Concord - Privacy Policy


Last updated:  October 16, 2023

Concord cares about your privacy. To better protect your privacy, this privacy policy explains how Concord Music Group, Inc. and its affiliates (collectively, “Concord” or “we,” “us” and “our”) collect and use personal information we collect from you or you provide to us through our websites, emails, and other means described here (“Sites”). “Personal information” – or “personal data” in other jurisdictions like the EU – is information that directly or indirectly identifies you as an individual, including, but not limited to:

  • Personal identifiers and contact information, such as your name, street address, email address, telephone number
  • Purchase or Transaction Information, such as product purchases and financial account information like credit or debit card number
  • Demographic Information, such as birth date or age, gender, country
  • Internet and online information, like IP address, device information, browsing history.
  • Account information, such as user name and password, music preferences, entertainment preferences, login times, length of session
  • Contents of communications you engage in, such as through the use of chatrooms, forums, or message boards provided by us, or through phone calls or emails.

If you are an employee or job applicant, in addition we may also collect the following personal information:

  • Background information, such as work and education history
  • Benefits information, such as compensation, payroll data, tax information, health, dental, and vision claims and/or information, disability and life insurance claims, unemployment, or retirement account information
  • Information required to fulfill legal obligations, such as child support obligations, worker’s compensation, unemployment, and similar information.

Information collected on the Sites may be used in the manner described below by Concord, our labels, our publishing companies, agents, subsidiaries and trusted partners acting on our behalf, including artists and artist management. This privacy policy does not address, and we are not responsible for, the privacy practices of any third party with independent relationships with you, including Facebook, Inc., Google LLC, our artists or their management, or financial partners.

HOW WE PROCESS YOUR PERSONAL INFORMATION

TRACKING TECHNOLOGIES / COOKIES

HOW WE SHARE YOUR INFORMATION

WHERE WE STORE YOUR PERSONAL INFORMATION

LINKS TO THIRD PARTY WEBSITES AND THE INTERNET

COMMUNITY FUNCTIONS

NOTICE TO MINORS

YOUR COLORADO, CONNECTICUT, UTAH, AND VIRGINIA PRIVACY RIGHTS

YOUR CALIFORNIA PRIVACY RIGHTS 

YOUR NEVADA PRIVACY RIGHTS 

CHANGES TO OUR PRIVACY POLICY

USERS OF SITES IN THE EUROPEAN UNION/EUROPEAN ECONOMIC AREA

YOUR AUSTRALIAN PRIVACY RIGHTS

YOUR NEW ZEALAND PRIVACY RIGHTS

CONTACT US

1. HOW WE COLLECT AND PROCESS YOUR PERSONAL INFORMATION

We collect and process your personal information for the following purposes. Please note that you are responsible for keeping your information current and up-to-date. You may update your information by contacting us as described in the CONTACT US section below.

(a) Participation in special activities. We collect and process your personal information when you register with us as part of your participation in our promotions, contests or sweepstakes. As part of your registration for the promotion, we may request the following (as required from case to case): direct identifiers (such as your name) contact information (such as your address, email address, or telephone number), indirect identifiers (such as birth date), demographic information (such as country and gender) and profile data (such as your music preferences and entertainment practices).

(b) Newsletters. We collect and process your email address that you provide us with to receive updates on a particular artist or type of music. We then add that address to the email list for that artist or type of music. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us as described in the CONTACT US section below.

(c) Product purchase. If retail opportunities, e.g. in online stores, are available and you choose to buy any of our products, we will collect and process your name, address, email address, telephone number, and order details, and may collect your birth date. Additionally, our financial partners involved in the processing of your banking or credit card data will collect and process the following additional personal information in order to complete your transaction: price, credit card number or other payment information and billing address as well as any further details on the purchase transaction.

(d) Website registration. We collect and process your login details if you choose to register a website user name and/or password so that we can communicate with you, provide the services you have requested and to provide a more personalized experience on our website. You are not required to provide us with this information, but if you choose not to do so, you may not be able to participate in some of the activities on our website. In addition to this, we will process all information you provide to us when you use our services as a registered user and also your usage data (e.g. login times, length of stay).

(e) Contact us. When you CONTACT US by phone, email or otherwise to submit information to us (such as when contacting us with a question or feedback), we collect and process the information you provide to us, e.g. your name, email address, telephone number and request, to respond to your inquiry.

(f) Job application. We collect and process your personal information such as name, address, email address, birth date, work experience, education and other related information you submit to review, verify and evaluate your job application information if you have applied for a job at Concord.

