Privacy policy

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EDM REKORDS  PRIVACY STATEMENT

Effec've date: (02/10/2021)

1. Defini7on and nature of personal data

The following terms and expressions, when used with uppercase ini'als, have the meaning aBribu- ted to them in the General Terms and Condi'ons of Use of the Services of

When you use our Site, we may ask you to provide us with personal data about yourself.

The term "personal data" refers to all data that allows an individual to be iden'fied, which corres- ponds in par'cular to your surname, first names, pseudonym, photograph, postal and e-mail ad- dresses, telephone numbers, date of birth, data rela'ng to your transac'ons on the Site, details of your purchases and subscrip'ons, credit card numbers, SIRET, intra-Community VAT number, as well as any other informa'on that you choose to communicate to us about you.

1. Purpose of this charter
   The purpose of this charter (hereinaSer the "Charter") is to inform you about the means we use to

collect your personal data, in the strictest respect of your rights.

In this respect, we inform you that we comply, in the collec'on and management of your personal data, with Law No. 78-17 of January 6, 1978 rela'ng to computers, files and freedoms, in its current version (hereinaSer: the "Data Protec7on Act"), as well as Regula'on (EU) 2016/679 of April 27, 2016 on the protec'on of individuals with regard to the processing of personal data and on the free movement of such data (hereinaSer: the "RGPD").

1. Iden7ty of the person responsible for data collec7on

The person responsible for collec'ng your personal data is the company  running under EDM REKORDS, We are registered in England and Wales under company number 12016861 and our registered office is at 29-31 Parliament Street, Liverpool, England, L8 5RN.  

1. Collec7on of personal data

The legal basis for our collec'on of your personal data is as follows:

1. (i)  this collec'on is necessary in order to execute the contract entered into when you use our Services on our Site.
2. (ii)  Legi'mate interest when you voluntarily provide us with personal data during your visit to our Site, the data being collected to enable us to beBer respond to your re- quests for informa'on about our Services.

Your personal data is collected for one or more of the following purposes:

1. (i)  Manage your access to and use of certain Services available on the Site,
2. (ii)  Carry out the opera'ons related to the management of Customers concerning contracts, invoices, loyalty programs, follow-up of the rela'onship with the Custo-

mers,

1. (iii)  To allow the Users to connect with each other in order to promote the develop-

ment of ar'sts,

1. (iv)  Build up a file of registered members, Users, Clients and prospects,
2. (v)  Send newsleBers, solicita'ons and promo'onal messages. If you do not wish to do

so, we give you the op'on to express your refusal to do so at the 'me of collec'on

of your data,

1. (vi)  Develop business and aBendance sta's'cs for our Services,
2. (vii)  Organize contests, loBeries and all promo'onal opera'ons, with the excep'on of

online gambling and games of chance subject to the approval of the Online Gaming

Regulatory Authority,

1. (viii)  Manage the management of people's opinions on products, Services or content,
2. (ix)  Manage any unpaid invoices and any disputes regarding the use of our products

and Services,

1. (x)  Personalize the answers to your informa'on requests,
2. (xi)  Respect our legal and regulatory obliga'ons. We inform you, when collec'ng your

personal data, if certain data must be filled in or if they are op'onal (by asterisks visible on the Site). We also inform you of the possible consequences of a lack of response.

When collec'ng your personal data, we will inform you whether certain data must be provided or whether it is op'onal. We also inform you of the possible consequences of a lack of response.

1. Recipients of collected data

Will have access to your personal data :

1. (i)  The staff of our company ;
2. (ii)  the services in charge of control (in par'cular the statutory auditor) ;
3. (iii)  our subcontractors (communica'on service providers, produc'vity soSware pro- viders, data hos'ng providers, payment service providers, billing service providers, audience analysis and measurement service providers, customer rela'onship ma- nagement service providers);
4. (iv)  Musical Influencers may also have access to certain data of the Clients in order to contact them.

Your personal data may also be received by public bodies, exclusively to meet our legal obliga'ons, court officials, judicial officers and bodies responsible for debt collec'on.

1. Dura7on of storage of personal data
   (i) Concerning the data related to the management of Clients and prospects :

Your personal data will not be kept beyond the dura'on strictly necessary for the manage- ment of our business rela'onship with you.

However, data that allow proof of a right or a contract to be established, which must be kept in order to comply with a legal obliga'on, will be kept for the period provided for by the law in force.

Concerning possible prospec'ng opera'ons for Clients, their data may be kept for a period of three (3) years from the end of the commercial rela'onship.

Personal data rela'ng to a prospect, non-Customer, may be kept for a period of three (3) years from the date of collec'on or from the last contact from the prospect. At the end of this three (3) year period, we may contact you again to find out if you wish to con'nue to receive commercial solicita'ons.

