Privacy Policy

Universal Music Publishing Group Australia

Privacy Policy

This policy explains how Universal Music Publishing Pty Limited and its Australian related companies (collectively, "UMP" or "we") manage personal information and comply with our obligations under the Australian Privacy Act 1988 (including the Australian Privacy Principles set out in that Act). The policy applies to all personal information that UMP collects, uses, discloses, stores and handles, including personal information collected through our websites (www.umusicpub.com.au and www.unippm.com.au) and via social media platforms (such as Facebook, Twitter and YouTube). In this policy, "personal information" means information or opinion about an identified individual, or an individual who is reasonably identifiable.

1. What kinds of personal information does UMP collect?

UMP is one of Australia's largest producers and distributors of entertainment goods and services. We collect personal information so that we can provide our goods and services, and information about those goods and services, to clients, fans and other interested parties.

Because most of UMP's clients are either organisations that want to use music in connection with their business activities (including film and television productions, websites, advertising campaigns and corporate or sporting events), or the artists and writers who create the music, most of the personal information we collect relates to individuals acting in their business or professional capacities. UMP does not usually need to collect personal information about individuals acting in their private capacities, except in the circumstances outlined in this policy.

The kinds of personal information we collect will depend on the purpose(s) for which we're collecting it, but may include the following:

o    Your name and, if applicable, the organisation you work for.
o    Your contact details, such as an email address, postal address and phone number.
o    Your (or your organisation's) entertainment preferences, for example the music or artists most relevant to your work.
o    The details of any specific goods or services you've browsed, purchased or requested (including music you have listened to while using our systems).
o    In the case of artists and writers, information about your relationship with UMP, including details of the music you've created. You can always refuse to give UMP any of the personal information we request, but that may mean we can't provide you with some or all of the goods or services you require.

2. How does UMP collect personal information?

We generally collect personal information directly from the individual concerned.

Sometimes we collect personal information from a third party, for example if we are updating our databases using information from industry publications, websites and other sources, or if someone gives us an individual's contact details so we can get in touch with that individual regarding our goods and services. Agents/managers of artists and writers will also provide us with personal information about the individuals they represent. In these cases, we will endeavour to ensure the third party has made the individual aware that their information will be passed on to UMP.

We may also collect personal information from a third party where particular circumstances require it, for example if we need to obtain a reference from a previous employer prior to offering an individual a job at UMP.

3. What are the purposes for which UMP collects personal information?

The primary purpose for UMP's collection of personal information will usually be obvious from the context in which it's collected, or it will be explained at the time of collection. The most common examples are set out below.  o    We collect your personal information when you sign up to receive information, news or offers from UMP, for example when you sign up to receive any of our email newsletters. You can opt-out of receiving this kind of material at any later time using the facility provided in each email communication, or by contacting UMP in the manner described at the end of this policy.
o    We collect personal information from people who register for and access UMPG Songs, the U-Cloud production music platform, or any other music services we make available. Access to these services is generally not open to the public, and will require UMP's approval.
o    If we don't already have it, we will collect your personal information when you place an order for any of our goods or services, for example a licence to use music in an advertising campaign you're working on. In this case, we will use your personal information for the purposes of fulfilling your order and delivering the requested goods or services, and for related purposes such as account management.
o    We collect personal information from our artists and writers, and their agents/managers, for the purposes of maintaining our relationship with them and fulfilling our contractual obligations and responsibilities.
o    We collect personal information from job applicants so we can review and assess their applications.
o    We also collect personal information in order to respond to individuals who make inquiries of UMP by email, telephone, letter or in person. This includes artists and writers who may be interested in being signed to UMP, and who send us samples of their music.
o    Finally, as noted above, we collect personal information about individuals who we deal with in a business context, including clients, licensees and suppliers. We only use this information for purposes related to the business relationship(s) we have with the individual and the company they work for.

4. How does UMP use personal information?

We generally use personal information only for the purpose(s) for which we collected it, or for related purposes. Some of those related purposes include managing our relationship with the individual concerned, communicating more effectively with the individual, and evaluating and improving our goods and services (including our music services, websites and social media pages).

