Privacy Policy
1. INTRODUCTION
​​
1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
​
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
​
1.3 In this policy, "we", "us" and "our" refer to ELT Songs Ltd. For more information about us, see Section 14.
​
2. THE PERSONAL DATA THAT WE COLLECT
​
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
​
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number and postal address. The source of the contact data is you.
​
2.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website.
​
2.4 We may process your website user usage data (“usage data”). The usage data may include when you watch a video, share a video using the shareable link creator, when a shared video is watched (differentiated by source: teacher, list name), and when you download a PDF. We may use this information to improve our services and to personalize your experience on our website. We may also use this information to track usage statistics and to analyze user behavior on our website. The source of the usage data is you.
2.5 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
2.6 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact form.
​
2.7 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
​
2.8 Please do not supply any other person's personal data to us, unless we prompt you to do so.
​
3. COOKIES
​
3.1 We use cookies and/or other tracking technologies to distinguish you from other users of the website and to remember your preferences. This helps us to provide you with a good experience when you use the website and also allows us to improve the website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, please see our cookie policy.
4. PURPOSES OF PROCESSING AND LEGAL BASES
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
​
4.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, managing abuse of the website, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
​
4.3 Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
4.4 Personalisation - We may process account data and/or usage data for the purposes of personalising the content that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
​
4.5 Direct marketing - We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
​
4.6 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
​
4.7 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
​
4.8 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
​
4.9 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.10 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
​
4.11 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
​
4.12 Data Analysis - We may process your usage data to personalize your experience on our website. We may also use this usage data information to track usage statistics and to analyse individual user behaviour on our website.
​
5. PROVIDING YOUR PERSONAL DATA TO OTHERS
​
5.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
​
5.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
​
5.3 Your personal data held in our website database will be stored on the servers of our hosting services providers Amazon Web Services.
​
5.4 We may disclose personal data to our external IT providers as detailed in the table below:
IT service provider: Vision Education
Data disclosed: All types
Purpose of processing: Website application development, maintenance and monitoring.
Location: Austria
IT service provider: Horizon Alpha GmbH
Data disclosed: All types
Reporting, code management, learning progress data, usage data and customer data management.
Provision of second level technical support
Location: Germany
IT service provider: SendinBlue
Data disclosed: Contact, account, transaction, communication, customer relationship data
Purpose of processing: Sending transactional, marketing and CRM emails and messages
Location: France
More Information: A separate declaration of consent is obtained from our users and the relevant stored e-mail address is sent to SendInBlue
IT service provider: Amplitude Inc
Data disclosed: Usage data
Purpose of processing: Analysing and measuring user behaviour and the performance of various advertisements within the app
Location: USA
More Information: Further information on data protection at Amplitude can be found at
IT service provider: Google LLC
Data disclosed: Usage data
Purpose of processing: Provision of Google Analytics service – this service enables us to understand how our users are using our applications.
Location: USA
More Information: You can find out more about Google's use of information by visiting
https://policies.google.com/technologies/partner-sites
and you can review Google's privacy policy at
https://policies.google.com/privacy
IT service provider: Amazon Web Services EMEA SARL
Data disclosed: All personal data types
Purpose of processing: Data storage
Location: Luxembourg
IT service provider: Facebook
Data disclosed: Marketing campaign data
Purpose of processing: Provision of Facebook Pixel service – this service enables us to understand how our users are reacting to our marketing campaigns.Location: USA
More Information: You can find out more about Facebook's use of information and you can review Facebook's privacy policy at https://www.facebook.com/privacy/
IT service provider: Freshworks Gmbh
Data disclosed: Marketing campaign data
Purpose of processing: This service provider processes and saves your email address, your contact details transmitted to the support-team and, if applicable, your IP address.
Location: Freshworks Gmbh, (Company Registration No.: HRB 176669 B), Neue Grünstraße 17, 10179 Berlin, Germany.
5.5Financial transactions relating to our website and services are handled by our payment services providers, Stripe Payments Europe Limited. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at
https://stripe.com/en-gb-es/privacy-center/legal
5.6In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
6.2 Some of our external third parties are based outside the UK and/or the EEA so their processing of your personal data will involve a transfer of data outside the UK and/or EEA.
