UNKLE Privacy Policy

A. Introduction
B. Collection and processing of personal data
C. Use of personal information
D. Newsletter
E. Disclosure of your information to third parties and UNKLE/ Songs for the Def Ltd. companies
F. Transfer of data to outside the European Economic Area (“EEA”)
G. Cookies
H. Other websites / third party links
I. Data security
J. Data Retention
K. Your rights
L. Changes to our privacy policy
M. Contact us

A. Introduction

Protecting our website visitors' personal data is an important concern for us at UNKLE.

What this policy does

This Privacy Policy sets out when, why and how we, and our third-party service providers, will collect process and treat the personal information which you provide to us while using the website(s) located at www.unkle.com and/or any of our other related online or mobile products, content and services, such as widgets and applications (collectively, the “Site”) (“Site”)

By using this website, you are assumed to accept the terms of this Privacy Policy.

Please note that we may change this Privacy Policy from time to time and such changes shall be effective from the date and time the revised Privacy Policy is posted on the Site.

Who are we?

The Site, together with all content on the Site, is owned or controlled by our company Songs for the Def Ltd. (“Company name”, “we’”, “us” or “our”). registered in England with company number 08080858, and having its registered address at Songs for the Def Ltd, 55 Kentish Town Road, Camden Town, London, NW1 8NX. We are registered as a Data Controller with the UK’s Information Commissioner’s Office (“ICO”).

Our values about personal information

We promise to treat the personal information of those we have contact with with respect, and to treat their data as we would wish our own personal data to be treated. We do not sell, rent or trade email lists with anyone else, we only share data where we are legally required to do so or where it is required in order to deliver a service to you or with our internal service providers and suppliers in order to fulfil our legitimate business interests.

B. Collection and processing of personal data

1. We and our third-party service providers may collect and process personal data, i.e. personal information that identifies, or makes it possible to identify, you (e.g. your name, address, email address or IP-address). When we talk about your “data” in this policy, this is what we mean. This may happen when you use or participate in various opportunities and services provided through the Site (the “Service Data”). Processing means any operation which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation, retrieval, any kind of disclosure, erasure or destruction or other use. We process personal data, such as when you:

(a) actively communicate with us;

(b) subscribe to services (e.g. newsletters/artist information bulletins or other communications) that we may provide through the Site;

(c) take part in a contest, competition, promotion, customer or fan survey, provide feedback, or participate in other types of promotion through the Site or through any linked social media or newsletter

This may include your name, postal address, email address, telephone number, age, date of birth.

2. Furthermore, on each of your visits to the Site we collect the following Technical Data transmitted by your browser to our website:

(a) your type of browser and type of operating system;

(b) the internet protocol (IP) address allocated to your internet access when you were visiting the Site;

(d) the URL of the internet page from which you arrived at the Site;

(e) the date and time when you accessed, clicked through and left the Site;

(f) the amount of data transmitted; and/or

(g) the searches you made and the pages you accessed on the Site;

3. All such personal information is collected, stored and processed by us, affiliated Songs

for the Def Ltd. Companies and our third-party service providers for the purposes set out in section C below.

C. Use of personal information

1. We, affiliated Songs for the Def Ltd. Companies and our third-party service providers may use your personal information as described in Section B for the following purposes:

(a) to provide access to our Site and services.

(b) to review and improve the services and products that we offer through assessment and analysis (e.g. customer, promotional and market analysis);

(c) to improve your experience of our Site by monitoring customer traffic patterns and Site usage; for further information on the use of data for web analytics and marketing purposes please refer to our cookie policy (UNKLE’s website does not currently use cookies however we will update our cookie policy and this privacy policy when we introduce these);

(d) to respond to your enquiries and to fulfil your requests (e.g. to send you newsletters or to provide you with information about our products, content and services);

(e) if you have consented to our doing so, to provide you, or to permit selected third parties to provide you, with information about products that we believe may interest you;

(f) to notify you about changes to Site terms, conditions and policies

(g) to allow you to take part in contests and similar promotions and to administer those activities (which may contain additional requirements and information about how we or our third-party service providers may use your personal information).

2. The above processing activities are based on our legitimate interests to improve your website experience and to optimise our services and products and to use our Site for marketing purposes. It is in our mutual legitimate interest to respond to your enquiries and requests. If you subscribed to our newsletter, any processing related to sending you newsletters or provide you with information about our products is based on the consent you gave separately when subscribing to the newsletter. You can withdraw your consent at any time by clicking on the link provided in each of our newsletters.

3. We process your personal data where necessary: (i) under any applicable laws or regulations of any jurisdiction of the EU or any member state for any purposes required under those laws or regulations; (ii) to enforce or apply our Site’s terms and conditions or other contracts; and/or (iii) to protect our, our users’ or any other third parties’ rights, property or safety.

