Privacy Notice

Effective Date: November 17, 2023

 

  1. 1. Introduction
  2. 2. Scope
  3. 3. What Information We Collect
  4. 4. How We Use Personal Information
  5. 5. How We Share Personal Information
  6. 6. Your Rights
  7. 7. Your Choices
  8. 8. Third Party Links
  9. 9. Retention of Personal Information
  10. 10. Security
  11. 11. International Transfers of Personal Information
  12. 12. EU and UK General Data Protection Regulation
  13. 13. U.S. Disclosures
  14. 14. Children’s Privacy
  15. 15. Changes to This Privacy Notice
  16. 16. Contact Us

 

1. Introduction

You have arrived at a website operated by Big Machine Label Group, LLC or one of our affiliates (“BMLG,” “we”, “our” or “us”). We are a record label encompassing Big Machine Records, The Valory Music Co., BMLG Records, Big Machine John Varvatos Records, The Hard Working Record Co., publishing company Big Machine Music, and digital radio station, Big Machine Radio.

This Privacy Notice (“Notice”) describes the types of Personal Information that we may collect, how we may use it, how and when may we share it, and the rights you may have with respect to Personal Information about you. It also explains how we may communicate with you and how you can make inquiries and requests to us. Within this Notice, “Personal Information” means any information relating to an identified or identifiable individual.

2. Scope

This Notice applies when you use or access any of the websites on this list the “Sites” and each individually a “Site”) and, to the extent applicable, their subdomains and/or portals, or otherwise provide Personal Information or interact with us online or in person (collectively, the “Services”).

Where applicable, we indicate whether and why you must provide us with Personal Information, and what happens if you do not do so. In some cases, if you do not provide Personal Information, you may not be able to benefit from some of our Services.

3. What Information We Collect

This section describes what information we may collect through our Services.

Information That You Provide to Us

We may collect the following Personal Information as you interact with our Services, such as when you contact us, or complete an online form, and through telephone calls, text messages, letters, emails, and/or through other communications.

On Our Sites

  • Contact information such as your first and last name, email address, address and/or location (country, state, city, zip code, etc.), and/or telephone number(s).
  • Information to sign up for a contest, sweepstakes, or other promotion such as your contact information, date of birth, and preferred size (for example, for a t-shirt);
  • Credentials, such as a username and password, if needed to establish or access an account.
  • Your image, likeness, and/or voice in photos and/or video recordings that you submit to us.
  • If you apply for a position, job application information such as your first and last name, email address, physical address, telephone numbers, your current or past employment or educational information, relevant licenses or certifications, and other information that could reasonably be used to identify you personally.

 

In Person

  • Contact information such as your first and last name, email address, physical address, telephone and/or number(s).
  • Information to confirm your identity, such as a photo ID.
  • Your image, likeness, and/or voice in photos and/or video recordings.
  • Your image and movement throughout certain public areas of our offices, as captured by our CCTV system.

 

Information That Is Automatically Collected

Like many businesses, we and our service providers automatically collect and/or store certain information when you visit or interact with the Sites (“Usage Information”). This Usage Information may be stored and/or accessed from the computer, laptop, tablet, mobile phone, or other device (a “Device”) whenever you visit or interact with our Sites. We may collect the following Usage Information:

  • IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
  • Device functionality (including browser, browser language, settings and behavior, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within the Sites that you visit and your activities there, including remembering you and your preferences;
  • Device location or other location information, including the zip code, state, and/or country from which you accessed the Services;
  • Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware);
  • Certain other data, including the time of day you visit our Sites or other information used to provide analytics or other usage information;
  • Information about your engagement with our emails; and
  • Statistical information about how both unregistered and registered users, collectively, use the Sites. This aggregate information is derived from Personal Information but cannot be tied back to any individual or Device.

For location information, some of our Services may include features based on location and may report on your or a Device’s current location (“Location-Based Services”). If you use Location-Based Services, we may collect and store information about your (or the Device’s) location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information comes from a variety of sources depending on the Device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.

