Privacy Policy

1. Who we are

Songs Aloud is a service supplied by Business Software Group Limited, a company registered in England and Wales under company number 02926171.

Our registered office is: Business Software Group Limited, Nine Hills Road, Cambridge, England, CB2 1GE.

For the purposes of UK data-protection law, Business Software Group Limited is normally the data controller responsible for the personal information described in this policy.

You can contact us about privacy or data protection at support@songsaloud.com.

In this policy:

• “Songs Aloud”, “we”, “us” and “our” mean Business Software Group Limited, which supplies the Songs Aloud service.
• “you” and “your” include website visitors, customers, prospective customers, recipients of songs and other people whose information is included in a commission.
• “commission” means a personalised song or related creative service requested from us.
• “brief” means the stories, names, memories, preferences, files and other information provided for a commission.
• “personal information” means information relating to an identified or identifiable person.

2. Scope of this policy

This policy explains how we collect and use personal information when you:

• Visit the Songs Aloud website;
• Contact us;
• Request a quotation;
• Begin or place an order;
• Complete a creative brief;
• Upload photographs, documents, audio or video;
• Take part in an interview;
• Receive or are mentioned in a commissioned song;
• Use a Songs Aloud customer account or portal;
• Submit feedback;
• Grant portfolio or publicity permission;
• Subscribe to marketing;
• Work with us as a supplier, contractor or referral partner; or
• Make a privacy request or complaint.

A separate Cookie Policy explains our use of cookies and similar website technologies.

3. Our privacy principles

We aim to:

• Collect only the information reasonably needed for a clear purpose;
• Explain how information will be used;
• Keep customer commissions private by default;
• Use separate permission for portfolio and publicity use;
• Avoid unnecessary sensitive information;
• Restrict access to people and providers who need it;
• Keep information secure;
• Retain it only for an appropriate period;
• Respect data-protection rights; and
• Use modern production technologies responsibly.

We do not sell personal information.

4. Information we collect

The information collected depends on how you interact with us.

4.1 Identity and contact information

This may include:

• Name;
• Postal address;
• Email address;
• Telephone number;
• Username or customer-account identifier;
• Organisation and job title;
• Billing details; and
• Preferred contact method.

4.2 Enquiry and order information

This may include:

• The service or package requested;
• Occasion and required date;
• Quotation details;
• Order number;
• Order status;
• Purchased extras;
• Delivery instructions;
• Contract acceptance;
• Cancellation-period instructions and consents;
• Invoices, refunds and payment status; and
• Customer-service communications.

We do not normally receive or store complete payment-card details. Payments are handled by an authorised payment-service provider.

4.3 Creative-brief information

A personalised song may require information such as:

• Names, nicknames and pronunciations;
• Relationships;
• Ages and significant dates;
• Childhood and family memories;
• Important places;
• Education, employment and achievements;
• Interests and personality traits;
• Private jokes and favourite expressions;
• Significant events;
• The emotional message of the song;
• Musical preferences;
• Words or subjects to include or avoid; and
• Information about the intended recipient and other people mentioned.

You decide how much information to provide. However, insufficient information may affect our ability to create the requested song.

4.4 Uploaded and recorded material

You may provide:

• Photographs;
• Written notes;
• Speeches;
• Poems or lyrics;
• Timelines;
• Audio recordings;
• Pronunciation recordings;
• Voice messages;
• Video;
• Existing melodies;
• Family documents; and
• Other material relevant to the commission.

We do not use voice recordings for biometric identification.

4.5 Interview and communication information

Where a package includes an interview, we may keep:

• Interview notes;
• An audio or video recording, where agreed;
• A transcript;
• Follow-up answers;
• Emails;
• Portal messages;
• Revision requests; and
• Approval records.

We will tell you before recording a telephone or video interview.

4.6 Song and production information

This may include:

• Lyric drafts;
• Musical instructions;
• Production briefs;
• Preview versions;
• Feedback;
• Final audio;
• Instrumental versions;
• Alternative arrangements;
• Lyric sheets;
• Videos;
• Artwork;
• Internal quality-review notes; and
• A record of the production and approval history.

4.7 Portfolio and testimonial information

Where you separately agree, we may collect and use:

• Your testimonial;
• The story behind the commission;
• Approved extracts from the song;
• Photographs;
• Names or pseudonyms;
• Recipient reactions;
• Reaction video or audio; and
• The specific permissions and restrictions you have selected.

Portfolio permission is optional and is not required to purchase a service.

4.8 Website and technical information

When you use the website, we may collect:

• Internet Protocol address;
• Browser and device information;
• Operating system;
• Approximate location derived from an IP address;
• Pages viewed;
• Links selected;
• Referring website;
• Date and time of access;
• Error and diagnostic information;
• Security events;
• Cookie preferences; and
• Website interaction and performance information.

