1. Introduction

 

The current legal requirements for website cookies and similar technologies stem from the Privacy and Electronic Communications (EC Directive) Regulations 2003 and, as of 25 May 2018, from the European General Data Protection Regulation 2016 (“GDPR”).

 

Privacy online is of great importance, all the more so in light of the GDPR which represents the single greatest step forward in privacy legislation since the Data Protection Act of 1998; a piece of legislation which was crafted before the advent (or at least the rise) of many forms of data collection and usage that are commonplace today, particularly online.

 

Privacy in general is also increasingly an important issue for internet users who are increasingly concerned that their data is being commodified largely without their permission or knowledge. This is not only important from a legal standpoint, but also from a business one. By complying with the law, not only is your business safe from penalties – particularly the tough ones introduced by the GDPR – but it is also likely to engender a greater degree of trust from its customers.

 

Central to the laws which govern cookies and similar technologies is the issue of consent. The law does not say that you cannot use cookies, trackers, beacons and so on. Rather, it requires that, in many cases, you must only do so with users’ permission. Current common practice is to simply inform users that your website uses cookies with their continued use of the site being taken as consent. As will be seen below, this is no longer sufficient. Users must be properly informed, must be given a genuine choice, and must give some kind of explicit indication of their consent.

 

 

1.1       Cookies and Similar Technologies

 

While most guidance focuses on cookies (indeed, the laws governing such technologies are commonly collectively referred to as “cookie law”) it is important to note that the law does not only govern cookies. A number of technologies may be used in a similar way, such as local shared objects (also known as “flash cookies”), web beacons, clear gifs, page tags, and web bugs. References to “cookies” in these Guidance Notes should be taken as also referring to these similar technologies. As technology develops quickly, the law could not keep up if it limited itself in scope to particular terms of art.

 

 

1.2       The Law’s Purpose

 

Simply put, the law aims to protect the privacy of internet users. The GDPR extends this protection due to the far greater scope of its definition of “personal data”. It may not be immediately obvious that a cookie or the data within it qualifies as personal data; however, where a cookie can identify an individual via their device, even if identification can only be made by combining the data in question with other data, it will fall within the definition. The rule of thumb we would suggest, then, is to err on the side of caution and treat all cookies and similar technologies in the same manner.

 

Those operating websites within the EU (even if the website itself or its operator/owner is based outside of the EU) are required by law to do the following:

 

  • Inform users about the purpose of the cookies that their website places and stores on users’ computers or devices; and
  • Obtain users’ consent before placing and storing those cookies.

 

 

1.3 Why Have This Law?

 

It is an inescapable truth that as regulations limiting the use of cookies and similar technologies get stricter, they become more of an impediment to business. Indeed, tougher consent requirements stand to negatively impact a number of things including behavioural advertising and the ability to track and analyse people’s use of your website.

 

A reasonable question to ask is why the cookie controls built into internet browsers cannot be relied upon for consent. Users are, after all, free to block cookies using browser settings or, for the more technically aware, browser extensions. The problem with such settings, however, is that many users are unaware of them. Furthermore, not all browsers are created equal and the sophistication of cookie and privacy settings varies considerably, often not providing sufficient levels of control. A user might want to stop you from tracking their use of your website, for example, but not prevent their login details and shopping basket contents from being saved. Even a browser that allows users to pick from blocking third-party cookies or blocking all cookies would not provide sufficient control in this scenario of your tracking was done using first-party cookies.

 

Proposals are afoot to address this state of affairs and were originally planned to come into force alongside the GDPR on 25 May 2018; however, at the time of writing the legislation in question remains in draft form and is still working its way through the European Union legislative process. Of particular interest is a new requirement imposed on the makers of web browsers to incorporate better controls — controls that would, in theory, eliminate the need for the consent mechanisms outlined below — however, until the legislation is finalised and browser makers have been given sufficient time to implement improved controls, the burden remains on the operators of websites to obtain consent from users proactively.

 

 

2. What Do I Need to Do?

 

The answer to this question depends largely upon what cookies you use on your website and for what purpose or purposes. The most effective way of identifying cookies (and similar technologies, remember), their functions, and indeed their importance, is to conduct a thorough cookie audit. This may also provide a useful opportunity to re-evaluate your use of cookies and their real value to your business.

 

 

2.1 Know Your Cookies

 

Before we move on to lay out the steps of a cookie audit, it important that you understand the different types of cookie.

 

2.1.1 Strictly Necessary Cookies

A cookie falls into this category if it is essential to the operation of your website. Strictly necessary cookies may, for example, be required for functions such as logging in, storing items in a shopping basket, or enabling payment transactions.

 

2.1.2 Analytics Cookies

Understanding how users use your website can be extremely valuable. Analytics cookies provide insights into many factors such as how users are navigating around the site and what features they are using. Analytics cookies may often be set by third parties, but not always. To add to complications, however, even if analytics cookies are set by you, if the data collected by them is processed by a third party, they will be treated differently from a data protection perspective.

 

2.1.3 Functionality Cookies

Many websites offer some level of personalisation and functionality cookies play a key role here. For auditing purposes, however, it is important not to confuse these with the strictly necessary variety. If the site can be used properly without the cookie, it isn’t strictly necessary.

 

2.1.4 Targeting Cookies

It is important to know when and how often someone visits your website, and which parts of it they have used (including which pages they have visited and which links they have followed). As with analytics cookies, targeting cookies allow you to better understand your users, enabling you to make your site and, more importantly, the advertising on it more relevant to those users’ interests. Targeting cookies may often be set by third parties.

 

2.1.5 First-Party Cookies

As the name suggests, these cookies are placed directly by your website (as opposed to those placed by third-party services, for which see below). Most, if not all, of your strictly necessary and functionality cookies will likely be first-party cookies.

 

2.1.6 Third-Party Cookies

These cookies are placed by third parties providing services such as advertising and analytics. Analytics and targeting cookies are common types of third-party cookie as such work is often not undertaken in-house.

 

2.1.7 Persistent Cookies

Any of the cookies listed above may be a persistent cookie. Persistent cookies are those which remain active on a user’s computer or device for a predetermined period of time and are activated when that user visits your website.

 

2.1.8 Session Cookies

Any of the cookies listed above may be a session cookie. Session cookies are temporary and only remain on a user’s computer or device from the point at which they visit your website until the web browser is closed, at which point they are removed.

 

 

2.2 The Cookie Audit

 

A cookie audit will help you to identify the cookies that are used by your website, what those cookies are doing, what type of cookies they are, how long they remain on a user’s computer or device, what personal data they collect, and whether or not they are being used in compliance with the law.

 

2.2.1 What Cookies Am I Using?

Begin by listing all of the cookies (yes, and similar technologies) currently used on your website. If you don’t know what cookies you are using, your web developer should be able to provide a list. Alternatively, a number of tools – free and otherwise – are available online.

 

2.2.2 What Do My Cookies Do?

For each cookie in your list, make a note of what it is used for. It is important that you are clear about each cookie’s function as this will assist in the next step.

 

2.2.3 What Types of Cookies Am I Using?

Going through the list again, identify what types of cookie are at work on your website. Refer back to the list above for guidance. Identify whether each cookie is first or third-party; whether it is a persistent or a session cookie; and whether it is strictly necessary, for analytics, functionality, or for targeting.

 

2.2.4 How Long Do My Persistent Cookies Last?

If you use persistent cookies, it is important to take note of their duration. Persistent cookies are considered to be more privacy-intrusive than session cookies, so for each one, consider whether its lifespan is truly necessary for the cookie’s purpose and shorten that lifespan if it seems excessive.

 

2.2.5 What Data Do My Cookies Collect?

Not all cookies collect and store personal data, but some do and in light of the GDPR it is more likely now that data used by cookies will be defined as “personal data”. In addition to the obvious – name, email address etc. – IP addresses and other seemingly anonymous identifiers qualify under the GDPR. As noted above, even an anonymised identifier that does not identify an individual on its own can count as personal data if it can be combined with other data and used to identify someone. If your cookies do use personal data, you will be processing personal data and must, as such, ensure that you comply with the requirements of the GDPR.

