Privacy Notification

Concord and Concord Theatricals care about your privacy.  To better protect your privacy, this Privacy Policy, together with our Terms of Use, explains how we collect, use and protect Personal Data (as defined below) that we collect from you or you provide to us through our Concord Theatricals websites, emails and other means described here (“Sites”).  We may have to change this Privacy Policy to reflect new regulations, new technologies or changes to how we collect, use or disclose your Personal Data.  We reserve the right to change this Privacy Policy at any time at our sole discretion.  The date of the most recent revisions will appear on this page.

Information collected on the Sites may be used in the manner described below by Rodgers & Hammerstein Holdings, LLC d/b/a Concord Theatricals, our parent company Concord Music Group, Inc., and both entities’ respective wholly owned subsidiaries and affiliates, including, without limitation, Concord Theatricals Corp., Concord Theatricals, Ltd., Samuel French, Inc., Samuel French, Ltd., and Tams-Witmark LLC, our labels, our publishing companies, agents, and trusted partners acting on our behalf (collectively, “Concord”).  When used herein, the terms “we,” “us” and “our” refer to Concord.

This Privacy Policy is incorporated into, and is subject to, the Concord Theatricals Terms of Use located at https://concordtheatricals.co.uk/resources/privacy. Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in the Concord Theatricals Terms of Use.

1.  Definitions

“Client” means a customer of Concord.

“Client Data“ means personal data, addresses, and other files, folders or documents in electronic form that a User of the Services stores within the Services.

“Personal Data”  - or “personal information” in certain jurisdictions – means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.  We do not consider Personal Data to include information that has been de-identified so that it does not allow a third party to easily identify a specific individual.  Your name, e-mail address, and IP address are all examples of data that may be Personal Data.  Since your IP address can help us identify you, we treat “cookies” as Personal Data.  Please see Section 9 below to review detailed information about our use of cookies and similar technology.

“Public Area” means the area of the Sites that can be accessed both by Users and Visitors, without needing to log in.

“Restricted Area” means the area of the Sites that can be accessed only by Users, and where access requires logging in.

“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Sites for the purpose of accessing the Services in such capacity.

“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Sites or Services.

2. The Information We Collect on the Services:

We collect different types of information from or through the Services. The legal bases for Concord’s processing of personal data are primarily that the processing is necessary for providing the Services in accordance with Concord’s Terms of Use and that the processing is carried out in Concord’s legitimate interests, which are further explained in the “How We Use the Information We Collect” section of this Privacy Policy, and, for users of the site in the EU/EEA, in Section 19 of this Privacy Policy. We may also process data upon your consent, asking for it as appropriate.

2.1 User-provided Information. When you use the Services, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Services, for example:

 

  • Site Registration. We process your login details if you choose to register for an Account so that we can communicate with you, provide the Services and provide a more personalized experience on our Sites. You are not required to register for an Account, but if you choose not to do so, you may not be able to participate in some of the Services offered through the Sites. In addition to this, we process all information you provide to us when logged into your Account, and also your usage data (e.g., login times, length of stay).
  • Product Purchase. When you choose to buy any products available through our online shop, in addition to your name, address, email address, telephone number, and birth date (if applicable), we will process the following additional Personal Data in order to complete your transaction: details of order, price, credit card number or other payment information, billing address, as well as any further details on the purchase transaction. We note that no credit card information is stored on our servers.
  • Newsletters. We process the email address that you provide us with to receive updates on particular titles, subjects or authors.  We then add that email address to the email list for that title, subject or author.  You may choose to stop receiving our newsletters or marketing emails by following the unsubscribe instructions included in these emails, accessing the email settings in the “Customer Dashboard” under “My Account,” or contacting us as described in the “How to Contact Us” section below.
  • Participation in Special Activities. We process your Personal Data when you register with us as part of your participation in our promotions, contests or sweepstakes.  As part of your registration for a promotion, we may request the following (as required on a case-by-case basis): Personal Data (such as your name, address, email address, telephone number and birth date), demographic information (such as country and gender) and profile data (such as your music preferences and entertainment practices).
  • Contact Us. When you contact us by phone, email or otherwise to submit information to us (such as when contacting us with a question or feedback), we process the information you provide to us, e.g., your name, email address, telephone number and request, to respond to your inquiry.
  • Job Application and Submissions. We process your Personal Data such as name, address, email address, birth date, work experience, education and other related information you submit to review, verify and evaluate your job application or submission information if you have applied for a job at Concord or submitted a manuscript for our review.
  • Updates Concerning Us. If you are a User, we process your email address in order to keep you informed about the operation of our services by sending emails and announcements that are needed for the proper functioning and administration of our Sites and Services.

