Privacy Policy

This privacy policy tells you how we use your personal data.

· Section 1: Introduction

· Sections 2 - 3: What information we collect, use, and why

· Sections 4 - 5: Sharing and transfer of data

· Section 6: Retention and deletion of data

· Section 7: Lawful bases and data protection rights

· Sections 8 - 11: Use and management of cookies

· Section 12: Contact details and how to make a data protection complaint

· Sections 13 - 14: Amendments and credits

1. Introduction

1.1 We are committed to safeguarding the privacy of our members and website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our members and website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.4 In this policy, “we”, “us” and “our” refers to Lyra Voices Limited. For more information about us, see Section 13.

2. What information we collect, use and why

2.1 We collect or use the following information to provide services, market and grow our business and manage your membership:

(a) name and contact details

(b) account status and history

(c) purchase history and payment information (card details are stored on our system, to enable automatic payments to be taken, but we do not have access to this information)

(d) website user information (including user journeys and cookie tracking)

(e) photographs and video recordings (including audio)

(f) information relating to compliments or complaints

2.2 We also collect or use the following special category information to provide services. (This information is subject to additional protection due to its sensitive nature.)

(a) health information (including health conditions, disabilities, allergies and dietary requirements)

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of enabling and monitoring your use of our website and services. operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name, telephone number and email address. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.5 We may process and use recorded images such as photos, video and audio recordings for marketing purposes. In addition, photos and videos are used to document our members’ work, evaluate their progress and help us identify learning points. The source of this data is classes, rehearsals, performances and events. The legal basis for this processing is our legitimate interests, namely enabling the advertising of our services, growing our business and supporting good educational outcomes.

3.6 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

3.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.9 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.13 Where our legal basis for processing is legitimate interests, we collect or use your information because it benefits you, our organization or someone else, without causing an undue risk of harm to anyone.

4. Providing your personal data to others

4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.2 Financial transactions relating to our website and services are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy

4.3 Marketing automation services relating to our website and services are handled by MailChimp. We may share your personal data (name and email address) with MailChimp in order that we can, as agreed with you, share information about us; provide newsletters and other communications and/or offer and sell to you relevant goods and services. You can find information about MailChimp’s privacy policies and practices at: https://mailchimp.com/legal/privacy/

4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 Our payment services provider, Stripe, and marketing automation platform, MailChimp, are situated in the United States of America. The EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. Data Privacy Framework (UK Extension to the EU-U.S. DPF), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) were developed to facilitate transatlantic commerce by providing U.S. organizations with reliable mechanisms for personal data transfers to the United States from the European Union / European Economic Area, the United Kingdom (and Gibraltar), and Switzerland that are consistent with EU, UK, and Swiss law. Further information about the Data Privacy Framework Program can be found at: https://www.dataprivacyframework.gov

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) Your name and email address will be retained for the duration of your membership, in order that you can access our services and we can communicate relevant information about these services to you. If receiving goods from us, your email address and phone number will also be retained for a reasonable period, not exceeding two years from the date of your last purchase, for the purposes of supplying you with said goods and maintaining a record of your transactions.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Your rights

7.1 Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

7.2 Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

7.3 Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

7.4 Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

7.5 Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

7.6 Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

7.7 Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organization, or to you. Read more about the right to data portability.

7.8 Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

7.9 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.

7.10 If you make a request, we must respond to you without undue delay and in any event within one month.

7.11 To make a data protection rights request, please contact us using the contact details at the end of this privacy notice.

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

9.1 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website

(b) status - we use cookies to help us to determine if you are logged into our website;

(d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e) analysis - we use cookies to help us to analyse the use and performance of our website and services; and

(f) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy?hl=en-GB&gl=uk

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via this link: http://www.allaboutcookies.org/manage-cookies/

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12. Our details and how to raise a data protection complaint

12.1 This website is owned and operated by Lyra Voices Limited.

12.2 We are registered in Scotland under registration number SC478502, and our registered office is at 5B Broomhill Terrace, Glasgow G11 7AG.

12.3 You can contact us; or if you have any concerns about our use of your personal information, you can make a data protection complaint to us by:

(a) using our website contact form;

(b) telephone, on 07714 459 243; or

12.4 If you remain unhappy with how we have used your data after raising a complaint with us, you can also complain to the ICO by contacting them via their:

(a) address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

(b) helpline number: 0303 123 1113

13. Amendments

13.1 We may update this policy from time to time by publishing a new version on our website.

13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

14. Credits

14.1 This document was created using templates from SEQ Legal (https://seqlegal.com) and the Information Commissioner’s Office (ICO).