Privacy Policy

We respect your right to privacy and are committed to protecting your information. This Privacy Policy sets out to define how we (including Affiliates) collect and safeguard your information as well as how we use this information to improve our products and services for the benefit of all our customers both online and in store.

The personal information you choose to share with us, along with data collected on how you use our Websites help us to better understand our customers as a group and as individuals. This then helps us to advise you on the products and services that meet your needs.

DEFINITIONS

‘Affiliates’ – means those companies listed under the Affiliate Details section (as may be amended from time to time).
‘Information Commissioner’ – means the Information Commissioner’s Office in the United Kingdom.
‘Loyalty Card’ – means the loyalty card provided to you when joining the Pure HMV Rewards Club. The Pure HMV Rewards Club is currently suspended.
‘Participating Retailers’ – means retailers that are participate in the Pure HMV Rewards Club and accept our Loyalty Card as part of this scheme. The Pure HMV Rewards Club has now been suspended.
‘Privacy Policy’ – means this privacy policy as may be updated from time to time.
‘Pure HMV Rewards Club’ – means the rewards club that was run and administered by Pure HMV Loyalty Limited. The Pure HMV Rewards Club has now been suspended.
'Store(s)' means HMV and Fopp branded stores in the United Kingdom.
‘United Kingdom’ – means England, Scotland, Wales, Northern Ireland, and the Channel Islands.
‘us’, ‘we’, ‘our’ – means Sunrise Records and Entertainment Limited.
‘Websites’ – means collectively the websites at fopp.com, hmv.com, purehmv.com, store.hmv.com, carees.hmv.com and individually each website (as relevant).
‘you’ and ‘your’ – means a user of the Websites and/or Loyalty Card.

WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

We will at all times only collect and process your personal information in accordance with the General Data Protection Regulation 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2015 as amended, and any other applicable data protection legislation including the following;

• information about your computer and about your visits to and use of our Websites (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths)
• searches completed and preferences selected when using any of our Websites linked to this policy
• information that you provide to us when registering with any of our Websites (including your name and email)
• information that you provide when you register with our Pure HMV Rewards Club (including your name, email, telephone, mobile and date of birth)
• information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email)
• information that you provide when completing your profile on any of our Websites (including your name, email, telephone, mobile and date of birth)
• information relating to any purchases you make of our goods or any other transactions that you enter into through any of our Websites (including your name, email, address, phone number and payment card details)
• information that you provide when you use our Loyalty Card, in whatever form 
• information that you provide when you buy products or services from us in Stores or via our Websites
• Information you provide when you take part in promotions, prize draws, competitions, customer surveys and questionnaires
• information you provide when you interact with us on social media sites;
• information about your use of our Loyalty Card and purchases (including your credit or debit card details)
• in person e.g. when purchasing an item in a store operated by us
• information you provide in a store when you order an item for home delivery
• Information that you provide when installing any of our apps
• information that you give us when you contact us in writing or by phone
• any other personal information that you choose to send to us

Finally, we may receive information about you from third parties who are legally entitled to disclose that information.

Please read this Privacy Policy carefully. By using any of our Websites, participating in Pure HMV Rewards Club programme or supplying your details to us by any other means, you agree to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please stop using our Websites and/or Loyalty Card immediately.

HOW DO WE PROCESS YOUR DATA?

By using our Websites and/or Loyalty Card or supplying your personal information to us by any other means, you agree that your information may be used by us (and where relevant by our Affiliates) for any of the following purposes:

• to process the delivery of goods ordered either online and/or in person e.g. when ordering product  in a Store
• to manage and improve your experience of our Pure HMV Rewards Club and use of the Loyalty Card
• to provide you with a personalised browsing experience when using our Websites
• to fulfil any contractual agreements between you and us
• when we have your consent, to send you details via email of other products and services which we think may interest you, or to conduct market research
• when we have your consent, to send your details (including name, email, phone number, address and date of birth) to third parties who require this information to enable them to deliver or to provide to you any prizes you have won when entering our competitions or prize draws
• to manage and operate any account that you hold with us
• to understand your shopping behaviour in order to develop and improve our products and services
• to request service review feedback
• to request and permit marketing opt-in confirmation
• to process your purchases
• to check and verify your identity and prevent and detect crime including any suspected fraudulent behaviour
• to reply to any queries, refund requests and complaints
• to comply with legal and regulatory requirements

We will only process your data for marketing purposes if you have given consent in the form of ticking the box when registering a new account, if you have opted in to receiving communications from us via your existing account settings, during the checkout process or you have signed up to one or more of our mailings lists via another means.

