1. Who We Are
Acumo Music Academy Ltd (“Acumo”, “we”, “us” or “our”) provides music education, one-to-one tuition, concerts, competitions, festivals, international study guidance, artistic mentoring and related music education services.
For the purposes of UK data protection law, Acumo Music Academy Ltd is the data controller responsible for the personal information described in this Privacy Policy.
If you have any questions about this Privacy Policy or how we use your personal information, please contact us:
Email: contact@AcumoMusic.com
Location: London, United Kingdom

2. Who This Privacy Policy Applies To
This Privacy Policy applies to personal information we collect about people who interact with Acumo, including:
• students and prospective students;
• parents and guardians;
• applicants to competitions, concerts, festivals, academies or other programmes;
• teachers, artists, musicians, adjudicators and other professionals;
• people who make enquiries or register their interest in our services;
• visitors to our website; and
• other individuals who communicate or work with us.
Some of our services are intended for children and young people. Where appropriate, information may be provided by or collected from a parent or guardian on their behalf.
Children have data protection rights in their own personal information, and privacy information should be presented in a way that they can understand where appropriate. 

3. Personal Information We May Collect
Depending on how you interact with us, we may collect the following types of personal information.
Identity and contact information
This may include:
• name;
• date of birth or age where relevant;
• email address;
• telephone number;
• postal address or location;
• parent or guardian details; and
• emergency contact details where appropriate.
Music and education information
Where relevant to the services you request, we may collect information including:
• instrument or area of musical study;
• current musical level;
• examination grades or qualifications;
• school, conservatoire or educational background;
• repertoire;
• musical experience;
• teacher information;
• performance history;
• audition or competition information;
• recordings, photographs or videos submitted as part of an application;
• academic or musical goals; and
• information relating to study-abroad or conservatoire applications.
Applications, bookings and participation
We may collect information you provide when you:
• enquire about a service;
• register your interest;
• book lessons;
• enter a competition;
• apply for a concert, festival, academy or programme;
• attend an event; or
• participate in another Acumo activity.
Payment and transaction information
Where payments are required, information relating to bookings, invoices, payments and refunds may be processed.
Payment card information may be handled directly by our payment service providers rather than stored by Acumo.
Communications
We may keep records of communications with you, including enquiries, emails, messages, application correspondence and feedback.
Website and technical information
When you use our website, we or our website service providers may automatically collect certain technical information, such as:
• IP address;
• browser type;
• device type;
• operating system;
• pages visited;
• approximate location derived from technical information; and
• information collected through cookies and similar technologies.

4. Special Category and Sensitive Information
We do not routinely request sensitive or special category personal information.
However, in some circumstances you may provide information relating to health, disability, accessibility, dietary requirements or other matters where this is relevant to your participation in lessons, events, travel or programmes.
Where we need to process such information, we will only do so where there is an appropriate legal basis and, where required, an additional condition under UK data protection law.
We aim to collect only the information that is genuinely necessary for the relevant purpose.

5. Information About Children
Many of our activities involve children and young musicians, so we take particular care when handling children's personal information.
Depending on the age of the student and the nature of the service, we may communicate primarily with a parent or guardian.
We may collect information about a child where it is necessary to:
• arrange lessons or educational activities;
• process applications or registrations;
• organise competitions, concerts or events;
• support study-abroad or conservatoire applications;
• communicate with parents, guardians or teachers;
• protect the child's safety and wellbeing; or
• provide the service requested.
We seek to collect only information that is reasonably necessary for these purposes.
Where consent from a parent or guardian is appropriate, we may request it before processing particular information or using photographs or recordings.

6. How We Collect Personal Information
We may receive personal information:
Directly from you
For example, when you:
• submit an enquiry form;
• contact us by email or telephone;
• register for an event or service;
• complete an application;
• book a lesson;
• submit recordings or other materials; or
• communicate with us.
From a parent or guardian
For children and young people, information may be provided by their parent or guardian.
From other people or organisations
Where appropriate, information may also be provided by:
• teachers;
• schools or educational institutions;
• artists or professional advisers;
• event organisers;
• partner organisations; or
• other individuals involved in an application or programme.
Where we receive information from another source, we will use it only where we have an appropriate reason to do so.
Automatically through our website
Some technical information may be collected automatically through cookies and similar technologies when you visit our website.

7. How We Use Personal Information
We may use personal information to:
• respond to enquiries;
• provide information about our services and opportunities;
• arrange and administer music lessons;
• match students with appropriate teachers;
• manage competition entries and applications;
• manage concerts, festivals, academies and events;
• administer auditions and selection processes;
• communicate with students, parents, guardians, teachers and participating artists;
• support conservatoire, school and study-abroad applications;
• provide artistic mentoring and advisory services;
• process bookings, invoices and payments;
• manage attendance and event administration;
• provide appropriate support to participants;
• operate and improve our website;
• maintain appropriate business and financial records;
• protect our organisation, website and users from misuse or security risks;
• comply with legal, safeguarding, accounting and regulatory obligations; and
• where permitted, communicate with you about relevant Acumo programmes, events or services.

8. Our Lawful Bases for Processing
UK data protection law requires us to have a lawful basis for processing personal information.
Depending on the circumstances, we may rely on one or more of the following.
Contract
We may process personal information where it is necessary to provide a service you have requested or to take steps before entering into an agreement with you.
For example, this may apply when you book lessons, register for a programme or apply for an Acumo service.
Legitimate interests
We may process information where it is necessary for our legitimate interests, provided those interests are not overridden by your rights and interests.
Our legitimate interests may include:
• operating and administering our music education services;
• responding to enquiries;
• organising events and programmes;
• improving our services and website;
• maintaining appropriate business records;
• protecting our organisation and website; and
• communicating with existing clients and participants where appropriate.
Consent
We may rely on your consent where appropriate, for example for certain marketing communications, optional cookies, or particular uses of photographs or recordings.
Where we rely on consent, you may withdraw it at any time.
Legal obligation
We may process personal information where necessary to comply with a legal or regulatory obligation.
ICO guidance requires organisations relying on legitimate interests to explain what those interests actually are, rather than simply stating “legitimate interests”. 

