Privacy & Cookies Policy

Updated May 25, 2018

This Privacy & Cookies Policy governs the websites (including both mobile and online versions) made available by The Copyright Promotions Licensing Group Limited (“CPLG”, “we” “our” or “us”) (collectively, the “Service”), regardless of how you access or use the Service, whether via computer, mobile device or otherwise. This Privacy & Cookies Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy & Cookies Policy. Subject to applicable law, this Privacy & Cookies Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our Service.

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Service’s Terms of Use, which governs your use of the Service. By using our Service, you consent to our Privacy & Cookies Policy and our Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy & Cookies Policy, please do not provide us with any information and do not use this Service.

The Full Detailed Privacy & Cookies Policy

1. What Information Does the Service Collect?

(a) Information You Provide to Us

On the Service, we may ask you to provide us or our service providers with certain categories of information, such as personally identifiable information, which is information that could be used to identify you personally, such as your first and last name, phone number, mailing address and email address (“Personal Information”). We may collect this information through various forms and in various places on the Service, including through “contact us” forms or when you otherwise interact with the Service.

(b) Information Collected and Stored As You Access and Use the Service

In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service or the Usage Information can otherwise be associated with you, we will treat it as Personal Information. Where required by applicable law (e.g., in Europe), we will treat Usage Information as Personal Information in any event.

This Usage Information may include:

your IP address, UDID or other unique identifier (“Device Identifier”) (a Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier);
your Device functionality (including browser, operating system, hardware, mobile network information);
the areas within our Service that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the time of day, among other information.

We will use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following:

Cookies. A cookie is a text file placed on a Device when it is used to visit the Service. A Flash cookie (or Locally Shared Object) is a text file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. “Regular” cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please refer to the help and support area on your browser for instructions on how to block or delete cookies. Note, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, go to Adobe’s website www.adobe.com. For information on managing “regular” cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.com (if you are resident in the E.U.), or visit www.aboutads.info (if you are resident in the U.S.), or visit http://youradchoices.ca/understanding-online-advertising#cookies (if you are resident of Canada), which has further information about behavioural advertising and online privacy. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Service may not function properly, and that when you visit our Service your ability to limit cookies is subject to your browser settings and limitations.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs”, “clear GIFs” or “pixels”) may be included in our Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

Browser/Device Fingerprinting. Collection and analysis of information from your Device, including your operating system, plug-ins, system fonts and other data, for purposes of identification.

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. These cookies or other Tracking Technologies are essential in order to help you use and access our Service. The information collected by these cookies relate to the operation of our Services, for example website scripting language and security tokens to prevent fraudulent activity, improve security or allow you to make use of Service functionality.

Performance‑Related. These cookies or other Tracking Technologies are used to assess the performance of the Service, including as part of our analytic practices by third-party providers including Google Analytics, or otherwise to improve the content offered through the Service. These cookies collect anonymous information about how you use the Service, for example which pages you visit most often, whether you receive any error messages, and how you arrived at our website.

Functionality‑Related. These cookies or other Tracking Technologies offer you enhanced functionality when accessing the Service, including identifying you when you use our Service or keeping track of your specified preferences, for example the country you visit our Service from, your language and the presentation of content on our Service (such as font size).

There may be other Tracking Technologies now and later devised and used by us in connection with the Service. Please note that third parties may use Tracking Technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party websites or online services. We do not control those Tracking Technologies and subject to applicable law, we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy & Cookies Policy do not apply to the Tracking Technologies or practices of such third parties.

(d) Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you. To the extent we combine information we receive from those sources with Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy & Cookies Policy to such combined information, unless we have disclosed otherwise.

(e) Interactions with Third-Party Services

The Service may include functionality that allows certain kinds of interactions between the Service and a third-party web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, if you click on social media icons on the Service (such as for Facebook, Twitter or LinkedIn), those actions may be associated with, and we may have access to, your Personal Information you provided on those third-party sites or applications. If so, we will then treat it as Personal Information under this Privacy & Cookies Policy, since we are collecting it as a result of your accessing of and interaction on our Service. In addition, we may provide third-party sites’ interfaces or links on the Service to facilitate your sending a communication from the Service. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy & Cookies Policy. CPLG may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Service.

(f) California Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

2. How Do We Use the Information Collected?

(a) Use of Information by Us.

We may use your Personal Information that is subject to this Privacy & Cookies Policy:

to provide you with information such as to send you electronic newsletters;
to provide you with promotional and marketing materials on behalf of us or third parties, including to let you know about upcoming events, where you have given us the appropriate permissions if required by applicable law;
to improve the Service;
to customize your experience on the Service where you have given us the appropriate permissions if required by applicable law;
to contact you with regard to your use of the Service and, in our discretion, changes to the Service and/or Service’s policies;
to improve the overall experience at the Service;
for internal business purposes; and
for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy & Cookies Policy.

3. How and When Do We Share Information with Third Parties?

We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities for the purposes identified in Section 2 above. If you are a California resident, you have the right to request additional information about this sharing, so please see Section (3)(e) below. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy & Cookies Policy. We may also disclose your information as follows:

