Privacy & Cookie Policy – Band Manager

1. General

This Privacy & Cookie Policy describes the way we process your personal data for the Band Manager platform.

We take the protection of your personal data seriously and comply with the applicable legislation, including the General Data Protection Regulation (“GDPR”), and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of their personal data.

This Privacy & Cookie Policy applies to our Band Manager Platform (hereafter the “Platform”). The Platform consists of various websites, apps, API’s and related services and software, including the url www.bandmanager.be or other domain names (hereafter the “Website”) and related services (hereafter the “Services”), applications (hereafter the “App”) and software (hereafter the “Software”). These are hereafter together referred to as the “Platform”. The goal of the Platform is to facilitate the management of sheet music for bands, orchestras, choirs, music schools, etc. in an online digital environment.

Upon your first registration on, or upon your first use of, the Platform, you will be asked to accept this Privacy and Cookie Policy. Any further use of the Platform implies that you agree with and are bound by this Privacy and Cookie Policy.

This Privacy & Cookie Policy applies to you because you are a registered user of the Band Manager Platform or because you visited the Platform (including the Website) of Band Manager.

Users, customers and visitors to our Platform are hereinafter referred to as "Users".

Capitalized terms in this Privacy & Cookie Policy will have the same meaning as in the Band Manager Terms & Conditions that apply to use of the Platform.

This Privacy & Cookie Policy can be adjusted if our services or the applicable legislation so require. We will then communicate the new version of the Privacy & Cookie Policy to you and publish it on our Platform. Further use of the Platform after you have been informed of the updated Privacy & Cookie Policy is considered an acceptance of the new Privacy & Cookie Policy.

2. Who processes your personal data?

Codewolf, with registered office at Fazantenlaan. 49, 8900 Ieper, registered in the Belgian Crossroads Bank for Enterprises under the number 0550.541.019 (hereinafter "Codewolf", “Band Manager” and "We") is responsible for the processing of your personal data on the Platform.

3. What personal data do we process?

We collect certain personal data from Users of the Platform (Website, App, API, Services and/or “Software”). These include in particular the following information:

Category 1: We process the name (surname and first name) and contact details of the Users of the Platform (e-mail, telephone number, address, visa and bank information for Organization-Users, etc.) and their function or role within the Organization-Member (e.g. which instrument do they play). If an Organization-User registers as a User on the Platform, we also process the name and contact details of the representative of the Organization-User (the “Administrator”) and of the various members of the Organization-User (the “Members”). These personal data of Administrators or Members are processed by us because the Administrators or the Members communicate these to us for processing, for example at the time of registration with the Platform or thereafter, or upon registration for our newsletter, or when you contact us by sending an email or completing the contact form on the Platform. Organization-Users and Administrators warrant and represent that they have the full right and permission to communicate personal data of their Members to us for processing. We emphasize that we will not share these data with third parties (apart from other Members that are linked to the same Organization-Member so that these Members can communicate with each other and with the Administrator, in particular for sharing sheet music), unless we are legally required to do so.

Category 2: Other data may also be processed if you explicitly share it with us, such as your gender, interests, age, date of registration to the Platform, national (insurance) numbers, etc. This data can be communicated to us at the time of registration with the Platform or upon registration for our newsletter. Here too, communicating this data to us and accepting this Privacy and Cookie Policy means that you give us permission for this processing.

Category 3: After your registration with the Platform we can also register your IP address. Accepting this Privacy and Cookie policy constitutes permission for processing this.

Category 4: In addition, certain data is collected via cookies. See below in article 11 more information regarding our use of cookies. Here too, accepting this Privacy and Cookie policy applies as permission for this processing.

If personal data of minors should be passed on to us, the person who passes this data on to us will be exclusively responsible and liable for the processing of this data.

In principle, we do not process special and/or sensitive personal data, unless you explicitly communicate such data to us.

Codewolf guarantees that all personal data will only be viewed by employees or associates to the extent that this is necessary for the performance of their duties. In addition, these persons are bound by a confidentiality obligation with regard to your privacy.

4. Legal grounds for processing your personal data

By communicating your personal data to us (for example when registering with the Platform or when submitting personal data to us through the contact form on our Platform or through other means), and accepting this Privacy and Cookie policy, you consent to the processing of your personal data. By continuing to use the Platform (for example logging in to the Platform), our newsletters or our Website or App, you confirm your acceptance of this Privacy and Cookie Policy every time.

The need to be able to offer you the contractually agreed services (namely access to the Platform) is an additional legal basis for the processing of your personal data (in other words, the execution of the agreement between you and us is also a legal basis for processing your personal data).

5. For which purposes do we process your personal data?

We process your personal data to enable Users to gain access to the Platform and to allow the Platform to function optimally, and to notify you of updates and other information with regard to the Platform.

