Last update: December 15, 2022
Effective date: December 15, 2022
1. GENERAL DEFINITIONS
1.1. Users & Visitors
As used in this Policy, a ‘User’ is a person or individual who has enrolled for lessons with Blanch Music and can log in to and use interactive services within the Blanch Music Site, and a ‘Visitor’ is an individual who visits a Blanch Music Service, but who has not enrolled for lessons with Blanch Music and therefore cannot log in to the Blanch Music Site. This Policy applies Users and Visitors, unless explicitely outlined.
1.2. Data Controller
In line with current data protection legislation, the Data Controller of your personal data is Blanchardstown School Of Music & Shop Limited, 1st Floor, Unit 3, Coolmine Industrial Estate, Dublin 15, D15 PF9W, firstname.lastname@example.org.
1.3. Policy Changes
Blanch Music reserves the right to revise, update or change this Policy at any time. Please ensure to review this Policy regularly. At the top of this policy you find the latest version date as per “Last Update”. Users will be notified for any significant changes to this Policy via email or on the Blanch Music Site before changes will be implemented.
2. COLLECTING DATA
We only collect and use personal data in compliance with current legislation. Therefore we may collect, use and process personal data for monitoring and reporting. We have carefully reviewed and planned the necessity of only collecting relevant data for the provision of our services and will only process data we have a legitimate interest in unless this might impact your personal freedom or fundamental rights. Data we collect is necessary as it is needed to prepare for or perform a contractual agreement between you as a customer or user of our services. In general, users have to consent that we can collect, use and process personal data. Where users or visitors have the right to withdraw consent, such withdrawal options will be indicated or can be requested as outlined in this Policy or by contacting us directly.
2.1. When is data collected:
Blanch Music collects personal data from Visitors or Users when they:
- enrol to lessons or make any purchases via Blanch Music (including inquiries, booking deposits, balance payments),
- create posts on any of the Blanch Music Services (including but not limited to any Social Media Pages),
- communicate with Blanch Music the Blanch Music Site Contact page
- ask for customer service or technical support
- leave feedback about the Blanch Music Service on the Blanch Music Sites, (including but not limited to the website and social media services).
Other personal data might also be collected within the Blanch Music Service in which case the purpose of data collection will be transparently explained.
2.2. Lesson Enrolment
To enrol for a lesson with Blanch Music Users must provide:
- First & Last Name of Student
- Phone Number
- Email Address
- Home Address
- Lesson Specific Information including but not limited to Date & Time Availability, Instrument, Previous Experience & Skill Level, Personal Prefences, Voluntarily Information regarding Special Needs,
- Age (for minor students only, no date of birth will be collected)
- In case of minor students under the age of 18, all information must be provided for both parents/ guardians for the purpose of child protection
As Blanch Music is an educational institution we are obliged to collect certain personal data in compliance to child protection and health and safety legislation.
As part of the lesson enrolment Users have to provide payment information to our Third-Party Payment Provider as outlined below.
2.3. Student Portal Registration
To gain access to the student portal, Users will be sent an email to set up their student account at which point Users will have to provide a Password. We highly recommend to use a unique and secure password with a minimum length of 12 characters, including numbers, capital and lower case letters and symbols.
Users can access, update and modify their information via the student portal. User information will automatically deleted upon termination of lesson enrolment or upon request, however, continuosly services cannot be provided with the essential data provided as per paragraph 4.3., and, First and Last Name of Booking including booking reference will be kept on file in legal compliance with revenue and financial legislation for a period of seven years from date of termination.
2.4. Student Progress and Attendance
To guarantee a customised high quality lesson experience we also collect information about Student Progress, Attendance, Punctuality and optional Exam Grades.
2.5. Forums, Reviews and Feedback
Forum posts, reviews and feedback can be submitted via our Service for which Users or Visitors must have registered via our Student Portal or have a valid account with a Third-Party Provider including, but not limited to any Social Media platforms.