 

2.2 Information Collected by Clients. A Client or User may store or upload into the Services Client Data. Concord has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Services as part of Client Data.

 

2.3 “Automatically Collected" Information. When a User or Visitor uses the Services, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “clear gifs" or “web beacons.” This “automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Services, the pages or other content the User or Visitor views or interacts with on the Services, and the dates and times of the visit, access, or use of the Services. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.

 

2.4 Integrated Services. You may be given the option to access or register for the Services through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google account, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Services.

 

2.5 User Interactions. We may obtain information, including Personal Data, when you interact with other users of the Sites or Services through communication or messaging capabilities.

 

2.6 Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Services, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Services, we will treat the combined information as Personal Data in accordance with this Privacy Policy.

3. How We Use the Information We Collect

We use the information that we collect in a variety of ways in providing the Services and operating our business, including the following:

3.1 Operations

We use the information – other than Client Data - to operate, maintain, enhance and provide all features of the Services, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Services. We process Client Data solely in accordance with the directions provided by the applicable Client or User.

3.2 Improvements

We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Services, and to develop new products, services, features, and functionality. Should this purpose require Concord to process Client Data, then the data will only be used in anonymized or aggregated form.

3.3 Communications

We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Services (ii) with a business transaction purpose; or (iii) for updates on products, services, new licensing opportunities, materials, promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”

3.4 Cookies and Tracking Technologies

We use automatically collected information and other information collected on the Services through cookies and similar technologies to: (i) personalize our Services, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Services and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Services. Cookies are embedded in the HTTP information that travels back and forth between your computer and the servers. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.

3.5 Analytics

We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Sites and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users' and Visitors’ activity on our Sites. For more information, see Google Analytics Privacy and Data Sharing.

We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Sites and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.

4. To Whom We Disclose Information

Except as described in this Privacy Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Services to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

4.1 Unrestricted Information

Any information that you voluntarily choose to include in a Public Area of the Services, such as a public profile page, or via a chat room, forum, message board and/or other community function, will be available to any Visitor or User who has access to that content.  Remember that any information you disclose in these areas becomes public information and you should exercise caution when deciding to disclose your personal, financial or other information.  Your use of such Public Areas and community functions is at your own risk.

4.2 Service Providers

We may share the categories of Personal Data described above with service providers and third parties that we partner with to assist us in various functions, including providing technical support, providing you with our Services and products (including helping us to administer contests and promotions), and providing your with communications and marketing information on our behalf. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

These services providers and third parties can be classified in the following categories:

  • Delivery partners, to deliver our products to the right location;
  • Financial partners, who are involved in the processing of your banking or credit card data on our Sites;
  • Marketing partners, who we use (for example) to send you promotional communications;
  • Product partners, who we work with to fulfill your orders for supplementary materials;
  • Promotional vendors, who help us to administer contests and promotions, including by maintaining separate contest and promotion microsites;
  • IT service providers, such as our data hosting provider; and
  • Other service providers, who we may engage to provide services to us or on our behalf.

 

If you apply to a job opportunity at Concord, you may be required to create an account on a third-party applicant tracking system (“ATS”).  During the recruitment process, we may use this ATS to compare and rank candidates, set up screening questions, create interview notes, send you meeting requests and messages, and if you are successful, send you an offer letter.  Once you accept this letter, your applicant profile will be transformed into an employee profile and you will be subject to our Employee Privacy Policy.

4.3 Non Personally Identifiable Information

We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Services.

4.4 Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Services and any facilities or equipment used to make the Services available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

4.5 Change of Ownership

Information about Users and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or Visitor Personal Data commits to a privacy policy that has terms substantially consistent with this Privacy Policy.