With your consent, we may contact you:

• with offers and information about our products and/or services;
• with offers and information about Participating Retailers products or services; and
• for customer research, e.g., to help improve our services.

You may indicate your consent to the above when signing up to our Pure HMV Rewards Club or on our Websites by ticking boxes indicating your consent.

You may opt-out from receiving marketing communications at any time by:

• following the opt-out instructions contained in the communications that we send you, such as clicking on the "unsubscribe" link on any email newsletter that we send to you;
• changing your marketing preferences when logging into your account online at each Website (as relevant); or
• Contact Us by using the Online orders option and sending us an email.

IS MY INFORMATION SHARED WITH ANYONE ELSE?

We will share your information with Affiliates where you join our Pure HMV Rewards Club (listed under Affiliate Details); delivery and services (listed under Affiliate Details) and payment providers (listed under Payment Providers) where you make a purchase on a Website.

We use your information only as set out in this Privacy Policy and will not sell, rent, or pass your information on to others for marketing purposes without your express consent. We may, however, share aggregated data with third parties in order to develop and enhance our Pure HMV Rewards Club and Loyalty Cards. This is statistical data which will not include information that could identify any individual.

We may also release account information where we believe in good faith that this release is reasonably necessary to comply with the law.

We may also disclose your information to third parties in connection with the sale, transfer, or disposal of our business, provided that they continue to use your information substantially in accordance with the terms of this Privacy Policy

HOW LONG WILL MY DATA BE RETAINED?

We will keep your personal information only for as long as necessary to fulfil the purposes for which we are processing your personal information unless the law permits or requires longer. For example, we might need to keep your personal data to assist with any warranties that may exist.

COOKIES & TRACKING

Our Websites use cookies and other tracking technologies to collect information about your online preference. Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. Please refer to How we use cookies to manage and learn more about how we use cookie data.

OTHER TRACKING TECHNOLOGIES

We also use your IP address and User Agent to gather non-personal information about how you interact with our site. When you visit our site, your IP and User Agent are assigned a random ID (using SHA256 encryption). Once encrypted, the raw IP Address and User Agent data is then deleted. This aspect of user tracking garners no personally identifiable information and uses no tracking cookies.

DISCLOSURE ON QUIVIDI ANONYMOUS MEASUREMENT SYSTEM

Sunrise Records and Entertainment Limited, as data controller, uses digital advertising systems located at selected Stores that are equipped with a counting and measurement system produced by the company Quividi SAS.

The software does not record and does not broadcast any image or video; it only collects anonymous numerical descriptors in order to identify the number of bystanders at any given moment and their demographic composition (by way of gender and age estimate).

The images detected by the software are never stored. From a technical standpoint, each image is present only in the volatile memory of the computer for a very short period of time and then immediately overwritten without any recording. All the anonymous data generated and collected by the counting and measurement systems of the audience are treated exclusively with IT systems, encrypted and sent securely to the servers hosting the service.

The aggregate information is treated exclusively by us in compliance with the provisions of the General Data Protection Regulation 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2015 as amended.

For further details, you can consult the FAQs concerning the product and the procedure by which anonymous data is managed at www.quividi.com/privacy or contact us directly using the details in the Contact Us section below.

HOW IS MY INFORMATION KEPT SAFE?

We follow strict technical and organisation security procedures in the storage and disclosure of information, which you have given us. This is to prevent the loss, unauthorised access, or unlawful processing of your personal information. We keep your information confidential and store it on a secure server which is password protected, hidden behind a firewall from the outside world.

However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet.

We (or Affiliates on our behalf) may store or process information that we collect about you within the European Economic Area adhering to the General Data Protection Regulation 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2015 as amended, and any other applicable data protection legislation.

WHAT ARE MY RIGHTS?

