Welcome to Powerchord's privacy policy
Powerchord respects your privacy and is committed to protecting personal data.
SCOPE OF POLICY
This privacy policy (together with our end-user licence agreement ("EULA") located at
http://my.peex.live/terms-and-conditions and any additional terms of use incorporated
by reference into the EULA, together our Terms of Use) applies to your use of:
- PEEX mobile application software (App), once you have downloaded or streamed a copy
of the App onto your mobile telephone or handheld device (Device).
- Any of the services accessible through the App (Services) that are available on the
App or our website (Services Site), unless the EULA states that a separate privacy
policy applies to a particular Service, in which case that privacy policy only
applies.
This privacy policy sets out the basis on which any personal data we collect from you,
or that you provide to us, will be processed by us.
It is important that you read this privacy policy together with any other privacy notice
or fair processing notice we may provide on specific occasions when we are collecting
or processing personal data about you so that you are fully aware of how and why
we are using your data. This privacy policy supplements other notices and is not
intended to override them.
Our App, Services and Site are not intended for children and we do not knowingly collect
data relating to children
Powerchord Group Limited is the controller and responsible for your personal data (collectively
referred to as "Powerchord", "we", "us" or "our" in this privacy policy.
Information We Collect From You
Personal data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the identity
has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which
we have grouped together as follows:
-
Identity Data includes first name, last name, username or similar identifier,
marital status, title, and gender.
-
Contact Data includes billing address, delivery address, email address
and telephone numbers.
-
Financial Data includes bank account and payment card details.
-
Transaction Data includes details about payments to and from you and
other details of products and services you have purchased from us.
-
Technical Data includes internet protocol (IP) address, your login data,
browser type and version, time zone setting and location, browser plug-in types
and versions, operating system and platform, and other technology on the devices
you use to access the App and Service Site. This will include unique application
numbers: when you install or uninstall a Service containing a unique application
number or when such a Service searches for automatic updates, that number and
information about your installation, for example, the type of operating system.
-
Profile Data includes your username and password, purchases or orders
made by you, your interests, preferences, and feedback.
-
Usage Data includes information about how you use our website, products
and services.
-
Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share
Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal
data in law as this data will not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing
a specific website feature. However, if we combine or connect Aggregated Data with
your personal data so that it can directly or indirectly identify you, we treat the
combined data as personal data which will be used in accordance with this privacy
policy.
We do not collect any
Special Categories of Personal Data about you (such as details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health, and genetic
and biometric data). Nor do we collect any information about criminal convictions
and offences.
How do we collect your personal data?
We use different methods to collect and process your data including through:
-
Information you give us (Submitted information): You may give us your
Identity, Contact, Profile and Financial Data by completing forms or corresponding
with us. This includes personal data you provide when you:
- Subscribe to marketing on our Service Site;
- Complete a contact form on the Service Site;
- Register for a new user account;
-
Information we collect from automated technologies or interactions.
Each time you visit the Services Site or use our App and as you interact with both we will automatically collect Technical
Data about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, server logs and other similar technologies. Please see
our [COOKIE POLICY] for further details. We will also collect Profile stored
on your device and Usage Data when you interact with our App and Services Sits.
-
Information we receive from other sources (Third Party or Publicly Available
Information).
We are working closely with third parties (including, for example,
business partners, sub-contractors in technical, payment and delivery services,
advertising networks, analytics providers, search information providers, credit
reference agencies) from whom we will receive personal data about you including:
- Technical Data from the following parties: (a) analytics providers such as
Google based outside the EU; and (b) mobile operating systems such as
iOS and Android based outside the EU; and
- Identity, Contact, Financial, Profile and Transaction Data from e-commerce
partners such Luzern based inside the EU.
- Identity, Financial and Contact Data from publicly available sources such
as Companies House and the Electoral Register based inside the EU.
Cookies
We use cookies to distinguish you from other users of the App, Appstore or the Service
Site. This helps us to provide you with a good experience when you use the App or
browse the Services Site and also allows us to improve the App and Services Site.
You can control the use of cookies at the individual browser level, but if you choose
to disable cookies, it may limit your use of certain features or functions of our
Service.
