Effective date: 07/15/2022
This privacy policy (the “Privacy Policy”) applies to your use of our websites, including kobaltmusic.com, the Kobalt desktop and mobile application portals (“Portal”), and all related websites, mobile apps, and web-based services (together, the “Websites”). Please read this Privacy Policy carefully and in conjunction with our Terms of Use and ensure that you understand them before you start to use the Websites.
By accessing and using the Websites, you acknowledge that you have read and understood the content of this Privacy Policy. We reserve the right to update this Privacy Policy from time to time.
The Websites are owned and operated by, or on behalf of, Kobalt Music Group Limited (“we” or “us”). We are registered in England and Wales under company number 04018752 and our registered office is at 120 Moorgate, London, England EC2M 6UR. Our VAT registration number is GB774150334.
This Privacy Policy does not apply to third-party websites, products or services, even if they may link to our Websites or our Websites may link to them through advertisements that we display on our Websites and on the Portal. We recommend you review the privacy practices of those third parties before connecting accessing third party websites and sharing any personal information.
For most data collection on our Websites, we are the data controller responsible for the collection and use of your personal information as set out in this Privacy Policy.
This Privacy Policy is provided in a layered format. You can jump to a specific section by clicking on the section below:
1- Information we collect from you |
We collect certain personal information about you when you sign up for an account or otherwise use our Websites. We also automatically collect information regarding your use of our sites as you use them. |
2- How we use your information |
We use your personal information for various purposes connected with your interest in our Websites, products, and services, and to allow us to maintain and improve them. |
3 - Sharing of personal information |
We may share your personal information with certain third parties, such as with our service providers and to provide you with opportunities that we believe may be of interest to you. |
4 - Children’s privacy |
Our Websites are not directed towards children and we do not knowingly collect personal information from them. |
5 - Data security and retention |
The security of your personal information is of utmost important to us and we maintain appropriate safeguards to protect it. |
6 - Your choices and rights |
You have certain choices and rights over how we use your personal information. |
7 - European Privacy Notice |
We provide additional disclosures and rights to individuals located in Europe. |
>8 - Australia Privacy Notice |
You may obtain further information about our Australian subsidiaries. |
9 - Cookies |
You may learn more about our use of cookies by visiting our Cookie Policy. |
10 - Changes to this Privacy Policy |
We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws. |
11 - Contact us |
You may contact us for comments or questions in various ways. |
For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through our Websites will be apparent by the context of the page, and may include but is not limited to the types of information described below.
We may collect the following personal information about you to you choose to provide us through our Websites:
Our Websites use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (“Cookies”), which collect information from you automatically as your use our Websites, including:
We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. Please review our Cookie Policy below for more information about our use of these technologies.
We may use any information about you:
We may share your personal information with the following categories of third parties:
Our Websites are not directed toward children (as defined by local law) nor does Kobalt knowingly collect information from children (as defined by local law).
If you are a parent or guardian and you are aware that a child has provided us with personal information without parental consent, please contact us using the information in the Contact Us section. If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove that information from our servers.
We take reasonable steps, including physical, technical and organisational measures, to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information submitted to us and any transmission is at your own risk.
This includes use of multi-factor authentication to use the Portal. This is designed to ensure that the person accessing your account is, in fact, you. You may choose to provide us with a telephone number so that we can text you a one-time use code. You may alternatively use a third party authentication app ("Authentication App"). When you download the Authentication App, the applicable third party's privacy notice and/or the relevant app store privacy notice will apply to the collection and use of your information by the Authentication App and relevant app store (as applicable). The Authentication App is not provided by Kobalt and Kobalt is not responsible for the processing of your information by the Authentication App. In particular, you may use the Google Authenticator app. Please see more information here.
Your personal information will be retained by Kobalt for a period of time as necessary and relevant to our legitimate operations, our terms of agreement (if any) with you and in accordance with applicable legal obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce the relevant terms of agreement or to identify, issue or resolve legal proceedings.
We may retain a record of you stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further, during the term of your objection.
You have options and choices over how we use your personal information. You may have the right under applicable laws to ask for details of the personal information we hold about you, or to amend, limit or delete your personal information. You may also have the right to object to further processing under certain circumstances.