More precisely, we process your personal data to:

For category 1 data: to be able to offer you the contractually agreed services.
For category 1 and 3 data: To ensure that the Platform functions optimally, namely to ensure that it permits Users to upload, share, read, manage and download digital sheet music in a safe and accessible environment, and to communicate with each other within closed groups;

For category 1 and 2 data: To provide you with targeted information such as e-mails and newsletters that may interest you (including information regarding new functionalities or details of our services;
For category 3 and 4 data: To do analytical research to optimize our Platform on technical and content level; and to map, based on anonymous data, the preferences, interests, surfing behaviour and backgrounds of the Users of our Platform (for more information on anonymous data, see article 11 regarding cookies below);
For data from category 1 to 4: to answer any questions from Users and to manage the technical administration of our Platform.

Your personal data is kept strictly confidential and will not be disclosed to third parties or used for direct marketing, unless we have obtained your explicit prior consent (“opt-in”), such for the purposes as explicitly stated in this Privacy and cookie policy (including newsletters), or unless we are legally obligated to disclose certain information e.g. to competent authorities. Your permission can be withdrawn at any time, without justification and free of charge by sending an e-mail to Dit e-mailadres wordt beveiligd tegen spambots. JavaScript dient ingeschakeld te zijn om het te bekijken..

Disclosure of anonymous data to third parties is permitted.

We have the right to communicate your data, in the event of (suspicion of) serious violations of the law or of the Terms and Conditions to the competent judicial services or police services or to third parties whose rights might have been violated (e.g. owners of copyrights to sheet music). We can also do this to protect our rights or those of third parties or to safeguard the safety of Users of the Platform.

6. For how long do we process your personal data?

All personal data is stored for the period necessary for us to deliver our Services to you.

This Privacy Policy remains valid between you and us until one of the parties cancels the entire contractual relationship with regard to the Platform in writing (cancellation is possible by email or by deleting your account). The processing of your personal data remains valid until the termination of the contractual relationship between you and us with regard to the Platform. Upon termination of the contractual relationship, we will automatically delete your personal data, unless we are legally obliged to keep certain personal data for a longer period. Codewolf has the right (but not the obligation) to continue processing personal data of Users for a period up to 3 months after termination of the contractual relationship to allow Users to re-activate their accounts and restore data connected to it or to transfer data to other service providers. …

7. Sharing of personal data with third parties

Codewolf does not disclose your data to third parties, unless this is necessary for the implementation of our legal obligations and qualifications or for the services we provide to you. If companies process your data on our behalf, we will conclude a data processing agreement to ensure an adequate level of security and confidentiality. Codewolf remains responsible for such processing. We will not sell or trade your personal data to third parties (except if this concerns the total or partial sale or transfer of the Platform or the Services).

8. Right of access, correction, and objection

You have the right to have free access to your personal data at any time. You can access your personal data by logging in to your account or you can request access by sending an email to Dit e-mailadres wordt beveiligd tegen spambots. JavaScript dient ingeschakeld te zijn om het te bekijken.. You also have the right to correct or change your personal data if they are incorrect, incomplete or irrelevant. You can do so by logging in to your account (and correct/change the data yourself) or by sending an e-mail to Dit e-mailadres wordt beveiligd tegen spambots. JavaScript dient ingeschakeld te zijn om het te bekijken.. For questions regarding accessing or correcting data, we ask you to always enclose a copy of your identity card so that we can verify your identity before we communicate this information. You also have the right to transfer your personal data to another entity responsible for the processing of your data (request to be sent via the same email address).

You have the right to object to the processing of your personal data. This can be done by sending an e-mail to Dit e-mailadres wordt beveiligd tegen spambots. JavaScript dient ingeschakeld te zijn om het te bekijken. (also with the addition of a copy of your identity card). However, you cannot object to the processing of your personal data if this is necessary for the fulfilment of the contractual obligations or compliance with the law.

You are always responsible for the accuracy of the information that you provide to us.

9. Contact: information, questions or complaints

If you have any questions, comments or complaints regarding the processing of your personal data or with regard to cookies, you can communicate this, either directly to us (by email: Dit e-mailadres wordt beveiligd tegen spambots. JavaScript dient ingeschakeld te zijn om het te bekijken. or through the contact details on our Platform or the postal address stated at the top of this Privacy & Cookie Policy), or to the Data Protection Authority (this is the former Privacy Commission: Drukpersstraat 35, 1000 Brussels, Dit e-mailadres wordt beveiligd tegen spambots. JavaScript dient ingeschakeld te zijn om het te bekijken., +32 (0)2 274 48 35, or through the contact details on its website www.gegevensbeschermingsautoriteit.be).