You have certain rights in relation to your personal information, including the right to;

• request access to and obtain a copy of your personal information (Subject Access Request)
• rectification of your personal information if it is no longer accurate
• erasure of your personal information if our retention is no longer necessary for the purposes for which it was collected
• restrict or object to the processing of your personal information (in certain circumstances)
• data portability (if applicable)

If you wish to exercise any of your rights in relation to your personal information, please send your request to us in writing via any of the following means;

• by email using address dataprotection@hmv.co.uk
• by post, Data Protection Officer, Sunrise Records and Entertainment Limited, Mermaid House, Puddle Dock, Blackfriars, London, EC4V 3DB

You also have the right to contact the Information Commissioner if you are unhappy with our privacy practices advised in this Privacy Policy.

MISUSE OF PERSONAL DATA

Any improper collection or misuse of personal information is in violation of this Privacy Policy. Please report it by emailing dataprotection@hmv.co.uk

You agree not to misuse any personal information available on our sites or to gather it or use robots or other automated scripts, codes, or functionalities to do so.

We may immediately suspend or terminate your access to any of our Websites without notice if we become aware that you are in breach of applicable terms and conditions of use or of this Privacy Policy.

EMAIL COMMUNICATIONS

The following disclaimer is appended to every non-marketing email we send to external email addresses:

DISCLAIMER: This email message is confidential and for use by the addressee only. If you are not the intended recipient, please retain confidentiality, delete the message, and advise the sender immediately of the error in transmission. Please then delete the message from your computer. Internet emails are not necessarily secure. 

Whilst all reasonable care has been taken to avoid the transmission of viruses, it is the responsibility of the recipient to ensure that the onward transmission, opening or use of this message and any attachments will not adversely affect its systems or data. No responsibility is accepted by the sender in this regard and the recipient should carry out such virus and other checks as it considers appropriate.  

Companies with company numbers: DKB Group Trading Limited (11914017), DKB Managed Services Limited (11968180), DKB Toys and Distribution Limited (13201192), Everest Sunrise Limited (11805762), Mightymast Leisure Limited (02357314) and Sunrise Records and Entertainment Limited (11805729). Registered in England and Wales with registered offices at Mermaid House, Puddle Dock, Blackfriars, London, EC4V 3DB.

AFFILIATE DETAILS

DPDgroup UK Limited incorporated and registered in England and Wales with company number 732993, whose registered office is at ROEBUCK LANE, SMETHWICK, B66 1BY.
DPD privacy policy

Encompass Print Limited incorporated and registered in England and Wales with company number 05858982, whose registered office is at ENCOMPASS HOUSE, MANNERS INDUSTRIAL ESTATE, 17 BIRKDALE CLOSE, ILKESTON, DERBYSHIRE, DE7 8YA.
Encompass privacy policy

Emarsys UK Limited incorporated and registered in England and Wales with company number 06892602, whose registered office is at 1ST FLOOR, FOCUS POINT REGENT QUARTER 21 CALEDONIAN ROAD, LONDON, N1 9DX.
Emarsys privacy policy

Inpost UK Limited incorporated and registered in England and Wales with company number 08090698, whose registered office is at UNIT C BOUNDARY PARK, BOUNDARY WAY, HEMEL HEMPSTEAD, HERTFORDSHIRE, HP2 7GE.
InPost privacy policy

Royal Mail Group Limited incorporated and registered in England and Wales with company number 03087786, whose registered office is at 100 VICTORIA EMBANKMENT, LONDON, EC4Y 0HQ.
Royal Mail privacy policy

Trustpilot A/K registered in Denmark, whose registered office is at PILESTRAEDE 58, 5TH FLOOR, DK-1112 COPENHAGEN K, DENMARK.
Trustpilot privacy policy

Zendesk Inc. incorporated and registered in the USA, with offices at 989 MARKET STREET, SAN FRANSISCO, CA 94103, USA.
Zendesk privacy policy

ZigZag Global Limited incorporated and registered in England and Wales with company number 09404819, whose registered office is at 4th FLOOR, 7-10 CHANDOS STREET, LONDON, W1G 8DQ 
ZigZag privacy policy

PAYMENT PROVIDERS

All Fopp and HMV branded stores and store.hmv.com financial transactions are handled through payment services provider WorldPay (UK) Limited. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via store.hmv.com, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
WorldPay privacy policy

KLARNA 

To offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.
General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s Privacy Policy.
Klarna privacy policy

Last updated: 21 February 2022