 

2.2.6 Are My Cookies Legal?

Keeping your own first-party cookies under control is important, and in addition to obtaining the correct consent to use them (see below), if any personal data is involved, it is crucial to comply fully with the GDPR. Moreover, if you use third-party cookies, while control over them rests (at least to a point) with the third party providing them, they are still being used on your website. It is therefore important to ensure that the third party or parties involved are also complying with the law.

 

2.3 Information and Consent

 

2.3.1 Informing Users

 

One of the most important principles of the GDPR focuses on transparency. Where personal data is concerned (and remember, this can include cookies), it is vital that individuals know what data you hold about them and what you are doing with it. It is only after being provided with such information that users can give you their informed consent.

 

It is a good idea to start with a clear, simple explanation of what cookies are and what they actually do. Many users will have heard of cookies, but they may not know a great deal about them. Consider, for example, including an explanation of the different cookie types similar to that included above in these Guidance Notes.

 

Even if you are only using strictly necessary cookies, it is important that users are fully informed about what you are doing. You may not need consent to place strictly necessary cookies, but that does not mean that you can avoid telling users about them. If you have reason to hide them, it is worth re-evaluating whether they are in fact strictly necessary after all. The general rule is, the more prominent your information, the better. Another general rule is to keep things simple; the average internet user does not possess a high degree of technical knowledge so using user-friendly, straightforward language in your cookie information is always advisable. Some websites tend to go a little overboard with friendly, fuzzy, humorous language, but this does have the benefit of downplaying the perception that cookies are little more than spyware rather than being the useful, innocuous little files that they (usually) really are.

 

Your cookie information should enable users to fully understand the functions of the various cookies placed by your website, what effect they will have on users, and in particular, what personal data is involved. In situations where cookies are used to provide useful information to you, such as analytics cookies, it may also be worth explaining how they benefit the user. Your explanation should be positive rather than negative. It is thus preferable to say something like:

 

“By seeing how you use our website using analytics cookies, we are better able to understand our customers and continually improve our services.”

 

as opposed to:

 

“If you do not accept our analytics cookies we will not be able to improve our services as we will be unable to track your movement and activity around our website.”

 

Put simply, tell your users why accepting your cookies is good for them, rather than why their refusal to accept them is bad for you.

 

Another useful element to include in your information is a table listing the cookies you use, what each one does, and what information it collects. Again, try to use user-friendly terminology as much as possible.

 

 

 

 

2.3.2 Where Should I Put My Information?

 

The key word here is “prominence”. Burying a brief mention of cookies in your privacy policy is not the best way to attract attention. That being said, the increased importance of transparency and consent under the GDPR also means that your privacy policy should be similarly prominent.

 

It is a good idea to bring cookies directly to first-time visitors’ attention, along with a request for consent to use cookies (where appropriate) and this is something we’ll go into in more detail below. Because your information and consent mechanisms (also see below for more information) should be presented together, it is important that it is available at all times. A prominent link on every page of your website, therefore, is the preferable route.

 

While it is a matter of taste to an extent, the separation of cookie information from your privacy policy is also important. Once again, the increased importance of consent and controls plays a part here. It is advisable to separate out your privacy policy and cookie information (or at least the links to them by linking directly to the cookie section of your privacy policy, for example). Not only does this help with prominence, but it also makes it easier for non-technical users to find what they are looking for.

 

2.3.3 Consent

 

Consent is one of the key features of the GDPR and an area in which stricter standards have been applied. Implied consent has, for quite some time, been a popular method of obtaining users’ permission to use cookies. A common method prior to the GDPR has been to provide users with information about cookies, informing them that their continued use of the website will be taken as consent to the use of those cookies. Controls have also been decidedly inconsistent.

 

This does not necessarily mean that users must be given control over every single cookie that you wish to use. Strictly necessary cookies are still acceptable. The GDPR itself in reality says very little about cookies and related technologies. The Privacy and Electronic Communications (EC Directive) Regulations 2003 are more focused on such matters, as is the forthcoming Regulation on Privacy and Electronic Communications (commonly referred to as the “ePrivacy Regulation”). It is important to note that, at the time of writing, the ePrivacy Regulation remains in draft form and is still being debated and amended by the various EU lawmaking bodies. It is intended to come into force at the same time as the GDPR (25 May 2018) however this is currently thought to be quite unlikely with some legal experts suggesting that it may not see the light of day until 2019. These Guidance Notes will be updated as more information becomes available. It is nevertheless helpful to be aware of the Regulation as it provides some insight, even as a draft, into what will and will not be acceptable in the future. Under the most recent draft available, if a cookie (or related technology) is “necessary for providing an information society service requested by the end-user” (i.e. your website or the service it provides), it is acceptable.

 

Can I Rely on Implied Consent?

 

Implied consent is no longer a sensible option in a GDPR world. Users must now take some affirmative action in order to indicate consent. Moreover, this must take place before any cookies are placed.

 

Can I Rely on Browser Settings?

 

This is a difficult question at present. The general advice has long been that relying solely on users’ browser settings is not a sensible idea. As has already been noted, many users do not possess sufficient technical knowledge or awareness. This, therefore, makes relying on browser settings for genuine consent a highly flawed method.

 

There is nothing, of course, to stop you from providing additional advice to your users on adjusting their browser’s privacy settings; however, reliance on those settings alone is not recommended.

 

This is a position that may change in the future under the aforementioned ePrivacy Regulation which is currently designed to impose new obligations on the makers of web browsers to the extent that, eventually, browser settings could be sufficient. It is very important, however, to note that this is not currently the law and that browser settings are not currently sufficient. Do not rely on them!

 

What About Affirmative Consent?

 

This, if it is not already clear by now, is by far the best way. It leaves no room for doubt, either on your part, on your users’ part, or on the Information Commissioner’s part, meaning that it is safest for everyone.

 

It is important that users are given a real choice. As has already been noted, it is no longer acceptable to simply tell users that by continuing to use your website, they are agreeing to accept your cookies. An important concept under the GDPR is known as “granular consent”. In practice, this means giving users more finite control over what their data is used for. You are not expected to enable users to prevent your website from letting them log in, store items in an online shopping basket etc. but you are expected to allow them to be selective. If, for example, your website offers additional personalisation features that are not essential to its functionality, but still make for a better user experience, it is not in your interests, or your users’ interests, to turn these off alongside, say, analytics cookies. Consider, therefore, breaking your cookies down into categories and providing separate opt-in and opt-out controls for each category. It is also important to keep in mind that it should remain possible for users to use your website in some way, even if they do not consent to your use of cookies.

 

It must also be easy for users to change their preferences later on. A popup that appears the first time a user visits your site, never to be seen again, is unlikely to deliver here. A first-visit popup is still a good idea for catching users’ attention, however the settings must remain easy to find on subsequent visits.

 

A further important point is keeping users aware of their privacy settings. It is good practice to apply this not only to cookies, but also to other user data such as personal information stored, for example, in a user’s account or profile on your website, and with respect to direct marketing preferences. Consider, therefore, a yearly email or other message to each user (where possible) reminding them to check their settings, including cookies.

 

It is undeniable that stricter consent requirements will be more onerous; not only for you as a business, but also for your users. Popups laden with information and asking for controls to be adjusted can often be annoying to users, but it is nonetheless important to comply with your obligations under the law and to help safeguard users’ rights, even if they might be unaware of them. The key, therefore, is to make the whole experience as unobtrusive and efficient as possible, while also maintaining sufficient prominence to avoid it being missed.

 

 

2.4 How Should I Do It?

 

Depending upon the types of cookies you use, and the purposes you use them for, you have various options that will assist in complying with the law. Some methods will be more suitable than others, and it is always important to remember that if you use anything more than strictly necessary cookies, you will need to give users a genuine choice and the ability to opt-in or opt-out not only before your website places any cookies on the user’s computer or device, but also at any time afterwards.

 

Option 1: Information Banner

 

 

This has been one of the most popular methods of providing cookie information to users thus far. A simple banner at the top or bottom of the (visible) web page provides a brief outline of your use of cookies and similar technologies along with a link to more detailed information. Note also the “about cookies” link in the navigation.

 

This option has the benefit of simplicity; however, it does not provide any form of control, only information. It is therefore only suitable for websites which use strictly necessary cookies alone — those without which the website would not function correctly for users.