6.3 Whenever we transfer your personal data out of the UK and/or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
b) Where we use certain service providers, we may use specific contracts approved for use in the UK and/or the EEA which give personal data the same protection it has in the UK and/or the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and/or EU.
6.4 The hosting facilities for our website are situated in Luxembourg. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of this country.
6.5 Vision Education, Horizon Alpha GmbH, SendinBlue, Amazon Web Services EMEA SARL and Stripe are located in the EEA. The competent data protection authorities have made an adequacy determination with respect to the data protection laws in the EEA.
6.6 Amplitude Inc and Google LLC as detailed above, are situated in USA. Transfers to each of these suppliers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
7. RETAINING AND DELETING PERSONAL DATA
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
​
a) the period of retention of all personal data categories for subscribers on the Website will be determined based on the length of a user’s subscription to the Website. Personal data will be retained no longer than 12 months after the end of the user’s subscription to the Website, also known as expiration of the membership period.
​
b) the period of retention of all personal data categories for users on the Website who agree to receive marketing emails will be determined based on the length of a user’s subscription to the marketing email mailing list. Personal data will be retained no longer than 3 weeks after the user indicates that they no longer wish to receive marketing emails.
​
c) the period of retention of all personal data categories for users on the Website who supply details through the acceptance of cookies will be determined based on the action, or lack thereof, taken by the user following receipt of a limited number of marketing emails. Personal data will be retained no longer than 3 weeks following the end of the email sequence or after the the user indicates that they no longer wish to receive marketing emails, whichever is sooner.
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. SECURITY OF PERSONAL DATA
8.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
8.3 The following personal data will be stored by us in encrypted form: contact information, password(s) and cardholder data.
8.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
8.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
9. YOUR RIGHTS
9.1 In this Section 9, we have listed the rights that you have under data protection law.
9.2Your principal rights under data protection law are:
​
a) the right to access - you can ask for copies of your personal data;
​
b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
​
c) the right to erasure - you can ask us to erase your personal data;
d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
e) the right to object to processing - you can object to the processing of your personal data;
f) the right to data portability - you can ask that we transfer your personal data to another organisation or to
you;
g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
9.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting the European Data Protection Board and the Information Commissioner's Office.
9.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
10. THIRD PARTY WEBSITES
10.1 Our website includes hyperlinks to, and details of, third party websites.
​
10.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
​
11. PERSONAL DATA OF CHILDREN
​
11.1 Persons aged under 18 may not register for an account on Planetpop.com. Whilst our content is structured to support learners between the ages of 5 and 15, our website may only be used by such learners under adult supervision and we do not knowingly collect the personal data of children.
​
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
​
12. UPDATING INFORMATION
​
Please let us know if the personal information that we hold about you needs to be corrected or updated.
​
13. AMENDMENTS
​
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
14. OUR DETAILS
14.1 This website is owned and operated by ELT Songs Ltd.
​
14.2 We are registered in England and Wales under registration number 11145238, and our registered office is at 54 Sun Street, Waltham Abbey, England, EN9 1EJ.
​
14.3 Our principal place of business is at Office Suite 3, 4 Bridge Street Mills, Bridge Street, Witney, OX28 1FX, United Kingdom.
​
14.4 You can contact us:
a) by post, to our principal place of business address given above;b) using our website contact form;c) by telephone, on the contact number published on our website; ord) by email, using the email address published on our website.
​
15. DATA PROTECTION REGISTRATION
​​
15.1 We are registered as a data controller with the UK Information Commissioner's Office.
​
15.2 Our data protection registration number is A9048878.
​
16. REPRESENTATIVES
​
Our representative within the EU with respect to our obligations under data protection law is European Data Protection Office (EDPO) and you can contact our representative by using the below contact details.
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), ELT Songs Ltd has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR: by using EDPO’s online request form:
​
https://edpo.com/gdpr-data-request/
​
by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium