This privacy policy applies between you, the User of this Website and Hal Leonard Europe Limited, the owner and provider of this Website. Hal Leonard Europe Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Personal Data collected by us or provided by you in relation to your use of the Website. This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: www.halleonardeurope.com/terms.
Please read this privacy policy carefully.
Definitions and interpretation
In this privacy policy, the following definitions are used:
- Personal Data
Collectively all information that you submit to Hal Leonard Europe Limited via the Website or that we collect automatically. This definition incorporates, where applicable, the definitions provided in the Personal Data Protection Laws; - Cookies
A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies); - Data Protection Laws
All applicable laws and regulations relating to the processing of Personal Data, including:
- the General Data Protection Regulation (EU) 2016/679 (EU GDPR),
- the UK General Data Protection Regulation (UK GDPR) as incorporated into UK law by the European Union (Withdrawal) Act 2018,
- the Data Protection Act 2018, and
- any relevant national implementing or supplementary legislation.
- Hal Leonard Europe Limited, ‘we’ or ‘us’
Hal Leonard Europe Limited, a company incorporated in England and Wales with registered number 10684804 whose registered office is at Acre House, 11/15 William Road, London, United Kingdom, NW1 3ER; - UK and EU Cookie Law
- in the United Kingdom, the Privacy and Electronic Communications Regulations 2003 (PECR) as amended; and
- in the European Union, the Directive 2002/58/EC (ePrivacy Directive), including national implementing laws governing the use of cookies and similar technologies.
- User or you
Any individual accessing or using the Website, other than employees or contractors of Hal Leonard Europe Limited acting in the scope of their professional duties. - Website
The website that you are currently using, www.halleonardeurope.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
In this privacy policy, unless the context requires a different interpretation:
- The singular includes the plural and vice versa;
- References to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
- A reference to a person includes firms, companies, government entities, trusts and partnerships;
- “Including” is understood to mean “including without limitation”;
- Reference to any statutory provision includes any modification or amendment of it;
- The headings and sub-headings do not form part of this privacy policy.
Scope of this Privacy Policy
This privacy policy applies only to the actions of Hal Leonard Europe Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
For purposes of the applicable Personal Data Protection Laws, Hal Leonard Europe Limited is the “data controller”. This means that Hal Leonard Europe Limited determines the purposes for which, and the manner in which, your Personal Data is processed.
Principles of processing
We agree to observe the following principles when processing Personal Data:
- Fairness: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it in accordance with applicable law.
- Lawfulness: We will process Personal Data only on lawful grounds.
- Purpose limitation: We will process Personal Data for specified and legitimate purposes, and will not process it in a manner that is incompatible with those purposes, unless permitted by applicable data protection laws.
- Data minimization: We will process Personal Data that is adequate, relevant and limited to what is necessary to achieve the purposes for which the data are processed.
- Data accuracy: We take appropriate measures to ensure that the Personal Data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing us promptly of any changes or errors. You should notify us of any changes to the Personal Data that we hold about you (e.g. new home address or change of name).
- Data security: We use appropriate technical and organisational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. Specific measures we use include to-date secure network architectures that contain firewalls and intrusion detection devices and backups.
Personal Data collected
We may collect the following Personal Data:
- Contact Information such as email addresses and/or telephone numbers;
- IP address (automatically collected);
- Web browser type and version (automatically collected);
in each case, in accordance with this Privacy Policy.
How we collect Personal Data
We collect Personal Data in the following ways:
- Personal Data is given to us by you; and
- Personal Data is collected automatically.
Personal Data that is given to us by you
Hal Leonard Europe Limited will collect your Personal Data in a number of ways, for example: when you contact us through the Website, by telephone, post, e-mail or through any other means; in each case, in accordance with this Privacy Policy.
Personal Data that is collected automatically
To the extent that you access the Website, we will collect your Personal Data automatically. For example, we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content. We will collect your Personal Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our purpose for using your Personal Data
The table below outlines:
- purposes for which we process your personal data
- legal grounds for each processing activity
- Contractual necessity: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
- Legitimate interests: the processing is necessary for our legitimate interests, unless interests are overridden by the interests or fundamental rights and freedoms of the data subject.
- Consent: you have given clear consent to process your personal data for a specific purpose.
- Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
- categories of personal data we collect and use for each purpose
| Purpose of processing | Legal grounds | Categories of Personal Data |
| To respond to your inquiries or requests submitted via our contact channels (e.g. email) |
Depending on the nature of your query, we will rely either on the necessity to take steps prior to entering into a contract with a potential customer or our legitimate interest to respond to customer queries |
– Email address
– Request text |
| To ensure the functioning of our Website | Legitimate interest |
– IP address |
| To ensure the improvement of the quality of the service and the user experience of using the Website through the collection, storage and further analysis of product and technical events of your interaction with the Website |
Consent
|
– IP address – User browser info (clicks, page views) – Cookies |
Who we share Personal Data with
All your personal information is stored on our servers in the UK. However, we use third party service providers and business partners who may be operating from outside the UK and EEA and therefore, your information may be transferred to, or accessed from those countries.
We may disclose your personal data to the following categories of recipients:
- to our group companies for purposes consistent with this Privacy Policy. We take precautions to allow access to personal data only to those staff members who have a legitimate business need for access and with a contractual prohibition of using the personal data for any other purpose;
- to our third party vendors, services providers and partners who provide data processing services to us, or who otherwise process personal data for purposes that are described in this Privacy Policy or notified to you when we collect your personal data. These vendors provide us with support, analytics, and other services. We do not use third party advertising services or data brokers;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the personal data for any other purpose;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Policy;
- to any other person if you have provided your prior consent to the disclosure.
Data retention
Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Personal Data be deleted.
Even if we delete your Personal Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Your rights
You have the following rights in relation to your Personal Data:
- Right to access. The right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct. The right to have your Personal Data rectified if it is inaccurate or incomplete.
- Right to erase. The right to request that we delete or remove your Personal Data from our systems.
- Right to restrict our use of your Personal Data. The right to “block” us from using your Personal Data or limit the way in which we can use it.
- Right to data portability. The right to request that we move, copy or transfer your Personal Data.
- Right to object. The right to object to our use of your Personal Data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Personal Data), please email the DPO (dpo@halleonardeurope.com)
If you are not satisfied with the way a complaint you make in relation to your Personal Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
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 the period for which we hold it.
Links to other websites
This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
Changes of business ownership and control
Hal Leonard Europe Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Hal Leonard Europe Limited. Personal Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Personal Data for the purposes for which it was originally supplied to us. We may also disclose Personal Data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Cookies
This Website may place and access certain Cookies on your computer. Hal Leonard Europe Limited uses Cookies to improve your experience of using the Website. Hal Leonard Europe Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
All Cookies used by this Website are used in accordance with current UK and EU Cookie Law. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Hal Leonard Europe Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
This Website may place the following Cookies:
- Strictly necessary cookies
Necessary cookies are absolutely essential for the website to function properly. This category only includes cookies that ensure basic functionalities and security features of the website. These cookies do not store any personal information.
- Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
How to contact us
If you have any questions or complaints about our Privacy Policy, you can contact us at dpo@halleonardeurope.com. Hal Leonard Europe Limited is responsible for overall management of personal data processing and has designated a personal data protection manager as follows to handle personal data processing requests:
Position: Data Protection Officer
Name: Artem Neroba
Email: dpo@halleonardeurope.com
Changes to this privacy policy
Hal Leonard Europe Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.