19 Aug
Universal Music Limited (“UM” or “we”) respects the privacy of the individuals it deals with, and is committed to complying fully with its obligations under the Personal Data (Privacy) Ordinance, Cap 486 Laws of Hong Kong (“the Ordinance”). “Personal data” is any data relating directly or indirectly to an individual from which it is practicable for the identity of the individual to be ascertained.
This Policy outlines the types of personal data UM collects and explains how it collects, uses, discloses and holds that data. The Policy also explains how you can gain access to personal data that UM holds about you and provides contact details for UM. Finally, the Policy sets out the way UM handles personal data online (i.e. on the internet).
This privacy policy applies to all UM websites including, but not limited to, http://www.umg.com.hk.
UM is one of the largest producers and distributors of entertainment goods and services. For the purposes of this Policy, these are referred to as “our goods and/or services”.
The primary purpose for which UM collects personal data is so that we can provide you with our goods or services and provide you with information in relation to our goods or services. UM also uses your personal data for purposes incidental to these purposes including, without limitation, for the purpose of managing its relationship with you, communicating with you effectively and identifying which of our goods and services may interest you in the future.
UM does not collect information or data it does not need. For example, UM does not collect sensitive information (such as information about your health or political beliefs) because it does not need it in order to provide you with our goods or services.
If you ask UM to provide you with our goods or services (including signing up to join one of its clubs, submitting a competition entry form, or choosing to receive promotional information), UM may ask you to provide your name and contact details such as telephone number, postal address and email address. UM may also ask you for additional information including, but not limited to, your age and entertainment preferences (e.g. what type of music you prefer).
You can refuse to provide UM with the personal data that it requests from you or you can refuse to allow UM to continue to use the personal data that it has collected from you. However, if you do not provide UM with the personal data it requests or refuse to allow UM to continue to use your personal data, UM may not be able to provide you with our goods or services.
If at any time you do not wish to be notified about goods, services or promotions offered by UM, or if you do not wish to receive any further communications from UM, you can opt-out of any, or all, UM communications by directly contacting UM. Further, if at any time you wish UM to stop using your personal data, you can contact UM. Details of how to contact UM are set out in section 9 below.
UM collects personal data in a number of different ways. The most common ways in which UM collects personal data, and the purposes for which that data is collected, are as follows:
Personal data is collected from application forms (including on UM websites) when individuals apply to become members of clubs run by UM. This data is collected for the purpose of providing news, information, offers and other services to members in accordance with the terms and conditions of the club.
Personal data is collected from competition entries and other promotions, for the purpose of running the competition or promotion and contacting the winner(s), and, if entrants/applicants do not tell UM otherwise, for the purpose of sending information, news and offers in relation to our goods and services.
Personal data is collected from order forms when UM’s goods and services are ordered by distributors and retailers, for the purpose of fulfilling the order and delivering the goods, and to maintain its relationship with the individual concerned. Personal data collected in this context may include credit, charge or debit card details. If you provide this additional credit information it will only be used for the purposes of purchasing our goods or services.
Personal data is collected from online order forms when UM’s goods or services are ordered by individuals, for the purpose of fulfilling the order and delivering the goods, and to maintain its relationship with the individual concerned.
Personal data collected in this context may include credit, charge or debit card details.
Personal data is collected from telephone, email, written and in-person enquiries directed to UM, for the purpose of responding to the enquiries.
Personal data may be collected from UM websites through automatic processes such as cookies, as discussed in section 8 below.
Generally, UM will not disclose personal data to individuals or organisations outside UM without your consent. However, in the circumstances described below, personal data may be disclosed outside UM.
