1. Privacy & Cookies Notice
Welcome to MelodyVR’s privacy & cookies notice (“Notice”).
We respect your privacy and are committed to protecting your personal data. This Notice explains how we handle your personal data when you use our virtual reality platform and service, including all features and functionalities, website, and user interfaces, and all content and software associated with the service that may be offered from time to time through a variety of Access Points (defined below), (collectively as the “Service”) or where you are an artist who works with us to provide content for the Service.
The term “Access Points” refers to, collectively, the MelodyVR website (available at: https://melodyvr.com/, the “MelodyVR Site”), applications, and other places where the Service and the Content are available, including websites, applications, software and hardware of MelodyVR’s third party distribution partners, third party platforms and/or websites where users or website operators are permitted to embed, stream or have otherwise licensed the Content.
“Content” means any live and on-demand programmes, including full concerts, individual tracks, and other audiovisual content that you select when using the Service.
Where you access the Service and/or Content through a third party’s platform, website, application, software or hardware, this Notice does not cover any personal data that is collected by such third party. Any personal data that you disclose to such third party will be governed by that third party’s own privacy notice, which will apply in addition to this Notice. You should review the privacy notices of all such third party sites before providing any information to them. We are not responsible or liable for the privacy practices or policies of any such third party. Any personal data that you provide to such third parties is at your own risk.
Important information and who we are
Purpose of this Notice
This Notice explains how we collect and process your personal data through your use of the Service, including any personal data you may provide to us when you sign up to the MelodyVR Site or view any Content and how we use personal data of artists.
The Service is not intended for children and we do not knowingly collect personal data relating to children.
It is important that you read this Notice together with any other Notice or fair processing notice we may give on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Notice supplements the other notices and is not intended to override them.
MelodyVR Limited is the organisation responsible for the collection, use and disclosure of your personal data.
Singnet Pte Ltd (company registration no. 199802130W) acting for and on behalf of itself and, where applicable, Singtel Mobile Singapore Pte Ltd (collectively “SingTel”), is our authorised reseller for the Service in Singapore, which may be offered, marketed and distributed to you, subject to such terms as may be made available by SingTel.
If you have any questions about this Notice, including any request to exercise your legal rights, please contact email@example.com.
You have the right to make a complaint at any time to the Personal Data Protection Commission (PDPC) for data protection issues (www.pdpc.gov.sg). We would, however, appreciate the chance to deal with your concerns before you approach the PDPC so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The MelodyVR Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the MelodyVR Site, we encourage you to read the Notice of every website you visit.
“Personal data” means any information about an individual, whether true or not from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you and any Content you have accessed together with any other details of products or services you have purchased from us where relevant.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the MelodyVR Site.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use the Service.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Artist Data means, for artists, in addition to Identity Data, Contact Data and Transaction Data as relevant, information related to the artist’s music, record company and or publisher details.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing specific Content. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect your National Registration Identification Card, passport or foreign identification number. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to validate your account or provide you with Content or to work with you where you are an artist). In this case, we may have to restrict access to the Service but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on the MelodyVR Site;
- subscribe to the Service;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- work with us as an artist; or
- give us some feedback.
Automated technologies or interactions.As you interact with the MelodyVR Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the cookies section of this Notice for further details.
Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties analytics providers such as Google;
- Identity and Contact Data from publicly availably sources.
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party), which a reasonable person would consider appropriate in the circumstances.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on your express consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need further information about the specific legal ground(s) we are relying on to process your personal data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer or artist||(a) Identity
|Performance of a contract with you|
|To deliver the Service or work with you as an artist:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and the MelodyVR Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the MelodyVR group of companies for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any emails or marketing message sent to you or by contacting us at any time by emailing firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies (subject to your preferences):
- Strictly necessary cookies.These are cookies that are required for the operation of the MelodyVR Site. They include, for example, cookies that enable you to log into secure areas of the MelodyVR Site. We do not require consent for these cookies.
- Analytical/performance cookies.They allow us to recognise and count the number of visitors and to see how visitors move around the MelodyVR Site when they are using it. This helps us to improve the way the MelodyVR Site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies.These are used to recognise you when you return to the MelodyVR Site. This enables us to personalise our content for you, greet you by name and remember your preferences.
- Targeting cookies.These cookies record your visit to the MelodyVR Site, the pages you have visited and the links you have followed. We will use this information to make the MelodyVR Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more details about the specific cookies we use including details of third parties to whom such information is provided through our [cookie preference center].
Change of purpose
We will only use your personal data for the purposes for which we collected it.
If we need to use your personal data for an unrelated purpose for which your consent is required, we will notify you of the purpose and seek your consent as required .
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.
- Other companies in the MelodyVR Group.
- Third party service providers.
- Professional advisers.
- Inland Revenue Authority of Singapore, regulators and other authorities.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers
We do not transfer your personal data outside Singapore except where we are satisfied that the organisation(s) to which we transfer your personal data outside Singapore provide a standard of protection to personal data so transferred that is comparable to that afforded to you under this Notice.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, in which circumstances you may have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you give us.
Request erasure of your personal data. You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. You may also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You may also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. You may ask us to suspend the processing of your personal data if: (a) you want us to establish the data’s accuracy; (b) our use of the data is unlawful but you do not want us to erase it; (c) you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.