Universal Music Limited (“UM” or “we”) respects the privacy of the individuals it deals with, and is committed to complying fully with its obligations under the Personal Data (Privacy) Ordinance, Cap 486 Laws of Hong Kong (“the Ordinance”). “Personal data” is any data relating directly or indirectly to an individual from which it is practicable for the identity of the individual to be ascertained.
This Policy outlines the types of personal data UM collects and explains how it collects, uses, discloses and holds that data. The Policy also explains how you can gain access to personal data that UM holds about you and provides contact details for UM. Finally, the Policy sets out the way UM handles personal data online (i.e. on the internet).
UM is one of the largest producers and distributors of entertainment goods and services. For the purposes of this Policy, these are referred to as “our goods and/or services”.
The primary purpose for which UM collects personal data is so that we can provide you with our goods or services and provide you with information in relation to our goods or services. UM also uses your personal data for purposes incidental to these purposes including, without limitation, for the purpose of managing its relationship with you, communicating with you effectively and identifying which of our goods and services may interest you in the future.
UM does not collect information or data it does not need. For example, UM does not collect sensitive information (such as information about your health or political beliefs) because it does not need it in order to provide you with our goods or services.
If you ask UM to provide you with our goods or services (including signing up to join one of its clubs, submitting a competition entry form, or choosing to receive promotional information), UM may ask you to provide your name and contact details such as telephone number, postal address and email address. UM may also ask you for additional information including, but not limited to, your age and entertainment preferences (e.g. what type of music you prefer).
You can refuse to provide UM with the personal data that it requests from you or you can refuse to allow UM to continue to use the personal data that it has collected from you. However, if you do not provide UM with the personal data it requests or refuse to allow UM to continue to use your personal data, UM may not be able to provide you with our goods or services.
If at any time you do not wish to be notified about goods, services or promotions offered by UM, or if you do not wish to receive any further communications from UM, you can opt-out of any, or all, UM communications by directly contacting UM. Further, if at any time you wish UM to stop using your personal data, you can contact UM. Details of how to contact UM are set out in section 9 below.
UM collects personal data in a number of different ways. The most common ways in which UM collects personal data, and the purposes for which that data is collected, are as follows:
Personal data is collected from application forms (including on UM websites) when individuals apply to become members of clubs run by UM. This data is collected for the purpose of providing news, information, offers and other services to members in accordance with the terms and conditions of the club.
Personal data is collected from competition entries and other promotions, for the purpose of running the competition or promotion and contacting the winner(s), and, if entrants/applicants do not tell UM otherwise, for the purpose of sending information, news and offers in relation to our goods and services.
Personal data is collected from order forms when UM’s goods and services are ordered by distributors and retailers, for the purpose of fulfilling the order and delivering the goods, and to maintain its relationship with the individual concerned. Personal data collected in this context may include credit, charge or debit card details. If you provide this additional credit information it will only be used for the purposes of purchasing our goods or services.
Personal data is collected from online order forms when UM’s goods or services are ordered by individuals, for the purpose of fulfilling the order and delivering the goods, and to maintain its relationship with the individual concerned.
Personal data collected in this context may include credit, charge or debit card details.
Personal data is collected from telephone, email, written and in-person enquiries directed to UM, for the purpose of responding to the enquiries.
Personal data may be collected from UM websites through automatic processes such as cookies, as discussed in section 8 below.
Generally, UM will not disclose personal data to individuals or organisations outside UM without your consent. However, in the circumstances described below, personal data may be disclosed outside UM.
From time to time, UM may provide information to other companies within the UM and to other companies outside the UM that perform certain functions on its behalf. Any personal data transferred between UM companies in such circumstances will be handled in accordance with this Policy. UM may also disclose personal data to third parties to whom it contracts out specialised functions (e.g. mailing houses, printing companies and event organisers). For example, when UM conducts a promotion, it may enter into a contractual arrangement with a mailing house, which will be subject to a contractual obligation to distribute on UM’s behalf information about its products, services or promotions. If UM does disclose personal data to third party contractors under outsourcing or contracting arrangements, UM will take steps to ensure that those contractors:
handle your personal data consistently with this Policy (regardless of whether they are a small business, or would otherwise be exempt from the Ordincance );
only use your personal data in order to provide the specific services or to perform the specific functions required by UM; and
store your personal data securely, and only for as long as is necessary to provide the required services or perform the required functions.
(b) Disclosures required or permitted by law
UM may also disclose personal data to individuals, corporations, organisations or governmental authorities without your consent if it is required to do so by law, by order of court or if the disclosure is permitted under the Ordinance.
(c) Disclosures to credit providers and credit-reporting agencies
If you purchase our goods or services, UM may disclose personal data to credit providers for credit related purposes such as credit-worthiness, credit rating, credit-reporting and fraud-checking. If we disclose your personal data to credit providers you acknowledge that this information may be recorded on the credit information file that the external credit provider may maintain about you.
