We are committed to protecting the privacy of our
customers and using your information responsibly.
This Privacy Policy discloses the privacy
practices of SRO Records, DBA. (sometimes referred to in this Privacy Policy as
"SRO Records", "SRORecords.com", "our site",
"we", or "us"), in connection with the SRORecords.com
website (the "Website") and any features and online services provided
by SRO Records that post or include a link to this Privacy Policy
(collectively, the "Services"). We have provided this statement of
our Privacy Policy to answer your questions about the types of information that
we gather, the ways in which we use and share this information, and your rights
and choices regarding such information. Please read this Privacy Policy
carefully. By visiting and using the Services, you agree that your use of the
Services is governed by this Privacy Policy. In addition to our Privacy Policy,
your use of the Services is governed by our Terms of Use, which govern in the
event of any conflict with this Privacy Policy.
SCOPE OF PRIVACY POLICY
This Privacy Policy applies to the SRORecords.com website and any features and
online services provided by SRO Records that post or include a link to this
Privacy Policy. It does not apply to SRO Records’ services that SRO Records’
customers may use on their own websites, to other companies' or organizations'
sites to which we link, or to companies that SRO Records does not own or
control, even if such companies are contractors or business partners of SRO
Records.
This Privacy Policy also does not cover how SRO
Records customers may treat your information as the use of your information by
such parties is governed by the privacy policies of such parties and is not
subject to SRO Records’ control. If you are a data subject located in Europe,
please see the section below entitled "Data Controller" for more
information on our relationship with our customers.
Third Party Content and
Links To Third Party Sites
Our site may contain content that is supplied by a third party, and those third
parties may collect Site usage information when you browse web pages from our
site or content served to your browser. In addition, when you are on Our Site
you may be directed to other web sites that are operated and controlled by
third parties that we do not control. We are not responsible for the privacy
practices employed by any of these third parties or third party web sites. For
example, if you click on a banner advertisement, the click may take you off our
site onto a different web site. These other web sites may send their own
cookies to you, independently collect data or solicit personal information and
may or may not have their own published privacy policies. We encourage you to
note when you leave our site and to read the privacy statements of all third
party web sites before submitting any personal information to those sites.
INFORMATION SRO RECORDS
COLLECTS
Information You Provide
We collect information that you voluntarily provide to us while using the
Services, such as when you register an account, make a purchase of one of the
products listed on our site, or communicate with our customer service team or
with other users of the Services.
The information we collect includes information
relating to identified or identifiable natural persons. Some examples of
information we collect include the following: contact data, including your
first and last name, telephone number, email address, and postal address; and
billing information; credentials, including your passwords; content data,
including the content of the messages you send to us. We also use third party
payment processes to collect and process payment data, including your payment
instrument and security code associated with your payment instrument, on our
behalf.
You may choose to voluntarily submit other
information to us through the Services that we do not request, and, in such
instances, you are solely responsible for such information.
Our site permits you to submit photographs and
images, image URLs, user profiles, writings, music, audio, video, questions,
comments or other content, which may include personal information. We or others
may reproduce, publish, distribute or otherwise use this content in any media
or format (currently existing or hereafter developed). Others may have access
to this content and may have the ability to share it with third parties. Please
think carefully before deciding what information you share, including personal
information, in connection with your personal content. Please note that we do
not control who will have access to the information that you choose to make
public, and cannot ensure that parties who have access to such publicly
available information will respect your privacy or keep it secure. This Privacy
Policy does not apply to any information that you disclose publicly, share with
others or otherwise upload onto our site. We are not responsible for the
accuracy, use or misuse of any content or information that you disclose or
receive through our site. For the full terms and conditions regarding personal
content you submit to our site, please review our Terms of
Use.
Information Collected
Automatically
We automatically collect information about your device and how your device
interacts with our Service. The types of data we collect and the methods by
which we may collect such data include the following:
Web Beacons
SRO Records may also use web beacons, small graphic images or other web
programming code (also known as "1x1 GIFs" or "clear
GIFs"), which may be included in our web pages and e-mail messages. Web
beacons may be invisible to you, but any electronic image or other web
programming code inserted into a web page or e-mail can act as a web beacon.
Web beacons or similar technologies may be used for a number of purposes,
including, without limitation, to count visitors to the Services, to monitor
how users navigate the Services, to count how many e-mails that were sent were
actually opened or to count how many particular articles or links were actually
viewed.
