THE SAYRE SERIES PRIVACY POLICY

Updated July 2018

The Sayre Series and Brownstyle LLC are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, in connection with our site (as defined below), will be collected, stored, used, disclosed and otherwise processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The Sayre Series, LLC is the controller of your personal data that it collects from you or otherwise receives. This means that it determines the purposes and means of the processing of your personal data. However, it will process your personal data in accordance with this policy.

1)     Definitions

In this policy:

  1. a)     we/our/us refers to The Sayre Series, LLC, a Delaware limited liability company, whose principal address is 1101 Hillsborough, Suite A2, Raleigh, NC, United States; and
  2. b)     personal data means any information relating to an identified or identifiable natural person (a data subject), and includes “personally identifiable information” as that term is used in the United States of America (USA). An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2)     Information we collect about you; policy concerning children

  1. a)     We will collect and process the following personal data about you:
  2. i)      The information you give us. This is information about you that you give us by contacting us via our website or filling in online forms on our website at http://thesayreseries.com (our site or our website), by communicating with us by telephone, e-mail or otherwise, by ordering products or services from us, or by posting reviews on our site. The information you give us may include: your name, e-mail address and phone number; your address/shipping address (including city, state/province, ZIP Code and country code); your billing/payment information (including card holder name, daytime phone, billing address, card type, and/or other card details); where relevant, your job title, company/employer name and work contact details including phone number and address; and, if you are a music teacher or other music professional, in addition to information as above, details of the type of music you teach or your professional role, and your membership of any teaching association or other organisation for music professionals. Please be aware that if you fail to provide to us information that we ask for, we may be unable to provide products or services to you or otherwise to fulfill your requirements. It is important that we hold current information about you, so please provide us with any appropriate updates.
  3. ii)     Information we collect about you. With regard to each of your visits to our site we will normally automatically collect the following information:

(1)   technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, your login information, and information about your computer or other device being used to connect to our site, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(2)   information about your visit, including the full Uniform Resource Locators (URL), click-stream to, through, and from our site (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

iii)   Information we receive from other sources. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers) who may provide information to us regarding our services to you. Such information may include delivery tracking data, delivery confirmations, and transaction IDs. Except in the case of payment services providers (who will inform us whether using your card is approved or declined) these third parties do not provide us with additional personal data. If your payment is declined we will inform you.

  1. b)     We do not knowingly collect personal data relating to children. If you are under the age of majority under the applicable law of the jurisdiction in which you are located please do not use this website or order products or services from us. Please, instead, ask an adult, such as your parent or guardian, to do these things for you.

 

3)     Uses made of the information

  1. a)     We comply with the law. We will only use your personal data to the extent that the law allows us to do so. Under the EU General Data Protection Regulation (the GDPR) we will rely on the following legal basis for processing your personal data:
  2. i)      where it is necessary to perform a contract we have entered into or are about to enter into with you;
  3. ii)     where it is necessary for the purposes of our legitimate interests (or those of a third-party) and your interests or fundamental rights and freedoms do not override those interests. Our legitimate interest means our interest in conducting and managing our business, including enabling us to provide you and our other customers with the best products and services we can and the best and most secure experience when dealing with us. In assessing our legitimate interests, we make sure we consider and balance any potential impact (both positive and negative) on you and others and your rights;

iii)   where you have given us your consent.

  1. b)     Information you give to us. We will use this information:
  2. i)      to process an inquiry received from you, or to respond to an expression of interest from you in one or more of our products and services;
  3. ii)     to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request or purchase from us;

iii)   to collect payments for any products or services you purchase from us;

  1. iv)    to provide you with information and status updates on orders that you place;
  2. v)     to provide payments, rebates or other benefits to you to which you are entitled pursuant to any of our membership programs (Affiliates, Easy Rebates and SMP Press);
  3. vi)    to moderate and publish reviews that you post on our site;

vii)  to provide you with newsletters;

viii) to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;

  1. ix)    to provide you with information about other products and services we or our Corporate Affiliates (as defined below) offer that are complementary to or related to those that you have already purchased or enquired about. This may include products and services that we or our Corporate Affiliates make available through one or more of our other websites or the websites of such Corporate Affiliates;
  2. x)    to provide your information to our marketing department who may contact you to request feedback and comments on our products or services or to provide information to you which may be of interest to you;
  3. xi)     to notify you about changes to our products or services; and

xii)    to try to ensure that content from our site is presented in the most effective manner for you and for your computer or another device.

  1. c)     Information we collect about you. We will use this information:
  2. i)      to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  3. ii)     to improve our site to try to ensure that content is presented in the most effective manner for you and for your computer or another device;

iii)   to allow you to participate in interactive features of our service when you choose to do so;

  1. iv)    as part of our efforts to keep our site safe and secure;
  2. v)     to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  3. vi)    to make suggestions and recommendations to you and other users of our site about products or services that may interest you or them; and

vii)  to provide you with the most relevant information, promotions, and products during your visit to our site.

