THE VOCAL & MUSIC ACADEMY LTD PRIVACY POLICY

If we say ‘Policy’ we’re talking about this Privacy Policy. If we say ‘User Terms’ we’re talking about the rules for using the site, it’s extensions and by extension our services. The rules vary by product and each product makes them separately available and seeks consent to them separately to this policy.

The type of personal information we collect

We collect certain personal information about visitors and users of our Sites.

The most common types of information we collect include things like: user-names, member names, parents names where relevant, email addresses, other contact details, survey responses, information supplied to us through forms by you.

Payment information such as payment agent details, transactional details, tax information are all processed securely via Stripe or Direct Transfer between your bank and ours. At no point do we collect any information regarding the process or means by which you make a payment.

Support queries and content you direct us to make available on our site (such as item descriptions) and web analytics data. We also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).

How we collect personal information

We collect personal information directly when you provide it to us, or through other people when you use services associated with the site or when we take details from emails we receive or manually gleaned from open sources on the internet.

We collect your personal information when you provide it to us when you complete registration and buy or provide items or services on our Site, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.

Personal information we collect about you from others

We generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other freely available sources. In particular:

Third party service providers (like Intuit, Squarespace, Google, Facebook, Instagram, TikTok, Snapchat, Twitter) who are located in the US or Europe, which may provide information about you when you link, connect, or login to your account with the third party provider and they send us information such as your registration and profile from that service, this only occurs if you are using The VMA website or interact with MailChimp our preferred Mailshot conduit. The information varies and is controlled by that service provider or as authorised by you via your privacy settings at that service provider; and other third party sources and/or partners from Ireland, US or UK, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification service.

How we use personal information

We will use your personal information…:

• To fulfil a contract or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the Site, like where you purchase an item related to our business. (Contract means for instance, when you purchase a class or a service we are contracted to provide you with that service which in essence is the ‘Contract’)
• Where this is necessary for purposes which are in our, or third parties, legitimate interests. (Third Party for example might be our Booking Software which is owned by Squarespace, which in order to provide the service we employ it to do needs to collect relevant information from you and dispense it to us so that we can provide the ‘Contract’ or Service to your satisfaction.)
• In the event we feel that both the singer/musician and the teacher can benefit from the experience of a third party (Master Teacher, Mentor or Ambassador) who can assist in helping a singer/musician through and beyond a difficult tendency in their voice/playing. In this case however it is most likely that it is only the name, age and a recording of the singer if the singer or third party are unable to ‘meet’ live via Video Conference. This is generally done however with a verbal consent directly with the student or the student’s parent or guardian.
• We may also take video of our students for the purpose of promotion of our School uness we are specifically asked not to do so by a student, parent, or guardian.
• To connect into a Third Party mail service (e.g. Mailchimp) for the purpose of sharing information we think will be of interest, benefit or use to you.

These interests include:

• Managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
• Managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
• Training VMA staff about how to best serve our user community;
• Improving our products and services.
• Providing general administrative and performance functions and activities; and
• Where you give us consent:
• Providing you with marketing information about products and services which we feel may interest you; and
• Customising our services and websites, like advertising that appear on the Site – where this involves the use of cookies or similar technologies – in order to provide a more personalised experience.
• For purposes which are required by law.
• For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

We record all Vocal Lessons. These recordings are shared via Dropbox for the purposes of:
a: Homework for the student to listen and follow as they practice;
b: In the event of the Singing Student being under 18 years the recordings are also shared with a parent/guardian unless expressly asked not to by the parent/guardian
c: For training purposes or for the purpose of re-listening to a section of a class we may feel later, we could have provided better instruction.

When we disclose your personal information

We will disclose personal information to the following recipients:

• Authors of any items or services made available to you, so they can facilitate support and license validation, who maybe located in any of the countries our products are available in.
• Subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above)
• Teachers (as set out above)
• Our professional advisers (legal, accountants, financial advisers etc.) which are located in Ireland.
• Regulators and government authorities in connection with our compliance procedures and obligations;
• A purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
• A third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
• A third party, in order to enforce or defend our rights, or to address financial or, reputational risks;
• A rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
• Other recipients where we are authorised or required by law to do so.

Where we transfer and/or store your personal information

We are based in Ireland so your data is processed in Ireland. Some of the recipients we have described above, and to whom we disclose your personal information, are based outside Ireland. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

We only use trusted third party partners in assisting us to run our business who are world class service providers in their line of business. Here are a list of the Third Party Service Providers we use and links to their Security Information and Policies:

Mailchimp – https://mailchimp.com/about/security/

Mialchimp – As it relates to GDPR – https://mailchimp.com/contact/

Stripe – https://stripe.com/guides/general-data-protection-regulation

Acuity – https://help.acuityscheduling.com/hc/en-us/articles/360003334751-General-Data-Protection-Regulation-GDPR-

Google Analytics – https://privacy.google.com/businesses/compliance/#?modal_active=none

Intuit – https://www.intuit.com/privacy/statement/

WordPress – https://wordpress.org/about/privacy/

 

How we keep your personal information secure

We store personal information on secure servers that are managed by us and/or our service providers (see above), and very occasionally hard copy files that are kept in a secure location in Ireland. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.

How you can access your personal information

You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us at any time.

To make an access or correction request, contact us using the contact details at the end of this policy.

Marketing Choices regarding your personal information

Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us or a user of any of our services), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our site may not work properly for you.

Cookies and web analytics

For more information about how we use cookies, web beacons and similar technologies see our cookie policy here and for more general information on cookies, see http://www.allaboutcookies.org.

When you visit our site, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account.

We’re talking about the following kinds of details:

• your IP address or proxy server IP address’;
• the domain name you requested;
• the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
• the date and time of your visit to the website;
• the length of your session;
• the pages which you have accessed;
• the number of times you access our site within any month;
• the file URL you look at and information relating to it;
• the website which referred you to our Sites; and
• the operating system which your computer uses.

Occasionally, we will use third party advertising companies to serve ads based on prior visits to our sites. For example, if you visit our site, you may later see an ad for our products and services when you visit a different site.

Information about children

Our site is suitable for children under the age of 18 years to browse, however if you are under 18 we ask that you only book classes or share any personal information or purchase anything from our website/s with the consent of a parent/guardian (if you are a young tech wiz, please direct your nearest responsible adult to use the Sites for you!).

It’s the responsibility of parents or guardians to monitor their children’s use of our Sites.

Information you make public or give to others

If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data.

There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media, or make contact with another user (such as a third party Author) whether via our Sites or directly via email. Before making your information publicly available or giving your information to anyone else, think carefully. If giving information to another user via our Sites, ask them how they will handle your information. If you are sharing information via another website, check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.

How long we keep your personal information

We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with the Vocal Academy services, you can request that we erase your personal information and close your Vocal Academy account. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

When we need to update this policy

We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

How you can contact us

If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our privacy champion in writing at The Vocal & Music Academy Limited, Croí Laighean Development Park, Easton Road, Leixlip, Co. Kildare or info@vma.ie .

We’re really glad you made it to the end of the privacy policy, because knowing this stuff is the best way to understand how your personal information is used and how to best manage it!

If you’re a user or visitor from outside the European Economic Area these rights also apply to you:

For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.

How you can access your personal information

You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict it’s processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.

These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.

Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory:

If such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.

If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.

Both personal information and personal data have the same meaning in the context of this Privacy Policy.

info@vma.ie

The Vocal Academy Privacy Policy v2, effective date 16 August 2023