Embedded Scripts
SRO Records may also use embedded scripts in connection with the provision of
its Services. "Embedded scripts" are programming code designed to
collect information about your interactions with a website, such as the links
you click on, and may assist our customers in providing us with information
used to provide the Services. The code is temporarily downloaded onto your
device from our web server, our customer's web server, or a third party service
provider, is active only while you are connected to the website containing the
embedded script, and is deactivated or deleted thereafter.
Log File Information
Your web browser automatically sends information to every website you visit,
including ours. For example, our server logs may receive and record information
such as the pages you access on the Services, referring URLs, your browser
type, your operating system, the date and time of your visit, and the duration
of your visit to each page.
User Agent Strings
Log file information may also include a user agent string, a series of
characters automatically sent with your Internet requests that provide
information necessary for smooth Internet communications, such as the operating
system and browser you used. A user agent string might be used to identify the
device originating a message.
Location Data
SRO Records may also request access to or otherwise receive information about
your device location when you access the Services. Your location data may be
based on your IP address and other location-aware technologies. We use location
data in connection with providing the Services and to help improve the
Services.
Image and Audio Data
If you upload an image or audio, or provide a URL that points to an image or
audio file SRO Records may transfer that data (or data the resides at the URL)
to our servers or to the account that SRO Records controls on Amazon AWS for
hosting and providing of Services.
Cookies
This site uses cookies, which are tiny files that are downloaded to your
computer, to improve your experience. This section describes what information
the cookies gather, how we use it and why we sometimes need to store these
cookies. We will also share how you can prevent these cookies from being stored
however this may downgrade or 'break' certain elements of the sites
functionality.
Cookies are alphanumeric identifiers that we
transfer to your computer's hard drive through your Web browser. They make it
possible for us to recognize your browser when you visit. By doing this, we can
personalize your return visits. For example cookies save you time during
checkout by not requiring you to sign in again, or by remember your currency
preference so prices are displayed in a currency you are familiar with. In
order to enjoy such benefits, your browser must be set to accept cookies.
For more information on cookies visit https://en.wikipedia.org/wiki/HTTP_cookie and https://www.allaboutcookies.org/.
How We Use Cookies
We use cookies for a variety of reasons detailed below.
Unfortunately in most cases there are no industry standard options for
disabling cookies without completely disabling the functionality and features
they add to this site. It is recommended that you leave on all cookies if you
are not sure whether you need them or not. This will ensure that our website
will work as intended and provide you the best user experience possible.
The Cookies We Set
If you create an account
with us then we will use cookies for the management of the signup process and
general administration. These cookies will usually be deleted when you log out
however in some cases they may remain afterwards to remember your site
preferences when logged out.
We use cookies when you are
logged in so that we can remember this fact. This prevents you from having to
log in every single time you visit a new page. These cookies are typically
removed or cleared when you log out to ensure that you can only access
restricted features and areas when logged in.
When you submit data to
through a form such as those found on contact pages or comment forms cookies
may be set to remember your user details for future correspondence.
In order to provide you
with a great experience on this site we provide the functionality to set your
preferences for how this site runs when you use it. In order to remember your
preferences we need to set cookies so that this information can be called
whenever you interact with a page is affected by your preferences. Examples of
of these cookies set could be to remember your prefered currency or recent last
searches you performed on the site.
Third Party Cookies
In some special cases we also use cookies provided by trusted third parties.
This section details which third party cookies you might encounter through this
site.
For more information on
Google Analytics cookies, see the official Google Analytics page.
HOW SRO RECORDS USES
INFORMATION
We use information for our legitimate interests, including for the following
purposes:
Providing Our Services
SRO Records uses information such as images or image URLs that you provide,
your first and last name, telephone number, email address, postal address,
billing information, or other contact information we obtain from you, our
customers, or our business partners, for the purposes of helping you buy and
sell your products and other services.
Communications with You
SRO Records maintains one or more contact lists (with email addresses and other
information) to allow SRO Records to communicate with individuals who do
business with SRO Records or who have expressed an interest in the Services. We
may contact you to confirm your purchases, give order updates, or respond to
requests that you make, notify you of changes to your account or the Services,
for marketing purposes, or to otherwise inform you of information related to
our business or your account with us.
Website Administration and
Customization
SRO Records uses the information we collect about you for a variety of website
administration and customization purposes. For example, we use your information
to process your registration request, provide you with services and
communications that you have requested, send you email updates and other
communications, customize features and advertising that appear on and off the
Services, deliver the Services content to you, measure Services traffic,
measure user interests and traffic patterns, and improve the Services.
Usage of IP Addresses
The SRO Records services, or third parties services that SRO Records partners
with (such as ShieldSquare.com), use IP addresses to help detect and block
robotic and/or fraudulent activity or to deterimine your general geographic
location.
