Privacy policy

Introduction

This Privacy Notice is designed to inform you about the personal data relating to you which Sabam, Société Belge des Auteurs, Compositeurs et Editeurs – Belgische Vereniging van Auteurs, Componisten en Uitgevers, a cooperative company with limited liability, with registered office at Rue d’Arlon, 75-77 in 1040 Brussels and registered with the Register of Legal Entities RPM Bruxelles under number BE 0402.989.270, (acting as data controller and hereinafter referred as “We”, Our and Us”) collects via the website http://www.sabam.be (referred to hereinafter as the “Website”), why We collect and process such personal data, on which legal basis, and how We will handle personal data you provide Us with and personal data We learn about you from your visit to the Website. Your use of the Website implies your acknowledgment of this Privacy Notice.
 

Legal basis

We process your personal data on the basis of your specific consent (article 6, 1, a of GDPR) or on the basis of the necessity to perform an agreement of which the data subject is a party (article 6,1,b of GDPR) or on the basis of the necessity of the processing for the performance of our public interest task (article 6, 1, e) of GDPR).

When the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of such processing before the withdrawal of consent.
 

Personal data collected

We collect personal data relating to you (referred to hereinafter asPersonal Data”) in two ways:

  • through registration and sending of information that you choose to enter on certain pages of the Website. The Personal Data must be provided, in order to enable Us to fulfill the processing purposes, as mentioned below. Such Personal Data directly collected from you include identifying information: your first and last name, password, pseudonym, birth date or age, place of birth, sex, nationality, national register number, language, personal or professional address, personal or professional email address, personal or professional mobile or other phone number, contact information of the person to whom you have given a proxy, , your activity, your profession, training, degrees and/or awards received in the creative field, a copy of your ID card, data related to the company share; your membership data; your data related to the bank account and the e-account; your data related to the social and cultural fund; your data as organizer of events; your data related to the works: title, names and first names of the right holders, names and first names of the performers, distribution key, IP name number, role, name of the society of which the right holder is a member, the work code ; the data related to the right holders’ agreements; your financial data as to the distribution of the works of Sabam’s national and international repertoire; your data as to the sound reproductions of the works; your data for notifying works of Sabam’s repertoire; the data related to the unidentified works: work’s title, names and first names of the identified right holders, names and first names of the identified performers, role, work’s code, indication of the amounts received; the data related to the audiovisual works produced in the US that have generated private copying royalties for the authors on the Belgian territory;  the billing data : billing address and VAT number of the customers;  your messages, or other personal information or contact information you provide Us with. We may also ask for your comments, suggestions, or other information relating to the Website, or services, or Our company. Other specific types of information may be requested in connection with contests, sweepstakes, or other marketing activities, including uploading text, video or audio content.
  • through cookies. For more information about cookies, please see below.
     

Use of Personal Data

Your Personal Data will exclusively be used to the extent necessary to allow Us:

