Swinglong Limited Website Privacy & Cookies Policy
At Swinglong Limited, we are committed to protecting the personal data that we obtain about you.
This Website Privacy & Cookies Policy (“Policy”) explains how we will process the data relating to you that you provide to us (or that we may collect from other sources) when you visit our website at www.a-ha.com (“Website”).
The Website is operated by Swinglong Limited (we, us, our, Swinglong), a company incorporated in England & Wales with company number 01960666 whose registered office is located at c/o OJK Limited, 180 Great Portland Street, London W1W 5QZ.
Where we decide the purpose and means for the processing of the personal data that we obtain via our Website, we are the “data controller”. As data controller, we will comply with all applicable data protection laws.
About our Website
Our Website contains hyperlinks to third party websites, including those of our e-commerce and payment third party service providers and our associated social media sites. These websites operate independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our Website is not an endorsement. This Policy does not apply to practices of companies that we do not own or control, or to individuals whom we do not employ or manage. Should you use any of these third party websites, such use is at your own risk and we would advise that you review their respective privacy policies.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
What personal information are we likely to collect about you?
In order to provide our online sales services and other related business activities, we will need to collect and process information about you.
Information provided by you
When you use our Website, whether for browsing to obtain news about a-ha and the band’s upcoming concert tours and featured performances, to discover links to the band’s catalogue of videos posted online, to find band paraphernalia, music recordings and other a-ha branded merchandise that can be purchased by clicking on our e-Store link or to find out more about any of the other products and services that we offer, we may obtain some personal information about you.
Should you contact us using the contact details provided on our Contact Us webpage, we may obtain the following personal information about you:
- your name
- your email address
- any information that you may voluntarily provide to us, such as additional contact details (e.g. postal address or telephone numbers) or any free-text message contained in your emails or letters (which may include personal data and/or special categories of personal data)
While it is possible that we might obtain sensitive personal information about you (also referred to as special categories of personal data), we will never ask for you to provide such sensitive personal information without your explicit consent, unless we are required to process such data by law or such processing is otherwise lawful, including under a lawful exception under data protection laws.
Subscription to our Newsletters
If you decide to subscribe to our newsletters and updates about the band, we will enter your details onto our mailing list database. We may ask you to provide:
- your name
- your email address
You may also be asked if you would like to receive information and promotional communications from our e-Store and ticket sales partner third party service providers. Should you change your mind after signing up for these communications, you will be able to opt-out from any of these at any time.
Submissions to the Gallery
Our Website features a photo archive called the Gallery. In addition to the over 15,000 photos from world class, award-winning photographers featured here, we welcome submissions from amateur fan photographers who have attended a-ha’s concerts and special events over the years.
If you submit your own original photograph(s) and we decide to showcase these in the Gallery (or on any of our other social media pages), in addition to your acceptance of the terms and conditions for contributors, we will first need to obtain some personal information about you before we are able to accept and publish your contribution, including:
- your full name (including title)
- your email address and/or postal address
- your telephone number(s)
- your preferred means of contact
If you would like to contribute to the a-ha.com photo archive, you can send your original photos to email@example.com.
Purchasing from our e-Store
If you decide to make a purchase or pre-order any of the products displayed on our Website (including concert tickets, music albums and DVD or VHS videos, and other a-ha branded merchandise), once you select your items, you may be asked to select your preferred payment services provider from a list of options. When you select your preferred third party payment service provider, you will automatically be re-directed to its website where you will be asked for your shipping, billing and financial details in order to complete the purchase.
All financial transactions via our e-Store function are handled directly by our third party payment service providers. We will not share any personal information with these third party providers, nor will we receive any of the shipping, billing or financial information that you provide to them.
We use a number of different third party payment service providers in order to cater to our fan base around the globe. Below we provide you with the details of some of our most frequently used service providers:
https://www.amazon.co.uk (for Amazon UK)
iTunes Store / Apple Music (Apple Store)
Please be aware that we use other service providers than those listed above, including a number of different concert ticket sales service providers, and that the above list may be subject to change from time to time. For more information about our other third party service providers, please contact us at firstname.lastname@example.org.
Information obtained via third parties
Data Analytics & Cookies
We are always trying to improve our Website and to offer the best, most accessible service possible to all of our fans and other Website visitors.
To evaluate and make improvements, we utilise third party data analytics service providers (such as Google Analytics) to improve our visibility and to monitor website browser behaviour and navigation across the Website. These third party data analytics service providers collect this information on our behalf in accordance with our instructions and in line with their own privacy policies. We have contracts in place to protect the confidentiality of your information with all of our third party data analytics service providers.
