Effective Date: 25th May 2018
We know that you care how information about you is used and shared. We take the privacy and security of your data as a priority.
Information We Collect
We collect information about you to provide our services. For us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.
(a) Our Service/registration:
We may collect personally identifiable information about you, such as your full name, phone number, email address, or similar, when you register for an account, contact us or respond to any surveys. If you choose to purchase a product from us, we or our third-party payment processors will collect your payment information.
We also collect data through our partners (customers) who use the Focusrite products (including by embedding our code on their websites) on their websites or mobile applications.
If you apply for a Job at Focusrite we will collect the information required and submitted as part of any CV/references.
When you use the Focusrite partners or if you visit such websites or mobile applications, we may receive certain information about you as described below.
We do not send any promotional emails unless you have opted in to receive them; however, we may send you service related emails related to your account or product purchase/registration. If you no longer wish to receive these emails, you may opt out of them by cancelling your account.
(b) Cookies and Tracking Technologies:
Technologies such as: cookies, beacons, tags and scripts are used by Focusrite and our partners (such as advertising, marketing and analytics), affiliates or analytics or service providers. These technologies may be used in analysing trends, administering the Sites, tracking users’ movements around the Sites and to gather demographic information about our user base.
We may receive reports based on the use of these technologies by Crimson Hexagon, Google Analytics etc on an individual as well as aggregated basis. Our partners may also use such technologies to deliver advertisements to you as described below.
Cookies give us the ability to personalise users’ online experience with our sites and services and enable users to customise their experience.
If you are in Europe, your IP address, keystroke activity, and personal information are never stored or shared with any third-parties. We process and keep all data within Europe and, if you wish to opt-out, you can do so at https://Focusrite.com/right-to-be-forgotten
(c) Log File Information:
Log file information is automatically reported by your browser or mobile application each time you access our Sites or the Focusrite partners. For example, when you access our Sites, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your operating system, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and other such information. We may use this data for analysing trends, administering the Sites, tracking users’ movements around the Sites and to gather demographic information about our user base.
(d) Information Related to Data Collected for Our Customers:
Focusrite collects information under the direction of its customers, and has no direct relationship with the individuals whose data it may process. If you are a user and would no longer like to be tracked, please contact the respective data protection officer directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
(e) Access and Retention of Data Controlled By Our Customers: **
An individual who is a current or former Focusrite user who seeks access or wishes to correct, amend or delete inaccurate data should direct their query to dpo@Focusrite.com or Focusrite Customer support team. An individual who is a client of a current or former Focusrite customer who seeks access or wishes to correct, amend or delete inaccurate data should direct their query to the respective customer first and then, if no response is obtained or such response is not satisfactory, should contact dpo@Focusrite.com. If we receive a request under this provision, we will acknowledge it within seventy-two (72) business hours and handle it promptly.
Focusrite will retain this personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
1. How We Use Your Information/data.
Data Purpose Legal Basis Website User Data Marketing Data Prospect Data
To keep you informed of any activities undertaken by us which we believe may be of interest to you and this use may include sending you email and postal marketing from time to time or requests to respond to a survey Consent – this will be requested either when you submit Your Data to us or, if we have received Your Data indirectly, by way of an email sent prior to us sending you any marketing communications.
Website User Data
Website background Data
Website analytic purposes. For further details on the technology we use to analyse our website’s performance, please see our cookies policy
Consent – this will be obtained when you click on the banner at the top of our website to accept certain cookies. Legitimate interest of Focusrite (see our cookies policy for further information) Website User Data Marketing Data Prospect Data To provide you with the newsletter(s) or information you have requested Performance of a contract Website User Data Marketing Data Prospect Data Website Background Data Survey Data To respond to requests for information from regulated bodies or government agencies Compliance with legal obligation Website User Data Prospect Data To respond to an enquiry, you have submitted Legitimate interest of Focusrite – it may be necessary for us to process Your Data to reply or respond to your enquiry Survey Data
To gather and analyse information on the market for our internal purposes which may be used to publish a report Consent – this will be requested when you submit Survey Data to us.