1. (ii)  Concerning iden7ty documents: In the event of exercising the right of access or rec'fica'on, data rela'ng to iden'ty documents may be kept for the period provi- ded for in Ar'cle 9 of the Code of Criminal Procedure, i.e. one (1) year. In case of exercise of the right of opposi'on, these data may be archived for the period of limita'on provided for in ar'cle 8 of the Code of Criminal Procedure, i.e. three (3) years.
2. (iii)  Concerning data rela7ng to credit cards: Financial transac'ons rela'ng to the payment of purchases and fees via the Site are entrusted to a payment service pro- vider (here MangoPay and Paypal) which ensures the smooth running and security.

For the purposes of the Services, this payment service provider may be the recipient of your personal data rela'ng to your credit card numbers, which it collects and stores in our name and on our behalf.

We do not have access to this data.

To enable you to make regular purchases or pay related fees on the Site, your credit card informa'on is kept during the 'me of your registra'on on the Site and at least un'l you make your last transac'on.

By having checked the box expressly provided for this purpose on the Site, you give us your express consent for this conserva'on.

The data rela'ng to the visual cryptogram or CVV2, wriBen on your credit card, are not sto- red.

If you refuse to have your personal data rela'ng to your credit card numbers kept under the condi'ons specified above, we will not keep this data beyond the 'me necessary to allow the transac'on to be carried out.

In any event, the data rela'ng to these may be kept, for the purpose of proof in the event of any dispute over the transac'on, in intermediate archives for the period provided for in Ar'cle L 133-24 of the French Monetary and Financial Code, in this case thirteen (13) months following the debit date. This period may be extended to fiSeen (15) months in order to take into account the possibility of using deferred debit cards.

(iv) Concerning the management of the lists of opposi7on to receive prospec7ng: The informa'on allowing to take into account your right of opposi'on is kept at least

three (3) years as from the exercise of the right of opposi'on.

(v) Concerning audience measurement sta7s7cs: The informa'on stored in the Users' terminal or any other element used to iden'fy Users and allowing their traceability or aBendance will not be kept beyond thirteen (13) months.

1. Security

We inform you to take all useful precau'ons and appropriate organiza'onal and technical measures to preserve the security, integrity and confiden'ality of your personal data and, in par'cular, to prevent them from being distorted, damaged or accessed by unauthorized third par'es. We also use secure payment systems that comply with the state of the art and applicable regula'ons.

1. Hos7ng

We inform you that your data is kept and stored for the dura'on of its conserva'on on the ser- vers of the company Amazon Web Services, located in the European Union.

1. Transfer outside the European Union

Your data may be transferred outside the European Union in the context of the tools we use and our rela'ons with our subcontractors (see Ar'cle 5 "Recipients of the data collected").

This transfer is secured using the following tools:

• -  Either these data are transferred to a country that has been deemed to offer an adequate

level of protec'on by a decision of the European Commission;

• -  Either we have concluded a specific contract with our processors governing the transfer

of your data outside the European Union, on the basis of the standard contractual clauses between a data controller and a processor approved by the European Commission.

1. Access, rec7fica7on, limita7on and dele7on of your personal data

You have the right to obtain communica'on and, if necessary, correc'on or dele'on of data concerning you, through online access to your Personal Space.

You may also contact the contact point iden'fied in Ar'cle 16.

You have the right to obtain the limita'on of the processing of your personal data, in the cases de- fined in ar'cle 18 of the RGPD :

• -  For the dura'on of the verifica'on process that we implement, when you dispute the accu- racy of your personal data,
• -  When the processing of such data is unlawful, and you wish to limit such processing rather than delete your data,
• -  When we no longer need your personal data, but you wish to retain it to exercise your rights,
• -  During the period of verifica'on of legi'mate reasons, when you have objected to the pro-

cessing of your personal data.

Persons whose data is collected on the basis of our legi'mate interest, as men'oned in Ar'cle 4, are reminded that they may at any 'me oppose the processing of data concerning them. We may, however, be led to con'nue processing if there are legi'mate reasons for the processing that pre- vail over your rights and freedoms or if the processing is necessary to ascertain, exercise or defend our rights in court.

You can unsubscribe from our promo'onal emails via the link provided in the emails. Even if you choose to stop receiving promo'onal messages from us, you will con'nue to receive our adminis- tra've messages.

12.Right to set guidelines for data processing aVer your death
You have the right to set guidelines for the storage, dele'on and disclosure of your personal data

aSer your death.

These guidelines may be general, i.e., they apply to all personal data concerning you. In this case, they must be registered with a trusted digital third party cer'fied by the CNIL.

The guidelines may also be specific to the data processed by our company. In this case, they should be sent to us at the address indicated in ar'cle 16.

By providing us with such instruc'ons, you expressly consent to the reten'on, transmission and performance of such instruc'ons on the terms and condi'ons set forth herein.