User names will be displayed publically.
2.6. What are we using data for?
Blanch Music only collects data for the purpose of offering and providing music lessons, User support or communication to/with Users and Visitors.
Third-Party Providers may collect and use information of their web services and web sites such as forum posts in which case Blanch Music cannot influence, monitor or control any such collection or use.
2.7. Third-Party Data Collection
Blanch Music Services are stored and hosted on servers which are provided by third-party services including WordPress, My Music Staff, Siteground and GoDaddy.
These service providers store information from Users and Visitors to guarantee the Blanch Music Services are working without interruption and securely (identify & fix any bugs), including:
- IP Address
- Operating System
- Browser type
- Internet Service Provider
- Visited Domain Name & Directories, Referring External Websites
- Click Stream
- Search Terms
- Data entered by Visitor and Users into the Blanch Music Sites
- Geographic Location
- Date and Time of website visit, log-in or use.
This data is stored in so called “Log Files” and is not connected to personal data, which means it is anonymous.
When you visit or use our services from a mobile device we also collect the following information:
- Type of device
- Mobile device software
- Mobile Service Provider (Carrier)
By visiting or using the Blanch Music Services, Vistors and Users agree and consent to the use and processing of analytical data by Blanch Music and their third-party Analytic Services (Google Analytics), as outlined above.
For Marketing purposes, Blanch Music may use other third-party advertisement services. You can opt out by visiting one of the following:
- EU: http://www.youronlinechoices.eu/
- Other: http://www.aboutads.info/ or http://networkadvertising.org/choices/
While Cookies are information saved on your computer’s hard drive while you are using our web services, Cookies cannot install malicious software or viruses on your computer, neither can they retrieve any data from your computer hard drives or identify your email address. We may collect information via session Cookies which will be auto-deleted when you close your browser window, and via persistent Cookies that will stay on your hard drive until you delete these. Instructions how to delete cookies and how to empty your cache can be found online and are dependent on the browser you use (Google Chrome, Mozilla, Safari, etc.).
Cookies we use can be broadly categorised into first and third party Cookies. First party cookies will only be used by us and third party Cookies will be used on our web services through third party service providers as outlined in this Policy. Both types of Cookies are used to recognise your computer or device when visiting our web services and help to
- a) improve performance,
- b) verify a user’s log-in details including email, password, location, IP address,
- c) improve customer service
2.8.1. Essential Cookies.
Essential Cookies are necessary Cookies to make it possible for Users and Visitors to use our services and its features, including for instance logging in to user specific dashboards and accounts, viewing user specific content or using courses and lessons. These Cookies are essential because they provide security, necessary service functionality and performance.
2.8.2. Functional Cookies.
Functional Cookies store information about your log-in details, language choices, general changes you make in relation your customised user or visitor experience on our web services. These Cookies help us to provide Users and Visitors with a more efficient and customised service.
2.8.3. Analytical and Performance Cookies.
Analytical and Performance Cookies gather data on how Visitors and Users use and experience our services. These Cookies cannot identify a User or Visitor, they only collect anonymous data including the amount of site visits and unique or non-unique site visitors, website referrals, individual pages visited on our services, time, date visited and amount of time spent on each page, geographical location in general, and similar information. We only use these Cookies to find out about our general demographic customer base, as well as to monitor the performance and activity on our websites.
Additionally, we use Google Analytics which also collects data via their own Cookies. Again, all Cookies are only used to improve our Service offering.
They are only used to improve how our Services works. Here is a link to Google Analytics information and how Google Analytics uses and protects user and Visitor data:
If Users or Visitors wish to prevent Google Analytics from collecting or using their information, they can download and install a particular browser plugin here (Please note that we don’t take any responsibility for this Plug In): http://tools.google.com/dlpage/gaoptout?hl=en-GB.
