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Privacy Policy

We ask that you read this privacy policy carefully as it contains important details about what personal data Manic Street Teachers (also referred to as "we," "us" or "our") collects, in relation to our Musician of the Month website, and processes when you use our services, including the choices we offer you to access, maintain and control it. 

 

1. Your Fluency Factory Account and Service Data
1.1. When you register for and use our services, we will collect and process your personal data, supplied by you, in order to be able to provide our services to you. Below is a table to inform you clearly of:

What personal data we collect on registration

Data Collected

  • email address

Purpose for Processing

  • To manage registration, perform account management and provide customer services

  • To identify you within our services and service usage

  • Administrative (i.e. financial, legal and regulatory compliance)

  • To contact you about products, events and services

  • Security

Lawful Basis For Processing

  • Contractual obligation, legal obligation, consent and legitimate interest

1.2. We may also collect additional personal data if you supply it to us, become a paid subscriber or contact us. The consequences of not supplying this personal data may be that you cannot benefit from all of the services that you have signed up for, or that the services we provide to you will not be as customised, effective or secure. Below is a table to inform you clearly of:

What personal data we may collect

Data Collected

  • first and last name

Purpose for Processing

  • Provide a delivery service for goods purchased, record keeping & prevention of crime

  • Service personalisation and service improvement

  • Security

  • To contact you about products, events and services

Lawful Basis For Processing

  • Contractual obligation and consent

Data Collected

  • full address, including name of school/workplace, county and post code

Purpose for Processing

  • Record keeping & prevention of crime

  • Service personalisation and service improvement

  • Security

  • To contact you about products, events and services

Lawful Basis For Processing

  • Contractual obligation and consent

Data Collected

  • Enquiry and Correspondence Data

Purpose for Processing

  • Customer services

  • Account management

  • To offer, market and promote products, events and services

Lawful Basis For Processing

  • Legitimet Interests

Data Collected

  • Transactional Data (i.e. payments)

Purpose for Processing

  • To process information on your purchases or supply of goods.
    To provide good administration
    Business reporting

Lawful Basis For Processing

  • Contractual obligation and legitimate interests

1.3. Where legitimate interest is the lawful basis of processing your personal data, the legitimate interests we are pursuing are as follows: -

  • Providing you any products or services you have requested;

  • Analysing your use and measuring the effectiveness of our services to better understand how they are being used so we can improve them and engage and retain users;

  • Sending you information about our products, events and services, special offers and similar information (where your consent is not required);

  • To enable and support our recruitment of employees and sub-contractors;

  • Analysing your use of our services and interaction with our communications, to tailor and customize our services and marketing communications;

  • Diagnosing problems in our services;

  • Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent to undertake such surveys, in which case we will only do this with your permission);

  • Investigating and responding to any comments or complaints that you may send us;

  • In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with legal process or litigation).

1.4. Where contractual and legal obligations are the lawful basis of processing your personal data, the consequence of failing to provide your personal data will be that we are unable to provide our service to you.

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2. Your Fluency Factory Service Usage Data
2.1. When you interact and make use of our services, we may capture and process usage data. This data is ultimately processed with the purpose of delivering reliable, secure and accurate services and to consistently enhance, improve and optimise your experience of using our services. We do not sell this data to third parties. Our legal basis for this processing is that of legitimate interest.
(Examples include: IP address; browser type and version; operating system used; website speed, website navigation paths and actions; and patterns of service use.)

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2.2. Our host site Wix can store site-visitors' data in a number of locations. Personal information may be stored in data centers located in the United States of America, Ireland, South Korea, Taiwan and Israel. Wix may use other jurisdictions as necessary for the proper delivery of our services and/or as may be required by law. Wix is a global company that respects the laws of the jurisdictions it operates within. The processing of the User Customer Data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection (transfer on the basis of an adequacy decision). 

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3. Sharing Your Personal Data
3.1. We will disclose your personal data to our employees to enable them to process your data.

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3.2. Your personal data may also be disclosed to other companies in the Manic Street Teachers group, and to our agents, sub-contractors, data processors and suppliers (3rd parties) to enable them to process your personal data on our behalf.

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3.3. When we supply any of your personal data to our agents, sub-contractors, data processors and suppliers (3rd parties), we protect your personal data by ensuring reasonable contractual arrangements are in place that stipulate compliance with this Privacy Policy.

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4. Marketing and Product Preferences
4.1. We may use account, service and usage data to provide you with information about our products and services. Our purpose is to provide you with a service to help meet your needs. Our lawful basis for processing this data is consent. You are free to withdraw your consent at any time. The consequences might be however, that we cannot offer you certain things, such as offers and promotions or resource alerts, which may be beneficial to you.

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4.2. You may opt-out at any time by unsubscribing from any Musician of the Month emails by replying with 'unsubscribe' or clicking on the Unsubscribe button at the bottom of any marketing emails.

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5. Our Use Of Cookies and Stored Device Data
5.1. A cookie is a small text file that is downloaded onto a computer or smartphone when the user accesses a website. It allows the website to store and retrieve information about how the device is using the website.

