1. Flat approach to privacy
1.1 We operate a service which allows you to create, edit, share and collaborate on music scores using our website located at www.flat.io and the Flat application (available for download on your mobile device) (the “Service”).
1.4 The Service is operated by Tutteo Limited (“Flat”, “we”, “our” or “us”) and we act as a data controller in relation to the personal information we hold about you.
2. Personal information we collect about you and how we use it
2.1 We collect personal information about you when you voluntarily submit information directly to us through our Service. This can include information you provide to us when you register with us, edit your profile, share content, purchase services, correspond with us, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to a survey, enter a promotion or use some other feature of our Service.
2.2 At various places on our site or our app you may be requested to enter certain personal information. Personal information that must be provided in order to use the requested services will be indicated at the time of collection. If you choose not to provide this personal information, we may not be able to provide some or all of the features and functionalities of the Service to you or respond to your other requests. Other personal information that you are not required to provide in order to receive our services may be voluntarily given and you are free to decide not to give such personal information.
2.3 The table sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of the personal information.
2.4 We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.
2.5 The table sets the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of the personal information.
2.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
2.7 We may anonymise and aggregate any of the information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and features.
3. Information we share with third parties
- (a) Social networks: if you are a Flat Individual user you can choose to make your content public and share your content on a social network. If you do, we will share your content with that social network. As part of the Service, other users can share your public content with social networks.
- (c) Service providers and advisors: third parties who provide a service to us. For example, third party service providers either provide IT infrastructure or help support it, help us to provide you with support in relation to the Service, process payments from you on our behalf, develop analytical information for us about our products and services and provide professional services such as legal and accountancy services. These third parties will only be allowed to use your personal information in accordance with our instructions and will be required to keep your information secure.
- (e) Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal information to or to whom we need to disclose your personal information to protect our rights, property or safety or to protect the rights, property or safety of others. We may also disclose personal information to third parties to help detect and investigate illegal activities and breaches of any agreement we have with you.
3.2 We do not disclose information about identifiable individuals to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of our Service but we will make sure no one can be identified from this information before we disclose it.
4. Marketing and advertising
4.1 From time to time we may contact you with information about our products and services. Most marketing messages we send will be by email. If you are using our app we may also send you push notifications. For some marketing messages we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
4.2 We will only send marketing messages to you if you have given us your consent to do so. We will only send marketing messages to users of our Flat Individual service or to users of our Flat Education service that have a designated “teacher” account. We will ask you if you would like to receive these messages when we first collect your contact details. You can also change your marketing preference at a later date by following the instructions outlined below.
Email – click on the unsubscribe link at the bottom of our marketing emails. If you have an online account with us you might be able to opt-out of marketing emails, features updates and comment notifications through your account settings.
App push notifications – you can change your push notification preferences at any time in the account settings for the app.
4.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.
4.5 You can also let us know at any time that you do not wish to receive marketing anymore by sending an email to us at firstname.lastname@example.org. You may also be able to unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.
5. Storing and transferring your personal information
5.1 Retention period: We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.
5.2 Security: we implement appropriate and reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change, or damage. All personal information we collect will be stored on our secure servers.
5.3 Phishing: We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
6. Our policy towards children
6.1 Our Flat Individual Service is not directed to persons under 13 and we do not knowingly collect personal information from children under 13. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
6.2 Our Flat Education Service may be used by children under 13, but only with the prior consent of their parent or school, as permitted by the Children’s Online Privacy Protection Act (COPPA). If Flat collects information from children under 13 through the Flat Education Service, Flat will collect, use, share and store such data only for the purposes of providing services to the student contemplated in our agreement with the school.
7. Your rights in respect of your personal information
7.1 If you are resident in the European Economic Area, in accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
- (a) Right of access. You have the right to obtain:
- (i) confirmation of whether, and where, we are processing your personal information;
- (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
- (iii) information about the categories of recipients with whom we may share your personal information; and
- (iv) a copy of the personal information we hold about you.
- (b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
- (c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
- (d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
- (e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- (f) Right to object. You have a right, in some circumstances, to object to any processing based on our legitimate interests. There may, however, be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case.
7.3 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
8. Cookies and similar technologies
8.2 Cookies are pieces of code that allow for personalisation of our website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.
8.3 We use the following types of cookies:
- (a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- (b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Online Services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
- (c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
8.4 The table at Annex 3 sets out further details about the cookies which are most frequently used on our website.
- (a) Cookie settings in Internet Explorer
- (b) Cookie settings in Edge
- (c) Cookie settings in Firefox
- (d) Cookie settings in Chrome
- (e) Cookie settings in Safari web and iOS.
8.6 If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative’s online sources at www.networkadvertising.org.
9. Links to third party sites
Our Service may, from time to time, contain links to and from third party websites of our partner networks, advertisers, partner merchants, news publications, retailers 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 their policies. Please check the individual policies before you submit any information to those websites.
10. Changes to this policy
11. Notice to you
12. Contacting us