Unless you have told us that you do not wish to receive this material, we may also use your personal information to send you information, news and offers about our goods and services that we think may be relevant to you or your organisation, for example new music releases. As noted above, you can opt-out of receiving this kind of information at any time using the facility provided in each email communication, or by contacting UMP in the manner described at the end of this policy.

Apart from the uses described above, we will only use your personal information for purposes that are permitted by law (including under the Privacy Act).

5. Who else do we give personal information to?

We will only disclose your personal information to individuals and organisations outside UMP in the limited circumstances described below, or if we have your consent or we are legally required or permitted to disclose the information.

We will never share your personal information with third parties for the purposes of them marketing their goods and services to you unless you have specifically consented to receive marketing material of this kind.

APRA|AMCOS

We need to exchange with APRA and AMCOS personal information about the artists and writers who are signed to UMP, so those collecting societies can determine whether our artists and writers are entitled to receive royalties from the use of their music.

Third-party service providers UMP engages a range of third parties to provide services and perform business support functions for us. Some of those third parties need access to personal information in order to provide the services or perform the functions UMP requires. Where we share your personal information with third-party service providers, they will be contractually bound to use and disclose the information only for the purposes of providing the services or performing the functions required by UMP, and to store the information securely.

Some of the third-party service providers we use are located outside of Australia, so we may need to transfer personal information to the countries in which they are based. Those countries include the USA, UK, France, India and the Philippines.

6. Sharing of personal information with Universal Music Publishing Group companies in other countries

As UMP is part of the worldwide Universal Music Publishing Group of companies ("UMPG"), we may from time to time transfer personal information to a local UMPG company located in another country. We will only do this where it is necessary or appropriate to achieve the purposes set out in this policy (for example, because that UMPG company is responsible for providing systems or services to other group companies like UMP), or it is otherwise made known to you at the time the personal information is collected.

Please note that where UMP transfers personal information to a UMPG company located outside of Australia, we will take steps to ensure that the information is only used for purposes permitted under this policy, and is given the same protection as it has here in Australia. No matter where your information is processed, this privacy policy will remain in effect.

UMPG companies operate in all major countries of the world, including the USA, the UK, France, Germany and other European countries, New Zealand, China, India and other Asia-Pacific countries, and in other regions such as the Middle East and South America. The UMPG companies that host systems and data (including personal information) on behalf of UMP and other group companies are located in the USA.

7. Cookies and other technologies

UMP websites collect other information that may or may not be personal information. Each time you visit a UMP website, its server automatically recognises and stores your “address” (e.g. your domain name or internet protocol address), the type of internet browser you are using, the address of the site that “referred” you to the UMP website and "clickstream data" (i.e. data about the way you're interacting with the website, including what you're clicking on).

In addition, UMP uses "cookies" to collect data about the usage of our websites. A cookie is a small text file that is placed on your computer, smartphone or other internet-enabled device. Most web browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt or refuse cookies. Please note that rejecting cookies may mean that not all the functions on the UMP websites you visit will be available to you.

UMP uses cookies to personalise your browsing experience (by remembering your preferences and recognising you as a repeat visitor to our websites), and to track statistics about the usage of our websites. This allows UMP to better understand its users and improve the layout and functionality of its websites. This tracking is conducted in such a way as to ensure the anonymity of visitors to UMP websites. While the cookie may identify your computer, it should not identify you unless you are registered with the website. In that case, the cookie may be linked to your profile so that we can identify you and provide more relevant content.

9. Storage and security of personal information

UMP takes reasonable steps to protect the personal information we hold and control against risks such as loss, misuse and interference, or unauthorised access, modification or disclosure. These steps include the use of firewalls, restricted access to databases and systems containing personal information, secure servers, and industry-standard encryption of credit card transactions. UMP only allows authorised personnel to access personal information to the extent necessary to perform their duties, and it is a condition of employment with UMP that its employees maintain the confidentiality and security of personal information.

