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AIM PRIVACY NOTICE (MAY 2021)

PRIVACY NOTICE 

INTRODUCTION

The Association of Independent Music Limited of PO Box 76406 London W5 9RP (“AIM”/“we”/“us”/“our”) is committed to protecting and respecting your privacy. 

This privacy notice (“Notice”) (together with any other contractual terms that may be in place between us and you) sets out the basis on which any personal data we receive from you, or that we gather in any other way, will be processed by us.  It applies to any data gathered in the course of membership of AIM, attendance at events, or due to your use of www.aim.org.uk, including the online members account area, (our “Platform”) or otherwise as a consequence of any dealings we may have with you including asking you to complete surveys such as WINTEL by which we gain your personal information. 

For the purposes of the General Data Protection Regulation (“GDPR”) we shall be the “controller” for all uses that we make of your personal data.

INFORMATION WE MAY COLLECT FROM YOU 

We and other third parties (such as third-party providers and partners) may collect and process data about you in the manner set out below. 

You may give us information about you by filling in forms on our Platform or by corresponding with us by phone, e-mail or otherwise. This includes information you provide if you register as a member of AIM or to use our Platform, subscribe to receive a newsletter, share data with our Platform’s directory functions, correspond or communicate with us or other users on our Platform, enter a competition, promotion or survey, when you report a problem with our Platform or when you upload information or data on our Platform. The information you give us may include without limitation your name, address, e-mail address, phone number, financial and credit card information, demographic information (such as age and/or other information that may identify you as an individual), personal description, photograph, job role, username, password, other registration information and marketing preferences. 

With regard to each of your visits to or use of our Platform we may automatically collect the following information about you or your devices: 

• technical information, including the type of device(s) you use, a unique device identifier, the Internet Protocol (IP) address used to connect your device(s) to the Internet, network information, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform; and
• information and details about your use of our Platform (including but not limited to traffic data; location data; weblogs and other communication data; the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); what 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)).

We may also gather information about journalists and influencers from public sources, such as organisation websites, or from clients, other journalists and influencers.

We may also receive information about you from partners that enter into agreements with, or provide certain services to us or our Members, and in which we play a facilitating or negotiating role. This includes collective bargaining agreements and anti-piracy services as well as information collected for research, statistical and survey purposes. We receive this data so that we can assess the effectiveness of such schemes and the data received is limited to that which is necessary for this purpose, and is not used for any other purpose.

 If you contact us with a complaint or query, we may keep a record of any phone number used to call us as well as the correspondence and the period of time it took for us to deal with a query or any request you had. 

At some of our events, we may photograph, record or film onsite activities. In which case, you may be filmed, photographed or recorded as part of any such activities.

COOKIES

Like most websites and mobile applications, our Platform uses cookies. A cookie is a small, often encrypted file of letters and numbers that we store on your browser, your computer, your mobile device or other device. Cookies help us to improve our Platform and your general experience on it. 

We may use the information we obtain from the cookie in the administration of our Platform, to improve our Platform’s usability and for marketing purposes. We may also use that information to distinguish you from other users of our Platform and to monitor traffic on our Platform. 

If you do not want us to store cookies on your computer or other device for these purposes, you may change the settings on your internet browser to reject cookies (or alternatively visit http://www.aboutcookies.org). Please note that if you set your browser to reject cookies, you may not be able to use all of the features of our Platform and/or may be prevented from accessing certain parts of our Platform. 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

USES MADE OF THE INFORMATION

We will use the information you give to us where we have a legal basis to do so, for the following purposes:

• To carry out our obligations arising from any contracts for membership of AIM (including Friends of AIM), contracts relating to your attendance at events entered into between you and us, or contracts under which you provide services to AIM, or in order to take steps at your request prior to entering into such a contract.
• For members and attendees at events, to provide you with information about other services we offer that are similar to those that you have enquired about or purchased, or we are currently providing to you. This is done on the basis of our legitimate interest in informing those persons likely to use our services about those services.
• If you have consented, to provide you with information about services or events provided by AIM, AIM Members, Friends of AIM or other groups affiliated or connected with AIM.
• If you have consented, we may share your name and contact details with AIM Members or Friends of AIM that have an expressed an interest in being in contact with you.
• If you have consented, we may process information about you fordata analysis, research, statistical and survey purposes and may share your name and contact details with other third parties for research, statistical and survey purposes.
• If you are a Friend of AIM, we will list your contact details in our public directory and may share your name and contact information with any AIM Member that requests it. This is in your and our legitimate interests, and the legitimate interests of our members of connecting service providers with those likely to need their services.
• In accordance with our and/or your legitimate interests under any contract between you and us, to facilitate, and if necessary, enforce any legal obligations you may owe to us, in respect of that contract.
• In the case of data we hold regarding journalists and influencers, to issue and circulate press releases and information about upcoming releases, events and other similar matters, either on AIM’s own behalf or on behalf of members or affiliates. In doing so, we act in our or our members’ legitimate interests publicising our or their businesses, and journalists’ and influencers’ legitimate interests in being kept up to date with news and events in the fields in which they are active. All communications sent to journalists and influencers are sent with the intention of providing information which may be useful to said journalists and influencers in their profession or activities, and are not intended to persuade the recipients of the communication to enter into any agreement or make any purchase of goods or services.
• In accordance with your and our legitimate interests, and the legitimate interests of other users of our services to ensure that our services are used in the most effective manner and for maximum benefit, to notify you about changes to our Platform or services and to ensure that content on our Platform is presented in the most effective manner for you and for your computer or mobile device.
• In accordance with our legitimate interest, and the legitimate interest of any counterpart, to facilitate such sale or purchase as part of, or as reasonably necessary for the purpose of, any sale or purchase of any of our business or assets of which the provision or offering of goods or services to you forms part.