(a) Outsourcing
From time to time, UM may provide information to other companies within the UM and to other companies outside the UM that perform certain functions on its behalf. Any personal data transferred between UM companies in such circumstances will be handled in accordance with this Policy. UM may also disclose personal data to third parties to whom it contracts out specialised functions (e.g. mailing houses, printing companies and event organisers). For example, when UM conducts a promotion, it may enter into a contractual arrangement with a mailing house, which will be subject to a contractual obligation to distribute on UM’s behalf information about its products, services or promotions. If UM does disclose personal data to third party contractors under outsourcing or contracting arrangements, UM will take steps to ensure that those contractors:
handle your personal data consistently with this Policy (regardless of whether they are a small business, or would otherwise be exempt from the Ordincance );
only use your personal data in order to provide the specific services or to perform the specific functions required by UM; and
store your personal data securely, and only for as long as is necessary to provide the required services or perform the required functions.
(b) Disclosures required or permitted by law
UM may also disclose personal data to individuals, corporations, organisations or governmental authorities without your consent if it is required to do so by law, by order of court or if the disclosure is permitted under the Ordinance.
(c) Disclosures to credit providers and credit-reporting agencies
If you purchase our goods or services, UM may disclose personal data to credit providers for credit related purposes such as credit-worthiness, credit rating, credit-reporting and fraud-checking. If we disclose your personal data to credit providers you acknowledge that this information may be recorded on the credit information file that the external credit provider may maintain about you.
(d) Transfer of personal data overseas
From time to time UM transfers personal data to overseas companies, both in the Universal Music group of companies and externally. For example, this may occur in the course of booking overseas tours for artists contracted to UM, or when we store personal data about customers, club members and competition entrants on servers that are hosted by a Universal Music company or an external offshore company.
If UM does transfer your personal data overseas, we will take steps to ensure your personal data is given the same privacy protection in the destination country.
(e) Personal data that you communicate or publish via UM websites
UM recommends that you do not publish or communicate personal data accessible to the public via UM websites unless you want that data to be seen by others.
Should you choose to publish or communicate personal data, or select features on UM websites that allow you to display, publish or communicate personal data about yourself to the public via UM websites, you acknowledge that UM cannot control the use of such personal data by others.
Under the Ordinance, you generally have a right to seek access to the personal data that UM holds about you and the purpose/s for which it is being held. However this Policy provides that there are some circumstances in which it is permitted or required to withhold access to some or all of that personal data. If UM denies you access based on any of the exceptions set out in this Policy it will endeavour, where appropriate, to inform you of the exception under which the denial falls.
You also have the right to ask UM to correct personal data about you that you think is inaccurate, incomplete or out of date.
If you wish to exercise your right under the Ordinance to seek access to the personal data UM holds about you, UM asks that you make a request in writing to its Privacy Officer (contact details are set out in section 9 below). Your request should state whether you are seeking access to all the personal data UM holds about you or to particular personal data (in which case you should specify that in your request). You should also provide some form of identification (e.g. a photocopy of your driver’s licence or passport) so UM can verify that you are the person to whom the personal data relates. You should also include details of how UM can contact you in case it needs to discuss your request. If you need more information before making a formal request for access, please contact UM’s Privacy Officer, who can explain how UM will handle your access request and assist you in making that request.
UM will assume (unless you tell it otherwise) that your request relates to UM’s current records about you. These current records will include personal data about you which is included in UM’s databases and in paper files, and which may be used by UM on a day to day basis. To provide you with access to current personal data, UM will ordinarily provide you with a print-out of the relevant personal data from its databases, or with photocopies of records which are held only on paper files. If personal data about you (e.g. your name and address details) is duplicated across different databases, UM will generally provide you with only one printout of this data. Ordinarily, UM will not charge you for the cost of providing this type of access to its records, and it will generally respond to access requests of this type within 30 days of receiving your request.
For legal and administrative reasons, UM may also store records containing personal data in its archives. You may seek access to the records held by UM which are not current records, but if you do so, UM may charge you for the cost of providing access. It may also take UM longer to respond to your request. Please contact the Privacy Officer to discuss your requirements.
If you think that any of the personal data UM holds about you is not accurate, complete or up to date, please provide UM’s Privacy Officer with your request for correction (contact details are set out in section 9 below). It is UM’s policy to consider and respond to any requests for correction within 30 days of receiving the request.