Consent
We also use information with your consent, including for the following purposes:
to allow you to participate in our surveys; to serve advertising tailored to
your interests on our Services and third party services; and to fulfill any
other purpose disclosed to you and with your consent. Some of our lawful bases
for processing your information stem from our customers on whose behalf we
provide services. SRO Records uses information that does not identify you for
any purpose except as prohibited by applicable law. For information on your
rights and choices regarding how we use your information, please see the below
section titled "Your Rights and Choices".
HOW SRO RECORDS SHARES
INFORMATION
Sharing with Our Service
Providers
We provide your information to our third party service providers, contractors,
business partners, and advertisers, for the purpose of delivering services to
you as well as for purposes related to Services administration and operation,
including conducting analytics and rooting out fraud and robots. When sharing
information for the purpose of providing you with the services you request, we
will share your information only as necessary for the third party working on SRO
Records’ behalf to complete its work for us.
We may use anonymous, statistical or aggregated
information about the website's use and share, publish, post, disseminate,
transmit or otherwise communicate or make available such information, to
suppliers, controllers, business partners, sponsors, affiliates and any other
third party, at our sole discretion.
Customers
We share your information with our customers in connection with us processing
your information on their behalf. For example, we share your information with
our customers to respond to your questions and comments, fulfill your order
requests, deterime fraud risk, and otherwise comply with applicable law.
Third Parties
We may share your information with third parties for purposes of providing you
with tailored advertisements, measuring and improving our Service and
advertising effectiveness, detecting fraud, and enabling other enhancements.
Security and Compliance
with the Law
We reserve the right to disclose your information to appropriate third parties
if we are required to do so by law or we believe that such action is necessary
in order (a) to comply with a legal process such as a search warrant, subpoena,
or court order; (b) to protect the company's rights and property; (c) to
investigate reports of users sending material using a false email address or
users sending harassing, threatening, or abusive messages; (d) to protect
against misuse or unauthorized use of the Website or Services; or (e) to
respond to emergencies, such as when we believe someone's physical safety is at
risk. SRO Records may be required to disclose information in a life-threatening
emergency or in response to a lawful request by public authorities, including
to meet national security or law enforcement requirements.
Transfer of Business
In the event that we sell some or all of our assets, or our company is acquired
by another company, or during the negotiation of such sale or acquisition, our
databases and any information we collect may be among the transferred or
negotiated assets.
Consent
We may share your information for any other purpose disclosed to you and with
your consent.
Without limiting the foregoing, in our sole
discretion, SRO Records shares information that does not identify you with
third parties, including our customers, for any purpose except as prohibited by
applicable law. For information on your rights and choices regarding how we
share your information, please see the section below titled "Your Rights
and Choices".
THIRD PARTY ANALYTICS;
ONLINE TRACKING
SRO Records works with certain third parties (including analytics
companies) to provide us with information regarding traffic on and use of the
Services. Some of these parties collect information when you visit the Services
or other online websites and services. These third parties set and access their
own tracking technologies (including cookies, embedded scripts, and web
beacons) and may otherwise collect or have access to your IP address or other
unique identifier, log information, and related information about you. These
tracking technologies, including the Google Analytics User ID feature, may be
used to assist in providing analytics, marketing, and for other purposes. We
also use third party plug-ins from ShieldSquare to protect our services from
robots and fraudulent users. ShieldSqaure's privacy policy is available at
https://www.shieldsquare.com/privacy/. SRO Records does not control the
information collection, use, or sharing practices of such third party
providers, and we encourage you to consult their online policies. Some third
parties may collect information about your online activities over time and
across different websites when you use the Services.
YOUR RIGHTS AND CHOICES
Opt-Out of Email Communications
If you are a registered member of the Services, you can make changes to your
account information by logging into the Website and modifying your preferences.
If you do not wish to receive email notifications from us, you may opt-out by
contacting us with your request. In addition, certain email communications we
send to you, such as newsletters and promotional announcements, contain a
clearly worded "Opt-Out" or "Unsubscribe" link allowing you
to withdraw your permission for future mailings. Please note that we reserve
the right to send you certain communications relating to your account or use of
the Services (for example, administrative, service announcements or updates on
your order purchases) and these transactional account messages may be
unaffected even if you opt-out from marketing communications.
Blocking or Deleting
Cookies
You can manually delete cookies, which are normally located in your temporary
Internet folder or cookie folder. You can also reset the preferences in your
web browser to notify you when you have received a cookie or, alternatively, to
refuse to accept cookies. Deleting or blocking cookies will prohibit your
ability to make online purchases on the Services and to use and access portions
of the Services that require logging in with a username and password, and may
affect other functionality.