If you do not wish for us or our service providers to collect and use location information, you may disable the location features on your Device. Consult your Device settings for instructions. Please note that if you disable such features, your ability to access certain features of our Services, such as specific content, promotions, and/or products may be limited or disabled.

Cookies

We may use cookies (small text files sent by Devices when you visit our Sites) and other tracking technologies to personalize the experience, analyze user trends, and improve the Services. These tracking technologies allow us to collect information such as Device type, browser type, interactions with our Sites, geographic location, web requests, the date and time of a request, Internet Protocol address, the domain name of the Internet service provider, and/or other data. If an individual can be identified from this information – for example by combination with other pieces of information – or we are required by law to do so, then we will treat it as Personal Information.

Many browsers default to accepting cookies. You may be able to change this setting and/or clear the cookies in your browser. If you do, you may lose some functionality of our Sites.

We may use the following types of cookies:

  • Strictly necessary cookies. These cookies are essential for you to browse a website and use its features.
  • Functionality cookies. Also known as “preference cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, or what your username and password are so you can automatically log in.
  • Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited, and which links you clicked on. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services.
  • Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always of third-party provenance.

We might also use pixel tags, which are small graphic files that allow us and third parties to monitor the use of the Sites and provide us with information based on your interaction with the Sites. These tags may collect a Device’s IP address and browser type. We may also use pixel tags provided by others to collect information about Site Visitors, including the links and other actions on our Sites. We may use this information in combination with cookies to display targeted advertisements.

To find out more about cookies and similar technologies, visit www.allaboutcookies.org, and/or www.youronlinechoices.com.

Information Collected from Third Parties

The Sites include functionality that allows certain kinds of interactions between you and the Sites (for example, to make a purchase, give a donation, or indicate your interest in an event) on a third-party website or application. The third-party host of the website or application may provide information to us about your interaction with that site or application. These third parties may also use cookies and other tracking technologies to capture information about your interactions with us.

We may also receive information about you from our artists or other parties associated with our artists with whom you interact.

Information We Infer

We derive information or draw inferences about you based on information we collect about you. For example, based on your browsing or purchases, we may infer your gender, your interest in certain activities or brands, or information about your purchasing activities over time.

Sensitive Information

We do not knowingly collect Sensitive Information (as that term is defined under applicable law).

4. How We Use Personal Information

We may use the Personal Information we collect in a variety of ways, including the following:

To Provide Our Services

We may process Personal Information when you access or use our Services, including to:

  • process your requests for information, products, and/or services;
  • create and verify user accounts;
  • verify your identity;
  • register you for an event or in a contest, sweepstakes, or other promotion;
  • deliver gift cards and/or gifts, e-cards and/or -gifts, and/or personalized messages;
  • facilitate the functionality of our Sites;
  • protecting the safety and security of people and assets at our offices; and
  • customize experiences and personalization when you are on our Sites or use our Services.

 

To Communicate with You

We may process certain information to communicate with you in relation to your accounts, our Services, our marketing, and your requests, including to:

  • communicate with you about orders, purchases, returns, services, accounts, programs, contests, and sweepstakes;
  • respond to your customer service inquiries and requests for information;
  • post your comments or statements on our Site;
  • send you personalized promotions, content, and special offers;
  • provide you with targeted advertisements or marketing communications we believe may be of interest to you; and
  • communicate with you about our brands, products, events, or other promotional purposes; and
  • implement your communications preferences, such as sharing information with our business partners so that they can email you about their promotions, products, and initiatives.

 

For Profiling

BMLG uses Personal Information to create profiles that allows us to send communications and/or advertisements that may be more appropriate for or interesting to you.

For Improvement of Our Sites and/or Services

We want to ensure that our Sites and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

  • maintain, improve, and analyze our Sites and/or Services; and
  • detect, prevent, or investigate suspicious activity or fraud.