If UM agrees that your personal data is not accurate, complete and up to date, UM will correct it for you. If it does not agree with your view, UM will provide you with reasons for its view, and will provide you with an opportunity to make a statement of your view and have it included with the information.
UM takes reasonable steps to protect the personal data it holds and controls from such risks as loss, misuse, unauthorised access, destruction, modification or disclosure. The means of protection UM uses includes, but is not limited to firewalls, password access, secure servers and encryption of credit card transactions. UM only allows authorised personnel to access personal data, and it is a condition of employment with UM that its employees maintain the confidentiality of personal data.
UM cannot guarantee the security of online transactions and communications sent by electronic means or post. You are responsible for ensuring the confidentiality and security of, and for all activities which occur under, any username and/or password assigned to you by UM for the purpose of providing our goods or services and any purposes incidental to the provision of our goods and services (including without limitation any unauthorised use of your credit card).
Unless a legal requirement requires otherwise, if UM no longer requires the personal data it has collected from you for the purpose for which it was collected, it will take reasonable steps to destroy or permanently de-identify your personal data .
UM will apply this policy to all personal data it handles, whether collected online or otherwise. To the extent that this Policy applies to online privacy issues, it is to be read as forming part of the terms of use for UM websites. This section 8 is intended to provide more information about privacy for the users of UM websites.
(a) Online collection of personal and non-personal data
As outlined in section 3 above, UM collects personal data through UM websites when you sign up to join one of its clubs or when you contact UM through its online enquiry forms.
UM websites may also collect other information that may or may not be personal data. Each time you visit a UM website, its server automatically recognises and stores your “address” (e.g. your domain name or internet protocol address), the type of internet browser you are using, the address of the site that “referred” you to UM websites and clickstream data.
In addition, UM websites use cookies to track usage of its websites. Most web browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt or refuse cookies. Please note that rejecting cookies may mean that not all the functions on the UM websites you visit will be available to you. UM uses cookies for tracking the statistics of its websites. This allows UM to better understand its users and improve the layout and functionality of its websites. This tracking is conducted in such a way as to ensure the anonymity of visitors to UM websites. While the cookie may identify your computer, it should not identify you.
(b) Links to other websites
Sometimes UM websites contain links to third party websites for your convenience and information. You should be aware that when you access a non-UM website, UM is not responsible for the privacy practices or policies of that site. UM suggests that you review the privacy policy of each site you visit, especially if you intend to provide any personal data via the site.
If you have any questions or comments about this privacy policy, if you wish to access any personal data UM holds about you, or if you wish to make a complaint about how UM has handled personal data about you, please contact UM’s Privacy Officer by one of the following methods:
by telephone: (852) 2301 5888;
by facsimile: (852) 2301 4629;
by email: leonard.wong@umusic.com; or
by letter: Level 28, Millenium City 6, 392 Kwun Tong Road, Kwun Tong, Kowloon, Hong Kong SAR.
This privacy policy may change from time to time.
Privacy Policy
Effective Date: April 1, 2024
Universal Music Group is the world leader in music-based entertainment. We are the home for music’s greatest artists, innovators, and entrepreneurs. As digital technology refashions the world, our unmatched commitment to lead by developing new services, platforms, and business models for the delivery of music and related content empowers innovators and allows new commercial and artistic opportunities to flourish.
As part of this mission, Universal Music Group operates websites, applications, stores, and other services (which we refer to in this privacy policy as “Apps”) to help our artists stay connected with fans in new and exciting ways.
This privacy policy describes Universal Music Group’s data practices, including the collection, use, and sharing of data through Apps that link to this privacy policy, along with the choices and rights you have to control those data practices.
WHO WE ARE
Apps that link to this privacy policy are operated by Universal Music Investments, Inc., located at 2220 Colorado Ave, Santa Monica, CA 90404. As used in this policy, “UMG,” “we,” and “our” refers to this entity, who acts as a data controller and is responsible for the processing of personal data by the Apps under applicable privacy and data protection laws.