D. Newsletter

When you subscribe directly to our newsletter via one of our mailchimp landing pages, we use a double opt-in process, i.e. we will only send you newsletters by email if you confirm in our notification email by clicking on a link that you are the owner of the e-mail address provided. If you confirm your email address, we will store your email address, the time of registration and the IP address used for registration until you unsubscribe from the newsletter. You can also subscribe indirectly to our mailing list when you consent to join at either Bandcamp or when making a Shopify purchase. This data is stored on their systems and periodically passed to us to update our subscriber lists.. You will not be asked to confirm your email via a double opt-in process in this instance. The sole purpose of the storage is to send you the newsletters and to be able to prove your registration. You can unsubscribe from the newsletter at any time. An unsubscribe link can be found in every newsletter. This is the easiest way to unsubscribe, though an e-mail or letter to the contact data given below is of course also sufficient. The legal basis of the processing is your consent.

In our newsletters we use software enabling us to measure interactions with the newsletters (e.g. opening of the e-mail, clicked links). We use this data for general statistical evaluations as well as for the optimisation and further development of our content and customer communication. This data is collected using small graphics embedded in the newsletter (called pixels), which can also collect Technical Data regarding the device you use. The legal basis for this is our aforementioned legitimate interest.

Through our newsletter we want to share content that is as relevant as possible for our fans and customers and better understand what readers are actually interested in. If you do not wish the analysis of usage behaviour, you can unsubscribe from our newsletter or deactivate graphics in your e-mail program by default.

E. Disclosure of your information to third parties and UNKLE/ Songs for the Def Ltd. companies

We may share your personal information as far as it is required for the above mentioned purposes from time to time with:

(a) any member of Songs for the Def Ltd.’s group of companies (which means our subsidiaries, our ultimate holding company and its subsidiaries) so that such third party may process your personal information in any way in which we are permitted to process your personal information under this privacy policy; and/or

(b) any of the following third parties:

  • our third-party service providers who provide us with Site-related services (such as hosting, data analysis (including webtracking services), search engines, payment processing, order fulfilment, IT services, email delivery, auditing and other similar services) to enable them to provide such services and/or to assist us in improving and optimising the Site. Any of these third-party service providers is bound by a Data Processing Agreement to ensure compliance with applicable privacy legislation;
  • any third party that sponsors or provides (in whole or in part) a contest or similar promotion through the Site for all purposes in connection with such contest or promotion, provided you have consented separately when taking part in the promotion;

(c) As far as transfer to above-mentioned recipients is required for any of the purposes mentioned in Section C, the transfer of data is based on our legitimate interests as specified in Section C or on your consent. This includes our interest to host the Website for informational and marketing purposes and to improve our services and products.

(d) We disclose your personal data to any person where necessary: (i) under any applicable laws or regulations of any jurisdiction of the EU or any member state for any purposes required by such person under those laws or regulations; (ii) to enforce or apply our Site’s terms and conditions or other contracts; and/or (iii) to protect our, our users’ or any other third parties’ rights, property or safety.

Third parties - summary

  • Our website team may have access to your data in order that they can provide services to us to maintain our website and make it better for site users. They can only use this data in order to provide the service to us and can not use it for any other purpose.
  • Our online shops and their shipping/courier providers, warehouse and distributors will have your data (you will nearly always have supplied this directly to them or indirectly at the point of purchase) in order to fulfil your purchases with them. We will expect and require these organisations to manage your data in accordance with the law and in a responsible manner.
  • We may also connect our online store to Mailchimp, (our mailing list software). This makes it possible for us to track individual visitors to our webstore from our Mailchimp campaigns, capture order information, and pass it all back to Mailchimp. From there, we can view purchase details, conversions, and total sales on the Reports page in our mailchimp account. It also allows us to organise data based on your purchase activity. This is based on your request to join our mailing list (consent) and our legitimate interest to review the data regarding who is a mailing list subscriber and a customer.
  • We may contract with consultants and freelancers in order to manage our business. Some of these may be involved in processing your data for the sole purpose of us delivering a service to you or to us, like sending you an e-newsletter, responding to your emails or social media messages, entering you into competitions, processing your orders or transactions, investigating complaints etc. This is for the sole purpose of providing a service, fulfilling a request, or allowing us to fulfil our legal obligations. We will expect and require them to manage your data in accordance with the law and in a responsible manner.
  • In collecting, processing and storing your data, we may use the following data processors in order to fulfil a transaction you have made, send you a newsletter, enter you into a competition etc:

○ Facebook
○ Instagram
○ Twitter
○ You Tube
○ Google
○ Dropbox
○ Mailchimp
○ Paypal
○ Bandcamp
○ Shopify

F. Transfer of data to outside the European Economic Area (“EEA”)

The information we collect from you may be transferred to, processed and stored at a destination outside the European Economic Area (“EEA). This might happen if our servers are located in a country outside the EEA or when we transfer data to third parties (e.g one of our service providers) who are situated in a country outside the EEA, or who have data servers situated outside the EEA.