9. Photographs, Video and Audio Recordings
Concerts, competitions, festivals, masterclasses and other Acumo activities may involve photography, video or audio recording.
Where appropriate, we will provide information about recording before the relevant event or activity.
For children and young people, we may request permission from a parent or guardian where appropriate.
Recordings or photographs may, where permitted, be used for purposes such as:
• documenting an event;
• educational purposes;
• promoting Acumo programmes and activities;
• our website; or
• Acumo's official social media and communications.
Where consent is the basis for a particular use, consent may be withdrawn for future use by contacting us.

10. Marketing Communications
Where permitted by law, we may send information about Acumo programmes, concerts, competitions, festivals, educational opportunities or related services.
Where consent is required, we will ask for your consent before sending marketing communications.
You may unsubscribe from marketing communications at any time by using an unsubscribe option where provided or by contacting us at:
contact@AcumoMusic.com
Unsubscribing from marketing does not prevent us from sending communications that are necessary to provide a service you have requested.

11. Sharing Personal Information
We do not sell personal information.
We may share personal information where reasonably necessary with organisations or individuals involved in providing our services.
These may include:
• teachers and music professionals;
• adjudicators or artistic panels;
• event venues and event providers;
• educational institutions or partner organisations where relevant to an application;
• website and hosting providers;
• email and communications providers;
• booking and administrative service providers;
• payment processors;
• IT and technology providers;
• professional advisers such as accountants or lawyers; and
• public authorities where disclosure is required by law.
We aim to provide only the information reasonably necessary for the relevant purpose.
Our website is created and hosted using third-party website technology, including Wix, and such providers may process information in connection with hosting, security and website functionality.

12. International Transfers
Some of the technology providers or other organisations we work with may process personal information outside the United Kingdom.
We may also work with international musicians, institutions or organisations where this is relevant to a programme or service.
Where personal information is transferred outside the UK, we will take appropriate steps required by applicable data protection law.
Depending on the destination and circumstances, this may include relying on:
• UK adequacy regulations;
• recognised contractual safeguards; or
• another permitted transfer mechanism.
The ICO's current guidance confirms that restricted international transfers must generally be covered by adequacy regulations, appropriate safeguards such as the UK IDTA or Addendum, or a permitted exception. ICO
You may contact us if you would like further information about the safeguards applying to your information.

13. How Long We Keep Personal Information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected.
The appropriate retention period depends on factors including:
• the type of information;
• the service provided;
• whether there is an ongoing relationship with you;
• legal or accounting requirements;
• safeguarding considerations where applicable; and
• whether information may be required to establish, exercise or defend legal claims.
When information is no longer required, we will delete it, anonymise it or otherwise dispose of it appropriately.
ICO guidance allows an organisation either to state a specific retention period or explain the criteria it uses to determine that period. 

14. Cookies and Similar Technologies
Our website uses cookies and similar technologies.
Some cookies are necessary for the website to function properly.
Other cookies may be used, with your permission where required, to:
• understand how visitors use our website;
• improve website performance;
• remember preferences; or
• support analytics or other optional functionality.
Where consent is required, non-essential cookies will not be used until you have made your choice through our cookie consent settings.
You can change or withdraw your cookie choices through the cookie settings made available on our website.
ICO guidance states that non-essential cookies should not be placed before valid consent has been obtained, and merely continuing to use a website does not amount to valid consent. 

15. Data Security
We take reasonable technical and organisational measures designed to protect personal information against:
• unauthorised access;
• accidental loss;
• misuse;
• alteration;
• disclosure; or
• destruction.
Access to personal information is limited to people who reasonably need it for their role or for providing the relevant service.
However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

16. Your Data Protection Rights
Depending on the circumstances and the lawful basis on which we process your information, you may have the right to:
• request access to your personal information;
• request correction of inaccurate or incomplete information;
• request deletion of personal information in certain circumstances;
• request restriction of processing;
• object to certain processing;
• request transfer of certain personal information in a portable format;
• withdraw consent where processing is based on consent; and
• complain to a data protection regulator.
Your right to object
Where we process your personal information on the basis of legitimate interests, you may have the right to object to that processing.
To exercise your rights, please contact:
contact@AcumoMusic.com
We may need to confirm your identity before responding to certain requests.

17. Complaints
If you have concerns about how we handle your personal information, we would appreciate the opportunity to address them first.
Please contact us at:
contact@AcumoMusic.com
You also have the right to complain to the UK's independent data protection regulator, the:
Information Commissioner's Office (ICO)
Information about contacting the ICO is available on its official website.

18. Third-Party Websites
Our website may contain links to websites operated by other organisations.
We are not responsible for the privacy practices of third-party websites.
We recommend reviewing the privacy information provided by the relevant organisation before providing personal information to them.

19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect:
• changes to our services;
• changes to our website or technology;
• changes to the way we handle personal information; or
• changes to legal or regulatory requirements.
Any updated version will be published on this page.
The date at the top of this Privacy Policy will show when it was last updated.

20. Contact Us
For questions, requests or concerns relating to privacy or personal information, please contact:
Acumo Music Academy Ltd
London, United Kingdom
Email: contact@AcumoMusic.com