Analytics and Advertising
You may exercise choice regarding the use of cookies from Google Analytics by
going to https://tools.google.com/dlpage/gaoptout and
downloading the Google Analytics Opt-out Browser Add-on.
For more information about and to exercise
certain choices regarding interest based ads from ad networks, go to:
U.S.: https://www.aboutads.info/choices and https://www.networkadvertising.org/choices/.
European Union: https://www.youronlinechoices.eu
Canada: https://youradchoices.ca/
Please be aware that, even if you are able to
opt out of certain kinds of interest-based advertising, you may continue to
receive other types of ads. Opting out only means that those selected members
should no longer deliver certain interest-based advertising to you, but does
not mean you will no longer receive any targeted content and/or ads (e.g., from
other ad networks). SRO Records is not responsible for effectiveness of, or
compliance with, any third-parties' opt-out options or programs or the accuracy
of their statements regarding their programs.
Your browser settings may allow you to
automatically transmit a "Do Not Track" signal to websites and online
services you visit; however, there is no consensus among industry participants
as to what "Do Not Track" means in this context. Like many websites
and online services, the Website currently does not alter its practices when it
receives a "Do Not Track" signal from a visitor's browser. To find
out more about "Do Not Track," you may wish to visit https://www.allaboutdnt.com.
Retention of Personal
Information
We retain personal information we process for as long as an account is active
or as needed to provide the Services. If you wish to terminate your account or
request that we no longer use your data, please contact us using the
information found in the "CONTACT FOR ADDITIONAL INFORMATION, OPTING OUT,
DATA ACCESS AND CORRECTION, AND DISPUTES" section below. We will retain
your data as necessary to comply with our legal obligations, maintain accurate
financial and other records, resolve disputes, and enforce our agreements. We
will delete all your data within 30 days once you raise the request to us
except as otherwise prohibited by applicable law.
Your California Privacy
Rights
California's "Shine the Light" law permits customers in California to
request certain details about how a business shares their personal information
as defined by "Shine the Light" with third parties (and in some cases
affiliates) for those third parties' or affiliates' own direct marketing
purposes.
SRO Records does not share personal information
as defined under California's "Shine the Light" law with third
parties or affiliates for those third parties' or affiliates' direct marketing
purposes. California customers may request information about our compliance
with this law by contacting us. Any such inquiry must include "California
Privacy Rights Request" in the first line of the description and include
your name, street address, city, state, and ZIP code. Please note that we are
only required to respond to one request per customer each year, and we are not
required to respond to requests made by means other than through this email or
mail address.
European Privacy Rights
If you are a data subject in Europe, you have the right to access, rectify, or
erase any personal data we have collected about you through the Services. You
also have the right to data portability and the right to restrict or object to
our processing of personal data we have collected about you through the
Services. In addition, you have the right to ask us not to process your
personal data (or provide it to third parties to process) for marketing
purposes or purposes materially different than for which it was originally
collected or subsequently authorized by you. You may withdraw your consent at
any time for any data processing we do based on consent you have provided to
us.
To exercise any of these rights, contact us
using the information below in the "CONTACT FOR ADDITIONAL INFORMATION,
OPTING OUT, DATA ACCESS AND CORRECTION, AND DISPUTES" section and specify
which right you intend to exercise. We will respond to your request within 30
days. We may require additional information from you to allow us to confirm
your identity. Please note that we store information as necessary to fulfil the
purposes for which it was collected, and may continue to retain and use the
information even after a data subject request for purposes of our legitimate
interests, including as necessary to comply with our legal obligations, resolve
disputes, prevent fraud, and enforce our agreements.
If your information has been processed by us on
behalf of one of our customers and you wish to exercise any rights you have
with such information, please inquire with our customer directly. If you wish
to make your request directly to SRO Records, please provide the name of the SRO
Records customer on whose behalf SRO Records processes your information. We
will refer your request to that customer, and will support them to the extent
required by applicable law in responding to your request.
If you have any issues with our compliance, you
have the right to lodge a complaint with a European supervisory authority.
INTERNATIONAL TRANSFER AND
PRIVACY SHIELD
We are based in the U.S. and the information we collect is
governed by U.S. law. If you are accessing the Services from outside of the
U.S., please be aware that information collected through the Services may be
transferred to, processed, stored, and used in the U.S. and other
jurisdictions. Data protection laws in the U.S. and other jurisdictions may be
different from those of your country of residence. Your use of the Services or
provision of any information therefore constitutes your consent to the transfer
to and from, processing, usage, sharing, and storage of your information in the
U.S. and other jurisdictions as set forth in this Privacy Policy. If your data
is collected in Europe, we will transfer your personal data subject to
appropriate or suitable safeguards, such as the Privacy Shield Framework
discussed below.