2.8.4. Social Media Cookies.
We use Social Media Cookies every time a Visitor or User engages with any of our Social Media websites which include Facebook, Twitter, LinkedIn, Instagram, Youtube. Engagement includes for example:
- Using a “Share” Button
- Linking a User Account, or following us
- Engaging with our Content (Post, Comment, Like, Dislike, Share, etc.)
Please note that all Social Media platforms keep a record of any such engagement.
Usually Users and Visitors can reject any of these Cookies in their web browser. Please be aware that most browsers are by default accepting these Cookies. Please refer to your browser’s Settings (you might need to use the help or tools functions or find a solution for your browser online) to reject or customise your Cookies settings.
Additional information about using, managing, rejecting and deleting Cookies can be found here:
Blanch Music Users must accept Cookies in order to being able to use any or specific features of the Blanch Music Services. Although Visitors and Users are able to reject or block certain or all Cookies on our websites or via their browser settings, please be aware that some of the Blanch Music Service pages or functions will not work at all or partially if browser settings prevents these Cookies.
2.9. Pixels & Facebook Pixel
Pixels, Pixel Tags, Web Beacons or Clear GIFs (hereinafter “Pixels”) are generally used to track the actions of users.
While Cookies are stored on a computer hard drive or a mobile device’s hard drive through a website, pixels are embedded invisibly on webpages.
Our pixels collect information about marketing and ad campaigns any related information that helps us to measure the success and usage of our marketing campaigns and websites. We use Pixels only to improve our services and run our Music School more effectively and efficiently. Again, no information collected from Pixels is linked to any personal User or Visitor data.
Facebook collects data to serve customised advertisement via their Facebook Pixel, which we may use from time to time.
To reject Facebook’s customised ads, please check this link:
2.10. Profiling & Do Not Track
Unless ordered by law, we will never use any personal User or Visitor Data for profiling or automated decision-making. In any such case we will inform you prior to such an event and give you the option to object officially.
At the moment, we don’t follow any ‘Do Not Track’ or similar functions that usually gives Users or Visitors the option to reject tracking on our website services.
More information can be found here:
- USING VISTOR & USER DATA & INFORMATION3.1. Personal Data
Generally, Personal Visitor and User Data is used to provide the Blanch Music Services or handle any User or Visitor related queries. In more detail, we use User and Visitor data to:
- Make sure Visitors and Users can use our web sites and services;
- Make sure Users can create and securely log-in and out of their accounts;
- Verify Users and accounts and their log-ins;
- Conduct our Music School Business, which includes administration, operation such as booking of lessons, invoicing, measures for business sustainability and growth;
- Improve user and visitor experience, quality of services and communications, efficiency;
- Comply with new legal regulations, including but not limited to financial, privacy rights, health and safety, child protection, etc.
- Communicate with Users via postal letters, email, text, phone or video conferencing for the purpose of conducting our business, as well as, conducting in-person or online lessons. Communications include
- Issuing and Processing Invoices, Deposit and balance payments;
- Booking Confirmations, Receipts, Lesson Reminders;
- Lesson Notes and Homework or Assignments;
- Lesson Progress, Reports, Attendance, Punctuality;
- Music Exams, Grading and issuing of Certificates;
- Events, School Notifications and Announcements;
- Newsletter which includes Product and Service Offers and Updates and Promotions (only if subscribed to and consented to separately by User, Users will be able to opt out of Newsletters at any time, Please be aware that Users will still receive school and lesson related communications if Users are signed up for music lessons with Blanch Music);
- Manage Employment and Employment Inquiries, in case you are an employee of Blanch Music or apply for a job at Blanch Music.
- SHARING VISTOR & USER DATA & INFORMATION
We may share certain personal data with third party service in order to provide our Services and conduct our business. By using our service you give your consent for us to do so.