(d) Transfer of personal data overseas
From time to time UM transfers personal data to overseas companies, both in the Universal Music group of companies and externally. For example, this may occur in the course of booking overseas tours for artists contracted to UM, or when we store personal data about customers, club members and competition entrants on servers that are hosted by a Universal Music company or an external offshore company.
If UM does transfer your personal data overseas, we will take steps to ensure your personal data is given the same privacy protection in the destination country.
(e) Personal data that you communicate or publish via UM websites
UM recommends that you do not publish or communicate personal data accessible to the public via UM websites unless you want that data to be seen by others.
Should you choose to publish or communicate personal data, or select features on UM websites that allow you to display, publish or communicate personal data about yourself to the public via UM websites, you acknowledge that UM cannot control the use of such personal data by others.
Under the Ordinance, you generally have a right to seek access to the personal data that UM holds about you and the purpose/s for which it is being held. However this Policy provides that there are some circumstances in which it is permitted or required to withhold access to some or all of that personal data. If UM denies you access based on any of the exceptions set out in this Policy it will endeavour, where appropriate, to inform you of the exception under which the denial falls.
You also have the right to ask UM to correct personal data about you that you think is inaccurate, incomplete or out of date.
If you wish to exercise your right under the Ordinance to seek access to the personal data UM holds about you, UM asks that you make a request in writing to its Privacy Officer (contact details are set out in section 9 below). Your request should state whether you are seeking access to all the personal data UM holds about you or to particular personal data (in which case you should specify that in your request). You should also provide some form of identification (e.g. a photocopy of your driver’s licence or passport) so UM can verify that you are the person to whom the personal data relates. You should also include details of how UM can contact you in case it needs to discuss your request. If you need more information before making a formal request for access, please contact UM’s Privacy Officer, who can explain how UM will handle your access request and assist you in making that request.
UM will assume (unless you tell it otherwise) that your request relates to UM’s current records about you. These current records will include personal data about you which is included in UM’s databases and in paper files, and which may be used by UM on a day to day basis. To provide you with access to current personal data, UM will ordinarily provide you with a print-out of the relevant personal data from its databases, or with photocopies of records which are held only on paper files. If personal data about you (e.g. your name and address details) is duplicated across different databases, UM will generally provide you with only one printout of this data. Ordinarily, UM will not charge you for the cost of providing this type of access to its records, and it will generally respond to access requests of this type within 30 days of receiving your request.
For legal and administrative reasons, UM may also store records containing personal data in its archives. You may seek access to the records held by UM which are not current records, but if you do so, UM may charge you for the cost of providing access. It may also take UM longer to respond to your request. Please contact the Privacy Officer to discuss your requirements.
If you think that any of the personal data UM holds about you is not accurate, complete or up to date, please provide UM’s Privacy Officer with your request for correction (contact details are set out in section 9 below). It is UM’s policy to consider and respond to any requests for correction within 30 days of receiving the request.
If UM agrees that your personal data is not accurate, complete and up to date, UM will correct it for you. If it does not agree with your view, UM will provide you with reasons for its view, and will provide you with an opportunity to make a statement of your view and have it included with the information.
UM takes reasonable steps to protect the personal data it holds and controls from such risks as loss, misuse, unauthorised access, destruction, modification or disclosure. The means of protection UM uses includes, but is not limited to firewalls, password access, secure servers and encryption of credit card transactions. UM only allows authorised personnel to access personal data, and it is a condition of employment with UM that its employees maintain the confidentiality of personal data.
UM cannot guarantee the security of online transactions and communications sent by electronic means or post. You are responsible for ensuring the confidentiality and security of, and for all activities which occur under, any username and/or password assigned to you by UM for the purpose of providing our goods or services and any purposes incidental to the provision of our goods and services (including without limitation any unauthorised use of your credit card).
Unless a legal requirement requires otherwise, if UM no longer requires the personal data it has collected from you for the purpose for which it was collected, it will take reasonable steps to destroy or permanently de-identify your personal data .
(a) Online collection of personal and non-personal data
As outlined in section 3 above, UM collects personal data through UM websites when you sign up to join one of its clubs or when you contact UM through its online enquiry forms.
UM websites may also collect other information that may or may not be personal data. Each time you visit a UM website, its server automatically recognises and stores your “address” (e.g. your domain name or internet protocol address), the type of internet browser you are using, the address of the site that “referred” you to UM websites and clickstream data.
(b) Links to other websites
by telephone: (852) 2301 5888;
by facsimile: (852) 2301 4629;
by email: email@example.com; or
by letter: Level 28, Millenium City 6, 392 Kwun Tong Road, Kwun Tong, Kowloon, Hong Kong SAR.