10. Data leaks

If you notice or suspect that a data leak has occurred, we request you to contact us as soon as possible (by email Dit e-mailadres wordt beveiligd tegen spambots. JavaScript dient ingeschakeld te zijn om het te bekijken. or through the contact details on our Platform or the postal address stated at the top of this Privacy & Cookie Policy), or the Data Protection Authority (Drukpersstraat 35, 1000 Brussels, Dit e-mailadres wordt beveiligd tegen spambots. JavaScript dient ingeschakeld te zijn om het te bekijken., +32 (0)2 274 48 35, or through the contact details on its website www.gegevensbeschermingsautoriteit.be).

11. Security

We take the security of your personal data seriously and have taken technical and organisational measures to protect your personal data.

Our Website is equipped with an SSL certificate (https connection) so that the communication between you and our Website is encrypted by adequate encryption standards.

We are, however, not liable for direct or indirect damage arising from your incorrect or unlawful use of personal data. You yourself are responsible for correctly storing your password, access code and other login details, and for keeping these confidential. Any negligent or unlawful use of these data by the User or a third party (unless this was caused by a mistake on our part) falls outside our responsibility and liability. In case of loss, theft, or unlawful use of your login details you must inform us as soon as possible.

Our Platform might contain links to other websites which we do not control and to which this Privacy & Cookie Policy does not apply. We are not liable for the content of these websites.

12. Information with regard to cookies

12.1. Information regarding our use of cookies

Cookies are small text or number files that are stored to the hard disk of the computer of website visitors. Cookies contain information such as the language preference of the surfer, to prevent him/her from having to enter this information again with each next visit to the same website. Some cookies enable a website to be displayed in a graphically correct manner, other cookies ensure the proper functioning of a website application, etc.

Our Platform uses cookies and similar technologies to distinguish your preferences for use from those of other users. This helps us to offer you a better user experience and allows us to optimise our Platform. Cookies make the interaction between our Platform and our users easier and faster. For example, they help you navigate between the different sections of our Platform. By identifying you through a cookie, we ensure that you do not have to enter the same data each time. We also use cookies to personalise the content of our Platform and make this more interesting for our users (for example, by tailoring the content to your personal interests). In addition, we use cookies to analyse your surfing behaviour (for example, how often and for how long certain pages are visited, in what way the interaction between various pages takes place, etc.). Statistic results enable us to improve our Platform where necessary by responding to the preferences and needs of our users.

Cookies and similar technologies do not allow for our systematic collection of data that can identify the users of our Platform. They help us to improve the functioning of our Platform, to better respond to the interests of our users, and to measure the efficacy of the content of our Platform.

12.2. Consent

When you first visit our Platform, you will be asked to accept this Privacy & Cookie Policy. For optimal use of our Platform, you need to accept the cookies.

You can do so through the browser settings, or by explicitly accepting our Privacy & Cookie Policy on registration or during a visit to our Platform. For certain cookies, you can also do this by continuing to surf on our Platform after seeing a “cookie warning” during your first visit to our Platform.

You can disable or block certain cookies through your web browser. Below you will find how you can do this for the most common web browsers:

Please note that if you disable or do not accept cookies, you will not be able to make (optimum) use of (certain parts of) our Platform.

Please note too that you cannot adjust all types of cookies in this way. Certain functionally necessary cookies and statistics cookies cannot be adjusted, as these cookies are necessary for the functioning of our Platform or for collecting general information on the way in which our users use the Platform. The data we collect through these cookies are always anonymous.

12.3. What cookies do we use on our Website?

We may use various types of cookies on our Platform, e.g. cookies that save your preferred language; security cookies; cookies that save your registration or login details; cookies that save certain preferences (e.g. for receiving newsletters, localisation of region, etc.); cookies that save certain interests; cookies used for statistical research in order to optimise the form, content, or structure of our Platform or for analysing the surfing behaviour or the origin of visitors, always on the basis of anonymous data (e.g. Google Analytics cookies); tracking cookies that enable us or partners to send, based on anonymous data, suggestions to users through newsletters, etc.

Below you will find a detailed list of cookies we use on our Platform:

Cookie	Description of purpose
Google Analytics:	Google Analytics is the analytics tool of Google that helps operators of websites understand how their visitors interact with their website. Google Analytics may use a set of cookies to collect information and to report statistics on the use of the website, without the identity of visitors being reported to Google. The most important cookie used by Google Analytics is the '__ga'-cookie. For more information, see https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Application Insights	Used by Microsoft Application Insights software to collect statistical usage and telemetry information. The cookie stores a unique identifier to recognize users on returning visits over time. Possible cookies: ai_user, ai_session
Joomla	https://www.joomla.org/cookie-policy.html