Client Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Services, and only if the recipient of the Client Data commits to a privacy policy that has terms substantially consistent with this Privacy Policy.

4.6 Organizational Accounts

When you create an Account as a User of the Sites, the account will be associated with an organization (“Organizational Account”).  Other Users may request to join your Organizational Account and certain Personal Data, specifically your organization’s physical address, will be viewable by such other Users to enable them to correctly identify the Organizational Account that they wish to join.  In the event that you, as a User, request to join an existing Organizational Account, certain Personal Data, specifically your first name, last name, and email address, will be shared with the administrator(s) of the Organizational Account you wish to join, so that the administrator(s) may verify that you are a member of the applicable organization and monitor the membership.

5. Your Choices

5.1 Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.

You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Services. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Services.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Concord’s Data Protection Officer at [email protected].uk. You also have a right to lodge a complaint with data protection authorities.

This provision does not apply to Personal Data that is part of Client Data. In this case, the management of the Client Data is subject to the Client’s own privacy policy, and any request for access, correction or deletion should be made to the Client responsible for the uploading and storage of such data into the Services.

5.2 Navigation Information

You may opt out from the collection of navigation information about your visit to the Sites by Google Analytics by using the Google Analytics Opt-out feature.

5.3 Opting out from Commercial Communications

If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email, or by sending an email to [email protected].

Users are able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by navigating to this direct site https://mailchi.mp/concordtheatricals.co.uk/ukmailinglist, or accessing the “Customer Dashboard” under “My Account”.

Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Services.

Concord has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly. If the Client requests Concord to remove the data, we will respond to its request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the “How to Contact Us” section, and include sufficient information for Concord to identify the Client or its customer or third party and the information to delete or amend.

6. Third-Party Services

The Services may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Services. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

7. Interest Based Advertising

Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.

We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in Concord products or services so that we can send them promotional emails or serve our advertisements to them on the websites and mobile apps of other entities.

These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.

In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.

The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.

We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads - for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.

Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.

Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all - of the interest-based advertising activities in which we or third parties engage.  Choices you make may be browser and device specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices. Other third-party websites provide visitors with the ability to opt-out of receiving interest-based ads on their websites that you need to control through your settings on that website. For example, to opt out of Google’s use of your online behavior for advertising purposes, visit Google’s Ad Settings page.

8. Do Not Track Policy

Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signals. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

9. Third Party Tracking Technologies and Cookies

We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the Sites. These third parties include (1) business partners, which collect information when you view or interact with one of their advertisements on the Sites; and (2) advertising networks, which collect information about your interests when you view or interact with one of their advertisements.

The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on the Sites and on other sites across the Internet tailored to your apparent interests.

The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.

We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Policy. Other than as discussed in this document, we have no control over these third parties.

9.1 The Following Types of Cookies Are Used in the Sites:
  • strictly necessary/essential cookies - These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. These cookies don’t collect information that identifies a visitor.
  • performance cookies - These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and, therefore, anonymous. It is only used to improve how a website works.
  • functionality cookies - These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
  • behaviorally targeted advertising cookies - These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
9.2 The Following Cookies are Used in the Sites: 
Service provider Cookie name Cookie type Expiration Content
Concord Theatricals ASP.NET_SessionId 1 Session Used for session tracking
Concord Theatricals CT.Customer 3 One year Serves as the unique identifier of a Visitor.
Concord Theatricals ctauthus 3 90 Days Serves as an authentication token to identify Client
Concord Theatricals ctauthuk 3 90 Days Serves as an authentication token to identify Client
Concord Theatricals _RequestVerificationToken 3 Session Used as an anti-forgery token
Concord Theatricals laravel_session 3 2 hours This is an encrypted session cookie to store basic information about the user across requests. The information includes a unique user id, ip address, user agent, and last activity. The information is encrypted in the cookie and is not stored anywhere else on the site.
Google Analytics _ga 2 2 years Used to distinguish users.
Google Analytics _gid 2 24 hours Used to distinguish users.
Google Analytics _gat 2 1 minute Used to throttle request rate.
Feedbackify _fby_site 2 1 month Used to associate a user session with user feedback (if any) for troubleshooting.