When you visit our Website, our service providers may collect the following data, which will almost always be anonymised and aggregated before reporting back to us:
- number of visitors to our Website
- pages visited while at the Website and time spent per page
- page interaction information, such as scrolling, clicks and browsing methods
- websites where visitors have come from and where they go afterwards
- page response times and any download errors
- other technical information relating to end user device, such as IP address or browser plug-in
To find out more about the use of data analytics and cookies, including how to opt out, please read the section below entitled Analytics & Cookies.
Our Website contains links to a-ha’s social media pages on Facebook, Instagram, Twitter, YouTube, Spotify and last.fm. These third party websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible.
Should you visit those websites and choose to follow us, Swinglong Limited on behalf of a-ha.com may receive personal information about you from those independent platform providers, including:
- your name (first and last)
- your email and postal addresses
- your telephone number(s)
- IP address
- location data
- social media account url
- your login details
- your date of birth / age
- your gender
- your general interests
How do we use your personal data and on what basis?
When you visit our Website, whether to browse our content, view footage of the band, sign up to our e-newsletter, to initiate a purchase or for any other reason, we (or our third party service providers acting on our behalf) may use the personal information that you provide for the purposes listed here below. All personal information that we hold about you will be kept securely in accordance with our internal security policy.
Customer Services & Enquiries
When you contact us to make enquiries, to subscribe to our newsletter, to submit photographs for our Gallery or for any other reason, we will use your personal data to:
- provide you with information in response to your specific enquiries, concerns or complaints
- respond to emails received in relation to submissions for our Gallery feature
- send you our e-newsletters (where you have subscribed) and other updates about a-ha’s latest and upcoming releases, performances, concerts and other events and news of the band, including marketing or promotional communications
If you contact us to make an enquiry or to raise a concern about our Website or any aspect of our online services, we aim to respond to you as promptly as possible and we do so on the basis that we have a legitimate interest in replying to you.
If you email us to submit your own photographs of the band for our Gallery feature, we will only collect, use and store the photographs for the purpose of our photo archive and to showcase the band in our Gallery feature or on our other social media sites. Please be aware that, due to the numbers of email submissions received, we may not always be able to provide responses to all such emails.
Tax and other legal obligations
Like any registered company operating in the UK, we have a number of legal obligations with which we must comply. In doing so, we will use your personal data to:
- report VAT and for other company tax reporting purposes (as required by law)
- comply with regulators, law enforcement agencies or in relation to any claims that may arise
We process personal information for the legitimate interests and under the legal obligation of ensuring that use of the Website and e-shop (i) is lawful and non-fraudulent, (ii) does not disrupt the operation of our services, (iii) does not harass our staff or other individuals, and (iv) to enforce our legal rights and comply with our legal obligations.
In accordance with our legal obligations, we may disclose your information to the extent required by law which may include for financial accounting and taxation purposes with our auditors, regulators or other government bodies such as HMRC. We may also disclose your information to third parties in order to enforce or apply our contractual terms, to investigate potential breaches, to protect the rights and freedoms, property or safety of our business or those of our customers and other individuals.
Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the information we hold may be included as part of that sale, in which case you will be notified via email and/or a prominent notice on the Website of any changes in ownership or use of your information, as any choices you may have regarding that information.
Analytics & Cookies
- learn about how the Website is being used and which types of individuals are using it
- record and report user behaviour, location, audience, demographic and interest data
- record which other websites and/or platforms have referred users to the Website
- optimise and improve the Website and improve our services
- make it easier for you to fill in forms via the Website
- enable the Website to remember your preferences
- provide you with relevant advertising
Our Website also uses Google Analytics and you can find out more here: How Google uses data when you use our partners' sites or apps.
To learn how to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout/ or your Google Ads Settings.
To view Google Analytics terms of service, please visit: https://www.google.com/analytics/terms/gb.html
For example, we use data analytics to:
- process information to understand how visitors use our Website and to compile statistical reports regarding that activity. (For example, your IP address may be obtained to approximate the country from which you access our Website, enabling us to use this information in aggregate to discern various statistics, such as from where most of the visitors to our Website come e.g. EU-based or more globally).
- process information that is crucial to the running of our online business, enabling us to better forecast and meet future demand of our visitors, to provide greater access to a wide base of Website visitors, and to effectively reach out to the followers of our featured artists and others who may be interested in our featured events, merchandise and other services. We therefore undertake such monitoring in the pursuit of our legitimate interests in improving our Website, and providing a better service and source of information to visitors.
This information is not used to develop a personal profile of you.
