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Privacy Policy

PRIVACY POLICY – IRMA

Effective from 25 May 2018

This Privacy Policy (Privacy Policy) sets out how we use your personal data and what your rights are in relation to that personal data. These rights are set out in the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018.

1. WHO ARE WE?

  1. 1.1 We are the Irish Recorded Music Association CLG (“IRMA”). IRMA is a company limited by guarantee. Its registered office and headquarters is at 63 Patrick St, Dún Laoghaire, County Dublin.
  2. 1.2 IRMA promotes and protects the welfare and interest of the Irish Recorded Music Industry.
  3. 1.3 IRMA’s activities include:
    • lobbying on behalf of the recorded music industry in respect of legislative proposals and enactments affecting the industry,
    • originating and promoting improvements in the law and in the administration of the law affecting music,
    • representing its members on all matters affecting the recorded music industry,
    • assisting and protecting its members’ interests in respect of infringements of copyright including by legal action and where necessary taking anti-piracy measures on their behalf,
    • providing a forum in which members may discuss matters of common interest,
    • maintaining understanding between the recorded music industry and the public, government departments, music professionals, local authorities and organisations in any way connected with the recorded music industry, co-operating with international affiliates in relation to matters affecting the record music industry and securing where appropriate adequate representation of IRMA on all other organisations dealing with the interests of its members,
    • co-operating with and becoming a member of or otherwise assisting any associations or institutions with objects wholly or in part similar to IRMA,
    • arranging for the preparation and publication of the Irish Music Charts and monitoring the operation of the charts to ensure that they retain their authenticity providing social, cultural, and / or educational services for and on behalf of the recorded music industry.

2. PERSONAL DATA

  1. 2.1 By “Personal Data” we mean any personal data including (without limitation) contact details such as your name, address, telephone number, email and any other data that may be used to individually identify you.
  2. 2.2 This notice sets out the basis on which any Personal Data we collect from you, or from others, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
  3. 2.3 For the purpose of GDPR, the data controller is IRMA when it deals with its members, employees, contractors and suppliers. IRMA is a joint data controller with the Official Charts Company, a company that IRMA has appointed as its agents to compile and market the Irish Charts.

3. PRIVACY POLICY

  1. 3.1 This Privacy Policy applies to the use of all Personal Data that we receive.
  2. 3.2 By becoming a member of IRMA you agree that any Personal Data that you submit or make available to IRMA will be processed in accordance with this Privacy Policy.
  3. 3.3 If you do not wish your Personal Data to be processed as set out below or, if you have any queries in relation to this Privacy Policy please contact us outlining your concerns by emailing GDPR@IRMA.ie.

4. WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU? / WHAT USE DO WE MAKE OF YOUR PERSONAL DATA

When Personal Data is submitted by you to IRMA, you acknowledge and agree that IRMA may collect, store and process such Personal Data for the following purposes:

  1. 4.1 Registering you, at your request as a member,
  2. 4.2 Dealing with members’ queries,
  3. 4.3 Dealing with any queries submitted by you; (when corresponding with us by phone, e-mail or otherwise, we ask you to disclose only as much information as is necessary to provide you with services or to submit a question / suggestion / comment in relation to our website or our services),
  4. 4.11 Sharing Personal Data in the manner set out below at paragraph 8.

5. WHAT INFORMATION ABOUT YOU DO WE OBTAIN FROM OTHERS?

When you use our services, we may obtain Personal Data to facilitate the provision of member services from the following:

  1. 5.1 Our agents the official charts company,
  2. 5.2 The international body representing the recorded music industry – International Federation of the Phonographic Industry (ifpi)
  3. 5.3 Other Members,
  4. 5.4 Publicly available sources such as social media and the Companies Registration Office.

6. WHY DO WE COLLECT THIS INFORMATION?

We collect the information in order to provide our member services.

  1. 6.1 We will use this information:
    1. 6.1.1 Members:
      • To set your company / business up as a member or a licensee on our systems,
      • To liaise with you about projects that we are undertaking with you,
      • To enforce and defend IRMA members’ rights arising from any infringement,
      • To ensure payment of our invoices.
    2. 6.1.2 Website users:
      • To administer and update our website,
      • To keep our website safe and secure,

7. WHAT IS THE LEGAL BASIS FOR COLLECTING THIS PERSONAL DATA?

The legal bases for the processing of your data are:

  1. 7.1 Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract;
  2. 7.2 Processing necessary for compliance with a legal obligation to which we are subject;
  3. 7.3 Processing necessary for the purposes of the legitimate interests which we pursue in representing the Irish recorded music industry where such interests are not overridden by your interests or fundamental rights or freedoms which require the protection of your information.

8. WITH WHOM IS YOUR PERSONAL DATA SHARED

When Personal Data is submitted by you, you acknowledge and agree that IRMA may share your Personal Data with:

  1. 8.1 The Official Charts Company as appropriate,
  2. 8.2 Bodies or organisations similar to IRMA such as ifpi for anti-piracy purposes,
  3. 8.3 with third party suppliers and contractors for the purpose managing the business of providing member services,
  4. 8.4 with relevant third parties when required by applicable law; and
  5. 8.5 with relevant third parties when IRMA believes it reasonably necessary in order to investigate, prevent, or take action regarding illegal or improper activities, suspected fraud, piracy, potential threats to the rights, property or safety of IRMA or its members,

wherever such persons and entities are located in the world.

9. HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?

The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.

10. DO WE TRANSFER YOUR DATA OVERSEAS?

  1. 10.1 We do not transfer your data outside the European Economic Area (EEA).

11. PERSONAL DATA PROVIDED TO YOU

Where Personal Data relating to individuals is made available to you, this is solely for the purpose of you being able to lawfully use the service provided by IRMA. You must keep any such information disclosed to you confidential and not use it for any other purposes.

12. WHAT ARE YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA?

You have the following rights:

  1. 12.1 The right to access the personal data we hold about you.
  2. 12.2 The right to require us to rectify any inaccurate personal data about you without undue delay.
  3. 12.3 The right to have us erase any personal data we hold about you in circumstances such as where it is no longer necessary for us to hold the Personal Data.
  4. 12.4 The right to ask us to provide your information to you in a portable format.
  5. 12.5 The right to request a restriction of the processing of your personal data.

Where our processing of your information is based on your consent to such processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.

You may exercise any of the above rights by contacting GDPR@IRMA.ie.

14. IF YOU WANT TO LODGE A COMPLAINT

You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commission. The website is www.dataprotection.ie.

15. WHAT WILL HAPPEN IF WE CHANGE OUR POLICY?

This notice may change from time to time, and any changes will be posted on our website and will be effective when posted. Please review this notice each time you use our website or our services. This version of the Privacy Notice is effective from the 25th of May 2018.

16. HOW CAN YOU CONTACT US?

Our Data Protection Contact is Alex Callow who may be contacted:

  • By phone: 01 / 2805977
  • By post: 63 Patrick Street, Dun Laoghaire, County Dublin
  • By email: GDPR@IRMA.ie

17. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with Irish Law.