Privacy Policy

Date of issuance: 12/01/2018

The website (hereinafter: the “Website”) is owned and operated by The Hana Road Music Group Sàrl, CH-550.1.058.866-1, with seat at Avenue du Casino 32, 1820 Montreux (hereinafter: the “Company”). The Website is available directly on Internet at and may also be available through other addresses or channels.

As a user of this Website (hereinafter: “User” or “you”), please refer to the Terms of Use in addition to this privacy policy (hereinafter: the “Privacy Policy”).


The Company provides this Privacy Policy to describe our procedures regarding the collection, use and disclosure of personal data we collect or receive from Users. Personal data has the meaning given by the Swiss Federal Act on Data Protection and the Ordinance to the Federal Act on Data Protection (hereinafter: “Personal Data”). The data controller (i.e. the legal entity responsible for the purpose and content of the data file) is the Company.

This Privacy Policy forms a part of the Terms of Use relating to the Website. Capitalized terms which are not defined in this Privacy Policy shall have the meanings set forth in the aforesaid Terms of Use.


The Company reserves the right to make any changes to the Privacy Policy as the Company deems necessary or desirable. Your use of the Website at any time after any such change to the Privacy Policy shall be deemed as a consent to such change. It is your responsibility to check regularly this Privacy Policy to be informed of any changes. If you do not agree to the Privacy Policy (including any amendments), then you should immediately cease using the Website.


This Privacy Policy applies to all information which is received during your visit to the Website. It does not apply to websites which are operated by third parties or under their control and are not affiliated with the Company. The Website may contain links to such third-party websites. The Company therefore requests that you consult the respective privacy policies of such third-party websites, which do not lie in the Company’s area of responsibility.

When you visit the Website, details of your access may be automatically registered, including the date and time of your visit, which browser you are using, your operating system version, your IP address, the place of connection, the volume of data transferred, the links that you may follow, the webpages and content that you view, the duration of such viewing as well as any other similar information and statistics that relate to your interactions with the Website. This information and data is collected automatically in particular through cookies (including performance and tracking cookies, functional cookies, technical cookies, browser cookies, tokens and Web beacons (see Clause 5). It is also collected through third party application and content tools such as Google Analytics (see Clause 6).

The Company may also collect Personal Data that you provide as part of registration and the administration and personalization of your Customer account, such as name, surname, email address, phone number. The Company may also collect the following Personal Data:

Type of device, operating system, login dates, the date and time you access to the Website, length of time you spend on the Website, your browsing history (recorded by the text and graphics files that compose that page);

Transactional information, including information about the Products you purchase or about which you make an inquiry, billing information, transaction history, your favorite Products;

Credit card information, such as surname, name, credit card number, expiry date, CVM number and passwords (collected by the Payment Provider through the secured Payment Interface);

User preferences, such as Product requirements, newsletter, community choices and other information you select in the Customer profile when registering on the Website or indicated by your use of the Website.

We may supplement information you provide with information received from third parties.

When you use the Website, you may submit information and content to your profile, send messages, perform searches, submit reviews, and otherwise transmit information to other Users, the Company stores this information and registration information so that we can provide you the Service and offer personalized features.

In addition to the information contained in this privacy policy, the Website may provide Users with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

Before ordering any Product on or through the Website, the different steps of the electronic purchase will be communicated to you. You will receive an automatic confirmation of the Products purchased through the Website and by email. Typographic mistakes will be automatically corrected by the Website.

Your consent to this Privacy Policy followed by your submission of Personal Data represent your explicit agreement to the collection, processing, storage and, when applicable, deletion of Personal Data by the Company as described in this Privacy Policy.


The main reason why we collect Personal Data about you is to provide you the Website and improve the Website features, to propose you Products that are suited to your, administer your Customer account and enable you to enjoy and easily navigate the Website.

The Company uses the collected information for the purpose of optimizing and continuously further developing the Website, as well as more generally to offer all functions of the Website to the Users.

We will use your Personal Data to provide you with a better service, and in particular to: keep internal records; improve the way we offer you Products; fulfill your requests for Products ; communicate with you; contact you for market research purposes; and provide you with information about new Products available, blog posts, promotions, special offers and other information; personalize the promotional offers you see, in particular based upon your activity and your transaction history; respond to your questions and comments; send you the Company’s newsletter, unless you unsubscribe ; prevent potentially prohibited or illegal activities ; conduct research and compile statistics on usage patterns; process Transactions; manage your Customer account; enforce the Terms; comply with our legal requirements; as otherwise described to you at the point of collection. If you contact us via the messaging system or via email to the contacts set out on the Website, we will keep a record of that correspondence. Within the applicable rules and regulations, the Company may use the collected information to analyze your preferences and habits, personalize your use of the Website as well as enhance the Website and all of its functions.

