Last updated 29 Sep 2019
MyLuthier (hereinafter referred to as “MyLuthier”, “we”, “us” or “our”) operates a platform and community marketplace that helps people find and musical instruments in their area. MyLuthier refers to MyLuthier Ltd, UK registered company no. 10269094.
- “Aggregated information” means information about all of our users or specific groups or categories of users that we combine together and which does not include the users’ Personal Information.
- “Data Controller” means MyLuthier, the company responsible for the use of and processing of Personal Information.
- “Personal Information” means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
What types of information does MyLuthier gather about its users?
- Information that you give us
We receive, store and process information that you make available to us when accessing or using our Platform. Examples include when you:
- fill in any form on the Platform, such as when you register or update the details of your user account;
- access or use the Platform,
- link your account on a third party site (e.g. Facebook) to your MyLuthier account, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorised by you; and
- communicate directly with MyLuthier.
When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
- Log data
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with MyLuthier or logged in to your MyLuthier account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.
- Cookies, and other tracking technologies
We may, either directly or through third party companies and individuals we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through third party companies and individuals we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and third party websites.
- Third-party social plugins
Our Platform may use social plugins which are provided and operated by third-party companies, such as Facebook’s Like Button.
As a result of this, you may send to the third-party company the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the third-party company, then the third party may not know your identity. If you are logged into your account with the third-party company, then the third party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the third party.
How MyLuthier uses and processes the information that you provide or make available
We use and process Information about you for the following general purposes:
- to enable you to access and use the Platform;
- to operate, protect, improve and optimize the Platform, MyLuthier’s business, and our users’ experience, such as to perform analytics, conduct research, and for advertising and marketing;
- to help create and maintain a trusted and safer environment on the Platform, such as fraud detection and prevention, conducting investigations and risk assessments;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by MyLuthier or our business partners; and
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
How MyLuthier uses and processes user communications
We may review, scan, or analyse your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyse messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking clients to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyse messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug product offerings.
We will not review, scan, or analyse your communications for sending third party marketing messages to you. We will also not sell these reviews or analyses of communications to third parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that MyLuthier, in its sole discretion, may review, scan, analyse, and store your communications, whether done manually or through automated means.
When MyLuthier discloses or shares Personal Information, and to whom
We will not transfer, store, use or process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”)
Your Personal Information may be disclosed as follows:
- Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes.
- Your public profile page will always include some minimum information such as your name and the instruments you have for sale, your public profile photo and public reviews and statistics related to your previous sales. Parts of your public Listing page may be displayed in other parts of the Platform to other users for marketing purposes. The Platform may also display your approximate geographic location on a map, such that a user can see the general area of the services offered.
- The Platform allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile, third-party search engines may not update their databases quickly or at all. We do not control the practices of third-party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile.
- You may link your account on a third party social networking site to your MyLuthier account. We refer to a person’s contacts on these third party sites as “Friends”. When you create this linkage:
- other MyLuthier users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
- the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes.
- The publication and display of information that you provide to MyLuthier through this linkage is subject to your settings and authorizations on the Platform and the third party site.
- We may also publish, disclose and use Aggregated Information and non-personal information for industry analysis, demographic profiling, marketing and advertising, and other business purposes.
Business transfers by MyLuthier
How to change or delete your information, or cancel your MyLuthier account
You may review, update, correct or delete the Personal Information in your MyLuthier account by logging in to your account. If you would like to cancel your MyLuthier account entirely, you can do so by logging in to your account and visiting the settings page via the main menu. Please also note that any reviews, postings and similar materials posted by you may continue to be publicly available on the Platform in association with your name, even after your MyLuthier account is cancelled.
Keeping your personal information secure
We have implemented reasonable administrative, technical, and physical security measures to protect your Personal Information against the unauthorised access, destruction or alteration of your information. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.
Your privacy when you access third-party websites and resources
Special features and programs
Referral service and requesting for references
The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform.
We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages via the third party site itself. These messages will be sent by the third party site, and MyLuthier does not collect or retain the contact information that is used to send them.
You may also send invitation/request emails via the Platform itself, in which case we will ask you for the email addresses to send these emails to. You can type in the email addresses manually, or you can request MyLuthier to import the contacts in your email account address book(s). In both cases, we will use the information sent to us for the sole purpose of sending your friends and contacts a one-time email, inviting him or her to visit the Platform or to write a reference for you. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins MyLuthier in response to your referral.
If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.
We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion.
For users residing in the EU only: your rights to review and update information
If you reside in the EU, you may request in writing copies of your Personal Information held by us. We will provide you with a copy of the Personal Information held by us as soon as practicable and in any event not more than 40 days after the request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom). We may also request proof of identification to verify your access request. All requests should be addressed to our Data Protection Compliance Officer, MyLuthier, 10 Hatfield Road, W13 9DG London UK.
We endeavour to keep your information accurate, complete and up to date. If your Personal Information that we hold is inaccurate, please let us know and we will make the necessary amendments, erase or block the relevant information and notify you within 40 days of your request that the relevant action has been taken.
You may also request the erasure of your personal data if you believe we are otherwise in breach of relevant data protection legislation. All requests should be addressed to our Data Protection Compliance Officer, at the address listed previously
MyLuthier uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognise your browser, while another could store your preferences and other information.
Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.
MyLuthier cookies and third party cookies
We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, third parties may also place cookies on your device for advertising purposes.
There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.
Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.
The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
Uses for MyLuthier cookies
- to enable, facilitate and streamline the functioning of the Platform across different webpages and browser sessions.
- to simplify your access to and use of the Platform and make it more seamless.
- to monitor and analyse the performance, operation and effectiveness of the Platform, so that we can improve and optimise it.
- to show you content that is more relevant to you.
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customise, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website (here) and make changes at the Global Privacy Settings Panel (here).