9.3 Social Media Plugins

We use so-called social plugins, e.g. “like buttons,” on our Sites. These are services that are provided by social media organizations such as Facebook, Instagram, Twitter and others. If you access a page of the Sites that contains such a plug-in, your browser establishes a direct connection to the social media provider’s servers. Via the plugins, the providers receive the information that you have visited our Sites even if you do not have a profile or are not currently logged in. This information (including your IP address) will be transferred from your browser directly to a server of the respective provider in the USA and stored there. If you are logged in to one of the social media services, the providers may allocate your visit of the Sites to your account with them. Interactions with plug-ins like the “like button” are sent directly to the providers’ servers and stored there. The information is also stored in the social network and published on your account. The purpose and scope of the data collection and the further processing of your data by the providers as well as your relevant rights and setting options for the protection of your privacy can be found in the privacy notices of the providers.

 

Below, please find more details on the social plugins we use:

 

 

9.4 Web Beacons

 

We, or our third party partners, may employ a software technology called web beacons (also known as web bugs, clear gifs or pixels) which helps us understand what content is effective, for example by counting the number of users who have visited these pages, and to understand usage patterns. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to let us know when content is viewed. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded on web pages, ads, and email. We, or our third-party partners, may tie the information gathered by web beacons to the other information we collect about you.

10. Minors and Children’s Privacy

Protecting the privacy of young children is especially important to us. The Services are not intended to be used by minors and are not intended to be used to post content to share publicly or with friends. To the extent that a minor has posted such content on the Services, the minor has the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as indicated in the “How to Contact Us” section. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.

 

  • COPPA. We strive to comply with the Children’s Online Privacy Protection Act.  We do not knowingly collect any Personal Data from those under the age of 13.  If you are under 13 years of age, please do not provide any Personal Data to us.  If you feel that we have unknowingly collected Personal Data from someone under the age of 13, please contact us immediately as described in the “How to Contact Us” section below and this information will be removed.  For more information on how to protect your children online: Visit onguardonline.gov for social networking safety tips for parents and youth.
  • GDPR. We strive to comply with the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”).  The Sites and Services are not intended for children and we do not knowingly collect data relating to anyone under the age of 16 in cases where GDPR is applicable.  If you feel that we have unknowingly collected Personal Data from someone under the age of 16 in a country where GDPR is applicable, please contact us immediately as described in the “How to Contact Us” section below and this information will be removed.

11. Data Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Services, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

12. Data Retention

We only retain Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:

  • the contents of closed accounts are deleted within 3 months of the date of closure;
  • backups are kept for 3 months;
  • billing information is retained for a period of 7 years as of its provision to Concord in accordance with applicable laws.
  • information on legal transactions between Client and Concord is retained for a period of 10 to 20 years as of its provision to Concord in accordance with applicable laws.

13. Settings

Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Services. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Services is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Services. We cannot and do not guarantee that information you post on or transmit to the Services will not be viewed by unauthorized persons.

14. Data Transfer

All the information you provide through the Sites may be processed and stored, transferred or accessed by entities around the world as described in this Privacy Policy.  We will take steps to ensure that Personal Data and Client Data is treated securely and in accordance with this Privacy Policy.

Clients, Users and Visitors in the EU/EEA please see Section 18 of this Privacy Policy.

15. Data Controller and Data Processor

Concord does not own, control or direct the use of any of the Client Data stored or processed by a Client or User via the Services. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. Concord is largely unaware of what Client Data is actually being stored or made available by a Client or User to the Services and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client and its Users.

Because Concord does not collect or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, Concord is not acting in the capacity of data controller in terms of the GDPR and does not have the associated responsibilities under the GDPR. Concord should be considered only as a processor on behalf of its Clients and Users as to any Client Data containing Personal Data that is subject to the requirements of the GDPR. Except as provided in this Privacy Policy, Concord does not independently cause Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on behalf of Concord in connection with Concord’s provision of Services to Clients. Such actions are performed or authorized only by the applicable Client or User.

The Client or the User is the data controller under the Regulation for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.

