What this policy covers
Your privacy is important to us. This policy is intended to help you understand:
- Our service and the type of account you have determines our responsibility to you
- What information we collect about you
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- How to access and control your information
- How we transfer information we collect internationally
- Other important privacy information
- How to contact us
This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, please do not access or use our Services or interact with any other aspect of our business.
When we refer to "nSpireMe," "we," or "us" in this policy, we mean nSpireMe Ltd., which controls the information nSpireMe collects when you use the Services. nSpireMe offers a collaborative digital portfolio, including a Website and Apps, which help users make their instrumental practice more efficient, effective and creative. We also offer related services, like support. We refer to all of these products, together with our other services and websites as "Services" in this policy.
Parents subscribe to nSpireMe to use it as a digital platform for their children to practise their music instruments with or without direction from a teacher. Teachers register with the Service in order to communicate with and provide guidance to their students and parents.
What information we collect from you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you input it into the Services or otherwise provide it directly to us. We shall tell you which information is mandatory at the point of collection. All personal data that you provide to us must be true, complete and accurate. At our request, you shall promptly provide evidence of your identity. When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
If you provide to us personal data about any other individual, you must have their consent to do so. If that other individual is a child, you must have either have parental responsibility to provide the child’s personal information to us, or have the consent of a person with parental responsibility to do so.
- Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences or otherwise contact us for any reason. For example, you provide your contact information when you register for the Services. You also have the option of adding a profile photo, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.
- Content you provide through our products: The Services include the nSpireMe Website and App products you use, where we collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include. Content also includes the musical compositions and performances you upload to the Services. Examples of content we collect and store include: messages, teachers’ notes, performance and progress data, uploaded music, tasks to do and reports on student performance.
- Content you provide through our Websites and Apps: We collect other content that you submit to these Websites and Apps, which include social media or social networking websites operated by us.
- Information you provide through our support channels: The Services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a Service.
Information we collect automatically when you use the Services
We collect information about you when you use our Services, including browsing our Websites and using our Apps, and taking certain actions within the Services.
- Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the music, next steps and other links you click on; the type, size and filenames of attachments you upload to the Services; frequently used search terms; and how you interact with others on the Services.
- Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services, although please note that you cannot restrict the collection of this information.
Information we receive from other sources
We receive information about you from other Service users when they provide it to us including in order to invite you to the Services. We may also receive information about you from our payment providers and security providers.
How we use information we collect
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
- To provide the Services and personalise your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. For example, we use the name and picture you provide in your account to identify you to other Service users. Our Services also include tailored features that personalise your experience, enhance your productivity and improve your learning by providing activity feeds, notifications, connections and recommendations that are most relevant for you and your team. Your audio recordings are stored in your own device only (and only for the duration of your performing an exercise), though future services may allow you to submit them to your teacher. nSpireMe do not have access to your audio recordings, and only analytical data from them rather than the recording itself is transmitted to our servers.
- For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. However, we do not use any personal information about you in this way. We also test and analyse certain new features with some users before rolling the feature out to all users.
- To communicate with you about the Services: We may use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages.
- To market, promote, and drive engagement with the Services: We may use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying nSpireMe ads on other companies' websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximising what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We may also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under "Opt-out of communications."
- Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyse crash information, and to repair and improve the Services.
- For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
- To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
- With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing (for EEA users): If you are an individual in the
European Economic Area
(EEA), we collect and process information about you only where we have legal bases for doing so
EU laws. The legal bases depend on the Services you use and how you use them. This means we
collect and use your
information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalised features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.
How we share information we collect
We provide a digital platform and we want this to work well for you. This means sharing information through the Services and with certain third parties. We may share information we collect about you in the ways discussed below but you can be rest assured that we are not in the business of selling information about you to advertisers or other third parties.
Sharing with other Service users
When you use the Services, we share certain information about you with other Service users, including your music teacher. You can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content based on settings you select. Some of the collaboration features of the Services display some or all of your profile information to other Service users when you share or interact with specific content.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services.
- Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
- Links to Third-Party Sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
- With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public Websites and Apps. With your consent, we may post your name alongside the testimonial.
- Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect nSpireMe, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
How we store and secure information we collect
- Information storage and security: We use data hosting service providers in the United Kingdom and within the EU to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable timeframe.
How long we keep information: How long we keep information we collect about you
depends on the type
of information, as described in further detail below. After such time, we will either delete or
information or, if this is not possible (for example, because the information has been stored
archives), then we will securely store your information and isolate it from any further use
until deletion is
- Account information: We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.
- Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we may continue to display comments and content you provided to cards or made assessments/reports.
- Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from mobile device technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. Some of these rights are complex, and not all of the details have been included below. Further information can be found https://ico.org.uk/your-data-matters/
We will respond to requests about this within a reasonable timeframe.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed. In the UK, that authority is the Information Commissioner, see www.ico.org.uk.
- Access and update your information: Our Services and related documentation give you the ability to access and update certain information about you from within the Service. For example, you can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
- Delete your information: Our Services and related documentation give you the ability to delete certain information about you from within the Service. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
- Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honoured or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
- Opt out of communications: You may opt out of receiving promotional communications from us by using unsubscribe links in emails, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
- Mobile Push Notifications: You can use the settings on your mobile device to enable or turn off mobile push notifications from nSpireMe.
- Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces under your sole control.
How we transfer information we collect internationally
We collect information globally and primarily store that information in the United Kingdom. We transfer, process and store your information outside of your country of residence, to wherever we, nSpireMe, or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
Other important privacy information
Our policy towards children
If you have questions or concerns about how your information is handled, please direct your inquiry to nSpireMe, as set forth below:
Commercial Unit 2,
124 East Road,
London N1 6FD
© nSpireMe 2018