 

 

This version of the banner adds simple opt-in / opt-out controls. This may be suitable where only a few cookies are used, particularly if they are of the same category. Care should nevertheless be taken with simple controls as they risk forcing users to disable functions that are still useful to them in order to disable those that they do not like; and forcing you to forego useful functions such as analytics. As above, note the presence of the “about cookies” link, helping to provide the ease of controlling cookies as users continue to use your website.

 

 

The approach taken here in this third evolution of the banner incorporates the so-called granular approach referred to above. Users are given essential information about cookies, with a link to more details, along with controls over each category of cookie. Strictly necessary cookies are noted, but no control is given; functional cookies can be turned on or off; and performance cookies (a friendlier name for analytics, in most cases) can also be turned on or off. Of the three banner options, unless your website only uses strictly necessary cookies, this should be the preferred option for legal compliance.

 

Option 2: Information Popup

 

 

In this scenario, a popup takes over the screen and provides the same details as the information banner. Popups can be more effective than banners when it comes to grabbing users’ attention as they require at least some kind of interaction from the user in order to get past them and return to the main features of the website, even if this is only clicking on a button or on an area of the screen outside of the popup’s border. In extreme cases, the website behind the popup could be effectively disabled until the user acknowledges the popup.

 

As with the information banner, however, keep in mind that this option is only suitable for strictly necessary cookies where you are not required to provide controls.

 

 

Once again, the popup approach here has the benefit of catching users’ attention. In addition, as with the information banner with controls, it provides a simple opt-in or opt-out choice. However, also as with the banner approach, offering such basic binary controls may often be undesirable.

 

 

As with the information banner with sophisticated controls, this choice has the benefit of granularity. Users are given more information and more control over how cookies and, by extension, their data, are used. As a popup, rather than a banner, this option also has the advantage of more space in which to provide information. Of the popup options, unless your website only uses strictly necessary cookies, this should be the preferred option for legal compliance.

 

 

 

 

Option 3: Settings or Feature-led Consent

 

 

This approach may be attractive if your website does not use cookies from the outset, but instead only uses them when a user wishes to use certain features — personalisation, in this case. Information can be provided and consent obtained at the time that a user wishes to use the relevant features. Despite the fact that such features may not work without cookies, unless they can be reasonably categorised as strictly necessary, users must remain free to refuse them, even though that may mean missing out on certain features.

 

Which Option for Me?

 

There is not necessarily a right or wrong answer to this question, however it remains important to emphasise that unless you are only using some basic, strictly necessary cookies that underpin the vital functions of your website, it is essential to get users’ express consent to cookies before placing them. As noted above, the GDPR expands the definition of “personal data” considerably over and above that under the Data Protection Act 1998. Data contained in cookies and similar technologies that might not qualify as personal data under the 1998 Act, or even by any conventional understanding, may well be caught by the GDPR. Instead of attempting to engage in a complex decision-making exercise to determine whether or not a particular cookie does or does not fall under the GDPR’s remit, it is, we would argue, preferable to treat all cookies alike and get users’ prior express permission to use them. Even if strict compliance with the letter of the law may not appear necessary, compliance with the spirit of the law and its push for improved transparency and user-led consent can surely only stand your business in good stead.

 

 

3. A Word On Advertising and Analytics

 

Many analytics and advertising services are provided by third parties and many use cookies and similar technologies in order to function. In many cases, advertising is often now provided with its own privacy controls and opt-out tools. AdChoices, for example, is a self-regulatory programme with hundreds of participants including major advertisers. Ads served up by AdChoices include controls enabling users to control related cookies.

 

The online advertising and tracking world is in a constant state of flux and it is expected by some that the GDPR, and the accompanying emphasis on consent and transparency, could herald a significant shift in how such technologies work, not least because asking for someone’s permission to “track” them and feed them advertising is unlikely to go down well.

 

Wherever possible, the importance of prior consent must be remembered. Placing cookies when a user first arrives on your site and getting permission after the fact is not true consent at all. At the very least, a detailed, user-friendly explanation should be provided. If you track users’ activity around your site for performance purposes using, for example, Google Analytics, explain the benefits to you and to your users. If your site serves up advertising, explain the benefits of allowing behavioural tracking here too — namely that users see ads that are more relevant to their interests and, therefore, less annoying and intrusive.

 

As the new world of the GDPR settles into reality (not to mention the forthcoming new world of the aforementioned ePrivacy Regulation) it is likely that providers of third-party services such as analytics and advertising will change the way in which their services work. For now, as the owner and/or operator of a website that employs such services, your job is to ensure that you are doing whatever you can to comply with the law and, at the risk of excessive repetition, this means keeping users as informed as possible, and getting their consent to use cookies and similar technologies that go beyond the strictly necessary category.

 

4. Conclusion

 

The collective bundle of requirements known as “Cookie Law” represents something of a thorn in the side for website operators. Indeed, when the so called “EU Cookie Law” first came into force in 2011, many website operators were unhappy, arguing that nobody particularly complained about cookies. What is evident, however, is that the lack of complaint was more down to a lack of knowledge and understanding among users than it was down to users being happy. It is quite possible that many still do not know or understand a great deal about the technology — simply clicking the close button or the “I agree” button and continuing to use the website in question. Meanwhile, at the other end of the scale, with the rise in the availability and popularity of browser extensions such as AdBlock and Ghostery, the more tech savvy user is quite clearly unwilling to let you or your cookies into their system or their personal data to any degree greater than is absolutely necessary for them to use your website. Some try to fight against these forms of user-centric controls, but we would argue that it is perhaps preferable to take the hint and address the reasons for their existence rather than trying to disable their effect (a course of action which is unlikely to meet with success for long anyway as the developers of such extensions frequently update them to address workarounds).

 

The current state of play, it must be said, is not perfect. Indeed, the increased emphasis on consent alone is set to make things more onerous for website operators and for users. More interruptions will be necessary to the user experience and users will need to read and do more before getting on with the business of using your website. Things are set to change again in the future, but for now, this is the approach that should be taken. These rules do, despite such annoyances, have honourable roots in seeking to increase and protect individuals’ rights to privacy and ultimately, it is to be hoped, there is more to be gained by complying than by resisting.

  1. Purpose
    • UNDRGRND Network (“the Company”) is committed to the practice of responsible corporate behaviour and to complying with all laws, regulations and other requirements which govern the conduct of our operations.
    • The Company is fully committed to instilling a strong anti-corruption culture and is fully committed to compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 (“the Act”) and ensures that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.

 

  1. Bribery
    • Bribery is defined as the giving or promising of a financial or other advantage to another party where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage is in itself improper conduct.
    • Bribery is also deemed to take place if any party requests or agrees to receive a financial or other advantage from another party where that advantage is intended to induce that party to perform a particular function improperly, where the acceptance of that advantage is in itself improper conduct, or where that party acts improperly in anticipation of such advantage.
    • Bribery of a foreign official is defined as the giving or promising of a financial or other advantage which is intended to influence the official in order to obtain business or an advantage in the conduct of business unless the foreign official is required or permitted by law to be influenced by such advantage.

 

  1. Consequences of Bribery
    • Anyone or any organisation found guilty of bribery under the Act may face fines and/or prison terms. In addition, high legal costs and adverse publicity are likely to result from any breach of the Act.
    • For employees of the Company, failure to comply with this Policy and/or with the Act may result in:
      • disciplinary action which may include dismissal; and
      • criminal penalties under the Act which may result in a fine and/or imprisonment for up to 10 years.
    • For the Company, any breach of this Policy by any employee or business associate may result in:
      • the Company being deemed to be in breach of the Act;
      • the Company being subject to fines; and
      • the Company suffering negative publicity and further associated damage as a result of such breach.