Concord is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User nor is Concord responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.

16. Changes and Updates to this Privacy Policy

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify the Privacy Policy, we will make it available through the Services, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Services after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of the Privacy Policy.

17.  Your California Privacy Rights

If you are a California resident, California Civil Code 1798.83 provides you with the right to receive (a) information identifying any third party to whom we may have disclosed, within the preceding calendar year, your Personal Data for that third party’s direct marketing purposes, and (b) a description of the categories of Personal Data disclosed.  To obtain such information free of charge, please contact us as described in the “How to Contact Us” section below.

 

In furtherance of Section 5 above and in accordance with the California Consumer Privacy Act of 2018 (“CCPA”), California consumers have the right to request:

 

  • the deletion of Personal Data that Concord has about them;
  • additional information about whether and how Concord has collected, used, disclosed, and sold Personal Data about them; and
  • the specific pieces of Personal Data we have about them.

 

California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above.

 

When you make a request, Concord may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it.  The verification steps we take may differ depending on the request you make.  We will match the information that you provide in your request to information we already have on file to verify your identity.  If we are able to verify your request, we will process it.  If we cannot verify your request, we may ask you for additional information to help us verify your request.

 

Consumers will be required to submit their first and last names and email address, and may also be asked to provide their telephone number and/or address so that Concord can verify the request.  Please provide as much of the requested information as possible to help us verify the request.  We will only use the information received in a request for the purposes of responding to the request.

 

California law permits California consumers to use an authorized agent to make privacy rights requests.  We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer.  An authorized agent must follow the process described below to make a request.  The authorized agent must also verify his/her/their own identity.  Concord will confirm the agent’s authority with the California consumer about whom the request was made.

 

You may submit a privacy rights request to Concord by:

 

 

We are not currently selling your Personal Data and have not sold Personal Data since January 1, 2020, the date that the CCPA went into effect.

18. Your Nevada Privacy Rights

Nevada residents have the right to submit a verified request directing Concord not to sell their Personal Data.  If you are a Nevada resident and would like to submit such a request, please send your request to [email protected].

19. Users of the Sites and Services in the European Union/European Economic Area

This section of the Privacy Policy applies only if you use the Sites or Services from a country that is a Member State of the European Union (“EU”)/European Economic Area (“EEA”) and supplements the information in this Privacy Policy.

 

  • Legal Bases for Processing Your Personal Data

 

  • Site Registration. We process the listed information to provide you with the requested services and administer your registration, so for contract performance.  We also process your information in this context for IT security reasons, so for our legitimate interest to provide secure services.
  • Product Purchase. We process the listed information to transact and administer your purchase, so for contract performance.
  • Newsletters. We send you newsletters based on your consent.  If you are already a User or Visitor who has purchased goods from us, we also process your email address to offer our own similar products, programs or services that may be of interest to you.  Such processing is based on our legitimate interest to conduct direct marketing.  You may always object to such processing.
  • Participation in Special Activities. We process the listed information to administer promotions, contests and sweepstakes, so for contract performance.
  • Contact Us. We process the listed information to respond to your inquiry, so to perform a (quasi) contract with you.
  • Job Application and Submissions. We process the listed information in preparation of a potential employment or representation agreement between you and Concord.
  • Updates Concerning Us. We send you accordance updates based on our legitimate interests to provide you with working Sites and satisfying Services.  If informing you about updates is required by law, we send you accordant updates to comply with our legal obligations.

 

  • Retention of Your Personal Data

 