If we do need to transfer Data outside the EEA, as described above, we will do what we can to ensure that your privacy rights continue to be protected as outlined in this privacy policy. You expressly agree to such transfers of Data.

G. Cookies

Cookies are small text files placed on your device’s hard drive to collect standard internet log information and visitor behaviour information when you access a website. This information is used to track visitor use of the website and compile statistical reports on website activity. We may also use this information for the purposes of targeting marketing messages on third party platforms including Facebook, Twitter, and Google.

For further information, visit www.aboutcookies.org or www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites explain how to remove cookies from your browser. However please note that in some cases, some website features may not function without cookies switched on.

UNKLE’s own website does not currently use cookies.

H. Other websites / third party links

The Site may contain links to other sites not owned or controlled by us. This privacy policy applies only to www.unkle.com

We are not responsible for the content of any such site, the site operator’s privacy policy or how the site operator treats information (personal or otherwise) obtained from users of the site so can’t guarantee that they will operate in the same way as we do . We advise you to check this site’s privacy policy to make sure you are happy as to how the site operator will treat any such information.

I. Data security

We will do all that we can to protect against security breaches: i.e the loss, misuse or alteration of your personal information and to ensure that it will be processed in accordance with this privacy policy.

Unfortunately, despite how hard we might try, use of online or mobile networks is not completely secure. You acknowledge and accept that others may intercept personal information you provide to us via those means, and that any such transmission is at your own risk.

Once we have received your information, We will put in place suitable physical and electronic security along with clear managerial processes for how your data is used to make sure it is as safe as possible and to try to prevent unauthorised access.

J. Data Retention

We strive to keep our processing activities with respect to your personal data as limited as possible. Personal data provided by you upon using our services (Service Data as described in Section B.1.) will be retained only for as long as we need it to fulfil the purpose for which we have collected it or as long as required by statutory retention requirements. Technical Data (as described in Section B.2.) will be retained only as long as it is necessary to provide access to our site.

K. Your rights

Your right to object

If you consider that we are misusing your personal data, you have the right to make a complaint to the Information Commissioner’s Office, and the right to seek to enforce your rights through judicial remedy.

Access to your information and correction

You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information, please email office@unkle.com or write to us at the address listed below.

We want to make sure that your personal information is accurate and up to date. You can correct the information we hold on you by clicking “update subscription preferences” in the footer of any marketing email we send to you, or by emailing us at office@unkle.com with the subject “update subscription preferences” or writing to us at the below address. Email is always best for us because our team works remotely.

Right to erasure

You have a right to require us to erase data that is no longer required for the original purposes or that is processed unlawfully. Wherever certain data is subject to retention periods, instead of deleting the data we will restrict processing to the duration and intended purposes of such period.

Wherever you gave consent to a data processing, you have the right to withdraw your consent to us at any time. As a result, we will not continue processing data based on this consent in the future. The withdrawal of consent does not affect the legality of the processing carried out based on the consent until the withdrawal.

Other things worth noting regarding transfer of rights

You can’t transfer your rights under this privacy policy to someone else – if you have an issue with things that we have done and you think we are in breach of your rights, you are the only one who can complain.

So that we can make your experience of our Website better and send you information that you have told us you would like to receive, we might transfer our rights under this privacy policy but where we believe your rights won't be affected.

L. Changes to our privacy policy

We may on occasion change the terms of this privacy policy.Any changes we make to our privacy policy in the future will be posted on the Site where you’ll be able to find them next time you visit, and, where we consider it appropriate, notified to you by email. Please check back frequently to see any changes to our privacy policy. Your continued use of the Site following the posting of changes to this privacy policy will be deemed as your acceptance of those changes.

M. Contact us

UNKLE and its related companies can be contacted as follows:

If you have a query related to a topic in our mailing list please email studio@unkle.com (the email from which the newsletter is sent) or you can easily unsubscribe using the unsubscribe links on our email.

If you have a specific enquiry about something else or a data protection query you can email office@unkle.com

– by post:

Songs for the Def Ltd
55 Kentish Town Road
Camden Town

Please note this is our registered office address. Our team works remotely so always best to email us with your queries.

Last modified: June 2022
© UNKLE / Songs for the Def Ltd.