SRO Records complies with the EU-US Privacy
Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the
US Department of Commerce regarding the collection, use, and retention of
personal data from the European Union and Switzerland to the United States,
respectively. SRO Records adheres to the Privacy Shield Principles of Notice,
Choice, Accountability for Onward Transfer, Security, Data Integrity and
Purpose Limitation, Access, and Recourse, Enforcement and Liability.
SRO Records is subject to the investigatory and
enforcement jurisdiction of the United States Federal Trade Commission in
complying with its commitments under the Privacy Shield Principles. We hereby
affirm our commitment to subject to the Privacy Shield Principles all personal
data transferred from the European Union and Switzerland in reliance on Privacy
Shield. This means that SRO Records shall be liable to you for any third party
agent to which we transfer your personal data and that processes such personal
data in a manner that violates the Privacy Shield Principles, unless we can
demonstrate that we are not responsible for the resulting damages. SRO Records
takes reasonable steps to ensure that personal data is relevant to its intended
use and is accurate, complete, and current and retained only as long as needed
for an intended or compatible purpose.
Any inquiries or complaints relating to SRO Records’
compliance with Privacy Shield, including any requests for access or correction
of personal data, may be addressed to our Data Protection Officer set forth in
this Privacy Policy. SRO Records will investigate and attempt to resolve any
inquiries brought to its attention. SRO Records commits to refer unresolved
privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to
BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider
located in the United States and operated by the Council of Better Business
Bureaus. If you do not receive timely acknowledgment of your complaint, or if
your complaint is not satisfactorily addressed, please visit
https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information
and to file a complaint. Under limited circumstances, in the event your
complaint is not resolved through these channels a binding arbitration option
may be available for a Privacy Shield Panel.
If there is any conflict between the policies in
this Privacy Policy and the Privacy Shield Principles, the Privacy Shield
Principles shall govern. To learn more about the Privacy Shield program, and to
view our certification page, please visit https://www.privacyshield.gov/.
SECURITY
SRO Records implements reasonable administrative, physical, and
technical security measures to help protect your data from loss, theft, misuse
and unauthorized access, disclosure, alteration and destruction. However, no
physical or electronic security system is impenetrable. SRO Records cannot
guarantee the security of the Service's servers or databases, nor can we
guarantee that information you supply will not be intercepted while being
transmitted to us over the Internet.
POLICY REGARDING CHILDREN
The Services are not intended for use by minor children without
the supervison of a responsible adult. SRO Records does not knowingly collect
information from minor children. If you are a parent or guardian, and believe
we have collected information about your child in violation of this policy,
please contact us.
CHANGES TO THIS PRIVACY
POLICY
We will occasionally update this Privacy Policy in response to
changing business circumstances and legal developments. We encourage you to
periodically review this Privacy Policy to be informed of how we are collecting
and using your information.
DATA CONTROLLER
SRO Records, located at the address set forth below, generally operates as a
processor on behalf of its customers that use the SRO Records’ services. The SRO
Records customer, the controller, determines the purposes and means of the
processing of personal data, such as orders that come to them through our
Services. SRO Records’ customer decides what personal data to share on our
Services. Please visit the applicable customer's privacy policy for information
about their privacy practices.
SRO Records also operates as a controller with
respect to certain of its services. For example, SRO Records operates as a
controller in connection with personal data collected from visitors through its
website. Also, when SRO Records combines personal data from different
customers, like many kinds of analytics services or orders of customers, it may
do this both as a processor at its customers' instruction and as a controller
itself for the purpose of providing services to all of its customers. For
example, SRO Records may process and aggregate some of the personal data that a
customer shares with SRO Records in order to make that personal data part of
another database for one or more other services provided to SRO Records
customers.
If you are a data subject located in Europe and
want to learn more about how to exercise your rights, please see the section
above entitled "European Privacy Rights".
CONTACT FOR ADDITIONAL
INFORMATION, OPTING OUT, DATA ACCESS AND CORRECTION, AND DISPUTES
If you have any questions or complaints about this Privacy Policy,
or you wish to exercise your opt-out rights hereunder or access or correct data
applicable to you, please contact us:
By email: legal@SRORecords.com
For EU-specific requests, including our compliance with Privacy Shield, please
contact our Data Protection Officer at:
By email: dpo@SRORecords.com
Last Updated: 07/20/2020