We also respect the rights you may have under applicable laws to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party where feasible).
If you wish to exercise any of the above rights in relation to the personal information we hold about you consistent with applicable law, wish to change your preferences at any time or have any questions about this privacy policy, please contact us:
Please note that we may require you to verify your identity before allowing you to access your personal information.
In addition to the above, we may offer the following additional ways to exercise your privacy rights and preferences:
This European Privacy Notice applies to any individuals located within the European Economic Area (EEA), United Kingdom (UK), or Switzerland from whom we may have collected personal data from any source, including through your use of our Websites, Products, and Services. We provide this European Privacy Notice to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states. Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.
European law provides individuals located in Europe with rights to receive certain disclosures regarding the collection, use, and sharing of personal data, as well as rights to be informed, access, rectification, erasure, restrict processing, data portability and to object with respect to collected personal data. For the purposes of this European Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person.
For most data collection on our Websites, we are the data controller responsible for the collection and use of your personal information as set out in this Privacy Policy.
Kobalt relies on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our terms of use; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.
We will retain your personal data for as long as required for the purpose for which we originally processed your information, or as long as the law permits.
Legitimate business interests. We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.
While our legitimate interests are detailed in Section 2 of our Privacy Policy, they generally include:
We may transfer your personal data to (i) to any third party to whom disclosure is necessary to enable us to provide you with any services which you have requested, including but not limited to data processors such as web hosting companies and email marketing service companies; (ii) where required to do so by law or court order; (iii) to any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under the Terms of Use; and (iv) to any group company or prospective buyer of all or substantially all of Kobalt Music Group Limited’s assets in connection with the sale or transfer of those assets to any prospective buyer.
Where we transfer personal information data we will seek to take account of any applicable statutory obligations relevant to personal information data transfers. In the case of transfers out of the EEA, we will, in the absence of an EC adequacy decision relevant to the destination country, seek to rely on appropriate safeguards such as a valid Privacy Shield certified US recipient or enter into appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
This may include the transfer of your personal data to one or more countries outside the UK and the EEA, where we (or other companies within the Kobalt Group), or our service providers maintain operations. You understand and accept that if your personal data is disclosed to third parties outside the UK and EEA those parties may be based in territories that may not have data protection provisions in law. In the case of transfers out of the UK and EEA, we will, in the absence of an EC adequacy decision relevant to the destination country, seek to rely on appropriate safeguards provided under law.
In certain circumstances, individuals located within the EEA, UK, and Switzerland are entitled to the following data protection rights regarding their personal data:
Where the processing of your personal data is based on your previously provided consent, you have the right to withdraw your consent at any time. If you would like to exercise any of these rights, please submit a written request using the information in the Contact Us section below. We will respond to these requests in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
You may also have the right to lodge a complaint about our data collection and processing actions with the appropriate supervisory authority. In the UK, the appropriate authority is the Information Commissioner’s Office (ICO), accessible here. In the EEA, you can view the contact information for your data protection authority here.
If you would like a copy of the privacy policy for the Australian subsidiaries please contact the Australian Kobalt office via privacy.policy.au@kobaltmusic.com.
“Cookies” are small pieces of information which are issued to your computer or mobile device when you visit a website and which store and sometimes track information about your use of the website. When you visit our website, our web server sends a cookie to your device which allows us to recognise your device.
You can find out more about how we use cookies and other similar tracking technologies, including information on how you can manage your cookie preferences, in our Cookie Policy.
We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws. The “effective date” legend at the top of this Privacy Policy indicates when it was last revised. Any changes are effective when we post the revised Privacy Policy on the Websites. If we make any material changes to this Privacy Policy, we will take reasonable measures to notify you via email and/or a prominent notice on our Websites prior to the change becoming effective, and will update the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.
If you have any questions about this Privacy Policy or wish to exercise one of your privacy rights, please contact us using the following information:
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privacy@kobaltmusic.com |
Address |
Data Protection Officer Kobalt Music Group 120 Moorgate, London, England EC2M 6UR |
© Copyright 2021 Kobalt Music Group, Ltd.