Irish Music Rights Organisation (“IMRO”, “we” or “us”) are committed to protecting and respecting your privacy.
IMRO, with an address at Copyright House, Pembroke Row, Lower Baggot Street, Dublin 2, is the licensing body that grants permission to users of musical works on behalf of the composers, authors and publishers of those works (being IMRO’s members). IMRO is, for purposes of the Data Protection Acts 1988 and 2003 (as amended, superseded or replaced from time to time)(the “Acts”), the data controller of personal data that it collects in that capacity and for its own business purposes.
Phonographic Performance Ireland (“PPI”), with an address at 63 Patrick Street, Dun Laoghaire, Co. Dublin, is the licensing body that grants permission to users of recorded musical works on behalf of record labels (being PPI’s members). PPI has appointed IMRO as its agent with effect from 1 January 2016 to perform certain services relating to its licensing operations (see 1.5 (PPI Agency) below for further details). As part of our appointment and in order for us to perform those services, PPI provided us with information relating to its licensees, including the licensees name, postal address, e-mail address, phone number and details of performance particulars and we may from time to time update that information or collect further information relating to PPI licensees as part of our services to PPI (together the “PPI Information”). To the extent that PPI Information contains any personal data, PPI is the data controller of such data for purposes of the Acts.
1 Information we obtain and how we use it
1.1 Information you give us. You may give us information about you when you enter into the Dual Licence Copyright Contract, fill in forms or when you correspond with us by phone, e-mail or otherwise. This includes information you provide when you register with us or subscribe to a service or newsletter available via the Site. The information you give us may include your name, postal address, e-mail address, phone number, date of birth (for identification / verification purposes), your CAE/IP number, information you may provide to participate in a competition and details of performance particulars (being information relevant to the performance of copyright music, including but not limited to the frequency of performance, nature of performance, audience / admission numbers, ticket price, floor area of the premises, number of seats, number of employees, etc.).
1.2 We will use this information:
(a) to administer IMRO licences and IMRO licence accounts and to collect IMRO licence royalties;
(b) to administer PPI licences and PPI licence accounts on behalf of PPI (see 1.5 (PPI Agency) below for further details);
(c) to carry out our obligations and enforce and defend our rights arising from any contract entered into between you and us (including the Dual Copyright Music Licence Agreement)
(d) to respond to any queries or other communications you submit to us;
(e) to notify you about changes to IMRO’s tariffs;
(f) for direct marketing purposes (see section 2 (Direct Marketing) for further details);
(g) to communicate with you to verify that you have applied to register for access to the Member’s Section of the Site, to verify that you have accessed the Member’s Section using your password or to inform you if you have won a competition; and / or
(h) to ensure that content from our Site is presented in the most effective manner for you and for your computer.
If you provide us with any information or communication specifically for the purpose of being published on the Site, we may publish this information on the Site without further notice to you. We have no obligation to you to publish or maintain any such information or communication. Any such information or communication will be considered non-confidential and non-proprietary, and by providing us with such information or communication you grant us an irrevocable licence and right to use, copy, store, reproduce, disclose, transmit, publish and distribute to third parties any such material for any purpose (including the right to sub-licence those rights). We will not be responsible or liable for the content or accuracy of any such information or communication. The views expressed by others on our via our Site do not represent the views of IMRO or PPI.
1.3 Technical information we collect about you. With regard to each of your visits to our Site we may automatically collect the following information:
(a) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, date and time of your access to our Site, the pages on our Site you visit, browser plug-in types and versions, operating system and platform; and
(b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), products and / or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
1.4 We will use this information:
(a) to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(b) to improve our Site to ensure that content is presented in the most effective manner for you and for your device;
(c) to allow you to participate in interactive features of our Site when you choose to do so;
(d) as part of our efforts to keep our Site safe and secure; and / or
(e) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
1.5 PPI Agency. We use PPI Information on behalf of PPI to:
(a) issue PPI licences;
(b) administer PPI licences and PPI licence accounts and to collect PPI licence royalties;
(c) to carry out PPI’s obligations under PPI licences on its behalf and, where required (and in conjunction with PPI), to enforce and defend PPI’s rights under those licences, to collect associated royalties;
(d) to respond to any queries or other communications relating to PPI licences that you submit to us;
(e) to notify you about changes to PPI’s tariffs; and
(f) for direct marketing purposes (see section 2 (Direct Marketing) for further details).
1.6 Information we receive from other sources. We may work with third parties (including, for example, business partners, sub-contractors in technical services, advertising networks, analytics providers and search information providers) and may receive information about you from them that is relevant to our business. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
2 Direct Marketing
We may (subject to applicable data protection laws) use your personal data to send you newsletters or make suggestions and recommendations to you about (as applicable) IMRO or PPI events, goods or services that may interest you. Those communications will give you the opportunity to opt out of receiving similar communications in the future. You can also choose to opt out of such future communications by contacting us at IMRO, Copyright House, Pembroke Row, Lower Baggot Street, Dublin 2 or by email at and in each case marked for the attention of Privacy Officer, IMRO.
4 Disclosure of your information
4.1 We may share your information with selected third parties including:
(a) our business partners, product and services suppliers and sub-contractors;
(b) PPI; and / or
(c) analytics and search engine providers that assist us in the improvement and optimisation of our Site.
4.2 We may also disclose your personal information to third parties:
(a) if we are acquired or we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
(c) to protect and enforce our (or PPI’s, our members, PPI’s member or other relevant parties’) rights, property or safety.
5 Passwords and Transmission of Information
5.1 Where you have chosen (or where we have given you) a password which enables you to access certain parts of our Site, you are responsible for keeping the password confidential. We ask you not to share your password with anyone.
5.2 Please be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your information transmitted to our Site and you transmit that information at your own risk. Once we have received your information, we will apply procedures and use security features to try to prevent unauthorised access.
6 Your rights
6.1 You have the right to request a copy of your personal data for which IMRO is the data controller. Subject to applicable law, we will provide you with a copy of your personal data as soon as practicable. There may be a charge for such a request (which will not be higher than an amount permitted by applicable law, currently €6.35). We may also request proof of identification to verify your access request. Any queries in relation to personal data for which IMRO is the data controller should be sent in writing to IMRO, Copyright House, Pembroke Row, Lower Baggot Street, Dublin 2 or by email to and in each case marked for the attention of Privacy Officer, IMRO.
6.2 You may also have the right to rectify, block or erase your personal data to the extent that it is inaccurate. If your personal data is inaccurate, you should inform us in writing using the applicable address above.
6.3 You have the same rights in relation to your personal data for which PPI is the data controller, subject to the same conditions as set out above. If you wish to request a copy of your personal data for which PPI is the data controller, please submit that request either to IMRO (using the contract details in 6.1 above) and we will receive and process on behalf of, and in conjunction with, PPI, or directly to PPI at 63 Patrick Street, Dun Laoghaire, Co. Dublin or by email to and marked for the attention of Privacy Officer, PPI.
7 Linked websites
7.1 Our Site may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for those websites or policies. Please check the applicable policies before you submit any personal data to those websites.
8 Changes to this Privacy Statement
We may from time to time revise this Privacy Statement by amending this page. You will be bound by such revised terms current when you use the Site and you should therefore periodically check this page for any amendments we make. This version of the Privacy Statement is effective from 1 December 2015.
Questions, comments and requests regarding this Privacy Statement are welcomed and should be addressed to IMRO, Copyright House, Pembroke Row, Lower Baggot Street, Dublin 2 or by email to firstname.lastname@example.org and in each case marked for the attention of Privacy Officer, IMRO.