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5.2. The Fluency Factory website by Manic Street Teachers uses cookies and stored device data for the following purposes:

  • to ensure the correct technical functionality of the services we provide and optimise global performance - for example, to help you find the most relevant content and get that content to you quickly and accurately;

  • to maintain website security, prevent website abuse and ensure legislative/regulatory compliance - for example, to prevent cyber-attacks;

  • to compile, and enrich, internal business data regarding website traffic and activity - for example, to help us to understand our most popular website pages, visit sources and time-of-day traffic;

  • to help to improve our services to you and better meet your future needs - for example, to understand your needs and preferences so as to improve your website experience.

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5.3. In general, the cookies which are placed on our Wix website may be categorized as essential cookies. However, there may be multiple components, codes and third-party applications so we may include other types of cookies which might require specific settings. Take a look at the table on the Wix site to see which cookies we may place on our site: https://support.wix.com/en/article/cookies-and-your-wix-site

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5.4. If at any point you wish to withdraw consent for the use of cookies you can clear these from your browser by clearing your website history and configure your browser to block cookies. Some of our website features may not function correctly and/or you may not receive the best website experience if you disable/do not consent to the use of cookies.

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6. How We Protect Your Personal Data
6.1. We have put in place a number of security procedures and technical organisational measures to safeguard your personal data. These measures are reviewed regularly and updated when necessary in order for us to meet business needs and in accordance with changes in technology and regulatory requirements.

Examples of procedures and technical and organisational measures:

  • We take steps to ensure our employees operate in accordance with our information security policies, procedures and applicable contractual conditions.

  • We have measures in place to protect against accidental loss and unauthorised access, use, destruction or disclosure of data. Some examples are: staff screening, encryption and hashing; firewalling and content filtering; virus/malware scanning and protection; vulnerability scanning; multi-factor authentication; pseudonymization; logging, monitoring, inventory and auditing; secure design; privacy impact assessments, physical security controls; system authentication/role-based access control, high availability configuration and regular backups.

  • We have a business continuity and disaster recovery strategy that is designed to safeguard the continuity of the Musician of the Month service and to protect you and your data.

  • Our organisation fully complies with GDPR regulations. We have completed internal data audits and have appointed a “Data Protection Officer” to monitor our on-going compliance.

  • We commit to notify users within 72 hours of any breach of Personal Information affecting them.

  • We use Wix as our host website. Please refer to sections, 4, 12 and 13 at https://www.wix.com/about/privacy for information on how Wix handles our site-visitors' data.

  • The security of users' sensitive data is of extreme importance to Wix and they are 100% committed to protecting it. See the security certificates received by Wix here: https://support.wix.com/en/article/security-of-wixs-billing-services-and-pci-compliance

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6.2. We will use all reasonable efforts to safeguard your personal data. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet.

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7. Overseas Transfers
7.1. The personal data you provide may be transferred to countries outside the European Economic Area ('EEA') that do not have similar protections in place regarding your data and restrictions on its use as set out in this Privacy Policy. However, transfers outside of the EEA will be protected by us imposing appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission to ensure the security of your data or via, independent privacy schemes approved by regulators (like the US Privacy Shield Scheme).

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7.2. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your data, you consent to these transfers for the purposes specified above.

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8. Your Rights Under Applicable Data Protection Law
8.1. Your rights in respect to how we process your personal data are set out below. Please note that some of these rights only apply in certain circumstances.

YOUR RIGHTS (INFORMATION COMMISSIONER'S OFFICE (ICO) GUIDANCE)

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8.2. We respect and value your right to access and control your data. You can exercise your rights, subject to appropriate identity verification procedures, in the following ways:

  • By amending your data or consent within your Service account area;

  • By contacting us via email on info@manicstreetteachers.com

  • By sending a letter to Manic Street Teachers, 14 Brookside Road, Ruddington, Nottingham NG11 6AW

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8.3. We take your rights seriously and want you to feel confident that we are handling your personal data responsibly and in line with good practice. You can seek further information or raise a concern to us by emailing info@manicstreetteachers.com.

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9. Data Retention
9.1. We retain personal data for as long as we reasonably require it for legal or business purposes. When determining data retention periods, we take into consideration applicable laws, contractual obligations and the expectations and requirements of our customers. When we no longer need personal data, we securely delete or destroy it.

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10. Sale Of Business
10.1. If Manic Street Teachers or The Fluency Factory site is sold or integrated with another business your personal data may be disclosed to our advisers, or any prospective purchasers and their advisers, and will be passed on to the new owners of the business.

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11. Your Consent
11.1. By using or interacting with our service, you are consenting to:

  • the use of cookies and other technologies;

  • the transfer of your data outside of the country where you live;

  • the transfer of your data outside of the European Economic Area;

  • the collection, use, sharing, and other processing of your information as described in this Privacy Policy.

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11.2. In each case, you consent to the processing of data by Manic Street Teachers, as data controller. If you don't agree with the terms of this Privacy Policy, then please don't use our service.

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11.3. Where the lawful basis of processing your data is consent, you have the right to withdraw your consent at any time.

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12. Manic Street Teachers 14 Brookside Road, Ruddington, Nottingham NG11 6AW


13. Changes to this Policy
13.1. We keep this policy under regular review. If we change the content of our Privacy Policy we will post the changes on this page.

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Last updated by Manic Street Teachers - July 2023

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