Datahandling
Privacy Policy
MusicTeachers.co.uk is owned and operated by More Music UK Limited, a limited liability company registered in England and Wales under the company number 10946567. The registered address is 837 Salisbury House, 29 Finsbury Circus, London EC2M 5QQ, and we are registered for VAT under number 370603027. Any reference to "we", "us" and/or "our" within this policy refers to More Music UK Limited. We are registered with the Information Commissioners Office (‘ICO’) under reference number ZA462894.
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about your privacy rights and how the law protects you as well as as to how we look after your personal data when you:
- visit our website (regardless of where you visit it from);
- utilise the services on our website / web platform, either as a customer, student or tutor; or
- contract with More Music UK Limited in any other capacity (e.g. as a supplier)
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of our website /web platform or if you contract with us as a customer, student, tutor or as a third-party supplier.
Our web platform is not intended for anyone under the age of 18 years of age. In the case of children and young people, parents and/or legal guardians must use the web platform on behalf of their children. We only collect data relating to children in the case where the student receiving music tuition from tutors through our web platform is a child.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
We are the controller and are responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy manager using the following details:
| Full name of legal entity: | More Music UK Limited |
| Email address: | [email protected] |
| Postal address: | More Music UK Ltd, Platform 2.02, New Station St, Leeds, LS1 4JB |
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on the 1st October 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website / our web platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. Please see the section below regarding the identity of these third parties and what services they supply to us which involve the processing of your personal data.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you. The different types of personal data we may process can be grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender and photograph.
Contact Data includes billing address, delivery address, email address and telephone numbers.
We only process limited financial data: we do not process bank account and payment card details as this is done on our behalf by our third party merchant supplier, currently Billwerk+. However we do process financial information for the purpose of managing accounts and debt collection using our third party accounting system, e-conomic. (For further details about e-conomic’s privacy policy please see the section below entitled Disclosures of your Personal Data.) This data includes; names, telephone numbers, postal and email addresses and amounts of monies received and due. Where you have paid for lesson(s) in advance we hold those monies in your account until you have received the lesson.
Transaction Data includes details about payments to and from you and other details of services you have purchased from our tutors.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website / our web platform.
Profile Data includes your username and password, orders for services made by you, your interests, preferences, feedback and survey responses and your profile photo if you choose to add one.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
We may collect information relating to a teacher’s criminal convictions and offences as part of our safeguarding and child protection obligations and in order to prevent or detect unlawful acts. Please note that if we ask for this information, we will ask you, the Teacher, to provide such information voluntarily in which case you give your consent to provide such information.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our web platform and related services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to use our web platform services;
- create an account on our web platform;
- subscribe to our publications; request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the "Cookies" section of this policy below for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as facebook.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you. ‘Performance of the contract’ means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. ‘Legitimate interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal obligation. ‘Comply with a legal obligation’ means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to such as anti money laundering regulations.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before retrieving information about you relating to previous criminal convictions. You have the right to withdraw consent at any time by contacting us, but as above, this may cause your access to our website / web platform and use of related services to be removed. Also consent may not be the only lawful basis on which we are processing your personal data in which case it may not prevent us further processing your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To create an account on the web platform and to register you as a new customer |
(a) Identity |
Performance of a contract with you and legal obligation |
|
To process and deliver our services via the web platform, including: |
(a) Identity |
(a) Performance of a contract with you |
|
To manage our relationship with you which will include: |
(a) Identity |
(a) Performance of a contract with you |
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity |
(a) Performance of a contract with you |
| To administer and protect our business and our website / web platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of our advertising |
(a) Identity |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website / web platform, marketing, customer relationships and experiences |
(a) Technical |
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Marketing
You will receive marketing communications from us if you have requested information from us or used our website / web platform services and you have not opted out of receiving that marketing.
We will never share your personal data with any third party for marketing purposes except for facebook for the purpose of targeted advertising only and facebook only processes the data on an anonymous basis (where the data is hashed i.e. the data is permanently converted) and facebook is also contractually prohibited from using your personal data independently.
You can ask us to stop sending you marketing messages at any time by:
- logging into your account on the web platform and checking or unchecking relevant boxes to adjust your marketing preferences; or
- by following the opt-out links on any marketing message sent to you; or
- by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of using our services via our website / web platform or other transactions through our website.
Cookies
You will be invited to accept our cookies when you access our website. If you do not wish us to run these cookies please do not use our site.