According to GDPR, third party services are data processors. We only use data processors to make it possible to conduct our music school business and provide services to you by using their necessary infrastructure, technology and software. Data processors are used to provide the following services for us:
- Domain, Website & Email Hosting;
- Website Development and Design;
- Booking of lessons, Student and Staff Management System;
- Payment Management and Processing;
- Book Keeping & Accounting Systems;
- Learn Management & Exam System;
- Communication Systems & Customer Relation Management;
- Marketing & Data Analysis Tools;
- Customer Review Services;
A full list of our Data Processors can be found here: Blanch Music Data Processors.
4.2. Financial Data
- Stripe: https://stripe.com
- PayPal: https://paypal.com
- Revolut: https://revolut.com
4.3. Social Media & Blanch Music Sites
User or Visitor may create posts, comments or disclose any information on any of the Blanch Music Services (including but not limited to websites, forums, reviews, testimonials and social media pages). We strongly recommend and ask all Users and Visitors to not disclose any personal information on any of our Services as this information becomes immediately public. We clearly state that Users and Visitors are responsible for any such disclosure and that Blanch Music will not be liable in any way for how others might use or even abuse any such publicly disclosed data.
When leaving a review, feedback or a testimonial, we may use any such data provided to publish, reproduce or distribute on any of our services and will only disclose the User or Visitor name in compliance with this Policy.
4.3.1. We are legally obliged to save, occasionally access and potentially share or disclose User and Visitor Data to legal institutions, but only if we believe that this is a necessity to comply with the law and if we are given a reason to do so. Any such reasons include:
- A subpoena;
- A court order;
- Third Party content violations;
- Law enforcement;
- Investigation of unauthorised access or illegal user or visitor activities;
- Health & Safety, Child Protection;
- Other people’s rights including but not limited to personal safety and property protection.
- Your explicit request or agreement.
4.3.2. We cannot control how personal data is used or shared in case Blanch Music will be involved in
- A company merger, sale or acquisition;
- Bankruptcy or Receivership;
- LINKS TO EXTERNAL WEBSITESOur websites and services may include hyperlinks to external websites. Privacy Policies and Data protection policies by any such external website are not covered under this Policy. Blanch Music will not take any responsibility or liability for any such external websites. Users and Visitors are requested to read and understand any such external website policies prior to engaging, submitting, entering and sharing any personal data with or on such external websites.6. SECURITY OF YOUR INFORMATION
Please be aware that the internet is an ever changing environment and that it is very difficult to guarantee a fully safe and secure infrastructure.
However, we aim to use the highest possible structural, organisational, administrative and technological procedures and security standards to protect personal User and Visitor data.
In case Users or Visitors experience a breach of security or feel that personal data has been processed, used or shared illegally through our services or systems, or if there was an illegal log-in into a User account, please inform Blanch Music immediately via the Contact page…
In case we notice a security breach on our systems and services, we will inform Users and Visitors as soon as possible via provided contact information including email, text or postal letter (only if absolutely necessary). Users and Visitors are entitled to receive a letter by post in which case we kindly ask you to contact us. Users and Visitors also have the right to withdraw their consent after any such security breach.
We hereby urge all our Users and Visitors not to click on links or share any log-in information with anyone. Emails that come form our services are clearly sent from our domain: email@example.com. Always check and verify the email sender by hovering over links and sender details.
Also make sure to use strong and unique passwords with a minimum of 12 characters including lower case, upper case letters, numbers and symbols.
- RETENTION OF USER DATA7.1. General
Blanch Music only retains user data for the required period of time that is necessary to comply with any legal regulations.
For any user data that is in relation to music lessons we will retain any learner data for a maximum period of 2 weeks after termination of services unless Users opt and consent to a “pause account” option which is useful in case users intend to pause their services and will come back after a certain period. In any such case, we retain user data for a maximum of 1 year.
For financial records this includes the full name and a booking reference for a period of a full 7 years for any monetary transaction. This period may be extended if applicable laws change and a longer retention period is necessary or allowed by law.
Please note, ALL personal data will be deleted and unretrievable forever after the indicated deletion periods.