User contacting support
To respond to an enquiry, you have submitted
Legitimate interest of Focusrite – it may be necessary for us to process Your Data to reply or respond to your enquiry Product registration Data
To gather and analyse trends/demographic behaviours in the market for our internal purposes to continually develop and improve our products and services.
Legitimate interest of Focusrite to allow us to support the products you have purchased.
2. How We Share Your Information
(a) Personally, Identifiable Information:
Focusrite will not rent or sell your personally identifiable information to others. We may store personal information in locations outside the direct control of Focusrite (for instance, on servers or databases co-located with hosting providers).
Any personally identifiable information you elect to make publicly available on our Sites, such as posting comments on our blog page, will be available to others. If you remove information that you have made public on our Sites or the Focusrite Service, copies may remain viewable in cached and archived pages of our Sites, or if other users have copied or saved that information.
Personal information is used by our customer support teams to help you with any issues, this information is stored in secure helpdesk tool.
(b) Non-Personally Identifiable Information:
We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, users’ operating systems, product and setup information gathered from surveys/registration etc.) with interested third parties to help them understand the usage patterns for certain Focusrite products and Services. Such results consist solely of non-personally identifiable information.
(c) Instances Where We Are Required To Share Your Information:
Focusrite will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Focusrite, our users or others.
(d) What Happens In The Event Of A Change Of Control:
We may sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as user names and email addresses, and other User information related to the Focusrite Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
(e) Behavioural Targeting / Re-Targeting:
We partner with third parties to display advertising on our Sites and manage our advertising on other sites. Our third-party partners may use technologies such as cookies to gather information about your activities on this Site and other sites in order to provide you advertising based upon your browsing activities and interests.
The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools (to learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org). If you access the Focusrite Sites on your mobile device, you may not be able to control tracking technologies through the settings.
(f) Testimonials: We display personal testimonials of satisfied users on our Site in addition to other endorsements.
With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at dpo@Focusrite.com .
3. Storage and Processing.
Your information collected through the Focusrite Service may be stored and processed in the United States, Europe, or any other country in which Focusrite or its subsidiaries, maintain facilities. Focusrite may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
4. How We Protect Your Information.
Focusrite is concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to Focusrite or guarantee that your information on the Focusrite Service may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. When you enter sensitive information (such as log in credentials) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).
No method of transmission over the Internet or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at dpo@Focusrite.com
We use an outside help platform, and a credit card processing company to bill you if you purchase services. These companies do not retain, share, store or use personally identifiable information for any other purposes.
5. We will keep your personal data for the duration of the period you are a customer of Focusrite.
We shall retain your data only for as long as necessary in accordance with applicable laws. On the closure of your account, we may keep your data for up to 7 years after you have cancelled your services with us. We may not be able to delete your data before this time due to our legal and/or accountancy obligations. We may also keep it for research or statistical purposes. We assure you that your personal data shall only be used for these purposes stated herein.
6. Focusrite self-certifies compliance with EU-US Privacy Shield at the U.S.
Department of Commerce. Focusrite complies with the EU Data Protection Directive 95/46/EC framework as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Focusrite has certified that it adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.
7. Compromise of Personal Information.
In the event that personal information is compromised as a breach of security, Focusrite will promptly notify our users in compliance with applicable law.
8. Your Choices About Your Information
For current Focusrite users, you can review, correct, update or delete inaccuracies to the information about you that Focusrite keeps on file by logging into your account to update your password and billing information. Alternately (and for former Focusrite users), you can contact us directly at customer.service@Focusrite.com . We will acknowledge your request within seventy-two (72) hours and handle it promptly. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
9. Children’s Privacy.
Protecting the privacy of young children is especially important. For that reason, Focusrite does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at dpo@Focusrite.com
10. Notification Procedures
11. Links to Other Web Sites
Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.