Non-essential analytics or advertising technologies will only be used where permitted by law and in accordance with your cookie choices.

4.9 Marketing preferences

We may record:

• Whether you agreed to receive marketing;
• When and how permission was obtained;
• Topics of interest;
• Emails sent and, where enabled, basic engagement information;
• Unsubscribe requests; and
• A suppression record showing that you must not be contacted.

5. Information about recipients and other people

A purchaser may commission a song about someone else, particularly as a surprise gift. This means we may receive personal information about a recipient or another person without receiving it directly from that person.

This policy also applies to those individuals.

We ask purchasers to:

• Provide only information reasonably necessary for the commission;
• Avoid information likely to cause unjustified embarrassment, distress or harm;
• Consider whether the person would reasonably expect the information to be used in this way;
• Obtain consent where required;
• Avoid highly private or sensitive information unless its use is necessary and lawful; and
• Provide the individual with access to this privacy policy where appropriate.

Where a song is intended as a surprise, we will not ordinarily contact the recipient before presentation because doing so would defeat the purpose of the commission.

We may ask the purchaser to provide this policy to the recipient on our behalf when the song is presented or shortly afterwards. Recipients and other people mentioned in a commission may contact us at any time about their information.

We may remove, generalise, anonymise or refuse to use information that we consider unnecessarily intrusive, unsafe or inappropriate.

6. Sensitive information

A brief may sometimes refer to information receiving additional protection under data-protection law, such as:

• Health information;
• Racial or ethnic origin;
• Religious or philosophical beliefs;
• Political opinions;
• Trade-union membership;
• Genetic information;
• Biometric information used for identification;
• Sex life; or
• Sexual orientation.

This is known as special-category information.

Please do not provide special-category information unless it is genuinely relevant to the commission.

Where you deliberately provide your own special-category information for inclusion in a commission, we will normally rely on:

• The relevant ordinary lawful basis described below; and
• Your explicit consent as the additional condition permitting us to process that sensitive information.

You may withdraw that consent, although this will not affect processing that was lawful before withdrawal. Withdrawal may make it impossible for us to complete the commission as originally requested.

You cannot give consent on behalf of another competent adult merely because you are purchasing a song about them. You must not provide another person’s special-category information unless:

• They have explicitly agreed;
• You are legally authorised to act for them; or
• Another valid legal condition clearly applies.

We may ask for evidence of permission or remove the information.

You should not provide criminal-conviction or alleged-offence information unless it is essential, lawful and agreed with us in advance.

7. How and why we use personal information

We use personal information only where we have a lawful basis.

7.1 Enquiries and quotations

We use contact details and enquiry information to respond to questions, discuss requirements, prepare quotations, arrange interviews and take steps requested before entering into a contract.

Our lawful bases are taking steps at your request before entering into a contract, and our legitimate interests in responding to enquiries and developing our business.

7.2 Creating and delivering a commission

We use the brief, uploads, communications and production information to:

• Understand the story;
• Write and edit lyrics;
• Develop the musical direction;
• Produce and review audio;
• Prepare previews;
• Make agreed revisions;
• Deliver the final materials; and
• Provide customer support.

For information about the purchaser, our principal lawful basis is that processing is necessary to perform the contract.

For information about recipients and others mentioned in the brief, our principal lawful basis is our legitimate interest in providing the requested personalised creative service, balanced against the rights and reasonable expectations of those individuals.

7.3 AI-assisted and digital production

We may use generative artificial intelligence and other digital production technologies to assist with:

• Organising and interpreting a brief;
• Developing or editing lyrics;
• Exploring musical directions;
• Generating or processing audio;
• Producing artwork or video;
• Transcription;
• Audio restoration;
• Mixing and mastering; and
• Quality control.

We aim to minimise the personal information submitted to production systems. Where practical, we may:

• Remove direct contact details;
• Use first names or pseudonyms rather than full identities;
• Submit only relevant extracts;
• Separate identifying information from creative instructions; and
• Delete temporary working material when it is no longer required.

Production outputs are reviewed by or on behalf of Songs Aloud. We do not use automated systems to make decisions about you that produce legal or similarly significant effects without meaningful human involvement.

7.4 Payments and accounting

We use order and transaction information to process payments, issue invoices, administer refunds, maintain accounting records, prevent fraud and meet tax and financial-reporting duties.

Our lawful bases are performance of the contract, compliance with legal obligations, and our legitimate interests in managing payments and preventing fraud.

7.5 Customer accounts and communications

We use account and communication information to operate the customer portal, authenticate users, provide status updates, request missing information, deliver previews, receive feedback, record approvals and resolve problems.

Our lawful bases are performance of the contract and our legitimate interests in providing effective customer service.

7.6 Security and service administration

We use technical and account information to protect accounts and files, detect unauthorised access, prevent fraud and abuse, diagnose technical problems, maintain backups, monitor availability and enforce our terms.

