One Virtuoso Ltd (Virtuoso) respects your privacy and is committed to protecting your personal data.
This privacy notice contains information about who we are and how and why we collect, store, use and share your personal data when you interact with us (including parents’/legal guardians’ and students’ personal data).
When we collect, use, or share your personal data, we are subject to applicable data protection laws including the General Data Protection Regulation and are responsible for that personal data as a data controller. This notice will also inform you about your privacy rights and how the law protects you.
It is important that you read this privacy notice 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 notice supplements the other notices and is not intended to override them.
1. Important information and who we are
Where we refer to “we”, “us” or “our” in this privacy notice, we are referring to Virtuoso, as the legal entity that is responsible for processing your personal data.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
One Virtuoso Ltd.
Ground Floor, Ruskin Chambers
We hope that you will approach us to resolve any query or concern you might have about our use of your personal data. However, 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).
Changes to the Privacy Notice and Your Data
This version was published on 1st August 2020 and last updated on 1st August 2020.
We may change this privacy notice from time to time and we will inform you when those changes may affect you in a material way.
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.
This website may include links to third-party websites, plug-ins and applications. For example, we may give you the option to connect with your social media network through third party platforms such as Twitter, Instagram or Facebook. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. Those sites may also set cookies over which we have no control, and which are subject to the cookie policies of the relevant third party platform. When you leave our website, we encourage you to read the privacy notice and cookie notice of every website you visit.
2. The data we collect about 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 follows:
- Identity Data which allows us to identify you including your name, title and date of birth.
- Contact Data including postal address, email address and telephone numbers.
- Financial Data including bank account and payment and credit card details which enable us to process your payments.
- Transaction Data including historical transactions for services from us.
- Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and general location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This also includes your username and password for our client portal.
- Usage Data including information about how you use our website and services including your service preferences and any feedback
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect personal data in relation to our students who may be under the age of 18. We only collect students’ data for the purposes of identifying the student, providing music lessons to the student and monitoring that student’s progress. We treat our students’ personal data as confidential and we do not share that data with third parties except for the student’s school, parent, legal guardian, or other group through which we provide services or where it may be required by external examination boards (if a student is taking an examination). If you sign your child up to our music lessons, you consent to us collecting your child’s Identity, Contact and Usage Data for the purposes described above. Students may exercise any of the rights set out in section 9 in relation to their personal data.
Students can register their details on our website and they will be contacted about new courses, classes and reminders for upcoming classes.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
Failing to provide personal data
Where we need to collect personal data in order to provide services to you and you do not provide that requested data, we may be prevented or delayed in providing you with our services.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
A. Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms and signing documents, dealing with our staff, or by corresponding with us by post, phone, email or our website. This includes personal data you provide when you:
- enquire about, request or order our services;
- access and receive our services or attend one of our events or talks;
- create an account on our website;
- subscribe to our emails or notifications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
B. Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below for more details about cookies.
C. Third parties or publicly available sources.
We may receive personal data about you from various third parties set out below:
- Identity Data from schools or teachers for the purposes of providing you with information about the services we offer;
- Technical Data from our IT providers, analytics providers and search information providers;
- Contact, Financial and Transaction Data from providers of technical and payment services;
4. How we use your personal data
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.
If you are a student or are under the age of 18, we ask the person with parental responsibility for you for their consent for the processing of your data. We will rely upon this consent as our legal basis for processing your data where (i) you are under the age of 13; or (ii) you are 13 or over and notify us that you withdraw or amend our right to process your personal data.
<h4>Using your personal data</h4>
We have set out below, a description of 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.
|Purpose / Activity||Type of personal data||Lawful basis for processing including basis of legitimate interest|
|To register your details as a new student or contact (whether via our website, a paper form, by phone, email or otherwise).||(a) Identity|
|Performance of a contract with you|
|To process your order:||(a) Identity|
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to collect payment for our services)
|To notify parents/legal guardians and schools to report on:||(a) Identity|
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to inform you of matters in relation to students’ learning)
|To enable you to partake in a promotion or complete a survey||(a) Identity|
(c) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(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 use data analytics and automated profiling to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity|
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 used our services or if you provided us with your details when you have opted in to receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us using the details set out at the start of this privacy notice.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of our services.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to checkout and make payments to us online.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information.
You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Sharing your personal data
We routinely share personal information with:
- third parties we use to help deliver our services to you – e.g. schools, payment service providers and examination boards;
- third parties approved by you – e.g. social media sites you choose to link your account to, third party payment providers.
- our banks, auditors, insurers, solicitors and other providers of professional services;
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We also make use of Visitor Action Pixels from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on this website.
This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter of GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
We do not transfer your personal data outside the European Economic Area (EEA).
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.
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.
Your personal data may be held at our office and at the locations of those third parties set out above. This includes personal data held on our IT systems.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Some data may be retained for legal (including tax) reasons for a period exceeding that which we require for our business purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 us using the details set out at the start of this privacy notice.
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 may 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 may 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Our service providers who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.