Other entities in the Universal Music Group family of companies may receive or process data in connection with the operation of the Apps, including UMG Commercial Services, Inc., UMG Recordings, Inc., and UMG Recordings Services, Inc., each of which is also located at 2220 Colorado Ave, Santa Monica, CA 90404. Where applicable, each of these entities separately makes the disclosures in this privacy policy.
Apps may be operated on behalf of artists and/or partners who may process personal data in connection with the Apps. In such cases we will disclose the relevant third parties on the Apps and/or at the point of data collection.
CONTACT US
Questions or comments about this privacy policy, our data practices, or requests regarding your privacy rights may be submitted through our Privacy Request Form by clicking here. We are only able to respond to requests related to our data practices through this form.
ALL NON-PRIVACY QUESTIONS: Please see this FAQ regarding how to contact UMG with questions or requests not related to our privacy practices or your privacy rights.
You may also contact UMG’s Data Protection Officer, by writing to Universal Music Group (ATTN: “Data Protection Officer”), 2220 Colorado Ave, Santa Monica, CA 90404 USA.
INFORMATION WE COLLECT
In our operation of the Apps, we collect the following categories of data:
Category of information | What may be collected | How it is collected, where applicable |
Information you choose to provide via the App or through other interactions with UMG, such as e-mail, social media, SMS, telephone, or other methods | · your name, · country of residence, · e-mail address, · phone number, · login information, including certain social media profile information if you login with a social media account, · gender, · age or date of birth, · payment card information, · billing and/or shipping address, · clothing sizes or similar physical descriptions, · personal description, · photographs, videos, or images, · comments. | · Forms you fill out on our App, including subscribing to direct marketing, creating an account, searches, uploading documents or media, or linking a social media account; · Correspondence with us (e-mails, phone transcripts or otherwise); · Purchases or orders placed on the App; · Participation in forums, chats, or other social media functions on the App; · Entering a competition, promotion, or survey; · Reporting a problem on the App or requesting support.
|
Information collected through your use of an App | · IP address and network information, · location (based on IP lookup), · user agent string including browser and OS version, · language and time zone, · identifiers set by cookies or similar tracking information (see cookies disclosure below), · unique device identifiers and hardware version, · page response times, · download or content errors, · page interaction information (such as scrolling, clicks, and mouse-overs, length of visit, pages viewed), · methods used to browse away from the page. | Visiting our App or interacting with us |
Information collected from third parties | · name or username, · age or birthdate, · address, · phone number, · gender, · household income, · device OS, · brand affinities, · consumer profile category, · music intent scores, · music concert spend category, · music genre interests. | Consistent with applicable laws, we may match and supplement information you provide, such as your email address or phone number, with data held by third party data providers or data brokers. |
HOW YOUR INFORMATION MAY BE USED
We may use information we collect to:
HOW YOUR INFORMATION MAY BE SHARED
In compliance with applicable laws, we may share information about you with third parties to facilitate the uses described above, including:
STORAGE AND RETENTION OF INFORMATION
We will retain the information we collect in accordance with applicable laws and as reasonably necessary for our processing purposes set out under this privacy policy, including resolution of disputes, enforcement of agreements, securing the Apps, and to comply with our legal obligations. When personal data is no longer necessary for our purposes we will delete or deidentify the data.
We will also take steps to ensure that the information we collect is treated securely and in accordance with this Privacy Policy. We have put in place technical and organisational procedures designed to safeguard the information we collect.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect the information we collect, we cannot guarantee its security.
CHILDREN
Our apps are not directed toward children (as defined by local law) nor does UMG knowingly collect information from children (as defined by local law) without parental consent except where in compliance with applicable laws.
YOUR RIGHTS
You may have certain rights regarding our processing of personal data about you. These rights may include access to, rectification, erasure, and/or portability of your personal data. You can exercise these rights by contacting us as described in the “Contact” section. We may take steps to verify your identity before completing your request. Our verification measures vary based on the risk to the individual and may involve confirming access to the relevant email account, providing a government-issued ID or other identification documents, or providing other account details or information that indicates a valid request.
