By visiting our website, providing us with your Personal Data, or entering into any contract with us, you expressly acknowledge that you have read and agreed to the terms of this Privacy Policy.
This notice does not apply to staff (consultants, employees or other workers).
This Privacy Policy relates to Anara Publishing Limited (company number 10387186 ), a company incorporated in England and Wales, with its registered office at 346 Loughborough Road, Leicester, LE4 5PJ, England.
This Privacy Policy relates to how we process personal data you may give us. If you are an artist, customer or visitor to our website, this Privacy Policy applies to you. As we are a publishing company working worldwide this means Personal Data you give us may be transferred or hosted outside your country of residence.
We take your privacy very seriously. Anara Publishing Limited and affiliates collect and process some Personal Data about you. Under the UK General Data Protection Regulations (UK GDPR, GDPR)) and Data Protection Act 2018 we are required to provide you with certain information about how and why we collect, hold and process and in some cases transfer your Personal Data. This Privacy Policy outlines:
- What data we collect.
- Why and how we collect this data.
- Your rights as an individual with regards to your data.
- Who we share this data with.
- How long we keep this data.
- Our Cookie Notice.
THE PERSONAL DATA THAT WE COLLECT
Personal Data is any information relating to you, which identifies you or allows you to be identified. This may include your name, an ID number, location, online identifier or factors specific to you (such as physical genetic, economic, mental, social or cultural, also physiological (thoughts, feelings).
The Personal Data is any information relating to you, which identifies you or allows you to be identified. This may include your name, an ID number, location , date of birth, address, email address, post/zip code, phone number, country, Skype username, an online identifier (IP Address, and cookie identifiers), time zone and social media usernames/profiles, or factors specific to you such as physical ,genetic, economic, mental, social or cultural, also physiological (thoughts and feelings). We collect this Personal Data from you when signing up to using our service. We also collect your stage name, photos, videos, biographies metadata, ISWC, ISRC, UPC codes.
We also collect some of this data when joining our mailing list so we can keep you up to date with any news or updates to our services.
We use 3rd party payment providers to make royalty payments to you including Convera and PayPal. When you provide payment credentials to us, you confirm that you are permitted to use that payment credential. We always ensure that we have a lawful basis for processing any Personal Data we collect. In this case, the lawful basis for processing this data is; to carry out our contractual obligations in order to promote any recordings we have agreed to publish or pay you any due royalties, as a legal requirement or by getting your express consent to collect this Personal Data.
If you contact us on www.anarapublishing.com the data entered will be sent to a CRM system on Bitrix 24.
HOW WE USE YOUR PERSONAL DATA
We are committed to using your Personal Data responsibly and lawfully. We use your Personal Data to:
- enter into a contract with you and provide agreed services;
- keep accounts and records;
- respond to your queries;
- communicate with you;
- complete payment transactions;
- process any recordings you submit to us to determine if we should work together quickly and efficiently;
- transfer your releases (together with any personal information contained in the metadata and accompanying materials) to various platforms around the world.
- provide you with a report on sales and usage;
- to administer our site and internal operations;
- pay you any due royalties, process payments and issue self-billing invoices;
- ensure we deal with any queries you may have in an efficient and timely manner; and
- send you; any updates on our services, information you have shown interest in or new services we have added.
As with most websites when you access our web pages certain information will be recorded by us, such as your IP address, browser type and information about web pages you have visited (see Cookies section below, for further information). This information is processed to work out how much use of the website is made by different users.
We confirm that we do not use auto decision making or automated profiling/ processing. Auto decision making means making a decision by automated means without human involvement. Auto processing means creating a profile by automatically processing personal data to evaluate things about an individual.
CONTACT US FORM
Where you contact us using the ‘Contact Us’ form on the Anara Publishing website. We keep these enquiries including your contact details for 24 months for follow up purposes, then they are removed from our records once they have been responded to.
ROYALTIES
If we contract with you and you wish to receive royalties our current payment mechanism is via bank transfer if you are based in the UK. If you are based overseas, we will pay you via Convera. Your bank details are kept securely and we conduct regular security checks to ensure continued security of our systems.