 

  1. Responsibility for Compliance and Scope of Policy
    • This Policy applies to all employees, agents, contractors, subcontractors, consultants, business partners and any other parties (including individuals, partnerships and bodies corporate) associated with the Company or any of its subsidiaries.
    • It is the responsibility of all of the abovementioned parties to ensure that bribery is prevented, detected and reported and all such reports should be made in accordance with the Company’s Whistleblowing Policy or as otherwise stated in this Policy, as appropriate.
    • No party described in section 4.1 may:
      • give or promise any financial or other advantage to another party (or use a third party to do the same) on the Company’s behalf where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage will in itself constitute improper conduct;
      • request or agree to receive any financial or other advantage from another party where that advantage is intended to induce the improper performance of a particular function, where the acceptance of that advantage will in itself constitute improper conduct, or where the recipient intends to act improperly in anticipation of such an advantage.
    • Parties described in section 4.1 must:
      • be aware and alert at all times of all bribery risks as described in this Policy and in particular as set out in section 9 below;
      • exercise due diligence at all times when dealing with third parties on behalf of the Company; and
      • report any and all concerns relating to bribery to <<insert position, e.g. line manager>> or, in the case of non-employees, their normal point of contact within the Company, or otherwise in accordance with the Company’s Whistleblowing Policy.

 

  1. Facilitation Payments
    • A facilitation payment is defined as a small payment made to officials in order to ensure or speed up the performance of routine or necessary functions.
    • Facilitation payments constitute bribes and, subject to section 5.3, may not be made at any time irrespective of prevailing business customs in certain territories.
    • Facilitation or similar payments may be made in limited circumstances where your life is in danger but under no other circumstances. Any payment so made must be reported to Aaron Munn | CEO as soon as is reasonably possible and practicable.

 

  1. Gifts and Hospitality
    • Gifts and hospitality remain a legitimate part of conducting business and should be provided only in compliance with the Company’s Gifts and Hospitality Policy.
    • Gifts and hospitality can, when excessive, constitute a bribe and/or a conflict of interest. Care and due diligence should be exercised at all times when giving or receiving any form of gift or hospitality on behalf of the Company.
    • The following general principles apply:
      • Gifts and hospitality may neither be given nor received as rewards, inducements or encouragement for preferential treatment or inappropriate or dishonest conduct.
      • Neither gifts nor hospitality should be actively sought or encouraged from any party, nor should the impression be given that the award of any business, custom, contract or similar will be in any way conditional on gifts or hospitality.
      • Cash should be neither given nor received as a gift under any circumstances.
      • Gifts and hospitality to or from relevant parties should be generally avoided at the time of contracts being tendered or awarded.
      • The value of all gifts and hospitality, whether given or received, should be proportionate to the matter to which they relate and should not be unusually high or generous when compared to prevailing practices in our industry or sector.
      • Certain gifts which would otherwise be in breach of this Policy and/or the Hospitality and Gifts Policy may be accepted if refusal would cause significant and/or cultural offence, however the Company will donate any gifts accepted for such reasons to a charity of Aaron Munn | CEO
      • All gifts and hospitality, whether given or received, must be recorded in the Hospitality & Gifts Register.

 

  1. Charitable Donations
    • Charitable donations are permitted only to registered (non-profit) charities. No charitable donations may be given to any organisation which is not a registered charity.
    • All charitable donations must be fully recorded in gift register.
    • Proof of receipt of all charitable donations must be obtained from the recipient organisation.
    • Under no circumstances may charitable donations be made in cash.
    • No charitable donation may be made at the request of any party where that donation may result in improper conduct.

 

  1. Political Donations
    • The Company does not make political donations and the Company is not affiliated with any political party, independent candidate, or with any other organisation whose activities are primarily political.
    • Employees and other associated parties are free to make personal donations provided such payments are not purported to be made on behalf of the Company and are not made to obtain any form of advantage in any business transaction.

 

  1. Due Diligence and Risks

The following issues should be considered with care in any and all transactions, dealings with officials, and other business matters concerning third parties:

  • Territorial risks, particularly the prevalence of bribery and corruption in a particular country;
  • Cross-border payments, particularly those involving territories falling under section 9.1;
  • Requests for cash payment, payment through intermediaries or other unusual methods of payment;
  • Activities requiring the Company and / or any associated party to obtain permits or other forms of official authorisation;
  • Transactions involving the import or export of goods;

 

TERMS AND CONDITIONS

 

BACKGROUND:

 

These Terms and Conditions, together with any and all other documents referred to herein, set out the terms of use under which you may use this website, www.ugnmusic.com (“Our Site”).  Please read these Terms and Conditions carefully and ensure that you understand them.  Your agreement to comply with and be bound by these Terms and Conditions is deemed to occur upon your first use of Our Site.  If you do not agree to comply with and be bound by these Terms and Conditions, you must stop using Our Site immediately.

 

 

  1. Definitions and Interpretation
    • In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:

 

“Content” means any and all text, images, audio, video, scripts, code, software, databases and any other form of information capable of being stored on a computer that appears on, or forms part of, Our Site; and
“We/Us/Our” means UNDRGRND Network [, a company registered in England under <<insert company number>>, whose registered address is <<insert registered address>> and whose main trading address is] OR [of] <<insert address>>.

 

  1. Information About Us
    • Our Site, ugnmusic.com, is [owned and] operated by UNDRGRND Network [, a limited company registered in England under <<insert company number>>, whose registered address is <<insert registered address>> and whose main trading address is] OR [of] <<insert address>>. [Our VAT number is <<insert VAT number>>.]

 

  1. Access to Our Site
    • Access to Our Site is free of charge.
    • It is your responsibility to make any and all arrangements necessary in order to access Our Site.
    • Access to Our Site is provided “as is” and on an “as available” basis. We may alter, suspend or discontinue Our Site (or any part of it) at any time and without notice.  We will not be liable to you in any way if Our Site (or any part of it) is unavailable at any time and for any period.

 

  1. Intellectual Property Rights
    • All Content included on Our Site and the copyright and other intellectual property rights subsisting in that Content, unless specifically labelled otherwise, belongs to or has been licensed by Us. All Content is protected by applicable United Kingdom and international intellectual property laws and treaties.
    • Subject to sub-Clause[s]3 [and 4.6] you may not reproduce, copy, distribute, sell, rent, sub-licence, store, or in any other manner re-use Content from Our Site unless given express written permission to do so by Us.
    • You may:
      • Access, view and use Our Site in a web browser (including any web browsing capability built into other types of software or app);
      • Download Our Site (or any part of it) for caching;
      • Print [one copy of any] page[s] from Our Site;
      • Download extracts from pages on Our Site; and
      • Save pages from Our Site for later and/or offline viewing.
    • Our status as the owner and author of the Content on Our Site (or that of identified licensors, as appropriate) must always be acknowledged.
    • You may not use any Content saved or downloaded from Our Site for commercial purposes without first obtaining a licence from Us (or our licensors, as appropriate) to do so. [This does not prohibit the normal access, viewing and use of Our Site for general information purposes whether by business users or consumers.]
    • [Nothing in these Terms and Conditions limits or excludes the provisions of Chapter III of the Copyrights, Designs and Patents Act 1988 ‘Acts Permitted in Relation to Copyright Works’, covering in particular the making of temporary copies; research and private study; the making of copies for text and data analysis for non-commercial research; criticism, review, quotation and news reporting; caricature, parody or pastiche; and the incidental inclusion of copyright material.]

 

  1. Links to Our Site
    • You may link to Our Site provided that:
      • You do so in a fair and legal manner;
      • You do not do so in a manner that suggests any form of association, endorsement or approval on Our part where none exists;
      • You do not use any logos or trade marks displayed on Our Site without Our express written permission; and
      • You do not do so in a way that is calculated to damage Our reputation or to take unfair advantage of it.
    • [You may link to any page of Our Site.]OR
    • [You may not link to any page other than the homepage of Our Site, ugnmusic.com. Deep-linking to other pages requires Our express written permission.]
    • [Framing or embedding of Our Site on other websites is not permitted without Our express written permission. Please contact Us at support@thisisunderground.co.uk for further information.]
    • You may not link to Our Site from any other site the main content of which contains material that:
      • [is sexually explicit];
      • is obscene, deliberately offensive, hateful or otherwise inflammatory;
      • promotes violence;
      • promotes or assists in any form of unlawful activity;
      • discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation, or age;
      • is intended or is otherwise likely to threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;
      • is calculated or is otherwise likely to deceive another person;
      • is intended or otherwise likely to infringe (or threaten to infringe) another person’s right to privacy;
      • misleadingly impersonates any person or otherwise misrepresents the identity or affiliation of a particular person in a way that is calculated to deceive (obvious parodies are not included in this definition provided that they do not fall within any of the other provisions of this sub-Clause 5.4);
      • implies any form of affiliation with Us where none exists;
      • infringes, or assists in the infringement of, the intellectual property rights (including, but not limited to, copyright, trade marks and database rights) of any other party; or
      • is made in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.
    • [The content restrictions in sub-Clause 5.4 do not apply to content submitted to sites by other users provided that the primary purpose of the site accords with the provisions of sub-Clause 5.4. You are not, for example, prohibited from posting links on general-purpose social networking sites merely because another user may post such content.  You are, however, prohibited from posting links on websites which focus on or encourage the submission of such content from users.]