  • Site Registration. We retain your Personal Data as long as you use our services for registered users.  We will delete your Personal Data if you have not logged in for 3 years unless we are required or permitted by law to retain it for a longer period (for example for archiving purposes).
  • Product Purchase. We retain your Personal Data as long as you continue purchasing our products. We will delete your Personal Data if you have not purchased anything for 3 years unless we are required or permitted by law to retain it for a longer period (for example for archiving purposes).
  • Newsletters. We will retain your Personal Data concerning marketing and newsletters for as long as you do not withdraw consent or opt-out from such marketing, unless we are required or permitted by law to retain it for a longer period (for example for archiving purposes).
  • Participation in Special Activities. We retain your Personal Data up to 3 months after the promotion, contest or sweepstakes is completed, unless we are required by law to retain it for a longer period (for example for archiving purposes).
  • Contact Us. We retain this Personal Data for the time required to respond to your request and, where applicable, as required or permitted by statutory law (for example for financial statements or legal claims or archiving purposes).
  • Job Application and Submissions. If your job application or submission is successful, we retain this Personal Data for the duration of your employment with us or representation by us (as applicable), and beyond based on requirements or permissioned by statutory retention requirements.  If we do not employ you or choose your manuscript for representation, we will retain your Personal Data for the time required to respond to your request and, where applicable, as required or permitted by statutory law (for financial statements or legal claims or archiving purposes).
  • Updates Concerning Us. We retain this Personal Data for as long as you use our Services for registered Users or purchase our goods.  We will delete your Personal Data if you have not logged in or purchased anything for 3 years unless we are required or permitted by law to retain it for a longer period (for example for archiving purposes).

 

  • Automated Decision-Making

 

We may use automated decision-making technologies, including profiling, to support our data processing activities.  Our auto-mated decision-making capabilities include logic that attempts to identify titles, communications, products or offers that we believe may interest you.  By using this logic, it helps us personalize your interactions with us.  For you, this means you may see online advertisements, direct marketing communications (if you have subscribed) or other advertising or marketing messages or special offers based on your activity on our Sites or interactions with us or our third-party partners.

 

  • International Transfers

 

Your sharing of your Personal Data, in accordance with this Privacy Policy, involves transferring your information outside the EU/EEA.  Whenever we transfer your Personal Data out of the EU/EEA, we ensure a similar degree of protection is afforded to it by ensuring, where required by law, at least one of the following safeguards is implemented:

 

  • transferring Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission;
  • using specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
  • transferring personal data to the United States to an entity if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States.

 

You may be entitled, in accordance with applicable law, to request a copy of the safeguards by contacting us as described in the “How to Contact Us” section below.

 

  • Your Rights

 

In furtherance of Section 5 above and in accordance with GDPR, you may have the following rights in relation to the Personal Data we hold about you, if the accordant preconditions are fulfilled:

 

  • Right of Access. You may ask us to confirm whether we are processing your Personal Data and, if so, to provide you with a copy of that Personal Data (along with certain other details).
  • Right to Rectification. If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to ask for rectification or completion.
  • Right to Erasure. You may ask us to delete or remove your Personal Data in some circumstances, e.g. if we no longer need it or you withdraw your consent (where applicable).
  • Right to Restrict Processing. You may ask us to restrict the processing of your Personal Data in certain circumstances, e.g. if you object to us processing it.
  • Right to Data Portability. You have the right to obtain Personal Data you have provided to us in a structured, commonly used and machine-readable format for reuse under certain circumstances.
  • Right to Object. You may ask us at any time to stop processing your Personal Data and we will do so, if we (i) rely on legitimate interests to process your Personal Data except if we can demonstrate compelling legal grounds for the processing, or (ii) process your Personal Data for direct marketing.
  • Rights in Relation to Automated Decision-Making and Profiling. You have the right not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
  • Right to Withdraw Consent. If we rely on your consent as legal basis for processing your Personal Data, you have the right to withdraw that consent at any time.  This includes, but is not limited to, cases where we use your Personal Data for direct marketing purposes.

 

You may also be entitled, in accordance with applicable law, to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.

 

For more information on your rights and accordant requirements, please see the information provided by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizends_en.

20. How to Contact Us

If you have questions, comments or requests regarding this Privacy Policy, please contact us at:

 

Concord Theatricals

235 Park Avenue South

Fifth Floor

New York, NY 10003

Attn: Privacy Data Officer

 

Concord’s Data Protection Officer may be contacted at [email protected].

 

For EU/EEA users: Our local representative in the EU/EEA may be contacted via email at [email protected] or via mail at:

 

Data Protection Department

Concord Theatricals

Aldwych House

71-91 Aldwych

London WC2B 4HN

United Kingdom

 

Last update: 7 February 2020