Please note that UMP cannot guarantee the security of online transactions and communications sent by electronic means or post, in particular where any personal information is transmitted over the internet. Any such communication is therefore sent at your own risk.Where we have given you (or you have chosen) a username and/or password that enables you to access any part of a UMP website, you are responsible for keeping them confidential. You should not share that information with anyone else.

10. Accessing and correcting your personal information

Under the Privacy Act, you generally have a right to seek access to personal information that UMP holds about you. You also generally have a right to ask UMP to correct personal information about you that you think is inaccurate, out of date, incomplete, irrelevant or misleading. If you wish to seek access to the personal information UMP holds about you, please make a request in writing to our Privacy Officer (contact details are set out at the end of this policy). Your request should state whether you are seeking access to all the personal information UMP holds about you or to particular personal information (in which case you should specify that in your request). You should also provide some form of identification (e.g. a photocopy of your driver’s licence or passport) so UMP can verify that you are the person to whom the personal information relates. You should also include details of how UMP can contact you in case we need to discuss your request. If you need more information before making a formal request for access, please contact the Privacy Officer, who can explain how UMP will handle your access request and assist you in making that request.

UMP will assume (unless you tell us otherwise) that your request relates to UMP’s current records about you. These current records will include personal information about you which is included in our databases and in paper files, and which may be used by UMP on a day to day basis. To provide you with access to current personal information, UMP will ordinarily provide you with a print-out of the relevant personal information from its databases, or with photocopies of records which are held only on paper files. If personal information about you (e.g. your name and address details) is duplicated across different databases, we will generally provide you with only one printout of this information. Ordinarily, UMP will not charge you for the cost of providing this type of access to its records, and it will generally respond to access requests of this type within 30 days of receiving your request.

For legal and administrative reasons, UMP may also store records containing personal information in its archives. You may seek access to the records held by UMP which are not current records, but if you do so, we may charge you for the cost we incur in providing access. It may also take UMP longer to respond to your request. Please contact the Privacy Officer to discuss your requirements.

If you think that any of the personal information UMP holds about you is inaccurate, out of date, incomplete, irrelevant or misleading, please provide our Privacy Officer with a written request for correction (contact details are set out at the end of the policy). It is UMP’s policy to consider and respond to any requests for correction within 30 days of receiving the request.

If UMP agrees that your personal information is inaccurate, out of date, incomplete, irrelevant or misleading, UMP will correct it for you. If we do not agree with your view, we will provide you with reasons for our view, and will provide you with an opportunity to make a statement of your view and have it included with the information.

11. How to make a complaint

If you believe that we have breached this policy, or any of the Australian Privacy Principles in the Privacy Act, then you should make a complaint to UMP in the first instance. You should address your complaint in writing to our Privacy Officer (contact details are set out below), and you should include as much detail as you can about the personal information affected, and the circumstances that you believe amount to a breach of this policy or the APPs.

We will undertake an internal investigation, and we may contact you if we need to obtain any further information in relation to your complaint. We will generally provide a written response to your complaint within 30 days. Our response will set out the results of our investigation, including whether we agree that UMP has breached this policy or the APPs.

If you are unhappy with our response to your complaint, you have the right to make a complaint to the Office of the Australian Information Commissioner. Details of how to contact the OAIC are provided on its website at www.oaic.gov.au.

12. Contacting UMP

If you have any questions about UMP's handling of personal information, or if you wish to make an access or correction request or complaint, you should contact the UMP Privacy Officer by one of the following methods:

By telephone:       02 9207 0500 (from outside Australia +61 2 9207 0500)

By email:              uma.privacy@umusic.com

By post:                 Privacy Officer

                               Universal Music Publishing Group Australia

                               150 William Street

                               Woolloomooloo NSW 2011

                               Australia

13. General

This policy was last updated on 15 December 2014.

UMP may make changes to this privacy policy from time to time, but we will not change the way we use personal information you have provided to us previously without your consent.

You can find more information about privacy and the protection of your personal information on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.