 

  1. Links to Other Sites

Links to other sites may be included on Our Site.  Unless expressly stated, these sites are not under Our control.  We neither assume nor accept responsibility or liability for the content of third party sites.  The inclusion of a link to another site on Our Site is for information only and does not imply any endorsement of the sites themselves or of those in control of them.

 

  1. Disclaimers
    • Nothing on Our Site constitutes advice on which you should rely. It is provided for general information purposes only.  [Professional or specialist advice should always be sought before taking any action relating to <<describe type of information/activity to which the website relates>>.]
    • Insofar as is permitted by law, We make no representation, warranty, or guarantee that Our Site will meet your requirements, that it will not infringe the rights of third parties, that it will be compatible with all software and hardware, or that it will be secure.
    • We make reasonable efforts to ensure that the Content on Our Site is complete, accurate, and up-to-date. We do not, however, make any representations, warranties or guarantees (whether express or implied) that the Content is complete, accurate, or up-to-date.

 

  1. Our Liability
    • To the fullest extent permissible by law, We accept no liability to any user for any loss or damage, whether foreseeable or otherwise, in contract, tort (including negligence), for breach of statutory duty, or otherwise, arising out of or in connection with the use of (or inability to use) Our Site or the use of or reliance upon any Content included on Our Site.
    • To the fullest extent permissible by law, We exclude all representations, warranties, and guarantees (whether express or implied) that may apply to Our Site or any Content included on Our Site.
    • [Our Site is intended for non-commercial use only.] If you are a business user, We accept no liability for loss of profits, sales, business or revenue; loss of business opportunity, goodwill or reputation; loss of anticipated savings; business interruption; or for any indirect or consequential loss or damage.
    • We exercise all reasonable skill and care to ensure that Our Site is free from viruses and other malware. We accept no liability for any loss or damage resulting from a virus or other malware, a distributed denial of service attack, or other harmful material or event that may adversely affect your hardware, software, data or other material that occurs as a result of your use of Our Site (including the downloading of any Content from it) or any other site referred to on Our Site.
    • We neither assume nor accept responsibility or liability arising out of any disruption or non-availability of Our Site resulting from external causes including, but not limited to, ISP equipment failure, host equipment failure, communications network failure, natural events, acts of war, or legal restrictions and censorship.
    • Nothing in these Terms and Conditions excludes or restricts Our liability for fraud or fraudulent misrepresentation, for death or personal injury resulting from negligence, or for any other forms of liability which cannot be excluded or restricted by law. For full details of consumers’ legal rights, including those relating to digital content, please contact your local Citizens’ Advice Bureau or Trading Standards Office.

 

  1. Viruses, Malware and Security
    • We exercise all reasonable skill and care to ensure that Our Site is secure and free from viruses and other malware.
    • You are responsible for protecting your hardware, software, data and other material from viruses, malware, and other internet security risks.
    • You must not deliberately introduce viruses or other malware, or any other material which is malicious or technologically harmful either to or via Our Site.
    • You must not attempt to gain unauthorised access to any part of Our Site, the server on which Our Site is stored, or any other server, computer, or database connected to Our Site.
    • You must not attack Our Site by means of a denial of service attack, a distributed denial of service attack, or by any other means.
    • By breaching the provisions of sub-Clauses 9.3 to 9.5 you may be committing a criminal offence under the Computer Misuse Act 1990. Any and all such breaches will be reported to the relevant law enforcement authorities and We will cooperate fully with those authorities by disclosing your identity to them.  Your right to use Our Site will cease immediately in the event of such a breach.

 

  1. Acceptable Usage Policy
    • You may only use Our Site in a manner that is lawful. Specifically:
      • you must ensure that you comply fully with any and all local, national or international laws and/or regulations;
      • you must not use Our Site in any way, or for any purpose, that is unlawful or fraudulent;
      • you must not use Our Site to knowingly send, upload, or in any other way transmit data that contains any form of virus or other malware, or any other code designed to adversely affect computer hardware, software, or data of any kind; and
      • you must not use Our Site in any way, or for any purpose, that is intended to harm any person or persons in any way.
    • We reserve the right to suspend or terminate your access to Our Site if you materially breach the provisions of this Clause 10 or any of the other provisions of these Terms and Conditions. Specifically, We may take one or more of the following actions:
      • suspend, whether temporarily or permanently, your right to access Our Site;
      • issue you with a written warning;
      • take legal proceedings against you for reimbursement of any and all relevant costs on an indemnity basis resulting from your breach;
      • take further legal action against you as appropriate;
      • disclose such information to law enforcement authorities as required or as We deem reasonably necessary; and/or
      • any other actions which We deem reasonably appropriate (and lawful).
    • We hereby exclude any and all liability arising out of any actions (including, but not limited to those set out above) that We may take in response to breaches of these Terms and Conditions.

 

  1. Privacy and Cookies

Use of Our Site is also governed by Our Cookie and Privacy Policies, available from <<insert link to Cookie Policy>> and <<insert link to Privacy Policy>>.  These policies are incorporated into these Terms and Conditions by this reference.

 

  1. Changes to these Terms and Conditions
    • We may alter these Terms and Conditions at any time. [If We do so, details of the changes will be highlighted at the top of this page.]  Any such changes will become binding on you upon your first use of Our Site after the changes have been implemented.  You are therefore advised to check this page from time to time.
    • In the event of any conflict between the current version of these Terms and Conditions and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.

 

  1. Contacting Us

To contact Us, please email Us at support@thisisunderground.co.uk or using any of the methods provided on Our contact page at <<insert link to contact page>>.

 

  1. [Communications from Us
    • If We have your contact details, We may from time to time send you important notices by email. Such notices may relate to matters including, but not limited to, service changes and changes to these Terms and Conditions.
    • We will never send you marketing emails of any kind without your express consent. If you do give such consent, you may opt out at any time.  Any and all marketing emails sent by Us include an unsubscribe link.  If you opt out of receiving emails from Us at any time, it may take up to <<insert period>> business days for Us to comply with your request.  During that time, you may continue to receive emails from Us.
    • For questions or complaints about communications from Us (including, but not limited to marketing emails), please contact Us at <<insert email address>> or via <<insert link to e.g. contact page or complaints page>>.]

 

  1. Data Protection
    • All personal information that We may use will be collected, processed, and held in accordance with the provisions of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”) and your rights under the GDPR.
    • For complete details of Our collection, processing, storage, and retention of personal data including, but not limited to, the purpose(s) for which personal data is used, the legal basis or bases for using it, details of your rights and how to exercise them, and personal data sharing (where applicable), please refer to Our Privacy Policy <<insert link to Privacy Policy>> [and Cookie Policy <<insert link to Cookie Policy>>].

 

  1. Law and Jurisdiction
    • These Terms and Conditions, and the relationship between you and Us (whether contractual or otherwise) shall be governed by, and construed in accordance with the law of [England & Wales] [Northern Ireland] [Scotland].
    • If you are a consumer, you will benefit from any mandatory provisions of the law in your country of residence. Nothing in Sub-Clause 16.1 above takes away or reduces your rights as a consumer to rely on those provisions.
    • If you are a consumer, any dispute, controversy, proceedings or claim between you and Us relating to these Terms and Conditions, or the relationship between you and Us (whether contractual or otherwise) shall be subject to the jurisdiction of the courts of England, Wales, Scotland, or Northern Ireland, as determined by your residency.
    • If you are a business, any disputes concerning these Terms and Conditions, the relationship between you and Us, or any matters arising therefrom or associated therewith (whether contractual or otherwise) shall be subject to the [non] exclusive jurisdiction of the courts of [England & Wales] [Northern Ireland] [Scotland].