MARKETING
We like to keep you up to date with our news and activities. We may do this by sending you information by email, social media, post, telephone call or text message. In order to do this we operate a database that contains your Personal Data.
We currently only use email and social media for marketing.
We use DISCO, which is a sync platform, but it has email creator capabilities. We use analystics, open clicks, and streaming download data analytics features, together with DISCOS newsletter feature.
The majority of our marketing is carried out in-house, we will only share your contact information with our trusted 3rd parties where you have agreed upon a marketing package and communication with them.
We use Facebook Ads and Google Ads to market (but do not share any personal details with them).
When doing marketing campaigns (trying to get promotion for clients) we share release data and sometimes Personal Data such as name and email addresses.
If you would like to unsubscribe from any mailing list you have previously opted into then you can select the ‘unsubscribe’ option at the bottom or top of any newsletter we send. Alternatively, you can also contact us to remove you from any mailing list.
JOB APPLICANTS
If you should apply for a job with Anara we will need to ask you for certain Personal Data and use it to assess your suitability for employment. You do not have to provide us with all Personal Data we request but if you do not it may affect your job application if you decide not to. Any Personal Data you provide us with as part of your job application will only be used for the purpose of progressing your application, or to fulfil legal requirements. We will not share any of the information you provide during the recruitment process with any third party for marketing purposes.
We may need to use the services of a recruitment agency from time to time, in particular, for temporary staff and senior staff. In this instance the recruitment agency will transfer personal details to us.
If you are unsuccessful, the Personal Data you have provided us with will be held for 6 months. If you are successful the Privacy Policy for Staff will detail how we deal with your Personal Data.
TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA
We may pass Personal Data to other organisations within or outside of the EEA who are contracted to provide services to us where the transfer is necessary for the provision of those services. Some of these countries may not have the same level of data protection as the UK. Whenever we transfer your Personal Data outside of the EEA, our procedure for dealing with this is to ensure a similar degree of protection is afforded to it by ensuring one of the following safeguards are implemented:
- checking whether the particular country to which Personal Data is being transferred to has been ‘deemed to provided an adequate level of protection’ for Personal Data by the European Commission;
- by putting contracts in place to ensure the 3rd party is aware of its responsibilities under the General Data Protection Regulations;
- transferring Personal Data to the United States to an entity if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the US.
SECURITY OF PERSONAL DATA
We take technical and administrative steps to protect all of the Personal Data we hold. Only authorised employees and contractors have access to your Personal Data. Although we do our best to protect your Personal Data no system on the internet is 100% safe.
We take appropriate administrative, technical, physical measures and more to safeguard your Personal Data against, theft, loss, unauthorised access and misuse. We store Personal Data on secure servers within the European Union. Our servers are hosted by Amazon in Ireland and Germany In addition, we use protection through data encryption processes such as encryption using SSL Certificates (a digital Certificate that authenticates a websites identity and enables an encrypted connection). We ensure there are limited employees and third-party staff to electronic files containing Personal Data. There are contractual obligations in place for our staff handling data, which impose confidentiality requirements they must fulfil.
Our servers are protected using Amazon CloudFront (a highly secure CDN that provides network and application level protection) and SSH keys which are used to create a secure line of communication between client and the server.
YOUR PERSONAL DATA RIGHTS
- Right to Rectification: If you believe any of your data we have is incorrect or out of date then please contact us to request this data is changed. You have the right to request us to rectify inaccurate information held abut you without undue delay.
- Right to Access: If you would like a copy of the data we hold on you then please contact us. We will require two forms of identification in order to process this request. If we do hold information about you we will give you a description of it, tell you why we are holding it, tell you who it could be disclosed to and let you have a copy of the information in intelligible form. This request can be made free of charge, in writing to the Data Protection Officer, details of which are below.
- Right to Object: If you would like to object to us processing your data or would like us to delete your data, and we don’t have a lawful reason to retain it, you can make a request for us to stop processing and/or delete this data by contacting us.