You may designate in your instruc'ons a person responsible for their execu'on. This person will then have the authority, aSer your death, to take note of your instruc'ons and to request that we implement them. Failing designa'on, your heirs will have the right to take note of your instruc'ons upon your death and to ask us to implement them.

You may change or revoke your instruc'ons at any 'me by wri'ng to us at the contact details pro- vided in Ar'cle 16.

13.Portability of your personal data

You have a right to the portability of the personal data that you have provided us, understood as the data that you have ac'vely and consciously declared within the framework of access and use of the Services, as well as the data generated by your ac'vity within the framework of the use of the Services. We remind you that this right does not apply to data collected and processed on any legal basis other than consent or the execu'on of the contract binding us.

This right may be exercised free of charge, at any 'me, and in par'cular when closing your account on the Plamorm, in order to retrieve and keep your personal data.

Within this framework, we will send you your personal data, by any means deemed useful, in a standard open format that is commonly used and machine-readable, in accordance with the state of the art.

14.Filing a claim before a supervisory authority

You are also informed that you have the right to lodge a complaint with a competent supervisory authority (the Commission Na'onale Informa'que et Libertés for France) in the Member State in which your habitual residence, your place of work or the place where the viola'on of your rights

would have been commiBed, if you consider that the processing of your personal data subject to this charter cons'tutes a viola'on of the applicable texts.

This recourse may be exercised without prejudice to any other recourse before an administra've or judicial court. Indeed, you also have the right to an effec've administra've or jurisdic'onal re- course if you consider that the processing of your personal data subject of the present charter cons'tutes a viola'on of the applicable texts.

1. Contact point for personal data

If you have any ques'ons regarding our processing ac'vi'es, or if you wish to exercise any of your rights, you can contact us at the following coordinates:

- e-mail address: support@edmrekords.com.com
- We are registered in England and Wales under company number 12016861 and our registered office is at 29-31 Parliament Street, Liverpool, England, L8 5RN.  

1. Modifica7ons

We reserve the right, at our sole discre'on, to modify this Policy, in whole or in part, at any 'me. These modifica'ons will come into force as of the publica'on of the new Charter. Your use of the Site following the coming into force of these modifica'ons will be deemed to be recogni'on and acceptance of the new Charter. If you do not agree with the new Charter, you should no longer ac- cess the Site.

Appendix - Cookie Policy

1. What is a Cookie?

During your naviga'on on our Site, cookies, pixels and other tracers (hereinaSer referred to together as "Cookies") are deposited on your browser.

A cookie is a small, oSen encrypted file stored in your browser or device and iden'fied by a name. It is deposited when you visit a site or applica'on. Each 'me you return to that site or applica'on, the Cookie is retrieved from your browser or device. Thus, each 'me you consult the site or applica'on, the browser is recognized.

The deposit of these Cookies is likely to allow us to access your naviga'on data and/or personal data concerning you.

1. Cookie Iden7fica7on
   ➢ Technical and func7onal cookies

Technical and func'onal Cookies are necessary for the proper func'oning of the Site and to provide you with our services. They are used throughout your naviga'on, in order to facilitate it and to per- form certain func'ons.

For example, a Technical Cookie may be used to store your responses to a form or your preferences regarding the language or layout of the Site, where such op'ons are available.

We use the following technical and func'onal Cookies:

Cookie Name

Cookie Func7on

Shelf life

authCreateUser- Backup

Backup system to keep user in- forma7on during the registra- 7on of an influencer ("user" data)

Un7l registra7on is finalized

"backupSes- sion_" + <id>

Backup system to allow swit- ching from one account to ano- ther once the two are linked

is browser-based: by default in- finite life time

flowSignupBa- ckUp

Backup system to keep the user's informa7on un7l the ar- 7st or representa7ve registra- 7on is finalized

Un7l registra7on is finalized

cgs

Allows to know if the user (ar- 7st or representa7ve) has given his authoriza7on of the general condi7ons of services concer- ning the addi7on of files (mp3, photos etc. ...) on the placorm when an influencer makes the request

is browser-based: by default in- finite life time

createBaseIn- fluencerBackup

Backup system to keep the user's informa7on during the registra7on of an influencer (country data, en7ty name...)

Un7l registra7on is finalized

patchLinkIn- fluencerBackup

Backup system to keep the user's informa7on during the registra7on of an influencer (link data of the influencer's site ...)

Un7l registra7on is finalized

patchSubsAnd- GenreBackup

Backup system to keep the user's informa7on during the registra7on of an influencer (fa- vorite genres and sub-genres data...)

