EMI PRECEDENT PRIVACY POLICY

This is the Privacy Policy of EMI Group Limited and its subsidiaries (collectively “EMI Group of Companies”, “we”, “us”) it was most recently updated on 23 April 2008. In conjunction with any Terms of Use, this policy sets out the basis on which any personal data you provide will be processed by us. Please read it carefully.

By visiting this Sean Lennon website, you are accepting and consenting to the practices described in this Privacy Policy which may be amended from time to time. If you use this website (the “Website”) after we have published such changes, you will be agreeing to be bound by those changes. If you do not agree to be bound by this policy at any time, you should not use the Website.

Children

You must be at least 13 years old to register with us. We ask you not to register any of your details with us if you are under 13 years old. If you are between the ages of 13 and 16 please ensure that you have your parent or guardian’s consent to register.

What we collect and why

When you use the Website, there are different ways we gather information about you:

• When you register with us, we ask for information such as your name, email address, address and contact details. We keep a record of this information and any other information relating to you that we may obtain from our suppliers or other third parties. This record will be stored and processed in the United Kingdom and other countries (see further below under “The EMI Group and how we store data about you” and “How we use data about you”). All this is necessary for us to recognise you, provide you with the services or information you have requested from us and where appropriate to maintain your account with us. We also use this information to improve our platform and prevent or detect abuses of our Website.
• We keep a record of any electronic correspondence you send us. This helps us keep track of any problems or concerns you've had with our Website or services.

Cookies and Analysis Tools

• We currently use Google Analytics to analyse how visitors use our Website and to try and improve it. To do this, we use Web beacons and cookies on this Website; these are text files that collect and log site user behaviour information including IP addresses (the number automatically assigned to your computer by your Internet Service Provider) in an anonymous form. The information collected is transmitted to Google and used to compile statistical reports for us. The information is not used to track or collect any information which may be used to identify a particular individual. All information is used and held anonymously.
• We may also use cookies and other technologies to optimise your experience on the site, cookies can be used to recognise users when they return and may help us customise the Website for you based on your preferences.
• We control how the data collected from our cookies and other technologies may and may not be used. If you do not want to help us learn how to improve our site, products, offers and marketing strategy, you can "opt-out" of our ability to analyse such data and disable cookies by modifying the settings in your browser. Note that this might affect some functionality on the Website. For more information about cookies and how to disable them please go to www.allaboutcookies.org.
• Third party advertisers on the site may use cookies and other technologies in their advertisements for statistical purposes, we have no control over cookies placed by third parties.

The EMI Group and how we store data about you

In order to communicate with you about local events, offers and opportunities and other news, the data that we collect from you may be transferred to, stored and processed by the EMI Group of Companies or one of our suppliers based in Europe, North America, South East Asia, Asia Pacific or Latin America. Such staff may be engaged in, among other things: preparing and sending newsletters to which you subscribe, the fulfilment of your order, the processing of payment details and the provision of support services. Not all countries legislate for the same levels of protection of personal data as your home country, particularly if you are resident in the EEA. By submitting data, you agree to this collection, transfer, storing or processing of data about you for the purposes described in this policy. We will take all reasonable steps to ensure data about you is treated securely in accordance with this policy, and all information you provide to us is stored on our secure servers or those of our service providers. A full list of EMI Group Companies who may jointly use data about you is available at http://www.emigroup.com/EMI/list.pdf. EMI Group Limited is the entity responsible for the management of jointly used personal data.

Passwords

Where we have given you (or you have chosen) a password to access the Website, you are responsible for keeping this password confidential. Please do not share it with anyone.

How we use Personal Data about you

All the information we collect via our Website or through correspondence with you is used to provide you with any information, products or services you have requested, operate the EMI Group’s business and hopefully improve the services and products that we offer you. We will use personal data about you for purposes such as:

• Managing the Website and access to it so it is presented in the most effective way for you and your computer;
• Dealing with orders and accounts for the supply of our goods and services;
• Planning and managing EMI business activities, including analysing users’ preferences;
• Research;
• Providing you with information about the products and services we offer (subject to your preferences where possible);
• Providing you with information about specially selected third party products and services (if you consent to receive such information on registration), and
• Notifying you of any changes to our products and services.

There are only a limited number of circumstances where we may share some or all data about you that we hold with others; these are set out below.

• With local agents such who assist us in the service we provide to you by for example hosting sites, or sending emails on our behalf. In these instances, we provide them with only the information they need to perform their function.
• In the event that our business assets are ever sold to or purchased by another company. (Our data records are part of our business.)
• To other members of the EMI Group of Companies, which means other companies across the world owned or controlled by our parent company, EMI Group Limited (see list).
• To our joint venture partners.
• If we are under a duty to disclose or share personal data about you in order to comply with any legal obligation at the request of public authorities, or in order to enforce or apply our Terms of Use to protect the rights, property or safety of EMI, our customers, or others.
• On your express consent.

So far as possible each disclosure will be subject to an obligation of confidentiality.

We may also share anonymised, aggregated data such as access statistics, with third parties such as advertisers. This will not involve the identification of individuals

How we DO NOT use Personal Data about you

We will never pass on your email address or personal information about you to a third party for marketing purposes, without your consent.

How do we communicate with you and how can you object to receiving future communications?

We may use the information we collect to contact you by post, email, telephone (including automated calls, by SMS text messages and other multimedia electronic messages such as picture messaging), in each case to communicate information to you about products, services, offers and other news.

We will never send you unsolicited premium rate sms messages (which are sms messages you pay to receive). You will be given the opportunity to opt-in to receiving such marketing information at the point when your details are collected. All promotional information from us will come with instructions on how to opt-out from receiving further information in the future.

Data over the Internet and other websites

The Internet is a global network - therefore there are cases where data about you travels globally and may not always be completely secure. We want you to know that if you provide us with data over the Internet, this is at your own risk. By using the Website, you agree to and authorise us to process data in this way. However, please be assured that we do use commercially reasonable procedures and security features to prevent unauthorised access to your data.

Where the Website contains links to third-party websites please note that these have been included for convenience only. Neither EMI nor any of its affiliated companies controls the content of any linked site and any personal data collected by such sites will be subject to the privacy policy of the third party operating that site. Please read any policy carefully before providing any personal information on such websites.

Further Information

If you have questions about personal data relating to you or our privacy policy or wish to change or update data we hold about you, please contact us at privacy@emimusic.co.uk. To see all the information we have about you, and to correct any inaccuracies or change your options in relation to the information you wish to receive, please write to The Data Controller, Capitol Records, 1750 Vine Street, 7th Floor , Hollywood, CA 90028. Any access request may be subject to a fee of £10 to meet our costs in providing these details.