- DATA COLLECTION OF MINORS UNDER 18 YEARSAs an educational institution we collect certain data from children and minors under 18 years. Any such information can only be submitted by their legal parents or guardians and include the following:
- first and last name of minor;
- age (not the date of birth);
- optional: special needs, medical attention & useful information
- optional: email address of minor;
- lesson related notes, assignments and homework;
- Lesson Progress, Attendance and Punctuality;
- Exams, Grades and Certificates.
In case a user, especially parent or guardian notices that a minor has entered data and shared personal information with our services please inform us immediately. Likewise, if we notice any information or personal data being submitted by a minor we will inform parents or legal guardians immediately if possible.
9. INTERNATIONAL USE OF DATA & DATA TRANSFER
Blanch Music is located in Ireland/EU and therefore complies with EU data protection laws.
Users and Visitors located outside the EU agree, understand and consent to the terms of this Policy.
Some personal data may be transferred, stored and processed outside the EU as we use third party data processors and their services as described in paragraph 4 of this Policy. Please be aware that countries outside the EU may not have a similar high level of data protection.
Data processors are sourced by us and we only select data processors which are GDPR compliant. In case a data processor is located outside the EU, we request and file a DPA from any such data processor.
Visitors and Users agree to any data transfer and data storage and processing for the purpose of using the Blanch Music Services.
- SENSITIVE DATANEVER submit, send, disclose, post, email, text any sensitive data to us or any of our services, including but not limited to: PPS number, Social Security Number, Bank Account Number, Passwords, Health Records, Passports, IDs, Religious or politicial opinions or beliefs, ethnic or racial origins, criminal records.
In case you apply for a job with Blanch Music or become an employee we will conduct a full gardai vetting. We will also ask all employees to take complete a certified child protection training course.
- USER & VISTOR RIGHTSUsers and Visitors have the right to:
- Opt out, cancel or unsubscribe at any time of any of our services including:
- Music lessons;
- Marketing campaigns;
- Collection Of Sensitive Data;
- Data Transfer to any third party data processors;
Users must be aware that opting out of 11.1.a and 11.1.d will make the use of our Services impossible.
- Access any personal data that we collect on the User account page or by contacting us.
- Update or Amend any personal data.
- Move any personal data to another institution that offers the same Services as we do by contacting us directly.
Delete or erase any current, old or incorrect data. Users must be aware that opting out of 11.1.a and 11.1.d will make the use of our Services impossible.
Users or Visitors that intend to execute any of these rights are asked to contact us directly by clearly identifying the following:
- Account name;
- Exact personal data the request is referring to;
- Which right you intend to exercise (see 11.1. – 11.4.).
We will always verify requests by means of direct contact via the submitted contact details and may need to verify a User Identity before completing any such request.
If permitted by law or failure to verify a User’s identity, we may not execute your request if we feel it is legally necessary.
We aim to complete your request as soon as reasonably possible but no later than 30 days after the request has been approved after verification. Users must be aware that we are legally required to retain certain information as outlined in paragraph 7 of this Policy.
- FEEDBACK, NOTIFICATIONS & COMPLAINTSIf you like to give us any feedback, notify us about any issues or file a complaint regarding your personal data, please contact us. We aim to complete and resolve any complaints as soon as possible, but no longer than 30 days. In case User complaints have not been resolved appropriately, Users have the right to get in touch with their local data protection authority.
- POLICY CHANGESFrom time to time we may implement changes to this Policy. Any such changes will be published on this page of our website and Users will be asked to review this Policy on a regular basis. Users will be notified by email or within a notification in their User account dashboards or on our website should we make any substantial Changes to this Policy.
- CONTACTFor any questions, comments, complaints, feedback please contact us directly:
Blanchardstown School Of Music & Shop Limited
1st Floor, Unit 3, Coolmine Industrial Estate
4 6 0 9 3 5