(g) Updates concerning us. If you are a registered user, we collect and process your email address in order to keep you informed about the operation of our services by sending emails and announcements that are needed for the proper functioning and administration of our Sites and services.

2. TRACKING TECHNOLOGIES / COOKIES

Our Sites have features that automatically collect information from you to assist us in creating Sites that honor your preferences and serve your needs, allow us to improve our Sites and provide you with tailored advertising. In certain instances, our Sites use cookies, which are small data files containing information about you that are stored on your hard drive. Cookies are embedded in the HTTP information that travels back and forth between your computer and the servers. Cookies allow automated customer customization and personalization, and, for example, cookies may be utilized to assure that a sweepstake’s applicant enters any given sweepstakes only once or to store session preferences.

(a) We use the following categories of cookies on our Sites:

Functionality cookies. These are used to recognize you when you return to our Sites in order to improve your experience on our Sites, allowing us to personalize our content for you.

Strictly necessary cookies. These cookies are essential for the operation of our Sites and include, for example, cookies that enable you to browse our Sites and use its features and to maintain secure areas of our Sites. We use these cookies based on our legitimate interest to provide you with functioning and secure Sites.

Analytical/performance cookies. These cookies collect anonymous information about how you use our Sites, for example how you arrived at our Sites and which pages you visit most often. This helps us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily. These cookies are sometimes placed by third-party providers of web traffic analysis services, such as Google Analytics. We use these cookies only if you have consented via the cookie banner.

Targeting cookies. These cookies record your visit to our Sites, the pages you have visited and the links you have followed. These cookies are usually placed by third-party advertising networks. They remember the other websites you visit, and this information is shared with third-party organizations, for example advertisers (including Sumo, Facebook, Twitter, Google and Spotify). We use these cookies only if you have consented via the cookie banner.

(b) Social Media plugins:

We use so-called social plugins, e.g. “like buttons,” on our Sites. These are services that are provided by social media organizations such as Facebook, Instagram, Twitter and others. If you access a page of the Site that contains such a plug-in, your browser establishes a direct connection to the social media provider’s servers. Via the plugins, the providers receive the information that you have visited our Sites even if you do not have a profile or are not currently logged in. This information (including your IP address) will be transferred from your browser directly to a server of the respective provider in the USA and stored there. If you are logged in to one of the social media services, the providers may allocate your visit of the Sites to your account with them. Interactions with plug-ins like the “like button” are sent directly to the providers’ servers and stored there. The information is also stored in the social network and published on your account. The purpose and scope of the data collection and the further processing of your data by the providers as well as your relevant rights and setting options for the protection of your privacy can be found in the privacy notices of the providers.

Below, please find more details on the social plugins we use:

Facebook is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. An overview of Facebook plugins and their appearance can be found here: https://developers.facebook.com/docs/plugins

Twitter is operated by Twitter Inc, 1355 Market St, Suite 900, San Francisco, CA 94103, USA. An overview of the Twitter buttons and their appearance can be found here: https://about.twitter.com/en_us/company/brand-resources.html

Instagram is operated by Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA. An overview of the Instagram buttons and their appearance can be found here: https://help.instagram.com

Tumblr is operated by Tumblr, Inc., 770 Broadway, New York, NY, 10003, USA. An overview of the Tumblr buttons and their appearance can be found here: https://www.tumblr.com/buttons

Google+ is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. An overview of Google’s logos including the Google+ logo can be found here: https://www.google.com/permissions/trademark/logos-list.html

You can find more information under the following link: http://www.google.com/intl/en/privacypolicy.html

(c) Web Beacons

Based on your consent, we, or our third-party partners, may employ a software technology called web beacons (also known as web bugs, clear gifs or pixels) which helps us understand what content is effective, for example by counting the number of users who have visited these pages, and to understand usage patterns. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to let us know when content is viewed. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded on web pages, ads, and e-mail. We, or our third-party partners, may tie the information gathered by web beacons to the other information we collect about you.