BACKGROUND:

 

These Terms and Conditions are the standard terms for the provision of services by UNDRGRND Network [, trading as <<insert trading name if different from company name>>,] a <<insert business type, e.g. Sole Trader, Partnership, LLP, Private Limited Company etc.>> [registered in England under number <<insert registration number>>] [,whose registered address is <<insert registered address>> and] whose main trading address is <<insert address>>.

 

 

  1. Definitions and Interpretation
    • In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:

 

“Business Day” means any day other than a Saturday, Sunday or bank holiday;
“Calendar Day” means any day of the year;
“Contract” means the contract for the provision of Services, as explained in Clause 3;
“Deposit” means an advance payment made to Us under sub-Clause 5.5;
“Month” means a calendar month;
“Price” means the price payable for the Services;
“Services” means the services which are to be provided by Us to you as specified in your Order (and confirmed in Our Order Confirmation);
“Special Price” means a special offer price payable for Services which We may offer from time to time;
“Order” means your order for the Services [as attached] OR [as shown overleaf];
“Order Confirmation” means Our acceptance and confirmation of your Order as described in Clause 3;
“We/Us/Our” means UNDRGRND Network [, trading as <<insert trading name if different from company name>>,] a <<insert business type, e.g. Sole Trader, Partnership, LLP, Private Limited Company etc.>> [registered in England under number <<insert registration number>>] [,whose registered address is <<insert registered address>> and] whose main trading address is <<insert address>>.

 

  • Each reference in these Terms and Conditions to “writing” and any similar expression includes electronic communications whether sent by e-mail, [text message,] fax or other means.

 

  1. Information About Us
    • UNDRGRND Network [, trading as <<insert trading name if different from company name>>,] is a <<insert business type, e.g. Sole Trader, Partnership, LLP, Private Limited Company etc.>> [registered in England under number <<insert registration number>>] [,whose registered address is <<insert registered address>> and] whose main trading address is <<insert address>>.
    • [Our VAT number is <<insert VAT number>>.]

 

  1. The Contract
    • These Terms and Conditions govern the sale and provision of Services by Us and will form the basis of the Contract between Us and you. Before submitting an Order, please ensure that you have read these Terms and Conditions carefully.  If you are unsure about any part of these Terms and Conditions, please ask Us for clarification.
    • Nothing provided by us including, but not limited to, sales and marketing literature, price lists and other documents constitutes a contractual offer capable of acceptance. Your Order constitutes a contractual offer that We may, at our discretion, accept.
    • A legally binding contract between Us and you will be created upon our acceptance of your Order, indicated by Our Order Confirmation. Order Confirmations will be provided in writing.
    • We shall ensure that the following information is given or made available to you prior to the formation of the Contract between Us and you, save for where such information is already apparent from the context of the transaction:
      • The main characteristics of the Services;
      • Our identity (set out above in Clause 2) and contact details (as set out below in Clause 11);
      • The total Price for the Services including taxes or, if the nature of the Services is such that the Price cannot be calculated in advance, the manner in which it will be calculated;
      • The arrangements for payment, performance and the time by which (or within which) We undertake to perform the Services;
      • Our complaints handling policy;
      • Where applicable, details of after-sales services and commercial guarantees;
      • The duration of the Contract, where applicable, or if the Contract is of indeterminate duration or is to be extended automatically, the conditions for terminating the Contract;
      • [Where applicable, the functionality, including appropriate technical protection measures, of digital content;]
      • [Where applicable, any relevant compatibility of digital content with hardware and software that We are aware of or might reasonably be expected to be aware of.]

 

  1. Orders
    • All Orders for Services made by you will be subject to these Terms and Conditions.
    • You may change your Order at any time before We begin providing the Services by contacting Us. [Requests to change Orders do not need to be made in writing.]
    • If your Order is changed We will inform you of any change to the Price in writing.
    • You may cancel your Order within 7 of placing it. If you have already made any payments to Us under Clause 5 (including, but not limited to the Deposit), subject to sub-Clause 5.6, the payment(s) will be refunded as soon as is reasonably possible, and in any event within 14 Calendar Days of Our acceptance of your cancellation.  [If you request that your Order be cancelled, you must confirm this in writing.]  If you wish to cancel the Services after this time period, or once We have begun providing the Services, please refer to Clause 10.
    • We may cancel your Order at any time before We begin providing the Services due to the unavailability of required personnel or materials, or due to the occurrence of an event outside of Our reasonable control. If such cancellation is necessary, We will inform you as soon as is reasonably possible.  If you have made any payments to Us under Clause 5 (including, but not limited to the Deposit), the payment(s) will be refunded as soon as is reasonably possible, and in any event within 14 Calendar Days of Us informing you of the cancellation.  Cancellations will be confirmed in writing.

 

  1. Price and Payment
    • The Price of the Services will be that shown in Our subscriptions in place at the time of your Order. If the Price shown in your Order differs from Our current Price We will inform you upon receipt of your Order.
    • If We quote a Special Price which is different to the Price shown in Our current <<insert document, e.g. price list>>, the Special Price will be valid for <<insert period>> or, if the Special Price is part of an advertised special offer, for the period shown in the advertisement. Orders placed during this period will be accepted at the Special Price even if We do not accept the Order until after the period has expired.
    • Our Prices may change at any time but these changes will not affect Orders that We have already accepted.
    • All Prices include VAT. If the rate of VAT changes between the date of your Order and the date of your payment, We will adjust the rate of VAT that you must pay.  Changes in VAT will not affect any Prices where We have already received payment in full from you.
    • Before We begin providing the Services, you will be required to pay a Deposit of 0% of the total Price for the Services. The due date for payment of your Deposit will be included in the Order Confirmation.
    • In certain circumstances, if your Order is cancelled, your Deposit will be refunded in full or in part. The amount due will be calculated based upon the Price for the Services, Our <<insert document, e.g. price list>>, and the amount of work (if any) already undertaken by Us.  Please refer to sub-Clauses 4.4 and 4.5 if your Order is cancelled before the Services begin, or to Clause 10 if the Services are cancelled after they have begun.
    • The balance of the Price will be payable [once We have provided the Services] OR [on a <<insert interval e.g. weekly>> basis in [advance] OR [arrears] during the provision of the Services].
    • We accept the following methods of payment:
      • PayPal;
      • Bank transfer;
      • <<insert type of payment>>;
      • <<insert type of payment>>;

 

  • [Credit and/or debit cards will be charged <<insert point at which a card will be charged>>.]

 

  1. Providing the Services
    • As required by law, We will provide the Services with reasonable skill and care, consistent with best practices and standards in the [market] OR [sector] OR [industry], and in accordance with any information provided by Us about the Services and about Us.
    • We will begin providing the Services on the date confirmed in Our Order Confirmation.
    • We will continue providing the Services for [a period] OR [an approximate period] of 31 days.
    • We will make every reasonable effort to complete the Services on time (and in accordance with your Order). We cannot, however, be held responsible for any delays if an event outside of Our control occurs.  Please see Clause 9 for events outside of Our control.
    • If We require any information or action from you in order to provide the Services, We will inform you of this as soon as is reasonably possible.
    • If the information or action required of you under sub-Clause 6.5 is delayed, incomplete or otherwise incorrect, We will not be responsible for any delay caused as a result. If additional work is required from Us to correct or compensate for a mistake made as a result of incomplete or otherwise incorrect information or action on your part, We may charge you a reasonable additional sum for that work.
    • In certain circumstances, for example where there is a delay in you sending Us information or taking action required under sub-Clause 6.5, We may suspend the Services (and will inform you of that suspension in writing).
    • In certain circumstances, for example where We encounter a technical problem, We may need to suspend the Services in order to resolve the issue. Unless the issue is an emergency and requires immediate attention We will inform you in advance in writing before suspending the Services.
    • If the Services are suspended under sub-Clauses 6.7 or 6.8, you will not be required to pay for them during the period of suspension. You must, however, pay any invoices that you have already received from Us by their due date(s).
    • If you do not pay Us for the Services as required by Clause 5, We may suspend the Services until you have paid all outstanding sums due. If this happens, We will inform you in writing.  This does not affect Our right to charge you interest under sub-Clause 5.10.