We will use the information we collect about you from the use of our Platform, in accordance with our and/or your legitimate interests, in order to improve your experience of our Platform: 

• to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to allow you to participate in interactive features when you choose to do so;
• as part of our efforts to keep our Platform safe and secure; and
• to make suggestions and recommendations to you and other users of our Platform about goods or services that may interest you or them.

We do not use your personal data as part of any automated decision-making, including profiling, which produces legal or similarly significant effects concerning you. 

DISCLOSURE OF YOUR INFORMATION 

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (if applicable).

We may share your information with other third parties (including partners and service providers) such as: 

• Our mailing partner, to deliver messages to you in accordance with the purposes set out above.
• Business partners, suppliers and sub-contractors for the performance of any contracts we enter into with you, including payment processing, web-hosting and event organising services.
• Analytics and search engine providers that assist us in the improvement and optimisation of our Platform.
• Suppliers of IT systems and services for the purpose of ensuring the correct operation, or enhancing the operation of IT systems, or to ensure the safety and security of personal data.
• Other third parties for data analysis, research, statistical and survey purposes where we have an agreement with such third party which includes clauses that protection your personal information.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements, or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE AND HOW WE STORE YOUR PERSONAL DATA 

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. For example, we use secure servers to store all information you provide to us. 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 Platform; any transmission is at your own risk.

The data that we collect from or about you may be transferred to, and stored at, a destination outside the UK or European Economic Area ("EEA") for example, for the purposes of storage, payment processing and event organisation. Some of these countries may have less strict or no data protection laws, when compared to those in the EEA or the UK. Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy notice. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, a copy of the appropriate safeguards can be obtained by writing to us at the email address given in this Notice. 

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

We will store your data for as long as necessary to fulfil the purposes for which it is originally collected, as explained in this Notice, or any other lawful purpose subsequently communicated to you, and for other essential purposes such as complying with legal obligations and enforcing our rights, such as those arising under any agreement with you. The retention period may therefore vary for different types of data, and depending on how and why it was gathered. Criteria relevant to determine retention periods include:

• If the data is necessary for the performance of a contract, we will retain it while performance under that contract remains active, and for a period thereafter in which that data may still be relevant to dispute resolution, enforcement of rights under the contract, or where additional connected contracts are likely to arise.
• If the data is processed pursuant to consent only, and consent is withdrawn, we may delete the data immediately, or we may cease processing and retain the data for a period if we have a need to keep it for dispute resolution or enforcement of rights. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
• In certain cases we may be legally obliged to hold data for a certain period of time, or to delete the data at a certain time, including in accordance with the exercise of your rights as data subject as explained in this Notice.

YOUR RIGHTS 

The GDPR provides you with rights to:

• request from us confirmation of whether or not your personal data is being processed and where that is the case, confirmation of the information set out in this Notice;
• request from us a copy of your data that is undergoing processing, including, in relation to data provided to us by you, and which is processed by automatic means pursuant to a contract with you, or pursuant to your consent, a right to request that data in a structured, commonly used and machine readable format;
• request that we rectify or complete your personal data, where it is inaccurate or incomplete for the purposes of our processing of the data;
• request that we erase your personal data in the following circumstances:
  • the personal data is no longer necessary in relation to the purposes for which it is processed;
  • you withdraw consent and there is no other legal ground for the processing;
  • you successfully object to the processing pursuant to your right of objection explained below;
  • the personal data has been unlawfully processed;
  • the erasure is necessary for compliance with a relevant legal obligation that applies to us;
• request that we restrict the processing of your personal data in the following circumstances:
  • you contest the accuracy of the personal data, for a period enabling us to verify the same;
  • the processing is unlawful, but you request restriction rather than erasure;
  • we no longer need the data, but it is required by you in respect of legal claims;
  • you have objected to the processing, until such that that we verify that there are legitimate purposes that justify such processing;
• request that we cease processing your personal data for direct marketing purposes;
• object to any processing that is based on our, or a third party’s legitimate interests, upon which event we shall suspend processing until we demonstrate legitimate purposes that justify that processing. We may at all times continue to use data for the purpose of establishment, exercise or defence of legal claims;
• withdraw your consent for future processing (where the processing is based on that consent); and
• lodge a complaint with the Information Commissioner’s Office, which is the data protection supervisory authority in the UK.

We will comply with any valid request for information under the rights explained above within one month, although we may tell you that this period is to be extended by a further two months where necessary, taking into account the complexity and number of the requests. This will normally be provided free of charge. If the request is manifestly unfounded, excessive or repetitive we may charge a reasonable fee or refuse to action the request.

The provision of personal data to us is not a statutory requirement. Where the provision of data is a contractual requirement, or a requirement necessary to enter into a contract, we will make that clear as part of the process by which the contract is concluded, which may include by way of terms of the contract. These provisions will also make clear the consequences of failure to provide such data.

Where the data is not a contractual requirement, you are not obliged to provide the data, but if you do not do so, we may be unable to offer certain benefits and functionality to you. For example, you may not be able to access part of the Platform.

Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our Platform is advertised).  If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these notices or for any personal data that may be collected through these websites or services. Please check these notices before you submit any personal data to these websites or use these services.

CHANGES TO OUR PRIVACY NOTICE 

Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next use our Platform. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of our Platform. Alternatively, please check back frequently to see any updates or changes to our Privacy Notice. 

CONTACT 

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to info@aim.org.uk. Note that this is the general information email address for AIM and response times may vary.