Your Personal Data may be accessed, processed and stored as necessary for the uses stated above in accordance with this Privacy Policy. While the Company may share your Personal Data with agents and contractors in order to perform the functions listed above, including hosting services, Payment Provider, Issuers, we require that they treat your Personal Data, and limit their use, in accordance with the standards specified in this Privacy Policy and according to the same security standards as those used by the Company. You understand and agree that the Company may transfer your Personal Data to a third party for hosting or processing purposes. You understand and agree that the Company may transfer your Personal Data to the Payment Provider for processing your payments.

The Company is not responsible for circumvention of any privacy settings or security measures contained on the Website. You understand and acknowledge that, even after removal, copies of your Personal Data may remain viewable in cached and archived pages or if other Users have copied or stored your Personal Data.


A cookie is a piece of information that is placed automatically on your computer’s hard drive when you access certain websites. The cookie uniquely identifies your browser to the server. Cookies allow the Company to store information on the server (for example language preferences, technical information, click or path information, etc.) to help make the Web experience better for you and to conduct site analysis and website performance review. Most Web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of the Website may not work properly if you refuse cookies. The Company may also use a “Web beacon” on the Website (also known as an “action tag”, a “tracking pixel” or “clear GIF technology”), or similar technology, which helps analyze the effectiveness of websites by measuring, for example, the number of visitors to a site, how many visitors clicked on key elements of a site or what Web pages were visited. The Company uses cookies, tokens, Web beacon and other tracking technology to facilitate your access to the Website and analyze the traffic and usage of the Website, as well as identify malfunctions. It also allows the Company to enhance your experience with the Website as well as improve its content and conception, in particular depending on your preferences. They may also be used for marketing purposes.

The Company may collaborate with other companies that place cookies, tokens, Web beacons or other tracking technology on the Website. These companies help the Company in the management of the Website and offer additional services and products. The use of these technologies by such third parties is subject to their own conditions, privacy rules and terms of use, which are not covered by this Policy and for which the Company does not have any responsibility.

You may choose to deactivate the use of some or all of the cookies by selecting appropriate parameters on your navigator (as the case may be, with the exception of technical cookies necessary for the functioning of the Website). However, deactivation of this kind might prevent the use of certain and/or all functions of this Website.


The Website may use Google Analytics, an Internet site analysis service supplied by Google Inc. (“Google”). Google Analytics uses cookies. The data generated by the cookies concerning your use of the Website (including your IP address) will be forwarded to, and stored by, Google on servers located in particular in the United States. Google will use this information to evaluate your use of the Website, compile reports on site activity for its publisher and provide other services relating to the activity of the Website and the use of the internet.

The use of Google Analytics on the Website may also integrate Google Analytics Advertising Features, especially for marketing and remarketing purposes. Such features may include the use of first-party cookies (Google Analytics cookies; and third-party cookies (such as the DoubleClick cookie).

Google may release the data received to third parties if there is a legal obligation to do so or when the third parties process these data for the account of Google including, in particular, the publisher of this Website. Google will not cross-reference your IP address with any other data held by Google.

You may deactivate the use of cookies by selecting appropriate parameters on your navigator. . Please check your browser’s cookie settings support pages to inform yourself on the instructions to be followed. Google has itself developed and Opt-out Browser add-on that enables you to opt-out of Google’s Analytics program in relation to various browsers (including Microsoft Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari and Opera). It is available on

Please note however that deactivation of this kind might prevent the use of certain functions of this Website. By using the Website you specifically consent to the processing of your personal data by Google under the conditions and for the purposes described above.


The Company may share the collected information with outside companies or agents only in relation to technological maintenance, hosting, payment processing or working on behalf of the Company for the Website. Such transfer is made to help or participate in the Website’s operation, in particular by managing, hosting or maintaining the Website, or to conduct research, monitor and analyze the network’s status. The Company shall conclude any required agreement with such outside companies or agents to ensure that data recipients guarantee adequate data protection at all times. The collected data may be passed on without restriction to any subsidiary or affiliates of the Company, which shall guarantee and be subject to the same data protection requirements as the Company. Your Personal Data collected through the contact form shall only be transferred, as the case may be, for the purpose of answering your query.