3. HOW WE SHARE YOUR INFORMATION WITH THIRD PARTIES

Other than as set forth below in this privacy policy, we do not share your personal information with other organizations. Specifically, we share your personal information as follows:

  • With third parties acting as service providers, which agree to use it only for that purpose, and to keep the information secure and confidential. These service providers can be classified in the following categories:
    • Delivery partners, to deliver our products to the right location;
    • Financial partners, involved in the processing of your banking or credit card data on our website;
    • Marketing partners, which we use to send you promotional communications, for instance if you register to join an artist’s mailing list;
    • Promotional vendors, who help us to administer contests and promotions, including by maintaining separate contest and promotion microsites;
    • Applicant Tracking System Provider, to process and manage your job application as applicable;
    • IT service providers, such as our data hosting provider; and
    • Other service providers that we may engage to provide services to us or on our behalf.
  • We may share information in the event of a corporate change (such as a merger, acquisition or sale of assets) in which case we will inform you separately before any transfer of your personal information.
  • We will also disclose information we maintain (i) when required to do so by law (for example, in response to a court order or a subpoena or other legal obligation); (ii) in response to a law enforcement agency’s request; or (iii) in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with our rights or property.
  • We use analytics technology, such as Google Analytics. You may be able to opt-out of this use of information about you by Google by clicking here. To learn more about how Google uses data when you use our Online Services, please click the link “How Google uses information from sites or apps that use our services”.

If you are a user from the EU/EEA, please also see additional information on international data transfers in section 11 of this privacy policy.

4. WHERE WE STORE YOUR PERSONAL INFORMATION

All the information you provide may be processed and stored, transferred or accessed by entities around the world as described in this privacy policy. We will take commercially reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy.

5. LINKS TO THIRD PARTY WEBSITES AND THE INTERNET

Our Sites may contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check the policies before you submit any personal information to these websites.

The transmission of information over the internet is not completely secure. If you provide us with information over the internet, any transmission is at your own risk. However, once we receive your information, we use commercially reasonable procedures and security to prevent unauthorized access to personal information about you.

6. COMMUNITY FUNCTIONS

Our Sites may make available to you chat rooms, forums, message boards and/or other community functions. Remember that any information you disclose in these areas becomes public information and you should exercise caution when deciding to disclose your personal, financial or other information. Your use of such community functions is at your own risk.

7. NOTICE TO MINORS

We do not knowingly collect any personal information from those under the age of 16. If you are under 16 years of age, please do not provide any personal information to us. If you feel that we have unknowingly collected personal information from someone under the age of 16, please contact us immediately as described in the CONTACT US section below and this information will be removed.  For more information on how to protect your children online: Visit www.OnGuardOnline.gov for social networking safety tips for parents and youth. 

8. YOUR COLORADO, CONNECTICUT, UTAH, AND VIRGINIA PRIVACY RIGHTS

Depending on where you live, you may be entitled to object to or request the restriction of processing of your personal information; to opt-out of the processing of your personal information for targeted advertising, for sale, or profiling in furtherance of decisions that produce legal or similarly significant effects;  to request access to, rectification, erasure, and portability of your own personal information; and to appeal a decision that we make regarding a consumer request made by you. You can exercise any of these rights by contacting us as described in the CONTACT US section below. We may require you to prove your identity with approved identification if you request this information.

You may exercise your rights, including the right to opt-out of the sale of your personal data, by contacting us as described in the CONTACT US section below.

9. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have the following rights:

  • The Right to Know what personal information Concord has collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about the consumer;
  • The Right to Delete personal information that Concord has collected from you, subject to certain exceptions;
  • The Right to Correct inaccurate personal information that Concord maintains about you;
  • The Right to Opt-Out of the sale or sharing of their personal information by Concord.
  • The Right to Limit the use or disclosure of sensitive personal information by Concord, subject to certain conditions
  • The Right not to Receive Discriminatory Treatment by Concord for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

To obtain information about your California Privacy Rights free of charge,  contacting us as described in the CONTACT US section below, so long as you haven’t made two other requests in the last 12 months.

Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. Concord currently does not act in response to these signals.

Processing “sensitive personal information”: Concord does not process your sensitive personal information for any purpose other than those permitted by law, such as to perform the services that you request of us or for cybersecurity purposes.

When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your request. We may ask for additional information to help us verify your request. If we are able to verify your request, we will process it. If we cannot verify your request, we may ultimately be unable to process your request.

Consumers will be required to submit their first and last name and email address and may also be asked to provide additional information so that we can verify the request. We will only use the information received in a request, or in connection with a request, for the purposes of responding to the request.

California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described below to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California consumer about whom the request was made.

You may submit a CCPA privacy rights request to us by:

10. YOUR NEVADA PRIVACY RIGHTS

Nevada residents have the right to submit a verified request directing us not to sell their Personal Data. If you are a Nevada resident, and would like to submit such a request, please send your request to [email protected].

11. CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify, alter or otherwise update this privacy policy at any time. We encourage you to review this privacy policy from time to time to be informed about how we protect your personal information. When we post changes to this policy, you will see the words “Last Updated” with the date of the last update at the top of this page. In case of substantial changes to this privacy policy, we will inform you about these in advance via email.

12. USERS OF SITES IN THE EUROPEAN UNION/EUROPEAN ECONOMIC AREA

This section of this privacy policy applies only if you use the Sites from a country that is a Member State of the European Union (“EU”) /European Economic Area (“EEA”), or the United Kingdom (“UK”), and supplements the information in this privacy policy.

(a) Legal bases for processing your personal data

  • Participation in special activities: We process the listed information to administer promotions, contests and sweepstakes. In such cases we process personal data for contract performance.
  • Newsletters: We send you newsletters based on your consent. If you are already a customer who has purchased goods from us, we also process your email address to offer our own similar products, programs or services to you that may be of interest to you. Such processing is based on our legitimate interest to conduct direct marketing. You may always object to such processing.
  • Product purchase: We process the listed information to transact and administer your purchase; in such cases we process personal data for contract performance.
  • Website registration: We process the listed information to provide you with the requested services and administer your registration. In such cases we process personal data for contract performance. We also process your information in this context for IT security reasons, pursuant to our legitimate interest to provide secure services.
  • Contact us: We process the listed information to respond to your inquiry. In such cases we process personal data for contract performance .
  • Job application: We process the listed information in preparation of a potential employment agreement between you and Concord. In such cases we process personal data for contract performance
  • Updates concerning us: We send you accordant updates based on our legitimate interests to provide you with working Sites and satisfying services. If informing you about updates is required by law, we send you accordant updates to comply with our legal obligations.

(b) Retention of your personal data

  • Participation in special activities: We retain your personal information up to three months after the promotion, contest or sweepstake is completed, unless we are required by law to retain it for a longer period (for example for archiving purposes).
  • Newsletters: We will retain your personal information concerning marketing and newsletters for as long as you do not withdraw consent or opt-out from such marketing, unless we are required or permitted by law to retain it for a longer period (for example for archiving purposes).
  • Product purchase: We retain your personal information as long as you continue purchasing our products. We will delete your personal information if you have not purchased anything for three years, unless we are required or permitted by law to retain it for a longer period (for example for archiving purposes).
  • Website registration: We retain your personal information as long as you use our services for registered users. We will delete your personal information if you have not logged in for three years, unless we are required or permitted by law to retain it for a longer period (for example for archiving purposes).
  • Contact us: We retain this personal information for the time required to respond to your request and, where applicable, as required or permitted by statutory law (for example for financial statements or legal claims or archiving purposes).
  • Job application: If your application is successful, we retain the personal information for the duration of your employment with us, and beyond based on requirements or permissions by statutory retention requirements. If we do not employ you, we will retain your personal information for the time required to respond to your request and, where applicable, as required or permitted by statutory law (for financial statements or legal claims or archiving purposes).
  • Updates concerning us: We retain your personal information as long as you use our services for registered users or purchase our goods. We will delete your personal information if you have not logged in for three years, unless we are required or permitted by law to retain it for a longer period.

(c) Automated decision-making

We may use automated decision-making technologies, including profiling, to support our data processing activities. Our automated decision-making capabilities include logic that attempts to identify artists, music, communications, products, or offers that we believe may interest you. By using this logic, it helps us personalize your interactions with us and our artists. For you, this means that you may see online advertisements, direct marketing communications (if you have subscribed), or other advertising or marketing messages or special offers based on your activity on our Sites or interactions with us or our third-party partners.

(d) International transfers

Our sharing of your personal information, in accordance with this privacy policy, may involve transferring your information outside the EU/EEA. Whenever we transfer your personal data out of the EU/EEA, we ensure a similar degree of protection is afforded to it by ensuring, where required by law, at least one of the following safeguards is implemented:

  • transferring personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, including to an entity in the United States who has self-certified under the EU-U.S. Data Privacy Framework;
  • using specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or

You may be entitled, in accordance with applicable law, to request a copy of the concrete safeguards by contacting Concord as described in the CONTACT US section.