The cookies we run are as follows and for the following purposes:
| Cookie key | Description |
| __cf_bm | This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. |
| XSRF-TOKEN | This cookie is written to help with site security in preventing Cross-Site Request Forgery attacks. |
| laravel_session | Internally laravel uses laravel_session to identify a session instance for a user |
| __stripe_sid | This cookie is associated with Calendly, a Meeting Schedulers that some websites employ. This cookie allows the meeting scheduler to function within the website. |
| __stripe_mid | This cookie is associated with Calendly, a Meeting Schedulers that some websites employ. This cookie allows the meeting scheduler to function within the website. |
| _ga | This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. |
| _gat | This cookie name is associated with Google Universal Analytics, according to documentation it is used to throttle the request rate - limiting the collection of data on high traffic sites. |
| _gid | This cookie is set by Google Analytics. It stores and updates a unique value for each page visited and is used to count and track pageviews. |
| ANONCHK | This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website. |
| VISITOR_INFO1_LIVE | This cookie is set by Youtube to keep track of user preferences for Youtube videos embedded in sites; it can also determine whether the website visitor is using the new or old version of the Youtube interface. |
| test_cookie | This cookie is set by DoubleClick (which is owned by Google) to determine if the website visitor's browser supports cookies. |
| CLID | This cookie is usually set by Dstillery to enable sharing media content to social media. It may also gather information on website visitors when they use social media to share website content from the page visited. |
| _gcl_au | Used by Google AdSense for experimenting with advertisement efficiency across websites using their services |
| IDE | This cookie is set by Doubleclick and carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website. |
| YSC | This cookie is set by YouTube to track views of embedded videos. |
|
_gat_gtag_UA_114431929_4 |
This cookie is part of Google Analytics and is used to limit requests (throttle request rate). |
| MUID | This cookie is widely used by Microsoft as a unique user identifier. It can be set by embedded microsoft scripts. Widely believed to sync across many different Microsoft domains, allowing user tracking. |
| _fbp | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers |
| SRM_B | This is a Microsoft MSN 1st party cookie that ensures the proper functioning of this website. |
| SM | This is a Microsoft MSN 1st party cookie which we use to measure the use of the website for internal analytics. |
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4.Disclosures of your personal data
We may share your personal data for the purposes set out in the table above, with the third parties set out below:
Billwerk+ - For all payments made through our website / web platform we utilise the third party payment service provider, Billwerk+. Billwerk+ provide a secure card payment facility with SSL encryption, so whilst we will never have sight of your Financial Data (i.e. payment card information etc.), Billwerk+ allows us to have access to anonymised transaction records which are stored for the purposes of refunds, auditing and the monitoring of purchases. A copy of Billwerk+'s privacy policy can be found here
OnlineCity.IO - We use this service to send SMS. notifications to teacher and student users to help us fulfil our contract. SMS notifications can be enabled / disabled in the settings area of user accounts. You can view the privacy policy of OnlineCIty.io here
Intercom - We use Intercom to manage teacher and student support and to give the best possible service to all our users. A copy of Intercom’s privacy policy can be found here
Telleroo - We use the Telleroo service to automate teacher payments. A copy of their privacy policy can be found here.
Trust ID - Trust ID helps us perform anti money laundering and “know your client” checks on new users of our services via an API. You click Verify ID on our website and are taken to a portal owned and operated by Trust ID. You are required to submit an official ID such as a passport/driving licence/biometric residence card by taking a photograph of it. Trust ID will take a photo of you and you are automatically assessed for likeness. You type in your address and background checks are made against your address. The official ID document is stored by Trust ID for 7 days and then permanently deleted. The Trust ID privacy notice can be found here
Postmarkapp.com - Postmarkapp.com are our service provider for transactional notification emails. Further to use of our web platform, you will be sent reminders and notifications via email when music lessons are created or you have received a message. This service is integrated into our platform. Postmarkapp.com’s privacy notice can be found here
Google Workspace - Day-to-day email and administration takes place via the cloud based applications and storage in ‘Gsuite for Business’. A copy of Google’s privacy policy can be found here
Google tag manager - helps us track interactions with our Web Platform on an aggregated basis. No personal information is sent to Google Tag Manager.
Zapier - To ensure your personal data is processed in the correct way, we use automation processes from Zapier. A copy of their privacy notice is found here
E-conomic - For some of our web platform services we use the integrated accounting platform E-conomic as a financial management tool. A copy of the E-conomic privacy statement can be found here
Active Campaign - We manage our marketing and information emails via a system run by Active Campaign. Active Campaign’s privacy policy can be found here
YouTube - We offer the optional service of embedding video messages into tutor’s profiles via a link from the MusicTeachers.co.uk YouTube channel. Youtube’s privacy policy can be found here
Personnel Checks - Further to our obligations surrounding child protection and safeguarding, we utilise the service of actioning an application for an enhanced DBS certificate for our tutors via our service provider, Ucheck. Ucheck’s privacy policy can be found here
Stripe - we formerly utilised the third party payment service provider, Stripe Payments UK Ltd. Stripe provided a secure card payment facility with SSL encryption, We retain anonymised transaction records which are stored for the purposes of refunds, auditing and compliance with our statutory responsibilities. A copy of Stripe’s privacy policy can be found here
DigitalOcean - Our website is hosted via Digital Ocean.com in their European data centre in Frankfurt, Germany. The DigitalOcean privacy policy can be found here
Cloudflare - Through our partner Cloudflare, we ensure all network data is encrypted via https and further security measures to protect against Ddos type attacks are in place.
More Music Technologies ApS – our website is supplied and maintained by our licensor, More Music Technologies in Denmark. They comply with the terms of this policy.
We may choose to sell, transfer or merge parts of our business or our assets with a third party. Alternatively, we may seek to acquire other businesses or merge with a third party. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (e.g. standard contractual clauses).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will we use your personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Such rights are as follows:
Request access to your personal data – (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data - This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure if there are specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data – You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- - If you want us to establish the data’s accuracy.
- - Where our use of the data is unlawful but you do not want us to erase it.
- - Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- - You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data - We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent – You have the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.