  • to process your membership applications to Sabam within the framework of the on-line affiliation (Article XI.248/1 and 2 of Book XI « Intellectual Property » of the Code of Economic Law – Article 6, 1, e of the GDPR) ;
  • to update your personal data within the framework of Sabam’s eServices (Article XI.248/1 and 2 of Book XI « Intellectual Property » in the Code of Economic Law – Article 6,1,b of GDPR) ;
  • to document the works of Sabam’s repertoire and to manage the distribution keys within the framework of Sabam’s eServices (Article XI.249 of Book XI « Intellectual Property » in the Code of Economic Law – Article 6,1,b and e of GDPR);
  • to document the publishing contracts of the works of Sabam’s repertoire within the framework of Sabam’s eServices (Article XI.249 of Book XI « Intellectual Property » in the Code of Economic Law – Article 6,1,b and e of GDPR); 
  • to grant licences and to collect the author’s rights and neighbouring rights for the use of Sabam’s repertoire as well as within the framework of its collaboration with Simim (Article XI.261 and XI.265 of Book XI « Intellectual Property » of the Code of Economic Law – Article 6,1,e of GDPR);;
  • to allow the users of Sabam’s eServices to consult their financial data as to the distribution of the works of Sabam’s repertoire (Article XI. 252, XI. 260, XI. 269 and XI. 270 of Book XI « Intellectual Property » of the Code of Economic Law – article 6,1,b and e of GDPR);
  • to respond to your direct request, as described at the time when we collect your Personal Data or as otherwise described to you prior to the use of your Personal Data (article 6,1,a of GDPR)
  • to process the uploading of the sound reproductions of your works belonging to Sabam’s repertoire in digital format on an online interface put at your disposal within the framework of our eServices in order to be able to collaborate with an external company that proposes an automatic identification service of the works performed during the broadcasts (article 6,1 a, b and e);
  • to process the online notifications as to the performance of works of Sabam’s repertoire (article 6,1 a, b and e). This notification allows Sabam to check the statement of the performed works and hence to properly distribute the collected royalties to the right holders of the copyrighted works that have been performed;
  • to publish the list of the unidentified works in order to allow Sabam to identify the right holders of these works, and this in order to be able to distribute the royalties (Article XI. 252 of Book XI « Intellectual Property » in the Code of Economic Law – Article 6,1, e of GDPR); 
  • to publish the list of the audiovisual works produced in the US that have generated on the Belgian territory private copying royalties for the authors in order to allow Sabam to identify the holders of these works and hence to properly distribute the royalties collected for these works (Article XI. 252 of Book XI « Intellectual Property » in the Code of Economic Law – Article 6,1, b and e of GDPR);
  • to make the repertoire of Sabam accessible to the public so that the latter can identify Sabam’s repertoire and its right holders (Article XI. 267 of Book XI « Intellectual Property » of the Code of Economic Law – Article 6,1,e of GDPR);
  • to manage your use of the Website, including to the extent applicable, your participation to contests or other marketing activities (provided you have given Us and/or partners the explicit prior consent to do so, where required under applicable law)  (Article 6,1,a du RGPD)
  • to send you newsletters, mailings, press releases or other marketing information which you may be interested in through email/mail/text messaging; (provided you have given Us and/or partners the explicit prior consent to do so, where required under applicable law) (Article 6,1,a of GDPR)

We may combine the Personal Data you submit with other personal data We have obtained about you for the same purposes from other sources, including if you have provided your information to Us in other places or through another medium (such as social media platforms). These sources are: databases, business cards, SIS, ICE, CISNET, IDA; the Verint system and Norricq, social media (Facebook, twitter, Linkedin, You Tube, Instagram, Google+), Mailchimp, Outlook, the databases of Roularta and Graydon, the webcrawling system (Procit), the websites, the event organizers, Sabam’s servers, the declarations of works on paper or by email, CWR, the playlists of channels and concerts, the customers, the representatives, the register for legal entities , Oracle Finance, the data subjects.

We may not use your Personal Data for new purposes which are as yet unforeseen in this Privacy Notice except on the basis of an applicable statutory permission. In any event, prior to using Personal Data for other purposes, We will inform you about such change to this Privacy Notice. In case of consent-based activities, We will not process your Personal Data for such new purposes without first obtaining your consent.
 

Special category of personal data

We will not collect or process any special category of personal data relating to you The special categories of Personal Data include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or other beliefs of a similar nature, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health, sex life or sexual orientation.
 

Direct marketing

We will not use your Personal Data for direct marketing purposes without your explicit prior consent, except where authorised under applicable law.

If at any time you decide not to receive any commercial or promotional information from Us, You may, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and oppose to the future processing of your Personal Data for such purposes by sending Us an email at newsletter@sabam.be and mention “opt-out” in the subject of your email. Alternatively, you may use the opt-out procedure provided in any promotional message you receive from Us.

Please note that opting out from receiving promotional messages from Us will not prevent you from receiving information that relates to any contract you may have entered into with Us.
 

Automated decision-making

We will not make use of automated decision-making processes, including profiling, except where authorised under applicable law. In such case we would inform you about the logic involved in the decision, as well as the significance and the envisaged consequences of such processing for you.
 

Sharing Personal Data and transferring Personal Data to third countries

We will not make your Personal Data available to any third party and shall not publicly disclose the Personal Data unless such transfers are based on your specific consent, necessary for the performance of a contract entered into between you and Us, or when such transfer of Personal Data is otherwise authorised or compulsory by law or by order of an administration or judicial authority.

