Last Updated: 10/07/2022
About this Notice This Privacy Notice ("Notice") explains how we (as defined below) collect, share and use any information that, alone or in combination with other information, relates to you ("Personal Data") when you ("you" and "your") use our website https://www.compositiontoday.com/ . Our Website makes available various services, including music-related tools and content (the "Service").
This Notice also sets out the rights that you have in relation to the Personal Data that we process about you and how you can exercise them.
compositiontoday.com treats compliance with its privacy obligations seriously. This is why we have developed this Notice, which describes the standards that compositiontoday.com applies to protect Personal Data.
For the purposes of this Notice, compositiontoday.com ("compositiontoday.com", "us", "we", or "our") acts as the data controller for the Personal Data that is collected via the Website and through the Service. As a data controller, compositiontoday.com is responsible for ensuring that the processing of Personal Data complies with applicable data protection law, and specifically with the General Data Protection Regulation.
Please take the time to read this Notice carefully. If you have any questions or comments, please contact us via email@example.com.
What Personal Data does compositiontoday.com collect and why?
The types of Personal Data that we may collect about you, and the reasons why we process it, are as follows:
|Why we collect it||Personal Data we collect||Legal grounds for processing|
-Administering our Website and App
-Ensuring the functioning of our Website and App, including chat rooms and message board and other community features, and for maintenance purpose
- IP address
-Device ID (Client ID for web), device type, screen resolution
-Browsing data (what actions user did on the site)-Country
-Payment info (such as payment ID)
-Name/Last name, gender (if user decided to add it)
- Legitimate interest of compositiontoday.com to offer and ensure the proper functioning of the Website |
-Improving our Website
-Device ID (Client ID)|
-Browsing data (clicks, page views)
|Please see our Cookie Notice|
|-Responding to your queries when you contact us through our Website||
- Device model, OS version
|- Depending on the nature of your query, we will rely either on the necessity to take steps prior to entering into a contract with a potential customer or our legitimate interest to respond to customer queries|
|-Completing your online registration on the Website||
-Links to social media accounts (if any)
-Profile and account information (such as your viewing and listening habits and preferences, the instructions you play and your level)
This includes optional information.
|- Contractual necessity|
|-Fulfilling your order and processing your payment or donation||
-Payment system ID
|- Contractual necessity|
|-Providing you with support through our customer support team||
-Communication with customer support team by email and other data stored by our customer support provider
|- Contractual necessity|
|-For legal enforcement||_Data necessary for law enforcement, litigation and authorities' requests (if any)||- Legitimate interest of compositiontoday.comto defend its legal rights and interests|
We also collect certain information automatically from your device. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. Collecting this information facilitates our online operations and ensures an efficient online experience for you. It enables us to better understand the visitors who come to our Website , where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. Some of this information is collected using cookies and similar tracking technology, as explained further in our Cookie Notice.
The Service we provide through the Website and the App is not intended for individuals below the age of 13. If you are under 13 years old, please do not use the Service. You may only use compositiontoday.comif you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of compositiontoday.comhas been provided to us.
Who does compositiontoday.comshare your Personal Data with?
We may disclose your Personal Data to the following categories of recipients:
to our group companies for purposes consistent with this Notice. We take precautions to allow access to Personal Data only to those staff members who have a legitimate business need for access and with a contractual prohibition of using the Personal Data for any other purpose.
to our third party vendors, services providers and partners who provide data processing services to us, or who otherwise process Personal Data for purposes that are described in this Notice or notified to you when we collect your Personal Data. The services these vendors provide to us are transaction services (e.g., fulfillment, billing, mailing, storage or delivery services), cloud storage, customer support, maintenance, database management, analytics, improvement of the Website's and App's features and advertising.
to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
to our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Data for any other purpose. We share Personal Data with our external counsel.
to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Notice;
to any other person if you have provided your prior consent to the disclosure.
How we protect your privacy
We will process Personal Data in accordance with this Notice, as follows:
Fairness: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it in accordance with applicable law.
Lawfulness: We will process Personal Data only on lawful grounds.
Purpose limitation: We will process Personal Data for specified and legitimate purposes, and will not process it in a manner that is incompatible with those purposes, unless permitted by applicable data protection laws.
Data minimization: We will process Personal Data that is adequate, relevant and limited to what is necessary to achieve the purposes for which the data are processed.
Data accuracy: We take appropriate measures to ensure that the Personal Data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing us promptly of any changes or errors. You should notify us of any changes to the Personal Data that we hold about you (e.g. new home address or change of name).
Data security: We use appropriate technical and organisational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. Specific measures we use include to-date secure network architectures that contain firewalls and intrusion detection devices and backups.
Data storage, retention and deletion
We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
Data storage and transfers of data
All your personal data is stored on our servers in the European Economic Area (EEA). However, we use third party service providers and business partners who may be operating from outside the EEA and therefore, your data may be transferred to, or accessed from those countries.
We have put in place appropriate safeguards (which includes the European Commission’s Standard Contractual Clauses) to ensure that whenever your Personal Data is transferred outside the EEA to countries that are not deemed adequate by the European Commission, your Personal Data receives an adequate level of protection in accordance with the GDPR.
In some instances, we carry out profiling to better understand our users and their potential interests. However, profiling does not result in automated decisions being taken that legally affect you or similarly significantly affect you.
Your data protection rights
You have the following data protection rights:
If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting via firstname.lastname@example.org
In addition, in certain circumstances, as stipulated in the applicable data protection legislation, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the following contact details: email@example.com
If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you. You can also access your profile page and modify your preferences.
If you have a complaint or concern about how we are processing your Personal Data then we will endeavour to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.)
We respond to all requests we receive at via firstname.lastname@example.org from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Linking to other websites
The Website may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and we urge you to review them. They will govern the use of Personal Data you submit whilst visiting these websites.
We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
Updates to this Notice
We may update this Notice from time to time in response to changing legal, technical or business developments. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws.
You can see when this Notice was last updated by checking the "last updated" date displayed at the top of this Notice.
How to contact us
If you have any questions or comments, or if you wish to exercise your data protection rights, please contact us via email@example.com
Additional Information for California Consumers
The California Consumer Privacy Act ("CCPA") provides California residents, referred to in the law as "consumers," with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access and control personal information. Certain information that we collect may be exempt from the CCPA because it is considered public information (because it is made available by a government entity) or covered by another federal privacy law, such as the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect personal information about you that is subject to the CCPA, that information, our practices, and your rights are described below.
compositiontoday.com welcomes your questions and comments about privacy. Please send e-mail to firstname.lastname@example.org
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