Our lawful bases are our legitimate interests in operating a secure and reliable service and, where applicable, compliance with legal obligations.

7.7 Legal and regulatory purposes

We may use and retain information to establish or defend legal rights, handle complaints, respond to rights requests, enforce contracts, comply with court orders, cooperate with regulators or law-enforcement bodies, protect individuals from harm and maintain evidence of permissions, instructions and approvals.

Our lawful bases are legal obligation and our legitimate interests in protecting our business and legal rights.

7.8 Improving Songs Aloud

We may use feedback, usage information and suitably minimised or anonymised production information to understand which services are useful, improve questionnaires and workflows, identify recurring technical problems, improve quality-control procedures and develop new services.

Our lawful basis is our legitimate interest in improving Songs Aloud.

We will not publish or reuse the personal story behind a commission as an example without separate permission.

7.9 Portfolio, testimonials and publicity

We use a song, story, photograph, testimonial or reaction publicly only where you have granted separate permission. Our lawful basis is consent.

You can withdraw portfolio permission for future use by contacting us. Withdrawal will not affect use that was lawful before we received it and may not enable us to recover material already printed, distributed or incorporated into completed publications.

7.10 Marketing

We may send news, offers or reminders where you have consented, where applicable electronic-marketing rules permit us to contact an existing customer about similar services, or where business-to-business marketing is otherwise permitted.

You can opt out at any time by using the unsubscribe option in the message, changing available account preferences, or contacting us.

We may retain minimal information on a suppression list to ensure that we respect an opt-out.

You have an absolute right to object to the use of your personal information for direct marketing.

8. When information is required

Some information is required to enter into or perform a contract, process payment, verify an instruction, comply with law, or create the commissioned song.

Where required information is not provided, we may be unable to accept or complete an order.

Other information, including portfolio permission and marketing consent, is optional.

9. Who we share information with

We disclose personal information only where reasonably necessary and subject to appropriate safeguards. Recipients may include:

9.1 Staff and contractors

Employees, consultants, writers, editors, producers, audio engineers, video editors and customer-support personnel who need access to perform their role.

9.2 Hosting and technology providers

Providers of website hosting, databases, cloud storage, backups, customer accounts, content-delivery networks, cybersecurity, monitoring, communications and technical support.

9.3 Creative and production providers

Providers assisting with generative text or audio, transcription, music production, voice and audio processing, mixing or mastering, artwork, video and file delivery.

Only the material reasonably needed for the relevant task should be shared.

9.4 Payment and financial providers

Payment processors, banks, accountants, auditors and tax advisers.

9.5 Communication and marketing providers

Email, messaging, customer-relationship management, survey and marketing providers. Marketing providers receive personal information only in accordance with applicable marketing and cookie requirements.

9.6 Analytics providers

Providers helping us understand website performance and usage, subject to your cookie preferences where consent is required.

9.7 Professional advisers

Solicitors, insurers, accountants, security consultants and other professional advisers.

9.8 Authorities and legal recipients

Courts, regulators, tax authorities, law-enforcement bodies and other recipients where disclosure is required or legally justified.

9.9 Business changes

A prospective purchaser, investor, lender or successor may receive appropriately limited information during a genuine restructuring, financing, merger, acquisition or sale. Confidentiality and data-protection safeguards will be applied.

We require service providers acting as processors to handle personal information only on our documented instructions and to maintain appropriate confidentiality and security.

10. International transfers

Some technology and production providers may store or access information outside the United Kingdom.

Where a restricted international transfer takes place, we will use a lawful transfer mechanism where required, such as:

• UK adequacy regulations;
• The UK International Data Transfer Agreement;
• The UK Addendum to approved European standard contractual clauses;
• Another legally approved safeguard; or
• A permitted exception applying to a particular transfer.

We will also consider the nature of the information, the destination and any additional technical or contractual protections reasonably required.

You may contact us for further information about the safeguards applying to your information.

11. How long we keep information

We retain information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, security and dispute-resolution requirements.

Our intended standard retention periods are:

These periods may be shortened or extended where:

• You request deletion and no overriding reason requires retention;
• A legal duty applies;
• A dispute or complaint is ongoing;
• Information is needed to establish or defend legal rights;
• Fraud or security concerns exist;
• The material has been anonymised; or
• A different period is agreed as part of a business commission.

Deleting information from live systems may not immediately remove it from encrypted backups. Backup copies are protected from ordinary access and removed through the normal backup cycle.

Customers should download and securely retain their final files. We do not promise indefinite archival storage.

12. Security

We use technical and organisational measures appropriate to the nature of the information and the risks involved. Measures may include:

• Encryption in transit;
• Restricted administrative access;
• Role-based permissions;
• Multi-factor authentication;
• Secure cloud storage;
• Private file links;
• Expiring download links;
• Logging and monitoring;
• Malware and file validation;
• Security updates;
• Backups;
• Staff confidentiality requirements;
• Supplier assessment; and
• Incident-response procedures.