Un7l registra7on is finalized

wa_pastille_la- test_sharing

Keep informa7on about the last no7fica7on of a piece that is wai7ng to be shared seen by the user

is browser-based: by default in- finite life time

needsWarmWel- come

Allows to know that the in- fluencer has just finished his registra7on

Un7l registra7on is complete and the user is redirected

displayInfluen- cerValidation- Message

Allows to know that the in- fluencer has just finished his registra7on

Until registration is complete and the user is redirected

"last_notif_- seen_" + id

Keep informa7on about the last no7fica7on seen by the user

is browser-based: by default in- finite life time

filter_backup_ + e.key

Backup system to store the se- lected filters on the page that shows all influencers

is browser-based: by default in- finite life time

rgpdOptIn

Allows to know if the user has given his authoriza7on of the general condi7ons of services of the site

is browser-based: by default in- finite life time

lang

Backup system to keep the ini- 7al choice of the user's lan- guage in memory

is browser-based: by default in- finite life time

switchLang

Backup system to keep track of a poten7al change in the user's language

is browser-based: by default in- finite life time

from_widget

allows to know if a user has cli- cked on an influencing widget to get to the site

7 days

sessionid

Allows authentication

Permanent

csrftoken

CSRF Security

Permanent

Facebook SDK

Authentication via Face- book

Permanent

➢ Adver7sing cookies
Adver'sing Cookies may be created not only by our Site but also by other websites and applica'ons

that serve ads, announcements, widgets or other elements on the page displayed.

These Cookies may be used, among other things, to personalize and measure the effec'veness of ad- ver'sing or to carry out adver'sing targe'ng.

We use the following adver'sing Cookies:

Cookie Name

Cookie Func7on

Shelf life

Facebook pixel

Facebook analy7cs

is browser-based: by default in- finite life time

➢ Content personaliza7on cookies

Content Personaliza'on Cookies allow us to provide you with content that is most likely to match your interests based on your browsing profile. Your browsing profile is established according to the content you have already consulted.

We do not use Content Personaliza'on Cookies.

➢ Social network cookies

Social Network Cookies allow you to share content from our Site on social networks and to make your opinion or consulta'on of our Services known on these networks by clicking on the "like" and "share" links.
These Cookies may also make it possible to trace users' browsing on the Site.

We invite you to consult the privacy protec'on policies of the social networks behind these Cookies, to learn about the purposes of use of the browsing informa'on they may collect through these Co- okies and the terms of exercising your rights with these social networks.

We do not use Social Network Cookies.

➢ Analy7cal cookies

These Cookies allow us to measure the number of visits, the number of page views and user ac'vity. If necessary, they may collect your IP address to determine the city from which you are connec'ng. Analy'cal Cookies allow us to generate sta's'cs on the use and naviga'on of our Site in order to im- prove our performance. Cookies also allow us to iden'fy naviga'on problems and eventually to solve them.

We use the following Analy'cal Cookies:

Cookie Name

Cookie Func7on

Shelf life

- client-id / google analytics

Google analy7cs

is browser-based: by default in- finite life time

Hotjar

understand user behaviors

is browser-based: by default in- finite life time

Amplitude

understand user behaviors

is browser-based: by default in- finite life time

Intercom

Dialogue with users directly on the site

is browser-based: by default in- finite life time

Survicate

Send ques7onnaires to users

is browser-based: by default in- finite life time

Sentry

Have more informa7on on technical problems that occur

is browser-based: by default in- finite life time

1. Your Cookie Preferences
   ➢ Cookies that can be deposited without consent

Some Cookies do not require your consent, such as :

• -  Technical and func'onal cookies that are necessary for the opera'on of the Site;
• -  Certain Cookies for audience measurement or Cookies that allow to test different versions of

the Site for the purpose of op'mizing editorial choices.

➢ Acceptance or refusal of Cookies subject to your express consent
All other cookies require your consent. These are Adver'sing Cookies and certain Audience Analysis

Cookies. You may freely choose to accept or decline the use of these Cookies.

You can accept or refuse these Cookies during your first naviga'on on the Site.

Your choices to accept or decline cookies will be retained for a period of six (6) months.

You are free to withdraw your consent and more generally to modify your preferences at any 'me, via the following link.

➢ Your browser segngs
It is also possible to set your browser to accept or reject certain cookies. Each browser offers different configura'on op'ons:

- For Internet Explorer: go to the "Sepngs" menu, then "Internet Op'on". Click on "Privacy" and then "Advanced Privacy Sepngs";

• -  For Chrome: go to the "Sepngs" menu and click on "Privacy and Security". Finally, click on " Authoriza'on " and " Cookies and site data " ;
• -  For Safari: go to the "Sepngs" applica'on then go to Safari. Click on the "Privacy and Securi- ty" tab. You can now choose to block all cookies;
• -  For Iphone : go to the " Sepngs " menu, then " Safari ", click on " Cookies ". You can now choose to block all cookies;
• -  For Android: go to "Chrome", click on the " tab at the top right of the screen, then on "Site Sepngs" and then on "Cookies". You can now choose to accept or block Cookies.