(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Service to receive certain information directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, certain portions of your Personal Information and other information may be disclosed to such third parties and all information disclosed will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools or apps on our Service or link to them from our Service. This may include using third-party tools such as those of Facebook, Twitter, LinkedIn or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Service, such as: (i) to assist us in Service operations; (ii) hosting the Service; (iii) designing and/or operating the Service’s features; (iv) tracking the Service’s activities and analytics; and (v) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, they need in order to carry out the services they are performing for you or for us. We do not authorize our service providers to use Personal Information for any purpose other than providing the services on our or your behalf. We may also use third-party analytics and other service providers to help us gather and analyze information about the areas that you visit on our websites in order to evaluate and improve the user experience and the convenience of our Service, and to help us evaluate some of the specific information related to your Service visits. Such third parties may set and access Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. Subject to applicable law, we are not responsible for those third party technologies or activities arising out of them. However, some of these third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) To Protect the Rights of CPLG and Others. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Service’s Terms of Use or other policies applicable to the Service, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Service or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d) Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information and Usage Information with our parent, subsidiaries and affiliates. Subject to applicable law, we may disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a prospective or completed merger, consolidation, restructuring, the sale of substantially all or part of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e) Your California Privacy Rights. We may elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2015 will receive information about 2014 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: enquiries@cplg.com, with “California Privacy Rights” as the subject line or mail us a letter to: One Queen Caroline Street, Hammersmith, London W6 9HQ United Kingdom, Attn: Director of Legal Services. You must include your full name, email address, and postal address in your request.

(f) Your European Privacy Rights. If you are a resident of the European Economic Area (“EEA”) or Switzerland, you may have the right to ask us not to process certain of your personal data (or provide it to third parties to process) for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. Further, you can prevent such processing by indicating who you are and any contact information you have previously provided to us, asking us to cease processing your personal data and indicating your jurisdiction of residence, by contacting us in the following ways: Postal Mail: One Queen Caroline Street, Hammersmith, London W6 9HQ United Kingdom, Attn: Director of Legal Services; By e-mail: enquiries@cplg.com.

4. Does Third-Party Content, Links to Third-Party Sites, and/or Third-Party Apps appear on the Service?

The Service may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Service are served to you for their own commercial purposes. In addition, when you are on the Service you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Service onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

5. How Do I Access, Update or Correct My Information, Communications Preferences and Questions?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Service may allow you to access, review, correct, update or delete Personal Information you have provided through the Service’s registration forms or otherwise by updating your Service account, and you may provide registration updates and changes by contacting us by email at: enquiries@cplg.com. In addition, depending on your jurisdiction, you may have the right to access all of your Personal Information in our custody and control, subject to certain exceptions prescribed by law, and you may do so by contacting us as set forth below. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for CPLG’s administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and Service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

If you have any questions or complaints about the Privacy & Cookies Policy or practices described in it (including the manner in which we or our service providers treat your information), you should contact us in the following ways: Postal Mail: One Queen Caroline Street, Hammersmith, London W6 9HQ United Kingdom, Attn: Director of Legal Affairs; Email: enquiries@cplg.com.

6. What About the Transfer of Information to Other Countries?

Although CPLG’s headquarters are located in One Queen Caroline Street, Hammersmith, London W6 9HQ United Kingdom, Attn: Director of Legal Services, we have offices in the United States and the European Union. Thus, the Service is operated in Canada, the United States and the European Union and intended for users located in these jurisdictions. If you are located outside of the Canada or the U.S., please be aware that information we collect including Personal Information, will be transferred to, and processed, stored and used in Canada or the U.S. by CPLG, its affiliates, and/or third party service providers. Also, please be aware that information we collect, including Personal Information, may be transferred to, and processed, stored and used in countries outside of Canada where the local governments, courts, government agencies and law enforcement authorities may be able to access that information. By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in Canada, the United States and/or the European Union as described in this Privacy & Cookies Policy.

7. What About Security?

We endeavor to incorporate commercially reasonable, technical, physical and administrative safeguards to help protect and secure your Personal Information in our custody and control. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Service and provide us with your information at your own risk.

8. What About Changes to the Privacy & Cookies Policy?

We reserve the right to change this Privacy & Cookies Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy & Cookies Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy & Cookies Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

Data Policy for Applicants

The Copyright Promotions Licensing Group Limited (the “Company”) provides this Data Privacy Notice to applicants submitting their personal data when applying to positions within the Company.

To submit an application for a specific position through the Company’s site or via Linked In, you may provide personal data including name, contact details (telephone number, e-mail address), educational history, training and professional experience, current and past employment details, immigration status and work permits, languages spoken (and level of proficiency), disability disclosures which may require accommodations, and such other information relevant to the position, or as provided in your CV.

The Company uses the personal information it collects from you to assist with the recruitment process and your suitability for the position. If a conditional offer of employment is made to you, we may also use your details to seek references, confirm your identity and conduct background checks prior to employment. We will share such information with the authorised staff involved with the recruitment process. During the recruitment process, the Company may contact you by email, SMS, telephone or post.

The legal basis for processing your personal data is to access your application for a position within the Company, which purpose is a legitimate interest. Your personal information will not be used for any other purposes, save as required by applicable law.

Your data will be treated securely. The Company cannot however guarantee the security of information transmitted over the internet, and any transmission is at your own risk.

The Company’s ultimate parent company is Canadian, and as part of the recruitment process, we may (depending upon the seniority of the position) transfer your data outside of the EEA to the relevant divisional staff in Canada. The European Commission has recognised Canada (commercial organisations) as providing adequate data protection. If any such transfer should occur, all intra-company transfer of information is made via an encrypted VPN, and the Company shall take all steps reasonably necessary to put in place appropriate safeguards for your information in accordance with applicable law.

If you become an employee of the Company, your personal data will become part of your personnel file, and will be used in accordance with the employee Data Privacy Policy. If your application is unsuccessful, we may retain your information for up to twelve months at which point it will be destroyed or deleted in accordance with the Company’s Data Retention Policy.

You have the right to request access to and copies of the personal data that we hold about you, to require the Company to rectify an inaccurate information, and subject to statutory exceptions, to request erasure of your personal data.

The Company may amend or withdraw this Notice at any time at our sole and absolute discretion. It will not form part of any contract that the Company may enter into with you.