We transfer your Personal Data to the following recipients: Affiliates, partners, sister societies, hosting provider, supplier, subcontractors, public service, Sabam’s lawyers, bailiffs, Sabam’s counsellors, accountants, etc.).

Please note that whenever your Personal Data are transferred to processors or third parties located outside the European Economic Area in countries which are not considered by the European Commission to guarantee an adequate level of personal data protection, We will ensure that appropriate measures are implemented according to the applicable national and European legislation relating to data protection. You may obtain a copy of the appropriate safeguards taken or information as to where they have been made available by sending Us an email at dpo@sabam.be.
 

Use of cookies  

Cookies are small text files that are placed on your computer or other device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
 

General information about the cookies used

This Website uses cookies in order to liven up your browsing session on the website, to store your language preferences, to analyse your use of the Website via Google Analytics, in order to distinguish your preferences from those of the other users and to measure the efficiency of our website’s content. By using cookies, we can also optimize our website and obtain a better overview of our users’ interests, without having to collect information in order to identify the latter. When you visit our Website for the first time, the entry page will show information on privacy and respective wording regarding the consent to the use of cookies through a “cookie banner”. If you continue to actively use the Website and do not actively object to the use of cookies, you agree to our use of cookies and such consent will be stored in your browser, so that the information does not have to be repeated on every page of the Website. Should the consent be missing in your browser (e.g. if you deleted your cookies), the “cookie banner” with privacy information will appear again the next time you visit the Website. We may install and use certain technically required cookies which therefore do not require your prior consent. We may also uses session cookies which are automatically deleted at the end of your session and which also do not require your prior consent. Other cookies (such as cookies to improve the navigational experience by keeping record of certain data – this avoids you having to reintroduce such data at each connection – and by tailoring the content of the Website to your preferences) may be installed and used on the basis of your consent. You will find all relevant information about the cookies used by this Website in the table below.
 

Cookie Name

Category of information stored

Purpose

Domain

Type of Cookie

Retention time

Related to user tracking

Communication to third party

Privacy policy of third party

Sabam

BNES_SABAM

 

Internal Application   (HttpOnly)

Info

 

Internal use

www.sabam.be

HTTP Cookie (Session Cookie)

 

Only valid during current browser session

 

N/A

N/A

N/A

ORA_WWV_APP_6010

 

Idem

Idem

Idem

Idem

Idem

Idem

Idem

Idem

BNES_ORA_WWV_APP_60010

 

Idem

Idem

Idem

Idem

Idem

Idem

Idem

Idem

HAS_js

 

See below

See below

See below

See below

See below

See below

See below

See below

_utma, utmb, _utmc, _utmt, _utmz (cookies Google Analytics)

 

See below

See below

See below

See below

See below

See below

See below

See below

1p_Jar, apisid,consent, hsid, nid, sapisid, sid, sidcc, ssid

(cookies Google Recaptcha)

 

See below

See below

See below

See below

See below

See below

See below

See below


Additional information about specific cookies

Sabam only uses first-party cookies, i.e. cookies that are created and managed by the Sabam website itself.

Has_js

A Drupal cookie to determine whether Javascript is enabled in the user’s browser. This is a functional cookie that allows our website to function properly. This cookie stores the user’s preferences in order to enhance the user experience on our website and it offers the user a more personalised browsing experience. It has a limited duration and is automatically deleted once the user leaves the website (session cookie).

Google Analytics: __utma, __utmb, __utmc, __utmt, __utmz

This Website uses Google Analytics, which is a web data analysis tool of Google Inc. (Google). Google Analytics uses cookies to help Us analyze how users use the Website.

Non-functional cookies that are used to collect grouped statistical information and to create reports on how users visit the website, without personally identifying the users. They aim to improve the website and the services provided for the users. One of these cookies used on our website is a session cookie (__utmc) with a limited duration that is automatically deleted after each session. The other cookies used are permanent cookies that are stored on the hard disk of the user’s computer or other device for a longer duration, even after closing the session. Permanent cookies remain on the device for the duration specified in the cookie or until they are deleted by the user.

For more details: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage describes how Google Analytics uses cookies to measure user interactions on websites.

Google Recaptcha: 1p_Jar, apisid,consent, hsid, nid, sapisid, sid, sidcc, ssid

Recaptcha is a service that protects our site from spam and abuse. It uses advanced risk analysis techniques to tell humans and bots apart.