 

To Comply with Applicable Laws

We may be required to process certain Personal Information to comply with law (for example, national, sates, and/or local tax laws) and other legal processes (such as litigation holds, subpoenas, and court orders), as well as to:

  • maintain appropriate records for internal administrative purposes; and
  • comply with applicable legal obligations and respond to lawful governmental requests, as needed.

 

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Sites and Services, we use Personal Information to ensure our terms, policies, and agreements with you and others are enforced and/or to resolve any dispute regarding our Services and the applicable terms, policies, and agreements.

To Evaluate Your Application for Employment

If you apply for employment (including internships) via our Site, we may use Personal Information to evaluate your application.

With Your Consent

We may process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

5. How We Share Personal Information

Service Providers

We share Personal Information with our service providers who provide services such as website and/or form hosting, data analysis, information technology, customer service, email delivery, online advertising, auditing, event planning and other services.

Third Party Advertising

We may share information about your use of our Sites and/or Services, and your interaction with our ads on other websites, with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We may collect and share some of this information directly with our advertising partners, and in some cases with cookies or other technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, visit the Network Advertising Initiative’s educational page here.

You can opt out of targeted advertising by visiting the following:

Facebook
Google
Twitter
LinkedIn
Pinterest
Instagram
Tik Tok

Other

Aside from the instances described above, we may share Personal Information:

  • to comply with the law;
  • to respond to claims or comply with legal process served on BMLG (e.g., a lawful subpoena, warrant, or court order);
  • to enforce or apply our policies or agreements;
  • to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
  • in connection with a business transfer, sale, liquidation, or merger;
  • if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
  • to other parties with your consent.

 

6. Your Rights

Depending on where you live, you may have certain rights under law. BMLG allows everyone to make the following requests with respect to Personal Information BMLG collects or processes:

  • to know what Personal Information we process about you and to access it;
  • to delete Personal Information;
  • to correct inaccurate Personal Information;
  • that we stop processing certain Personal Information, such as for the sale of Personal Information, processing of Personal Information for targeted advertising, processing of sensitive Personal Information, or processing of Personal Information for profiling;
  • that we restrict the processing of certain Personal Information; and
  • data portability (the right to get a copy of Personal Information we have collected from you, in a structured, machine-readable, and commonly used format).

In addition, you also have the right to withdraw consent at any time with respect to any ways that BMLG processes Personal Information about you based on your consent.

Right to Non-Discrimination

We may not discriminate against you because you have exercised any of these rights, including by:

  • denying you Services;
  • charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;
  • providing you a different level or quality of Services; or
  • suggesting that you will receive a different price or rate for Services, or at a different level or quality of Services.

 

How to Exercise Your Privacy Rights

You or your authorized agent may make a request to exercise any of your rights. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You make a request by:

  • submitting a request to privacy@BMLG.net;
  • completing this webform; or
  • calling us at (866) 462-3288

Please note that, as permitted or required by applicable law, we may take steps to verify your identity and/or residency, and if you are submitting a request on someone else’s behalf, we may also ask for proof of your authority to act on their behalf, before granting you access to Personal Information or otherwise acting on your request to exercise your rights. This might include asking for your email address. If you are requesting specific pieces of Personal Information that we have collected about you, you will also be required to email us at privacy@BMLG.net a signed declaration under penalty of perjury that you are a resident of the place where you claim to reside and that you are the consumer whose Personal Information is the subject of the request. Note that we will not process your request to disclose specific pieces of Personal Information we have about you until we receive this signed declaration, and your request will not be considered timely submitted until we have this document in our possession.

We may limit our response to your request as permitted by law. We will confirm receipt of the request and/or respond to your request within the timeframes specified in applicable law based on where you live, or let you know if we need additional time.

If we decline to act on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to the relevant authority (for example, your state Attorney General or a European Data Protection Authority).

