11702989, having its registered office at 130 Shaftesbury Avenue, 2nd Floor, London, United Kingdom, W1D 5EU.

The company is the owner of the website located on the domain faders.io known as ‘Faders’.

Faders is hosted by Amazon Web Services Inc, a company incorporated under the laws of the state of Washington, USA but having the ability to provide hosting services within the UK.

The servers upon which the platform is hosted are located in London.

We determine the purposes and means of processing personal data of visitors to and Creators of Faders. This means we are the data controller for the personal data which is processed through the platform and therefore we are responsible for managing this data and ensuring compliance.

THE PERSONAL DATA WE COLLECT

If you are visiting Faders but do not have an account, the servers will recognise the browser on the computer or other device that you are using to view the platform by seeing the IP address given by your browser.

Some cookies may be stored, temporarily, on your computer or other device. To understand more about our use of cookies, please follow this link:faders.io/cookies.

When creating an account with us through the platform, we will gather some personal information.

Each person signing up as a Creator will create their own username. Creators can be private users (“Consumer Users”) or they can be representatives of businesses (“Business Users”). In both instances we will ask for that person’s name and email address.

In the course of using certain of the functions of the platform we may require further information from Business Users. This information will be business information relevant to any transaction that may be made between us through the platform

When we collect personal information about you the personal information we collect will include:

We collect personal information directly from you. For example, we ask for the information when you create your Creator account on Faders.

ON WHAT BASIS DO WE COLLECT DATA

Processing of personal data is allowed under a number of lawful bases. The data required for the provision of services to Creators is processed on the basis we have a contract with each Creator. That contract is detailed elsewhere on the platform.

However you have rights, as listed below, which impact how we can use and process your data.

SPECIAL CATEGORY INFORMATION

We warn Creators that they should not send any such special category data to us as our policy is not to process such data.

However, we recognise that use of the platform may create circumstances where a Creator imparts personal information which is then processed on our host server.

A Creator may provide such data through their use of Faders, perhaps because in the course of creating music about their own conditions or beliefs.

We expect this to be a rare occurrence (if it ever does happen).

We recognise that it may be the case that you choose to publish information on the platform about yourself through music or by storytelling. In this case you will be providing that data in the course of the contract between us in your use of the platform.

It may also be that the person publishing the information is not the person to whom the information relates. We at Faders will not have sufficient information to identify that person and we have no need of that information.

In these circumstances we will not be processing that person’s data because we will not be able to identify them.

Any special category data which is published on the platform will therefore be lawfully processed.

Where it is not necessary to publish special category data through Faders, then we require our Creators not to do so.

DATA RETENTION

Our policy is to keep personal information only for so long as is necessary to keep it for the purpose for which it was collected.

We will keep personal information about our Consumer Users for only as long as they continue to maintain a Creator account on Faders.

Once a Creator has closed their account or the account has not been used for a continuous period of 3 months, we will ensure that all personal data concerning that Creator is permanently removed from our systems in order to meet regulatory or legislative requirements.

Personal information will be securely disposed of.

HOW WE USE YOUR PERSONAL INFORMATION

We process your information in order to support and maintain our contractual relationship with you and to comply with legal and regulatory requirements.

This includes the following:

We also process your data for specific business purposes to enable us to give you the best service and the best and most secure experience.

Our business purposes include the following:

You have the right to object to this processing if you wish, please see the “YOUR RIGHTS” section below.

Please bear in mind that if you object this may affect our ability to provide our services for you.

WHO WE SHARE YOUR INFORMATION WITH AND WHY

We share your information with third parties who perform tasks for us and help us to provide the services to you and also as may be required by law. These include:

HOW WE KEEP YOUR INFORMATION SECURE

We are committed to ensuring the confidentiality of the personal information that we hold and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.

YOUR RIGHTS

We try to be as open as we can be in terms of giving people access to their personal information and therefore have outlined your rights below.

Each Creator whose data is processed through Faders has the following rights in relation to their own data:

If you wish to correct, restrict, delete or make changes to your personal information, or any of the data subject rights listed above, please contact us at using the details given below.

HOW TO CONTACT US

If you have questions about this policy, need further information about our privacy practices, or wish to give or withdraw consent, exercise preferences or correct your personal information, please contact us by email via info@semanticaudio.co.uk.

HOW TO COMPLAIN

If you wish to raise a complaint about how we have handled your personal data, you can contact The Office of Data Protection who will investigate the matter.

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to our regulator:

Information Governance department

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

ENGLAND

See www.ico.org.uk/concerns or by phone to 0303 123 1113

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