No online service can guarantee absolute security. You should use secure devices and keep customer-portal access links and credentials confidential.

Please contact us promptly if you believe an account, link or file has been accessed without permission.

13. Cookies and website analytics

We may use:

• Strictly necessary cookies required for security, navigation, forms, payments and customer accounts;
• Preference cookies remembering selected settings;
• Analytics technologies helping us understand website use;
• Marketing technologies, if introduced; and
• Similar local-storage or device-access technologies.

Where consent is required, non-essential technologies will not be activated before you make a choice.

You can review or change available choices through our cookie controls. Further details appear in our Cookie Policy.

Blocking some cookies may affect website functionality.

14. Links and third-party websites

The website may contain links to third-party websites.

A third party normally controls the information it collects when you visit its website. Its own privacy policy will apply.

We are not responsible for the privacy practices of independent third parties.

15. Children

The Songs Aloud ordering service is intended for adults aged 18 or over.

A commissioned song may mention or feature a child. The purchaser must:

• Have an appropriate relationship with the child;
• Act in the child’s best interests;
• Provide only information reasonably necessary;
• Avoid unnecessary sensitive information; and
• Obtain permission from a person with parental responsibility where required.

We will not knowingly use a child’s photograph, voice, video or story in public marketing without appropriate, separately recorded permission.

A child has data-protection rights in their own information. We will take age and understanding into account when handling a request involving a child.

16. Business customers

For most Songs Aloud transactions, we act as an independent data controller.

For some business commissions, an organisation may determine why and how personal information about its staff, customers or other people is used. In that situation, we may act as a data processor for part of the service.

Where we act as a processor:

• The business customer is responsible for providing required privacy information and establishing a lawful basis;
• We will process the relevant information only on documented instructions;
• Separate data-processing terms may apply; and
• We may still act as an independent controller for billing, security, legal compliance and management of our own business.

17. Your data-protection rights

Depending on the circumstances, you may have the right to:

• Be informed about how your information is used;
• Ask for access to your personal information;
• Ask us to correct inaccurate or incomplete information;
• Ask us to erase information;
• Ask us to restrict its use;
• Object to processing based on legitimate interests;
• Object to direct marketing;
• Receive certain information in a portable format;
• Withdraw consent;
• Challenge qualifying solely automated decisions; and
• Complain about our handling of your information.

These rights are not all absolute. The applicable right may depend on our lawful basis and the circumstances.

To exercise a right, contact support@songsaloud.com. Please describe:

• Who you are;
• Your relationship with Songs Aloud;
• The order or commission concerned, where relevant;
• The information or processing concerned; and
• The action you would like us to take.

We may request information reasonably necessary to verify your identity and protect information from unauthorised disclosure.

There is normally no fee. We aim to respond within one month, although the period may be extended where permitted for a complex request. We will tell you if an extension applies.

Withdrawing consent does not affect processing that took place lawfully before withdrawal.

18. Your right to object

Where we rely on legitimate interests, you may object to our use of your information.

We will stop the relevant processing unless:

• We demonstrate compelling legitimate grounds overriding your interests, rights and freedoms; or
• Processing is needed to establish, exercise or defend legal claims.

Where information is used for direct marketing, your right to object is absolute and we will stop using it for that purpose.

19. Data-protection complaints

You may complain to us if you believe that we have not handled personal information in accordance with data-protection law. You do not need to use legal terminology.

Email: support@songsaloud.com

Post: Privacy Complaints, Songs Aloud, Business Software Group Limited, Nine Hills Road, Cambridge, England, CB2 1GE

Please provide:

• Your name and contact details;
• A description of the concern;
• The order or account concerned, where relevant;
• Any relevant dates or documents; and
• The outcome you are seeking.

We will:

• Acknowledge the complaint within 30 days;
• Begin investigating without undue delay;
• Take reasonable and proportionate steps to establish what happened;
• Keep you informed of material progress or delay; and
• Tell you the outcome of our investigation.

You also have the right to complain to the Information Commissioner’s Office, the independent UK data-protection regulator.

We would appreciate the opportunity to consider your concern first, but contacting us does not remove your right to approach the regulator.

20. Changes to this policy

We may update this policy to reflect changes to our services, new production or technology providers, changes to legal requirements, new website features, or improvements to our privacy practices.

The latest version will be published on this page with its effective date.

Where a change materially affects an existing customer or the agreed use of their information, we will take reasonable steps to provide notice.

21. Contact us

Questions, rights requests and data-protection complaints should be sent to:

Songs Aloud, Business Software Group Limited, Nine Hills Road, Cambridge, England, CB2 1GE. Email: support@songsaloud.com