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Privacy Policy of The Focusrite group

The Focusrite group collects some Personal Data from its Users.

This document contains a section dedicated to California consumers and their privacy rights.

This document contains a section dedicated to Virginia consumers and their privacy rights.

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Owner and Data Controller

Focusrite Plc
Windsor House,
Turnpike Rd,
High Wycombe
HP12 3FX

Raising a Data Privacy Request:

We are a Group of companies with multiple different brands, so it is really important to us that we deal with your request in the best way possible. Filling this form is the quickest way to have us process your request.

Data Removal/Amendment Form

*** Please use the form rather than emailing the DPO mailbox email address advertised below***

Use the form or you can call 310-322-5500 to exercise your CCPA rights.

Owner contact email: privacy@focusritegroup.com

Types of Data collected

Among the types of Personal Data that The Focusrite group collects, by itself or through third parties, there are: Tracker; Usage Data; first name; last name; country; email address; ZIP/Postal code; phone number; Microphone permission; Data communicated while using the service; various types of Data; geographic position; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using The Focusrite group.
Unless specified otherwise, all Data requested by The Focusrite group is mandatory and failure to provide this Data may make it impossible for The Focusrite group to provide its services. In cases where The Focusrite group specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by The Focusrite group or by the owners of third-party services used by The Focusrite group serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through The Focusrite group and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of The Focusrite group (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Contacting the User, Handling payments, Device permissions for Personal Data access, Displaying content from external platforms, Heat mapping and session recording, Interaction with data collection platforms and other third parties, Interaction with external social networks and platforms, Interaction with live chat platforms, Interaction with online survey platforms, Interaction with support and feedback platforms, Location-based interactions, Managing contacts and sending messages, Managing data collection and online surveys, Managing support and contact requests, Platform services and hosting, Registration and authentication, Remarketing and behavioral targeting, SPAM protection, User database management, Advertising, Marketing, Beta Testing, Tag Management, Content performance and features testing (A/B testing), Selling goods and services online, Infrastructure monitoring and Traffic optimization and distribution.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Device permissions for Personal Data access

Depending on the User's specific device, The Focusrite group may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of The Focusrite group.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by The Focusrite group.

Microphone permission

Allows accessing and recording microphone audio from the User's device.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on The Focusrite group, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside The Focusrite group. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

Facebook Lookalike Audience (Facebook, Inc.)

Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of The Focusrite group or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.

Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of The Focusrite group, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Countly (CLY)

Countly is an analytics service provided by CLY.

This service is designed for mobile apps analytics and can collect various information about the User’s device, highlighted in the Countly privacy policy.

Personal Data processed: Cookies; Usage Data.

Place of processing: Turkey – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

HubSpot Analytics (HubSpot, Inc.)

HubSpot Analytics is an analytics service provided by HubSpot, Inc.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out .

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Cookies; Usage Data.

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Google Analytics with anonymized IP

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of The Focusrite group, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Focusrite Groups Novation Components Application

Google Analytics
Within the Focusrite Groups' Novation Components application we use Google Analytics to track and examine use of the application.

Hotjar
Within the Focusrite Groups' Novation Components application we use Hotjar to track and examine use of the application. Hotjar is also used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of User behaviour.
Some of these services may record sessions and make them available for later visual playback.

Google Optimize
Within the Focusrite Groups' Novation Components application we use Google Optimize to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the Novation Components application.

To learn how to prevent tracking in the Novation Components Application click:-
https://support.novationmusic.com/hc/en-gb/articles/360021363080

This processing constitutes:

a sale according to the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Beta Testing

This type of service makes it possible to manage User access to The Focusrite group, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of The Focusrite group in a personally identifiable form.

Product design research and Beta testing

By entering the personal information listed below in the webforms of this website or other Focusrite group websites; researchers, consumers and beta testers authorise employees and contractors of the Focusrite Group to use their details to contact them for the purposes of improving the products and services of the Focusrite Group.

Personal Data collected at Sign Up: First Name, Last name, Email address, City, Country, Affiliation to other audio industry companies (if applicable).

Personal Data collected if researcher/Beta tester is selected: Postal address, Phone Number, Skype address, Yammer profile, and their Facebook login or Novation login where applicable.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Contacting the User

Contact form (The Focusrite group)

By filling in the contact form with their Data, the User authorizes The Focusrite group to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: country; email address; first name; last name; ZIP/Postal code.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the VCDPA

Mailing list or newsletter (The Focusrite group)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning The Focusrite group. Your email address might also be added to this list as a result of signing up to The Focusrite group or after making a purchase.

Personal Data processed: first name; last name.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the VCDPA

Phone contact (The Focusrite group)

Users that provided their phone number might be contacted for commercial or promotional purposes related to The Focusrite group, as well as for fulfilling support requests.

Personal Data processed: phone number.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the VCDPA

Content performance and features testing (A/B testing)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of The Focusrite group.

Google Optimize (Google Ireland Limited)

Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google").

Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Device permissions for Personal Data access

The Focusrite group requests certain permissions from Users that allow it to access the User's device Data as described below.

Device permissions for Personal Data access (The Focusrite group)

The Focusrite group requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

Personal Data processed: Microphone permission.

Category of personal information collected according to the CCPA: internet information.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of The Focusrite group and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Maps widget (Google Ireland Limited)

Google Maps is a maps visualization service provided by Google Ireland Limited that allows The Focusrite group to incorporate content of this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Handling payments

Unless otherwise specified, The Focusrite group processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. The Focusrite group isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Recurly (Recurly, Inc.)

Recurly is a payment service provided by Recurly, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Adyen (Adyen B.V.)

Adyen is a payment service provided by Adyen B.V.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Netherlands – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Heat mapping and session recording

Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Infrastructure monitoring

This type of service allows The Focusrite group to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of The Focusrite group.

New Relic (New Relic)

New Relic is a monitoring service provided by New Relic Inc.
The way New Relic is integrated means that it filters all traffic of The Focusrite group, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on The Focusrite group to be collected.

Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Interaction with data collection platforms and other third parties

This type of service allows Users to interact with data collection platforms or other services directly from the pages of The Focusrite group for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Hotjar Recruit User Testers (Hotjar Ltd.)

The Hotjar Recruit User Testers widget is a service for interacting with the Hotjar data collection platform provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Cookies; Usage Data; various types of Data.

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of The Focusrite group.
The interaction and information obtained through The Focusrite group are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on The Focusrite group isn’t being connected back to the User’s profile.

YouTube button and social widgets (Google Ireland Limited)

The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Ireland Limited.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages of The Focusrite group, for contacting and being contacted by The Focusrite group support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Zendesk Chat (Zendesk, Inc.)

Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.

Personal Data processed: email address; first name; last name.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Interaction with online survey platforms

This type of service allows Users to interact with third-party online survey platforms directly from the pages of The Focusrite group.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

SurveyMonkey Widget (SurveyMonkey Inc.)

The SurveyMonkey Widget is a service for interacting with the SurveyMonkey online survey platform provided by SurveyMonkey Inc.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Interaction with support and feedback platforms

This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of The Focusrite group.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Zendesk Widget (Zendesk, Inc.)

The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.

Personal Data processed: email address; first name; last name; phone number.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Location-based interactions

Geolocation (The Focusrite group)

The Focusrite group may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by The Focusrite group.

Personal Data processed: geographic position.

Category of personal information collected according to the CCPA: geolocation data.

This processing constitutes:

a sale according to the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

HubSpot Email (HubSpot, Inc.)

HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.

Personal Data processed: email address; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Managing data collection and online surveys

This type of service allows The Focusrite group to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Hotjar surveys (Hotjar Ltd.)

Hotjar surveys is a survey builder and data collection platform provided by Hotjar Ltd.
Hotjar surveys may use cookies to track User behavior. Users can Opt-Out of Hotjar surveys cookie tracking by visiting this opt-out page.

Hotjar surveys respects the Do Not Track option available in most modern browsers that, if activated, sends a special signal to stop tracking User activity. Users can find more information on how to enable Do Not Track for each supported browser here.

Personal Data processed: email address; first name; last name.

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA

SurveyMonkey (SurveyMonkey Inc.)

SurveyMonkey is a survey builder and data collection platform provided by SurveyMonkey Inc.

Personal Data processed: email address; first name; last name.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Survey Gizmo

Survey Gizmo is a survey builder and data collection platform provided by Survey Gizmo

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Managing support and contact requests

This type of service allows The Focusrite group to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Zendesk (Zendesk, Inc.)

Zendesk is a support and contact request management service provided by Zendesk Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Freshdesk (Freshworks, Inc.)

Freshdesk is a support and contact request management service provided by Freshworks, Inc.

Personal Data processed: Data communicated while using the service; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Marketing

Competition Partners

We work with Production Expert to run competitions in which our products are given away. Focusrite only processes entrants’ personal data when the data subject has given their explicit consent to the data controller.

The Focusrite Group may also collect personal data comprising images of persons in the context of promotional competitions which will be collected and processed on the basis of Focusrite Group's legitimate interest. Competition entrants have the right to object to any processing of this nature.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Platform services and hosting

These services have the purpose of hosting and running key components of The Focusrite group, therefore allowing the provision of The Focusrite group from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Apple App Store (Apple Inc.)

The Focusrite group is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of The Focusrite group. Much of this information is processed on an opt-in basis.

Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Shopify (Shopify Inc.)

Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Canada – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Registration and authentication

By registering or authenticating, Users allow The Focusrite group to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, The Focusrite group will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Facebook Authentication

Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Google OAuth (Google Ireland Limited)

Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Remarketing and behavioral targeting

This type of service allows The Focusrite group and its partners to inform, optimize and serve advertising based on past use of The Focusrite group by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of The Focusrite group with the Facebook advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Twitter Remarketing (Twitter, Inc.)

Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of The Focusrite group with the Twitter advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Twitter Tailored Audiences (Twitter, Inc.)

Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of The Focusrite group with the Twitter advertising network.

Users can opt out from interest-based ads by going to: Personalization and Data.

Personal Data processed: Cookies; email address.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Google Ads Remarketing

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of The Focusrite group with the Google Ads advertising network and the DoubleClick Cookie.

Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Facebook Custom Audience

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of The Focusrite group with the Facebook advertising network.

Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.

Personal Data processed: email address; Tracker.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Selling goods and services online

Advansys ECommerce Management System

Advansys is a platform provided byADVANSYS LIMITED that allows the Owner to build, run and host an e-commerce website.

This processing constitutes:

a sale according to the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

SPAM protection

This type of service analyzes the traffic of The Focusrite group, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information; inferred information.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on The Focusrite group in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA

Traffic optimization and distribution

This type of service allows The Focusrite group to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between The Focusrite group and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through The Focusrite group, i.e., communication between The Focusrite group and the User's browser, while also allowing analytical data from The Focusrite group to be collected.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to The Focusrite group, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving The Focusrite group.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on The Focusrite group.

HubSpot CRM (HubSpot, Inc.)

HubSpot CRM is a User database management service provided by HubSpot, Inc.

Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

HubSpot Lead Management (HubSpot, Inc.)

HubSpot Lead Management is a User database management service provided by HubSpot, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Salesforce Sales Cloud (Salesforce.com, inc.)

Salesforce Sales Cloud is a User database management service provided by salesforce.com, inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

Spot

Profile name, what they have put in the comment and potentially other details. i.e location, where purchased

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Analysis and predictions based on the User’s Data (“profiling”)

The Owner may use the Personal and Usage Data collected through The Focusrite group to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

Automated decision-making

Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. The Focusrite group may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. The Focusrite group adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:

to enable or otherwise improve the decision-making process;
to grant Users fair and unbiased treatment based on consistent and uniform criteria;
to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within The Focusrite group, Users can check the relevant sections in this document.

Consequences of automated decision-making processes for Users and rights of Users subjected to it

As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:

obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
request and obtain from the Owner human intervention on such processing.

To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by The Focusrite group depends on the payment system used.

Push notifications

The Focusrite group may send push notifications to the User to achieve the purposes outlined in this privacy policy.

Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for The Focusrite group, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of The Focusrite group.

Push notifications for direct marketing

The Focusrite group may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by The Focusrite group).

Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for The Focusrite group or all of the apps on the particular device.

Users must be aware that disabling push notifications may negatively affect the utility of The Focusrite group.

Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

The Service is not directed to children under the age of 13

Users declare themselves to be adult according to their applicable legislation. Minors may use The Focusrite group only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use The Focusrite group.

Unique device identification

The Focusrite group may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

User identification via a universally unique identifier (UUID)

The Focusrite group may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

Pseudonymous use

When registering for The Focusrite group, Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on The Focusrite group shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on The Focusrite group, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.

Personal Data collected through sources other than the User

The Owner of The Focusrite group may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Cookie Policy

The Focusrite group uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of The Focusrite group or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

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

System logs and maintenance

For operation and maintenance purposes, The Focusrite group and any third-party services may collect files that record interaction with The Focusrite group (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

The Focusrite group does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within The Focusrite group and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running The Focusrite group and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).

Notice at collection

Categories of personal information collected, used, sold, or shared

In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, internet information, geolocation data and inferred information.

We do not collect sensitive personal information.

We will not collect additional categories of personal information without notifying you.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of The Focusrite group and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

How we collect information: what are the sources of the personal information we collect?

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use The Focusrite group.

For example, you directly provide your personal information when you submit requests via any forms on The Focusrite group. You also provide personal information indirectly when you navigate The Focusrite group, as personal information about you is automatically observed and collected.

Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

How we use the information we collect: disclosing of your personal information with third parties for a business purpose

For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.

We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.

Your right to opt out of the sale or sharing of your personal information and how you can exercise it

We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on The Focusrite group.

If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.

What are the purposes for which we use your personal information?

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

Your privacy rights under the California Consumer Privacy Act and how to exercise them

The right to access personal information: the right to know and to portability

You have the right to request that we disclose to you:

the categories of personal information that we collect about you;
the sources from which the personal information is collected;
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on The Focusrite group, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.

The right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information

You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Information for Virginia consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the VCDPA.

Categories of personal data processed

In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

Categories of personal data we collect

We have collected the following categories of personal data: identifiers, internet information, geolocation data and inferred information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

How we use the data we collect: sharing of your personal data with third parties

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.

Sale of your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.

To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a minor under your parental authority.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through The Focusrite group (or third-party services employed in The Focusrite group), which can include: the IP addresses or domain names of the computers utilized by the Users who use The Focusrite group, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using The Focusrite group who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of The Focusrite group. The Data Controller, unless otherwise specified, is the Owner of The Focusrite group.

The Focusrite group (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by The Focusrite group as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to The Focusrite group, if not stated otherwise within this document.

Latest update: January 10, 2022