 

  1. Problems with the Services and Your Legal Rights
    • We always use reasonable efforts to ensure that Our provision of the Services is trouble-free. If, however, there is a problem with the Services We request that you inform Us as soon as is reasonably possible [(you do not need to contact Us in writing)].
    • We will use reasonable efforts to remedy problems with the Services as quickly as is reasonably possible and practical. [In emergency situations, such as those where vulnerable people living in your property may be affected, We will use reasonable efforts to remedy problems within 24 hours.]
    • We will not charge you for remedying problems under this Clause 7 where the problems have been caused by Us, any of our agents or employees or sub-contractors or where nobody is at fault. If We determine that a problem has been caused by incorrect or incomplete information or action provided or taken by you, sub-Clause 6.6 will apply and We may charge you for remedial work.
    • As a consumer, you have certain legal rights with respect to the purchase of services. For full details of your legal rights and guidance on exercising them, it is recommended that you contact your local Citizens Advice Bureau or Trading Standards Office.  If We do not perform the Services with reasonable skill and care, you have the right to request repeat performance or, if that is not possible or done within a reasonable time without inconvenience to you, you have the right to a reduction in price.  If the Services are not performed in line with information that We have provided about them, you also have the right to request repeat performance or, if that is not possible or done within a reasonable time without inconvenience to you (or if Our breach concerns information about Us that does not relate to the performance of the Services), you have the right to a reduction in price.  If for any reason We are required to repeat the Services in accordance with your legal rights, We will not charge you for the same and We will bear any and all costs of such repeat performance.  In cases where a price reduction applies, this may be any sum up to the full Price and, where you have already made payment(s) to Us, may result in a full or partial refund.  Any such refunds will be issued without undue delay (and in any event within 14 calendar days starting on the date on which We agree that you are entitled to the refund) and made via the same payment method originally used by you unless you request an alternative method.  In addition to your legal rights relating directly to the Services, You also have remedies if We use materials that are faulty or incorrectly described.

 

  1. Our Liability
    • We will be responsible for any foreseeable loss or damage that you may suffer as a result of Our breach of these Terms and Conditions or as a result of Our negligence (including that of Our employees, agents or sub-contractors). Loss or damage is foreseeable if it is an obvious consequence of the breach or negligence or if it is contemplated by you and Us when the Contract is created.  We will not be responsible for any loss or damage that is not foreseeable.
    • We provide Services for domestic and private use (or purposes). We make no warranty or representation that the Services are fit for commercial, business or industrial purposes of any kind [(including resale)].  By making your Order, you agree that you will not use the Services for such purposes.  We will not be liable to you for any loss of profit, loss of business, interruption to business or for any loss of business opportunity.
    • [If We are providing Services in your property and We cause any damage, We will make good that damage at no additional cost to you. We are not responsible for any pre-existing faults or damage in or to your property that We may discover while providing the Services.]
    • Nothing in these Terms and Conditions seeks to exclude or limit Our liability for death or personal injury caused by Our negligence (including that of Our employees, agents or sub-contractors); or for fraud or fraudulent misrepresentation.
    • Nothing in these Terms and Conditions seeks to exclude or limit Our liability for failing to perform the Services with reasonable care and skill or in accordance with information provided by Us about the Services or about Us.
    • Nothing in these Terms and Conditions seeks to exclude or limit Your legal rights as a consumer. For more details of Your legal rights, please refer to Your local Citizens Advice Bureau or Trading Standards Office.

 

  1. Events Outside of Our Control (Force Majeure)
    • We will not be liable for any failure or delay in performing Our obligations where that failure or delay results from any cause that is beyond Our reasonable control. Such causes include, but are not limited to: power failure, internet service provider failure, strikes, lock-outs or other industrial action by third parties, riots and other civil unrest, fire, explosion, flood, storms, earthquakes, subsidence, acts of terrorism (threatened or actual), acts of war (declared, undeclared, threatened, actual or preparations for war), epidemic or other natural disaster, or any other event that is beyond Our reasonable control.
    • If any event described under this Clause 9 occurs that is likely to adversely affect Our performance of any of Our obligations under these Terms and Conditions:
      • We will inform you as soon as is reasonably possible;
      • Our obligations under these Terms and Conditions will be suspended and any time limits that We are bound by will be extended accordingly;
      • We will inform you when the event outside of Our control is over and provide details of any new dates, times or availability of Services as necessary;
      • If an event outside of Our control occurs and you wish to cancel the Contract, you may do so in accordance with your right to Cancel under sub-Clause 10.3.3. Any refunds due to you as a result of that cancellation will be paid to you as soon as is reasonably possible, and in any event within 14 Calendar Days of Our acceptance of your cancellation notice;
      • If the event outside of Our control continues for more than 4 weeks, We will cancel the Contract in accordance with Our right to cancel under sub-Clause 10.6.3 and inform you of the cancellation. Any refunds due to you as a result of that cancellation will be paid to you as soon as is reasonably possible, and in any event within 14 Calendar Days of Our cancellation notice.

 

  1. Cancellation
    • If you wish to cancel your Order for the Services before the Services begin, you may do so under sub-Clause 4.4.
    • Once We have begun providing the Services, you are free to cancel the Services and the Contract at any time by giving Us 31 days written notice. If you have made any payment to Us for any Services We have not yet provided, these sums will be refunded to you as soon as is reasonably possible, and in any event within 14 Calendar Days of Our acceptance of your cancellation.  If We have provided Services that you have not yet paid for, the sums due will be deducted from any refund due to you or, if no refund is due, We will invoice you for those sums and you will be required to make payment in accordance with Clause 5.
    • If any of the following occur, you may cancel the Services and the Contract immediately by giving Us written notice. If you have made any payment to Us for any Services We have not yet provided, these sums will be refunded to you as soon as is reasonably possible, and in any event within 14 Calendar Days of Our acceptance of your cancellation. If We have provided Services that you have not yet paid for, the sums due will be deducted from any refund due to you or, if no refund is due, We will invoice you for those sums and you will be required to make payment in accordance with Clause 5.  If you cancel because of Our breach under sub-Clause 10.3.1, you will not be required to make any payments to Us.  You will not be required to give 31 days notice in these circumstances:
      • We have breached the Contract in any material way and have failed to remedy that breach within 7 days of you asking Us to do so in writing; or
      • We enter into liquidation or have an administrator or receiver appointed over Our assets; or
      • We are unable to provide the Services due to an event outside of Our control (as under sub-Clause 9.2.4); or
      • We change these Terms and Conditions to your material disadvantage.
    • We may cancel your Order for the Services before the Services begin under sub-Clause 4.5.
    • Once We have begun providing the Services, We may cancel the Services and the Contract at any time by giving you 7 days written notice. If you have made any payment to Us for any Services We have not yet provided, these sums will be refunded to you as soon as is reasonably possible, and in any event within 14 Calendar Days of Our cancellation notice. If We have provided Services that you have not yet paid for, the sums due will be deducted from any refund due to you or, if no refund is due, We will invoice you for those sums and you will be required to make payment in accordance with Clause 5.
    • If any of the following occur, We may cancel the Services and the Contract immediately by giving you written notice. If you have made any payment to Us for any Services We have not yet provided, these sums will be refunded to you as soon as is reasonably possible, and in any event within 14 Calendar Days of Our cancellation notice.  If We have provided Services that you have not yet paid for, the sums due will be deducted from any refund due to you or, if no refund is due, We will invoice you for those sums and you will be required to make payment in accordance with Clause 5.  We will not be required to give 31 days notice in these circumstances:
      • You fail to make a payment on time as required under Clause 5 (this does not affect our right to charge interest on overdue sums under sub-Clause 5.10); or
      • You have breached the Contract in any material way and have failed to remedy that breach within 7 days of Us asking you to do so in writing; or
      • We are unable to provide the Services due to an event outside of Our control (for a period longer than that in sub-Clause 9.2.5).
    • For the purposes of this Clause 10 (and in particular, sub-Clauses 10.3.1 and 10.6.2) a breach of the Contract will be considered ‘material’ if it is not minimal or trivial in its consequences to the terminating party (i.e. you under sub-Clause 10.3.1 and Us under sub-Clause 10.6.2). In deciding whether or not a breach is material no regard will be had to whether it was caused by any accident, mishap, mistake or misunderstanding.