7. Your Choices

Cookies

You can opt-out of cookies by clicking on the “Cookie Choices” link at the bottom of our Sites or by enabling an opt-out preference signal or Global Privacy Control (GPC) on your browser.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers:

Note that if you turn cookies off, you may be unable to access certain parts of the Sites and you may not be able to benefit from the full functionality of the Sites.

Do Not Track

Your browser may offer you a “Do Not Track” (“DNT”) option, which allows you to signal to operators of websites and web applications that you do not wish such operators to track some of your online activities over time and across different websites and platforms. There is no universally agreed-upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. Learn more about Do Not Track here.

Universal Opt-Out Mechanisms

Some browsers and browser extensions support one or more Universal Opt-Out Mechanisms (“UOM”s), such as the Global Privacy Control (“GPC”), that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including targeted marketing. In certain territories, when we detect such a signal, we will make reasonable efforts to respect your choices indicated by a UOM setting, as required by applicable law.

If you use a UOM, you will be able to exercise any opt-out rights available to you under applicable state law.

Communication Preferences

BMLG may communicate with you via a variety of channels; as required by law, we will provide you an opportunity to opt out of communications through specific channels, and/or only communicate with you via that channel if you have opted in.

You can opt out of receiving emails and text/SMS messages from us at any time. To manage your communications preferences with BMLG — or to opt out of communications entirely — please unsubscribe via the link provided at the bottom of our emails, reply STOP to a text message, or contact us at privacy@bmlg.net.

Analytics

We use Google Analytics to help us understand how visitors use the Sites. Read more about how Google uses Personal Information here and opt-out of Google Analytics here.

8. Third Party Links

Our Sites may contain links to other websites such as social media platforms, and event and partner websites (for example, to purchase event tickets, indicate your interest in a concert, and/or purchase merchandise). Those other websites are not covered by this Privacy Notice. Please review the privacy notices or policies of those websites to understand their privacy practices.

9. Retention of Personal Information

BMLG will retain Personal Information for as long as is necessary for the purposes set out in this Privacy Notice and to comply with our legal obligations (for example, if we are required to retain Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We have implemented measures designed to ensure that we will not retain Personal Information longer than necessary to fulfil the purposes described in this Privacy Notice.

In some circumstances we may choose to de-identify, pseudonymize, and/or anonymise Personal Information (so that it can no longer be directly associated with any individual), in accordance with applicable law. We may do this, for example, to conduct research or statistical purposes, in which case we may retain this information indefinitely.

When deciding how long to keep Personal Information, we consider:

  • how long we have had a relationship with you or provided our Services to you;
  • whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them, for example based on applicable statutes of limitation); and
  • whether we have taken any legal positions (e.g., in connection with any anticipated or ongoing litigation or governmental action, etc.).

 

10. Security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information. For example, we use encryption on our Site pages that include webforms through which you submit Personal Information to us, and all Personal Information you provide to us is stored on our or our storage providers’ secure servers.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where you use a password so that you can access certain areas of our Sites, you are responsible for keeping that password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us using the information in the Contact Us section below.

11. International Transfers of Personal Information

The Sites are operated in the United States. If you are in another jurisdiction, please know that any Personal Information we collect from or about you will be transferred to, stored in, and processed in the United States. Please note that the privacy laws in the United States may not be the same as laws in the country where you live. We and our service providers strive to use safeguards appropriate to transfer Personal Information to the United States.

By using the Sites and providing us with information, you consent to the transfer, processing, and storage of Personal Information to and in the United States.

12. EU and UK General Data Protection Regulation

The information in this section is intended to supplement and not replace the information provided in other sections of this Notice; in the case of any conflict, the information in this section will apply for individuals residing in the European Economic Area (“EEA”) or the United Kingdom (“UK”).

Any capitalized terms used in this section and not otherwise defined in this section or elsewhere in this Privacy Notice will have the meaning given in the European Union General Data Protection Regulation (“EU GDPR”) and/or United Kingdom General Data Protection Regulation (“UK GDPR”), as applicable based on where you live.

