Updated 19 April 2018
ROLI Ltd. ("we/us/our") are committed to protecting and respecting your privacy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is ROLI Ltd. of 2 Glebe Road, London E8 4BD.
ROLI offers only a limited version of the Platform for children under the age of 13 who are located in the US or children under the age of 17 who are located anywhere else in the world (collectively called “Limited Users”). This limited version of the Platform restricts certain features and options to ensure that ROLI does not collect any personal data from the Limited User other than as provided for in this paragraph. Except in the case of responding to a specific request to register ROLI products from a Limited User, as more fully described below, ROLI does not collect or store any personal data from such Limited Users, apart from a persistent identifier that is used only for support of the internal operations of the ROLI Platform. Such persistent identifier is not used or disclosed to contact the Limited User, including through behavioral advertising; to amass a profile on the Limited User; or for any other purpose other than internal operations. Internal support operations include the following:
In the event a Limited User desires to register their ROLI products in order to access certain limited features of the products, then, upon request from the Limited User, ROLI may collect the Limited User’s email address, and such Limited User’s parent’s email address, in order to give the parent notice and an opportunity to opt-out of the collection of the Limited User’s email address. ROLI only uses the Limited User’s email address in order to respond to the Limited User’s specific requests to register ROLI products, and such email address will not be used for any other purpose and will not be disclosed or combined with other information of the child. ROLI does not collect any other personal data from a Limited User except as described herein. As a parent of a Limited User, you may opt-out of allowing ROLI to collect the Limited User’s email address by following the link in the notice you receive from ROLI, or otherwise by contacting ROLI through our support page.
ROLI does not share Limited Users’ personal data with any third parties, except to the extent it is required to share with our processors in order to provides the Platform as described herein, in order to comply with legal obligations or to protect the rights and safety of ROLI and its customers, as is further described in Section 5 below. ROLI takes all steps reasonably necessary to ensure that your data is treated securely, with adequate protections when engaging processors on our behalf.
This Section 3 describes ROLI’s collection practices for non-Limited Users, who are 13 years of age or older in the case of US users, or 17 years of age or older in the case of non-US users throughout the world. Please see section 2 for ROLI’s collection practices for Limited Users.
You may give us information about you by filling in forms on the Platform or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register, visit or use the Platform, place an order on the Platform, subscribe to the newsletter and when you report a problem with the Platform. The information you give us may include your name, address, e-mail address and phone number, personal description, photograph, and which products you have purchased from us.
With regard to each of your visits to the Platform we may automatically collect the following information:
We work closely with third parties - including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers (such as Google Analytics, Mixpanel, and SnowPlow) search information providers, credit reference agencies - and we may receive information about you from such third parties.
When you save or share a music project file through our Platform, we may receive information about your device, software and your composition, as well as any notes or comments you post related to it or any other content on the platform.
We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your personal data with selected third parties including, business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, and analytics and search engine providers that assist us in the improvement and optimization of our Platform.
In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.
If we are under a duty to disclose or share your personal data (including in the case of Limited Users) in order to comply with any legal obligation, or in order to enforce or apply our General Terms of Sale and other agreements; or to protect the rights, property, or safety of ROLI Ltd., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Union, the European Economic Area and Switzerland (“the Territory”), and in particular the United States. It may also be processed by staff operating outside the Territory who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We will ask for your permission if we intend to use your data for marketing purposes, and we never market to Limited Users. Incase you decide that you no longer want to give us such a permission, you may do so by unsubscribing from the newsletter or simply by contacting us via our support page.
We will also ask for your permission if we intend to disclose your information to any third party for marketing purposes. This permission may also be withdrawn, for example by contacting us via our support page. Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. We strive to give you ways to update or delete your personal data. Please contact us, if you have such or similar requests. See Section 12 below for contact information.