Uses made of the information
We will only use your personal data when the law allows us to. Most commonly, we will
use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered
into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and
your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data
although where we do require consent we will ask for that separately and clearly,
and you have the right to withdraw consent at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use
your personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending
on the specific purpose for which we are using your data. Please contact us if you
need details about the specific legal ground we are relying on to process your personal
data where more than one ground has been set out in the table below.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
To register you as a new user |
- (a) Identity
- (b) Contact
- (c) Profile
|
Performance of a contract with you |
To process and deliver your order including:
- (a) Manage payments, fees and charges
- (b) Collect and recover money owed to us
|
- (a) Identity
- (b) Contact
- (c) Financial
- (d) Transaction
- (e) Marketing and Communications
|
- (a) Performance of a contract with you
- (b) Necessary for our legitimate interests (to recover debts due to us)
|
To manage our relationship with you which will include:
- (a) Notifying you about changes to our terms or privacy policy
- (b) To provide customer support
- (c) Asking you to leave feedback
|
- (a) Identity
- (b) Contact
- (c) Profile
- (d) Marketing and Communications
|
- (a) Performance of a contract with you
- (b) Necessary to comply with a legal obligation
- (c) Necessary for our legitimate interests (to keep our records updated
and to study how customers use our products/services)
|
To administer and protect our business and our App or Service Site (including
troubleshooting, data analysis, security, testing, system maintenance, support,
reporting and hosting of data) |
- (a) Identity
- (b) Contact
- (c) Technical
|
- (a) Necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security, to
prevent fraud and in the context of a business reorganisation or
group restructuring exercise)
- (b) Necessary to comply with a legal obligation
|
To deliver relevant content to you and measure or understand the effectiveness
of that content |
- (a) Identity
- (b) Contact
- (c) Profile
- (d) Usage
- (e) Marketing and Communications
- (f) Technical
|
Necessary for our legitimate interests (to study how customers use our App and
Service Site, to develop them, to grow our business and to inform our marketing
strategy)
|
To use data analytics to improve and personalise our App and Service Site, marketing,
customer relationships and experiences |
|
Necessary for our legitimate interests (to define types of customers for our
App and Service Sites, to keep our App and Service Site updated and relevant,
to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about products or services that may be of interest to you. To facilitate product,
software and applications development, conducting research, analysis, studies
or surveys and identifying usage trends.
|
- (a) Identity
- (b) Contact
- (c) Technical
- (d) Usage
- (e) Profile
- (f) Marketing and Communications
|
Necessary for our legitimate interests (to develop our Apps, Service Site and
grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
what we think you may want or need, or what may be of interest to you. This is how
we decide which products, services and offers may be relevant for you (we call this
marketing).
You will receive marketing communications from us if you have requested information from
us or purchased products or services from us and you have not opted out of receiving
that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third
party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by
contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal
data provided to us as a result of [a product/service purchase, warranty registration,
product/service experience or other transactions].
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out
in the table above.
- Service providers acting as processors based both inside and outside the EU who provide
IT, e-commerce, payment and system administration services.
- Professional advisers acting as processors or controllers including lawyers, accountants,
bankers, auditors and insurers based in the United Kingdom who provide consultancy,
banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based [in the United Kingdom.
Where We store your personal data
The data that We collect from you may be transferred to, and stored at, a destination
outside the European Economic Area (EEA). It may also be processed by staff operating
outside the EEA who work for us or for one of our suppliers. These staff may be engaged
in the fulfilment of your request, order or reservation, the processing of your payment
details and the provision of support services.
- We will only transfer your personal data to countries that have been deemed to provide
an adequate level of protection for personal data by the European Commission.
- 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.
- Where we use providers based in the US, 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.
Please contact us if you want further information on the specific mechanism used by us
when transferring your personal data out of the EEA.
Data Security
We have put in place appropriate security measures to prevent your personal data from
being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors
and other third parties who have a business need to know. They will only process
your personal data on our instructions and they are subject to a duty of confidentiality.
All information you provide to us is stored on secure servers using cloud infrastructure
provided by Microsoft Azure. Any payment transactions carried out by our chosen third-party
provider of payment processing services will be encrypted using Secured Sockets Layer
technology. Where We have given you (or where you have chosen) a password that enables
you to access certain parts of the Services Site, you are responsible for keeping
this password confidential. We ask you not to share a password with anyone.
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 the Services 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 unauthorised access.
We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally required
to do so.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any legal,
regulatory, tax, accounting or reporting requirements. We may retain your personal
data for a longer period in the event of a complaint or if we reasonably believe
there is a prospect of litigation in respect to our relationship with you.
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 your 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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available
in our retention policy which you can request from us by contacting us.
Your rights
-
Request access to your personal data (commonly known as a "data 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.
-
Request correction of the personal data that we hold about you. This
enables you to have any incomplete or inaccurate data we hold about you corrected,
though we may need to verify the accuracy of the new data you provide to us.
-
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 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.
-
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.
-
Request restriction of processing of your personal data. This enables
you to ask us to suspend the processing of your personal data in the following
scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we
have overriding legitimate grounds to use it.
-
Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data
in a structured, commonly used, machine-readable format. Note that this right
only applies to automated information which you initially provided consent for
us to use or where we used the information to perform a contract with you.
-
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.
If you wish to exercise any of the rights set out above, please contact.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the
other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we could refuse to comply with
your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity
and ensure your right to access your personal data (or to exercise any of your other
rights). This is a security measure to ensure that personal data is not disclosed
to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could
take us longer than a month if your request is particularly complex or you have made
a number of requests. In this case, we will notify you and keep you updated.
Changes to privacy policy
Any changes We may make to our privacy policy in the future will be posted on this page
and, where appropriate, notified to you by SMS or by e-mail or when you next start
the App or log onto the Service Sites. The new terms may be displayed on-screen and
you may be required to read and accept them to continue your use of the App or the
Services.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should
be addressed to privacy@powerchord.co.uk or Powerchord Group Limited 1 Blythe Road,
London, United Kingdom, W14 0HG
You have the right to make a complaint at any time to the Information Commissioner's
Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach
the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 29
May 2018.
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 your relationship with us.