While our Website does not provide a permanent e-Store facility, the Website often provides links to our partnering e-Store providers’ websites. All financial transactions via the e-Store are handled directly by our third party e-commerce and payment service providers. We will not receive any of the financial information that you provide to them. Please see above section “Purchasing from our e-Store” for more information about e-commerce and payment service providers which we use.
Do we share your personal information with anyone else?
We will only ever share your personal information with third parties in the ways that are described in this Policy. If you would like to find out more about how those third parties use your information, this should be set out in their respective privacy policies accessible on their websites.
Personnel, Suppliers and Subcontractors
We keep your personal information confidential, but may disclose it to our personnel, suppliers or subcontractors (including our cloud-based data processing, data analytics and payment service providers) insofar as it is reasonably necessary for the purposes set out in this Policy, provided that they do not make independent use of the information and have agreed to adhere to the rules set out in this Policy.
In some instances, this data sharing may involve the transfer of information outside the European Economic Area (“EEA”), including to personnel, suppliers and subcontractors of our group companies or those of our trusted third parties. Please see our section on International Data Transfers below.
Purchases via third party websites
If you have purchased merchandise or tickets via our Website, you will have been re-directed to one of our partnering third party payment service providers (as shown above). These service providers operate independently from us. We do not share any personal information about you with those service providers, and they will not share with us any of the personal information that you provide them.
Marketing and Communications
Where you have subscribed to our newsletters and updates, you will be asked about marketing permissions. We use the services of a third party mailing list service provider (GoDaddy.com LLC; https://uk.godaddy.com/) to provide you with our newsletter updates and promotional materials about the band.
We may anonymise information about you (so that you cannot be identified from it) and use that anonymised data to make improvements to our marketing and/or our Website or provide the anonymised data to third parties for marketing analysis purposes. We will not pass your personal information (which identifies or could be used to identify you) on to third parties for marketing purposes unless we have obtained your consent to do so.
Our Website contains links to a-ha’s social media pages on Facebook, Instagram, Twitter, YouTube, Spotify and last.fm. For more information about the data that we obtain via social media, please refer to the above “Social Media” section.
If we do receive any personal information about you from these third party social media platforms, we will not process your information for the purposes of direct marketing unless you have provided your consent or it is otherwise lawful for us to do so.
If you would like us to delete the personal information that we have received about you from these sites, please email us at email@example.com. If you do not want us to receive further information about you from these sites, you should contact the sites directly to turn off the ‘follow’ setting.
If you would like to have deleted the personal data that you’ve shared with the social media accounts that you have joined or that you follow, please contact the social media providers directly.
Your choices and rights in relation to personal data which we process relating to you
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest:
- to ask for a copy of data we are processing about you and have inaccuracies corrected;
- to ask us to restrict, stop processing, or to delete your personal data;
- to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
- to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/
To make a request in relation to any of the aforementioned rights, please email us at firstname.lastname@example.org.
If you are unhappy with the way that we are processing your personal data, please let us know. The best way to bring this to our attention is by emailing us at email@example.com.
We do not knowingly use the Website to solicit data from or to market to children under the age of 13.
If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us or otherwise interacting with our Website without consent of a parent or guardian, we ask that this be brought to our immediate attention. We will make it our priority to address this situation and delete information relating to a child as soon as practicable. In such an event, please contact us at firstname.lastname@example.org.
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our customers and other individuals who might be impacted.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss, or alteration, and unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Website and your personal information a high priority and we devote considerable time and resources to implementing and maintaining robust information technology security, no security system can prevent all security breaches. By choosing to share your personal information with us, you accept the aforesaid and provide your information at your own risk.
In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.Once the purpose for which information has been collected has been fulfilled, we will either permanently delete your personal information or remove all identifiers within it so that it is no longer personal data. We may use such anonymised data for research and/or business analysis purposes.
International Data Transfers
Our servers are located in the European Union and the information that we collect directly from you will be stored in these servers. We may also transfer your personal data to members of our group of companies and our third party service providers, many of whom may be located outside of the EU, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EU.
There are agreements in place between our group company members and with all of our third party service providers to ensure that those parties process personal data using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses.
If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this policy, please let us know by emailing us at email@example.com.
We may make changes to this Website Privacy and Cookies Policy in the future, from time to time. We will notify you of any changes to this Policy by posting the new version on our Website. You are advised to consult this Policy webpage regularly for any changes.
Questions, comments and requests in relation to this Policy are welcome and should be addressed to firstname.lastname@example.org.
Alternatively, you may address these to the data protection supervisor at c/o OJK Limited, 180 Great Portland Street, London W1W 5QZ.
This Policy was last updated in August 2018.