For more details: https://www.google.com/recaptcha/intro/v3beta.html#


How to prevent cookies to be set

You may prevent cookies to be set by adjusting your browser accordingly. Indeed, most web browsers allow some control of most cookies through the browser settings. To find out more about how to prevent cookies to be set, visit http://www.allaboutcookies.org.

However, in such case, certain features of the Website may not work properly and some functionalities of the Website might no longer be available to you.


How to delete/deactivate cookies

In order to delete/deactivate all cookies set on your computer, the majority of web browsers allow you to disable completely the use of cookies, or to delete cookies created by specific domains/websites. To find out how to do it, please refer to your browser’s help page:

You can specifically prevent Google’s collection and use of data (cookies and IP address) for any website you visit by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en-GB.


Share on social networks

We make use of a social plug-in to enable you to share Website’s information on Twitter, Linkedin, You Tube, Facebook, Instagram, Google, through “Share” buttons.

For data privacy reasons, we deliberately opted against utilizing direct social network plug-ins on our Website. Instead, we employ an alternative technical solution that allows you to decide whether to transmit data to the social network operators and when. Thus when you visit the Website, data are never automatically transmitted to a social network. Only when you actively click on the respective button yourself will your web browser connect to the servers of the social network, i.e. clicking on elements then clicking on the social network’s icon indicates your consent to your browser connecting to the servers of the social network and sending usage data to that social network operator, whether or not you are a subscriber of such social network.

We have no influence over the nature or scope of data that social networks may then gather. For information regarding the purpose and scope of data collection, further processing and use of data by social networks and regarding your data privacy rights and relevant configuration settings, see the social networks’ respective data privacy advisories.


Links to third parties websites

On certain areas of this Website, We may provide links to third parties websites, which are not subject to this Privacy Notice. These links are provided as a convenience to you; however please be aware that We do not control such third parties or their websites and that those third parties will have a different privacy notice applying to information collected from you when you are on those third parties’ websites. We encourage you read the privacy notices of all websites carefully before providing personally identifiable information.


Storage duration

We will retain your Personal Data only as long as necessary for the fulfilment of the purposes described above or as required by law, having regards to the following criteria: legislation, legal prescription, standards of copyright collective management societies.


Security and confidentiality

We have implemented technical and organisational measures in accordance with standard industry practices to ensure an appropriate level of security of the Personal Data processed. Nevertheless, security requires efforts from all actors involved. We thus encourage you to contribute to these efforts by taking appropriate security measures yourself, including using strong passwords and keeping all user names and passwords (if any) confidential.


Children on the Website

This Website is not intended for or directed to children under 16. We do not knowingly collect any information from such individuals. If you believe your child has provided Us with Personal Data, please contact Us at dpo@sabam.be.


Your rights

At any time, you may exercise your right to request access to or rectification of and, as the case may be, erasure of any Personal Data relating to you. You may also object to processing, or request a restriction of processing and benefit of a right to data portability (as the case may be), in compliance with applicable data protection law, by sending a signed request form with a copy of your ID card, passport or other proof of identity to dpo@sabam.be or in writing to Sabam, DPO, rue d’Arlon, 75-77, in 1040 Brussels.

When applicable, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent made prior to such withdrawal.

As a data subject, you have a right to lodge a complaint with a supervisory authority (in particular in the Member State of the European Union of your usual place of residence, your place of work or the place where the violation occurred) if you consider that the processing of Personal Data relating to you infringes the applicable legislation relating to data protection.
 

Data protection officer

We have designated a data protection officer whose contact details are dpo@sabam.be, Sabam, DPO, Rue d’Arlon, 75-77, in 1040 Brussels.

You may contact Our data protection officer with regard to all issues related to processing of your Personal Data and to the exercise of your rights under the applicable national and European legislation relating to data protection.
 

Effective date and changes

This Privacy Notice is in effect since May 25, 2018. We reserve the right, at Our complete discretion, to change, modify, add, or remove portions of this Privacy Notice at any time. You should check back periodically at this page to read the most recent version of this Privacy Notice as your continued use of this Website following the posting of changes to these terms will mean you acknowledge these changes.

Thank you for visiting this Website.