At Sounded.com ("We") are committed to protecting and respecting your privacy. The purpose of this Policy (together with our Terms and Conditions and any other documents referred to on it) is to provide you with information about how we use your personal data and set out the basis on which any personal data we collect from you, or which you provide to us, will be processed by us.
We process your personal data for the purposes set out in this Privacy Policy. The two main purposes for our processing activities are (i) in order to offer to you and provide you with our services, for which you will be required to register a user account and where applicable transact for the use of our services; (ii) to ensure compliance with our legal and regulatory obligations, which includes keeping records of transactions made using our services.
By visiting our website www.sounded.com (our “Site”) or downloading and using our Mobile App (our “App”) and/or using any of our services, you are accepting and consenting to the practices described in this Privacy Policy.
For the purpose of the Data Protection Act 2018 (as amended from time to time) (the “Act”), the data controller is Sounded Limited of Second Floor, 18-20 North Quay, Douglas, Isle of Man, IM1 4LE. This is who we will refer to in this Privacy Policy, when referring to “Sounded”, “we”, “our”, and “us” etc.
We have an appointed Data Protection Officer. They can be reached at data@sounded.com. Whilst our Data Protection Officer can be reached, our customer support team support@sounded.com will be your initial point of contact should you wish to exercise your data protection rights.
We may collect and process the following data about you:
• Information you give us. You may give us information about you by filling in forms on our Site or App or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Site or App, subscribe to our service, search for a product, place an order on our Site or through our App, participate in surveys on our Site or App, browse certain categories of products on our Site or App, when you make a purchase and when you report a problem with our Site or App.
The information you give us may include your name, address, age, gender, e-mail address and telephone number, financial and credit card information, personal descriptions (including author and pen names) and depending on your jurisdiction, tax information. We may also collect other information necessary for us to process any of your personal data for the purposes set out in this Privacy Policy. Additional information may also be required from you to use some of our services and we may ask for this from time to time.
• Information we collect about you. With regard to each of your visits to our Site or App we may automatically collect the following information:
• technical information, including but not limited to the Internet Protocol (“IP”) address used to connect your computer or mobile device to the Internet, your device type, your login information, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our Site or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
This information is useful as it helps us get a better understanding of how you use our Site so we can provide the best experience possible. Some of this information is collected using cookies, set out below.
In this Privacy Policy, we use the expression “cookie” to refer to cookies or similar technologies we use to store information (such as a web beacon). A cookie is a simple text file which is stored on your computer or mobile device by a website’s server. Only the server which has placed the cookie will be able to retrieve and read the contents of the cookie. Each cookie is unique to your web browser.
Almost all websites use cookies, to improve your visitor experience, including remembering your device, your last browsing session, or a repeat visit.
Our Site and App uses cookies to distinguish you from other users. This helps us to provide you with a good experience when browsing and also allows us to improve our Site, App and services. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
Most browsers and mobile devices will allow you to disable cookies in your browser settings. If you have this feature enabled or reject one or more of our cookies, certain functions of our Site or App may not work correctly.
We are allowed to use and share your personal data where we have a proper and legitimate reason to do so. We use information held about you in the following ways:
• Information you give to us. We will use this information:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services you request from us;
• to provide you with information about other goods and services we offer which are similar to those you have already purchased or enquired about;
• to provide you, with information about goods or services we consider may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the account registration form;
• to notify you about changes to our service;
• to ensure content from our Site or App is presented in the most effective manner for you and for your device.
• Information we collect about you. We will use this information:
• to administer our Site and App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Site and App to ensure content is presented in the most effective manner for you and for your device;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Site and App safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users about goods or services which may be of interest.
• Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also share your information with selected third parties including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Advertisers and advertising networks which require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them 500 men aged under 30 have listened to their advertisement on any given day).
• We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, in a particular postcode). We may make use of the personal data we have collected to enable us to comply with our contractual obligations with advertisers for the displaying of advertisements to a specific target audience.