(e) Your rights

In furtherance of section 8 above and in accordance with GDPR you may have the following rights in relation to the personal information we hold about you, if the accordant preconditions are fulfilled:

  • Right of access:You may ask us to confirm whether we are processing your personal information and, if so, to provide you with a copy of that personal information (along with certain other details).
  • Right to rectification:If the personal information we hold about you is inaccurate or incomplete, you are entitled to ask for rectification or completion.
  • Right to erasure:You may ask us to delete or remove your personal information in some circumstances, e.g. if we no longer need it or you withdraw your consent (where applicable).
  • Right to restrict processing:You may ask us to restrict the processing of your personal information in certain circumstances, e.g. if you object to us processing it.
  • Right to data portability:You have the right to obtain personal information you have provided to us in a structured, commonly used and machine-readable format for reuse under certain circumstances.
  • Right to object: You may ask us at any time to stop processing your personal information, and we will do so, if we:
  •  rely on legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing or
  •  process your personal information for direct marketing.
  • Rights in relation to automated decision-making and profiling:You have the right not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and us.
  • Right to withdraw consent:If we rely on your consent as the legal basis for processing your personal information, you have the right to withdraw that consent at any time. This includes, but is not limited to, cases where we use your personal information for direct marketing purposes.

You may also be entitled, in accordance with applicable law, to lodge a complaint with a supervisory authority if you consider that our processing of your personal information infringes applicable law.

For more information on your rights and accordant requirements, please see the information provided by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

13. YOUR AUSTRALIAN PRIVACY RIGHTS

This section of this privacy policy applies only if you use the Sites from Australia or are an Australian resident, and supplements the information in this privacy policy,

(a) Collection, use and disclosure of sensitive information

The Australian Privacy Principles (“APP”) and the Privacy Act 1988 (Cth) (“AU Privacy Act”) recognise that some personal information is “Sensitive Information”, including but not limited to information that is related to:

  • health information
  • membership of a professional or trade association (including unions)
  • employment records
  • ethnicity
  • criminal records
  • educational records

We will not collect Sensitive Information except with your consent, and then only if collection of such information is necessary for a particular activity or function.

We may collect Sensitive Information with your consent for employment and job application purposes and to evaluate other business relationships. In addition to any personal information required as set out at clause 1(f), Sensitive Information we collect with your consent may include work experience, education and other related information you submit to review, verify and evaluate your job application information if you have applied for a job at Concord. We will not use or disclose your Sensitive Information unless it is directly related to the primarily purpose it’s collected for, such as employment and job application processes (e.g. for required background checks in connection to your role) or if use or disclosure is otherwise required by law. We will use our reasonable best efforts to seek your consent in each instance use or disclosure is required.

(b) Australian Spam Act 2003 (Cth)

We recognise your right under the Spam Act 2003 (Cth) to opt out from direct marketing, and as such these consents can be modified at any time in accordance with clause 1(b).

Please note certain non-marketing related correspondence from us, including messages relating to payment, will be automatically sent to you by virtue of your use of the Website and associated services and you may not have the option to unsubscribe from receiving this correspondence.

(c) Your rights to your information

You have a general right to access any personal information that is held about you by us, unless a valid exception applies under the AU Privacy Act or APP. You can request this at any time by contacting Concord’s Data Protection Officer (details below). Please note that we cannot modify your personal information. You can modify your own information at any time by emailing Concord’s Data Protection Officer.

14. YOUR NEW ZEALAND PRIVACY RIGHTS

This section of the privacy policy applies only if you are accessing the Sites from New Zealand or are a New Zealand resident, and supplements the information in this privacy policy,

(a) Your rights:

  • Access to personal information: You have a general right to access any personal information that is held about you by us, unless a valid exception applies under the New Zealand Privacy Act 2020 and the Privacy Principles. You can request this at any time by contacting Concord’s Data Protection Officer (details below).
  • Correction of personal information: You can correct your own information at any time by emailing the Concord’s Data Protection Officer, if you think your personal information provided to us is wrong. If we do not agree that your information needs correcting, you may further request that we correct your information by attaching a statement of correction to our records by contacting Concord’s Data Protection Officer. We will attend to such requests in accordance with the New Zealand Privacy Act 2020.
  • Accuracy of personal information: Before any required and necessary use or disclosure of your personal information, we may take reasonable steps in the circumstances to confirm such information is accurate, up to date, relevant, complete, and not misleading.
15. CONTACT US

If you have questions, comments or requests regarding this privacy policy, please contact us at:

Concord
Attn: General Counsel
10 Lea Ave. Suite 300
Nashville, TN 37210
Attn: Deputy General Counsel

Concord’s Data Protection Officer may be contacted at [email protected]

For EU/EEA users: Our local representative in the EU/EEA may be contacted via e-mail at [email protected] or via mail at:

Data Protection Department

Boosey & Hawkes Music Publishers Limited
Aldwych House
71-91 Aldwych
London WC2B 4HN
United Kingdom