Under the EU GDPR and UK GDPR, we are considered the “data controller” of the Personal Information we handle under this Notice. In other words, BMLG is responsible for deciding how to collect, use and disclose Personal Information, subject to applicable law.

Legal Basis for Processing Personal Information

We rely on the following legal bases for processing Personal Information:

  • Contract: To enter into or perform a contract with you, for example:
    • to manage and fulfill orders, facilitate delivery, and to provide Services;
    • to manage our accounts and records;
    • to handle your inquiries and requests; and
    • when you apply for employment (including internships) through our Site, we will process the information you submit, including your contact details and data about your employment history and education, to evaluate your job application, conduct job interviews, and as otherwise needed for recruitment.
  • Legitimate Interests: For our internal operations and business functions, for example:
    • to maintain, improve, and analyze our Sites, ads, and Services we offer;
    • to conduct marketing activities;
    • to detect, prevent, or investigate security breaches or fraud; and
    • to facilitate the functionality of our Sites.

When we process Personal Information for our legitimate interests, we consider and balance any potential impact on individuals and their rights, and we will not use Personal Information for activities where our interests are overridden by the impact on individuals, unless we have consent or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests, as described in the “Your Rights” section of this Notice.

  • Legal Compliance: To comply with our legal obligations, for example:
    • to maintain appropriate records for internal administrative purposes; and
    • to provide important product safety information and notice of product recalls.
  • Consent: There are certain activities that we will only engage in with your consent, for example to send you SMS/text marketing messages about our Services or promotions. You have the right to withdraw your consent at any time as described in this Notice.

 

How to Exercise Your Rights

If applicable, you may exercise your rights under the EU or UK GDPR on your own behalf or on behalf of someone else by submitting a request to us. Your request must include your full name, email address, and confirmation that you are a citizen or resident of the EU or UK (as applicable) by including your country of citizenship or residence. Any request that you submit on behalf of someone else must contain this information about the person for whom you are submitting the request, along with proof of your authorization to submit the request on their behalf. We will respond to your request within the time required by EU or UK GDPR (as applicable, based on where you live) or let you know if we need additional time.

Please note that we may ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

If you wish to raise a concern about BMLG’s use of Personal Information about you without prejudice to any other rights you may have, you have the right to do so with your local supervisory authority; however, we hope that we can assist with any questions or concerns you may have about our use of Personal Information first by contacting us as follows:

Big Machine Label Group
1219 16th Avenue South
Nashville, TN 37212
Email: privacy@bmlg.net

UK office:
Soho Works, Royalty House
72-74 Dean Street, W1D 3SG
UKgdpr@bmlg.net

EU representative:
Archie Gormley
Director, International
gdpr@bmlg.net

Complaints

If you are dissatisfied with any response you receive from us, you have the right to lodge a complaint with your local supervisory authority. For the EU, you can find your local supervisory authority here. You can find contact information for the UK Information Commissioner Office here.

 

13. U.S. Disclosures

Please click here to see supplemental information about our data collection and use practices, as required under various U.S. state laws.

California Shine the Light

If you are a California resident, you have the right to request information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you also may ask us to refrain from sharing Personal Information about you with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us using the information in the Contact Us section below.

We do not disclose any Personal Information to third parties for their direct marketing purposes.

14. Children’s Privacy

Our Services are not directed at children under the age of 18, and we do not knowingly collect or receive Personal Information from them. If you believe that we have received Personal Information from a child under the age of 18, you may contact us using the information in the Contact Us section below to request deletion of that information.

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

15. Changes to This Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the Notice the modified effective date. We encourage you to refer to this Notice on an ongoing basis. If and as required by applicable law, we will notify you of the changes.

By continuing to use the Sites and/or the Services or providing us with information following the posting of any changes to our Notice, you will be deemed to have reviewed and understood the Privacy Notice as changed.

16. Contact Us

If you have any questions about this Privacy Notice, please contact us at:

Big Machine Label Group
Email: privacy@bmlg.net
Contact number: (866) 462-3288