• Analytics and search engine providers to assist us in the improvement and optimisation of our Site and App.
In cases where we share your personal data, we will have a contract in place with each processor to ensure your data is kept safe.
We may disclose your personal information to third parties:
• In the event we sell or buy any business or assets, in which case we may disclose personal data to the prospective seller or buyer of such business or assets;
• If all or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of Sounded, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We store your personal data in the Isle of Man, a territory which has received an Adequacy Decision from the European Commission regarding its suitable data protection laws. In certain circumstances, personal data collected from you may be transferred to, and stored at, a destination outside the European Union (“EU”). It may also be processed by staff operating outside the EU who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. In cases where your personal data is shared outside of the EU, we will ensure standard contractual clauses, or an adequacy decision is in place to safeguard personal data. By using our Site or App and/or submitting any of your personal data to us, you agree to this transfer, storing or processing.
We will take appropriate security, technical and organisational measures reasonably necessary to ensure your personal data is treated securely and in accordance with this Privacy Policy.
Information you provide to us is stored on our servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site or App, in accordance with our Terms and Conditions, you are responsible for keeping this password confidential as well as your login details. We ask you not to share a password with anyone.
In accordance with our Terms and Conditions, you acknowledge understand and agree, unfortunately, the transmission of information via the internet is not completely secure and security can never be guaranteed. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to our Site or App; any transmission is at your own risk, and you will not hold us liable.
You have the following rights in relation to your personal data:
• A right to access your personal data held by us (known as a subject access request)
• A right to receive certain personal data in machine readable form
• A right to have inaccurate or out of data personal data corrected
• A right to withdraw consent to processing of your personal data (in circumstances where we have requested your consent, and have no other lawful conditions we can rely on for processing
• A right to have certain personal data which we no longer require for processing, to be erased
• A right to object to processing if the lawful basis is in our legitimate interests
• A right to request an explanation regarding any decisions taken about you or your account if those decisions have been taken through automated means
• A right to object to direct marketing, which can be done through opting out of receiving marketing correspondence through your account settings. You also have a right to object to profiling based on any direct marketing.
If you would like to exercise any of your rights, you can do so by contacting our support team: support@sounded.com. Kindly note, there may be situations when we are unable to accommodate your request and where we are still entitled to continue processing your information. This includes where we may have legal or regulatory obligations, which means we may refuse your request or may only be able to comply with part of it.
When you make a request in respect of your rights, we will ask for proof of identification. We will also ask you to clarify your request to us. When responding to requests, this may take up to 30 days following confirmation of your identity, but it may take longer in some instances and we will contact you to inform you if this is the case. We reserve the right to not respond to any unreasonable, vexatious, or illegitimate requests in our sole discretion.
If you have signed up to use our services, we may send direct marketing communications to you (including communications for services from companies in our group) provided you have given us consent to do so.
At any time, you can manage your consent to receive marketing communications from settings within your user account. If you would like stop receiving marketing communications from us, you should log into your user account. From within the account user settings menu, you should select opt-out from receiving marketing communications. Once you have selected this option, it may take up to seven days for any marketing communications to stop. Kindly note, this does not prevent us from sending you notices or communications regarding our service, or your use of our service.
If we use your personal information to provide you with or show relevant advertising on social media platforms, or if you follow any of our accounts on social media platforms and do not wish to see any advertisements or marketing, you can do this in your account settings on the specific social media platform.
From time to time, our Site or App may contain links to and from the websites of third parties. If you follow a link to any of these websites, you should take care to be aware of and check their privacy policies before you submit any personal data to these websites. We do not take any responsibility for the policies of the third-party websites or the way in which they process your personal data.
This Privacy Policy may be updated from time to time, so we recommend you review it regularly. If we make material changes to this Privacy Policy, we will take steps to alert you to those changes.
24 January 2023