The information obtained through the Website is mainly stored in the United Kingdom, but may also be sent to other countries when appropriate. You expressly consent to such a transmission, being specified that the Company shall respect all applicable rules and regulations and shall adopt all required and necessary measures prior to the transmission of data abroad.

The Company may transfer the collected Personal Data to any government and law enforcement officials or private parties as it, in its sole discretion, believes necessary or appropriate to respond to claims and legal actions (including but not limited to subpoenas), to protect the property and rights of the Company or a third party, to protect the safety of the public or any person, or to prevent or stop any activity that may be considered to be, or to pose a risk of being, illegal, unethical or legally actionable.


The Company may transfer your Personal Data to providers for the purpose of delivering the services. Providers will process your Personal Data and will be solely responsible for them after the transfer by the Company. You hereby expressly agree that the Company may transfer your Personal Data to providers located abroad, with a similar level of protection than Switzerland and that the Providers will process your Personal Data under their sole responsibility and subject to the laws applicable in their country.


The Company may transfer your Personal Data to Payment Providers in order to proceed to the payment of your order. You understand and explicitly agree that the Payment Provider, not the Company, will act as a data controller of the payment information.

The Company may transfer your email address to the Payment Provider and you agree that the Payment Provider enters into contact with you for the following purposes:

(i) sending of a receipt to confirm the status of a transaction and/or the billing descriptor to appear on the your credit/debit card and bank statement;

(ii) request additional information to confirm or complete the transaction;

(iii) sending of a confirmation of the transaction.

The Company guarantees not to copy, save, capture or intercept payment instrument related information, such as credit card numbers, credit card holder name, CVM codes, passwords that are directly entered into the Payment Provider’s Payment Interface.

By submitting your payment information, you authorize the Payment Provider to access, collect, process, use and, when applicable, delete this information in order to process the payment of the Services. The Payment Provider proceeds to the payment through your credit or debit card in strict compliance with the applicable payment scheme rules PCI/DSS and TPPP rules. You understand and agree with the operation of payments by these external services.


The Company may use only non-identifiable aggregated data collected through the Service to analyze Website usage and system performance (“Big Data”). Provided Big Data does not contain Personal Data (even by recoupment of information or of Personal Data) you understand and agree that Big Data may be used by the Company and shared with third parties in any manner. The Company may share Big Data and/or aggregated information that does not include Personal Data or log data with third parties for analysis and other purposes.


The Company uses standard technology and security precautions, rules and other procedures to protect your personal information from unauthorized access, improper use, disclosure, loss or destruction. It is your personal responsibility to ensure that the computer you are using is adequately secured and protected against malicious software, such as Trojans, computer viruses and worm programs.



As a User, you can ask the Company whether it has stored any personal data on you, file a request for further information, receive a copy of the data stored in our systems (to that end, the Company shall require a copy of an official form of identification) as well as subsequently instruct the Company to correct any erroneous personal data. Any request for access must be sent by registered letter with a copy of your ID to: The Hana Road Music Group Sàrl, Avenue du Casino 32, 1820 Montreux, Switzerland.


Any Personal Data that has been collected through the Website may be kept and remain for a certain duration, in particular (without limitation) in case of back-up systems and/or in order to answer to a User’s query made through the contact form, but shall be suppressed as soon as its use is not required anymore. Anonymous information (including in particular data collected through the use of cookies) may be kept without any limitation.


The Company may sell, transfer or otherwise share some or all of its assets, including your Personal Data and Big Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy or insolvency event. Your consent to this Privacy Policy followed by your submission of Personal Data represent your explicit agreement to that transfer.


The Privacy Policy, as well as all matters arising out or in relation to it (including non-contractual disputes or claims and their interpretation) shall be governed by the laws of Switzerland, to the exclusion of the rules on conflicts of laws. Any claim or dispute regarding the Policy or in relation to it shall (including for non-contractual disputes or claims and their interpretation) be subject to the exclusive jurisdiction of the Courts of Lausanne, Switzerland, subject to an appeal at the Swiss Federal Court. You agree that any dispute is personal to you and the Company, and that any dispute shall only be resolved by an individual litigation and shall not be brought as a class action, or any other representative proceeding. You agree that a dispute cannot be brought as a class or representative action or on behalf of any other person or persons. You shall maintain the confidentiality of any proceedings, including but not limited to, any and all information gathered, prepared, and presented for purposes of the litigation or related to the dispute(s) therein.