 

  1. Communication and Contact Details
    • If you wish to contact Us, you may do so by by email at support@thisisunderground.co.uk.
    • In certain circumstances you must contact Us in writing (when cancelling an Order, for example, or exercising your right to cancel the Services). When contacting Us in writing you may use the following methods:
      • Contact Us by email at support@thisisunderground.co.uk; or

 

  1. Complaints and Feedback
    • We always welcome feedback from Our customers and, whilst We always use all reasonable endeavours to ensure that your experience as a customer of Ours is a positive one, We nevertheless want to hear from you if you have any cause for complaint.
    • All complaints are handled in accordance with Our complaints handling policy and procedure, available from ugnmusic.com/legal.
    • If you wish to complain about any aspect of your dealings with Us, including, but not limited to, these Terms and Conditions, the Contract, or the Services, please contact Us in one of the following ways:
      • [In writing, addressed to Aaron Munn, 17 Manor Road Rusthall Tunbridge Wells KENT TN4 8UD UK;]
      • [By email, addressed to Aaron Munn, support@thisisunderground.co.uk;]
      • [Using Our complaints form, following the instructions included with the form;]

 

  1. How We Use Your Personal Information (Data Protection)
    • All personal information that We may use will be collected, processed, and held in accordance with the provisions of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”) and your rights under the GDPR.
    • For complete details of Our collection, processing, storage, and retention of personal data including, but not limited to, the purpose(s) for which personal data is used, the legal basis or bases for using it, details of your rights and how to exercise them, and personal data sharing (where applicable), please refer to Our Privacy Notice available from ugnmusic.com/legal.

 

  1. Other Important Terms
    • We may transfer (assign) Our obligations and rights under these Terms and Conditions (and under the Contract, as applicable) to a third party (this may happen, for example, if We sell Our business). If this occurs you will be informed by Us in writing.  Your rights under these Terms and Conditions will not be affected and Our obligations under these Terms and Conditions will be transferred to the third party who will remain bound by them.
    • You may not transfer (assign) your obligations and rights under these Terms and Conditions (and under the Contract, as applicable) without Our express written permission.
    • The Contract is between you and Us. It is not intended to benefit any other person or third party in any way and no such person or party will be entitled to enforce any provision of these Terms and Conditions.
    • If any of the provisions of these Terms and Conditions are found to be unlawful, invalid or otherwise unenforceable by any court or other authority, that / those provision(s) shall be deemed severed from the remainder of these Terms and Conditions. The remainder of these Terms and Conditions shall be valid and enforceable.
    • No failure or delay by Us in exercising any of Our rights under these Terms and Conditions means that We have waived that right, and no waiver by Us of a breach of any provision of these Terms and Conditions means that We will waive any subsequent breach of the same or any other provision.

 

  1. Governing Law and Jurisdiction
    • These Terms and Conditions, the Contract, and the relationship between you and Us (whether contractual or otherwise) shall be governed by, and construed in accordance with the law of [England & Wales][Northern Ireland] [Scotland].
    • As a consumer, you will benefit from any mandatory provisions of the law in your country of residence. Nothing in Sub-Clause 15.1 above takes away or reduces your rights as a consumer to rely on those provisions.
    • Any dispute, controversy, proceedings or claim between you and Us relating to these Terms and Conditions, the Contract, or the relationship between you and Us (whether contractual or otherwise) shall be subject to the jurisdiction of the courts of England, Wales, Scotland, or Northern Ireland, as determined by your residency.

 

UNDRGRND Network understands that your privacy is important to you and that you care about how your personal data is used. we respect and value the privacy of everyone who visits this website, www.ugnmusic.com (“our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested at all times while using ugnmusic.com.

 

  1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

 

“Account” means an account required to access and/or use certain areas and features of our Site;
“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

 

  1. Information About us

our Site is [owned and] operated by UNDRGRND Network, a limited company registered in England under company number 11993599.

Registered address: Undrgrnd Network Ltd 71-75 Shelton Street Covent Garden London WC2H 9JQ.

Main trading address: Undrgrnd Network Ltd 71-75 Shelton Street Covent Garden London WC2H 9JQ.

 

  1. What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site. our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

  1. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

  1. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
  2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we Please contact us using the details in Part 15 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. we would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

 

  1. What Data Do You Collect and How?

Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.

 

Data Collected How we Collect the Data
Identity Information including name, title, date of birth, gender Sign up, profile fields.
Contact information including address, email address, telephone number. Sign up, profile fields
Business information including business name, job title, profession. Sign up, profile fields
Profile information including preferences, interests, login details, purchase history. Sign up, profile fields
Technical information including IP address, browser type and version, operating system. Sign up, profile fields, cookies

 

  1. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

 

What we Do What Data we Use our Lawful Basis
Registering you on our Site. Name, date of birth, email address. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Providing and managing your Account. <<insert data type(s)>>. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Providing and managing your access to our Site. subscription level. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Personalising and tailoring your experience on our Site. <<insert data type(s)>>. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Administering our Site. <<insert data type(s)>>. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Administering our business. <<insert data type(s)>>. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Supplying our products and services to you. <<insert data type(s)>>. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Managing payments for our products and services. <<insert data type(s)>>. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Personalising and tailoring our products and services for you. <<insert data type(s)>>. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Communicating with you. email address. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.
Supplying you with information by email that you have opted-in-to (you may opt-out at any time by emailing gdpr@ugnmusic.com. <<insert data type(s)>>. <<insert lawful basis (if “legitimate interests”, state what the legitimate interest(s) is or are>>.

 

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including analytics and google ads) whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

  1. How Long Will You Keep My Personal Data?

we will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

 

Type of Data How Long we Keep It
Identity Information including name, title, date of birth, gender. Until your account is closed or request that it is removed.
Contact information including address, email address, telephone number. Until your account is closed or request that it is removed.
Business information including business name, job title, profession. Until your account is closed or request that it is removed.
Profile information including preferences and interests, username and password, purchase history. Until your account is closed or request that it is removed.
Technical information including IP address, browser type and version, operating system. Until your account is closed or request that it is removed.

 

  1. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

 

  1. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  1. How Can I Control My Personal Data?
    • In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails [and] OR [,] at the point of providing your details [and by managing your Account]).
    • You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

 

  1. Can I Withhold Information?

You may access [certain areas of] our Site without providing any personal data at all. [However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.]

You may restrict our use of Cookies. For more information, see Part 14 [and our Cookie Policy ugnmusic.com/legal].

 

  1. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.]

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

we will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

  1. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on our Site for analytics. For more details, please refer to the table below. These Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing consent to them.

All Cookies used by and on our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a popup bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.

Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

 

Name of Cookie Purpose Strictly Necessary
cookie_notice_accepted Whether you have accepted the cookie policy or not YES
PHPSESSID session ID YES
wp_logged_in Whether user is signed in or not <<yes / no>>

 

 

Our Site uses analytics services provided by Matomo. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our Site is used. This, in turn, enables us to improve our Site and the products and services offered through it.

The analytics service(s) used by our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Site, it does enable us to continually improve our Site, making it a better and more useful experience for you.

The analytics service(s) used by our Site use(s) the following Cookies:

 

Name of Cookie First / Third Party Provider Purpose
<<insert file name>> first analytics.services.ugnmusic.com <<insert description>>
<<insert file name>> first analytics.services.ugnmusic.com <<insert description>>
<<insert file name>> first analytics.services.ugnmusic.com <<insert description>>
<<insert file name>> first analytics.services.ugnmusic.com <<insert description>>
<<insert file name>> first analytics.services.ugnmusic.com <<insert description>>

 

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]

 

  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Aaron Munn):

Email address: gdpr@ugnmusic.com.

 

  1. Changes to this Privacy Policy

we may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. we recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 17 May 2019.

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