- Right to confirmation: If you would like to obtain from us confirmation whether or not Personal Data concerning you is being processed by us you can contact us at the email address below.
- Right to Erasure (right to be forgotten): you have the right to have the personal data we hold about you erased without undue delay, however if the processing is necessary for us to perform our service this may be difficult. If you would like to consider having your Personal Data erased please contact us on the email address below.
- Right to data portability: you are entitled to receive from us a copy of the Personal Data we hold concerning you in a machine readable format.
- Right to withdraw consent: where consent forms are the basis for processing, you have the right to withdraw your consent to the processing at any time.
In all cases above you can reach out to us at hello@anarapublishing.com or by using the ‘Contact Us’ form on the website – to make any of these requests.
YOUR RESPONSIBILITIES
GDPR requires that Personal Data is accurate. It is essential that you let us know if your contact details change. If we do not have the correct contact details, we cannot take responsibility for its accuracy.
WHO WE SHARE YOUR DATA WITH
We may need to share some Personal Data, which you provide to us, with a third party in order to seek sync opportunities for you and to assist us with our business operations. Third Party companies will have their own Privacy Policies. Anara do not accept any liability for any of these polices or their terms which you are responsible for reviewing to determine if you accept them. We may pass Personal Data to third parties in the following circumstances:
- your Personal Data may need to be shared internally, for example, in order to deal with a query you may have, or in order to process a any sync of publishing deals;
- all metadata you provide to us (and accompany Materials such as Bio, photographs, videos etc) may be sent to any and all of our partners in order for us to publish your release(s), within the terms of our contract;
- we may need to share details with third-party partners such as our bank Convera, in order to process songs, payments, royalties and invoices. This is to enable us to carry out our contractual obligations;
- we use WordPress for our website https://en-gb.wordpress.org/;
- we use Convera and PayPal for making royalty payments to clients.
- to suppliers (such as IT Service providers) who process information on our behalf;
- to independent suppliers who are under a contractual obligation to assist us with our business operations;
- analytics and search engine providers that assist us in improvement and optimisation of our website;
- we use google ads and facebook ads;
- if required by our internal auditors;
- we may also need to share your details with third parties to issue and resolve legal notices or exercise or defend out legal rights or have rights recognised;
- to protect you, or 3rd parties from illegal acts, fraud, abuse or breach of contract;
- where a platform has informed us there may artificial streaming suspected and they wish to contact you; and
- where an infringement claim is made by a third party and that third party wishes to contact you.
We do not sell your data to any third party companies under any circumstances.
Where we do share your Personal Data with a third party, we ensure any transfer outside of the EU is in accordance with GDPR.
EMBEDDED CONTENT FROM OTHER WEBSITES
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
Your Personal Data will be retained by us for the duration of your contract with us and may be retained for a period after this time in order to carry out our contractual obligations or in accordance with any applicable legal requirements. This may include retaining data necessary; to meet our tax reporting requirements, to enable us to carry out our contractual obligations or for identifying, issuing and resolving any legal requirements. If you require any further information on how long we keep information for, please contact us at the email address detailed below.
Name and Address of the Controller
The Controller is Anara Publishing Limited, and we determine the purposes and means of processing of the Personal Data. Anara Publishing Limited has its registered office at The Old School, 346 Loughorough Road, Leicester, LE4 5PJ, United Kingdom. Phone (0)116-218 2725 Email hello@anarapublishing.com
Name and Address of the Data Protection Officer
The Data Protection officer is Nick Dunn.
You may contact our Data Protection Officer with any enquiries relating to Data Protection. Please use the following email address nick.dunn@horusmusic.global
Name and Address of the Lead Supervisory Authority
The lead supervisory authority overseeing is the Information Commissioner’s office, Wycliffe House, Water Lane, Cheshire, SK95AF, United Kingdom, Phone +44 (0) 3031231113.
Representation for data subjects in the European Union
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our European Privacy Representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/17748512208