You may also be entitled, in accordance with applicable law, to lodge a complaint with a supervisory authority if you consider that our processing of your personal data infringes applicable law.
Specific information regarding rights related to data processing of European data and personal data about residents of California, Colorado, Virginia, Connecticut, and Utah can be found on our “Your Privacy Rights” page.
INTERNATIONAL DATA TRANSFERS FROM THE EU, UK, OR SWITZERLAND
UMG’s US-based group companies UMG Recordings Services, Inc., UMG Recordings, Inc., Universal Music Investments, Inc., Universal Music Group Holdings, Inc., Universal Music Group, Inc., UMG Commercial Services, Inc., and Universal Music Publishing, Inc. participate in the EU-US Data Privacy Framework, the Swiss-US Data Privacy Framework, and the UK Extension to the EU-US Data Privacy Framework (collectively the “DPF”) regarding the collection, use, and retention of personal information transferred to the United States from member countries of the European Economic Area, Switzerland, and the United Kingdom. UMG has certified to the United Stated Department of Commerce that we adhere to the Data Privacy Framework Principles. More information about the Data Privacy Framework, including UMG’s certification, is available on the Data Privacy Framework (DPF) Program website.
Our group companies are subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).
UMG collects and uses personal information as described in the “Information we collect” and “How your information may be used” sections above. We may disclose personal information about you as described in the “How your information may be shared” section above. UMG may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Where we transfer personal information subject to the DPF to a third party, we require that third party to access, use, and disclose the personal information in compliance with the DPF. UMG is responsible for the processing of personal information we receive under the DPF and subsequently transfer to third parties acting as an agent on our behalf. We remain liable if such third parties process personal information inconsistent with the DPF Principles unless we prove that UMG is not responsible for the event giving rise to the damage.
Individuals whose data is subject to the DPF have the right to access personal information about them. You may also have choices to limit the use, and disclosure of personal information about you. Please see our “Your Privacy Rights” page for additional information regarding your rights and how to make privacy requests.
Dispute Resolution
If you have any questions or complaints regarding UMG’s handling of your personal information, please contact us using our Privacy Request Form or email us at privacy.officer@umusic.com. We will respond promptly. If you are not satisfied with our resolution of your privacy or data use complaint you may contact our US-based independent dispute resolution body, JAMS by clicking here. It may be possible, under certain conditions, for individuals to invoke binding arbitration.
CHANGES TO OUR PRIVACY POLICY
Any material changes we may make to our privacy policy in the future will be posted here. Please check back frequently to see any updates or changes to our privacy policy.
DIGITAL ADVERTISING
We use third party partners to enable targeted advertising on third-party social media platforms, websites, and mobile apps. These companies collect information through our Apps to target users and serve ads. Some of these ads may be personalized, meaning that these ads are intended to be relevant to you based on information the companies collect or receive about your use of our App and third-party sites and apps over time, including through the use of cookies and other tracking technologies.
Visit the DAA Webchoices tool at www.aboutads.info to learn more about targeted advertising and how to opt out of targeted advertising by companies participating in the DAA self-regulatory program. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool.
To opt-out of targeted advertising in mobile apps by companies participating in the DAA’s AppChoices program, you can download that app onto your device from https://youradchoices.com/appchoices. You can also limit data collection and use by third parties for targeted advertising in your mobile device settings, where available.
Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.
COOKIES
Our Apps use cookies and other similar technologies to improve your experience and support targeted advertising. For the purpose of this Cookies Policy, cookies, and other similar technologies (like scripts, plug-ins, tags, device fingerprints, Local Stored Objects, beacons, and pixels) are all referred to as “cookies.”
You can find more information about the cookies and other tracking technologies we use, the purposes for which we use them, and make certain choices about cookies through the cookie choices tools available on our Apps.
Most internet browsers are automatically set up to accept cookies. However, if you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. Please note you may not be able to take advantage of all the features of our App, including certain personalised features, if you delete or disable cookies.
For more information on managing cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.eu which has further information about behavioural advertising and online privacy.