5)     Disclosure of your information

  1. a)     You agree that we have the right to share your personal data with selected third parties  (and agree that third parties may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites) including:
  2. i)      entities that provide customer service applications to us to better enable us to respond to your requests for information or assistance;
  3. ii)     business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or them, for example, suppliers of shipping services to fulfill your orders for physical products;

iii)   credit card processors and other payment services providers, for the purposes of effecting payments by or to you;

  1. iv)    entities who provide services to us in relation to marketing, in order to assist us in marketing to you as described above;
  2. v)     advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
  3. vi)    cloud service providers, including the entity that hosts this website, for the purposes of storage and such hosting; and

vii)  analytics providers that assist us in the improvement and optimization of our site.

Google Analytics.  Please note in particular that our site uses Google Analytics, including its data reporting features.  Information collected by Google Analytics includes but is not limited to web metrics.  For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Do Not Track.  The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

  1. b)     We will disclose your personal data to third parties:
  2. i)      if The Sayre Series or Brownstyle LLC or all or substantially all its assets or the relevant part of its assets are acquired by a third-party, in which case personal data held by it about its customers (or the relevant customers) will be one of the transferred assets and we may disclose your personal data in connection with any such transaction;
  3. ii)     if we are under a duty to disclose or share your personal data in order to: comply with any legal obligation, including without limitation lawful requests by public authorities such as to meet national security or law enforcement requirements, and including with regulators and other authorities who require reporting of processing activities in certain circumstances; or to enforce or apply our standard terms and conditions of business and other agreements; or to protect the rights, property, or safety of The Sayre Series, Brownstyle LLC, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;

iii)   if we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding; or

  1. iv)    to our Corporate Affiliates; for purposes of this privacy policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with The Sayre Series, Brownstyle LLC, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

6)     Where we store your personal data

  1. a)     All information you provide to us is stored on secure servers. These may be located anywhere in the world, including the USA. See below concerning international transfers of personal data.
  2. b)     Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
  3. c)     We will also use reasonable efforts intended to ensure that third parties to whom we disclose your personal data to take appropriate measures to ensure the security of your personal data and not to use it except for the purposes for which we disclose it to them.

7)     International transfers of personal data

  1. a)     We may share your personal data within the group of companies of which The Sayre Series, LLC is a member (i.e. amongst its Corporate Affiliates, as defined above). This may involve transferring your personal data outside the European Economic Area (EEA), including to the USA.
  2. b)     Many of our external third parties to whom we transfer your personal data as described above are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
  3. c)     We may transfer your personal data out of the EEA, including without limitation in the following contexts:
  4. i)      We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
  5. ii)     Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;

iii)   Where we use providers based in the United States of America, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield;

  1. iv)    You have specifically consented to the proposed transfer.You hereby expressly grant consent to us to: (a) process and disclose your personal data in accordance with this privacy policy; (b) transfer such personal data throughout the world, including to the United States or other countries that do not ensure adequate protection for personal data (as determined by the European Commission); and (c) disclose such personal data to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements; or
  2. v)     The transfer is necessary for the performance of a contract between you and us.

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

8)     Retention of personal data

  1. a)     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 that 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 requirements. If by law we are required to retain any information about our customers or their interactions with us, we will retain your personal data insofar as required to comply with such law.
  2. b)     We may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9)     Your legal rights

  1. a)     Under certain circumstances, you have the right to:
  2. i)      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.
  3. ii)     Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

iii)   Request erasure of your personal data. 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 in certain other circumstances, namely 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.

  1. iv)    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
  2. v)     Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it.
  3. vi)    Request the transfer of your personal data to you or to another person or entity. In that case, we will provide to you, or to the person or entity to whom you wish us to transfer your personal data, your personal data in a structured, commonly used, machine-readable format.

vii)  Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

viii) Lodge a complaint with the UK Information Commissioner’s Office (ICO) or another applicable regulator. If you have any complaints about the way in which we process your personal data please do contact us, as set out below, as we would appreciate the opportunity to resolve your complaint.

  1. b)     If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data or request that we transfer a copy of your personal data to another party, please contact us using the contact details provided below.

10)  Other websites

Our site may, from time to time, contain links to and from the websites or apps of our partner networks, advertisers, and affiliates.  If you follow a link to any of these websites or apps, please note that these websites and apps have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites or apps.

11)  Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

12)  Contact

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to info@thesayreseries.com

13)  Public Areas

Our site may feature various community areas and other public forums, including blog areas and places where users can post reviews (collectively, the “Public Areas”). These Public Areas are open to the public and should not be considered private. We cannot prevent such information from being used in a manner that may violate this privacy policy, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings.

Any information you share in a Public Area (including personal data) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot control or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If you mistakenly post personal data in a Public Area you can send us an e-mail to request that we remove it by contacting us at info@thesayreseries.com. You should understand that in some cases, we may not be able to remove your information.

 

 

 

 

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