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Privacy Policy

Introduction

This is an informational translation only. In the event of any discrepancies or differences in interpretation, the original Dutch text shall prevail and shall be considered the only legally binding version.

This Privacy Statement is intended to inform you about the personal data relating to you that is processed by Sabam, Belgian Society of Authors, Composers, and Publishers, a limited partnership (cv), with its registered office at Tweekerkenstraat 41-43, 1000 Brussels, and registered with the Brussels Register of Legal Entities ( RPR ) under number BE 0402.989.270, (acting as data controller and hereinafter referred to as“We,”“Our”and“Us”) collects, among other things, via the website www.sabam.be (hereinafter referred to as the“Website”) and through other means (mailings, emails, telephone contact, exchanges with our sister associations, etc.) , the reasons why We collect and process such personal data, the legal basis for doing so, and how We handle the personal data you provide to Us and the personal data We obtain about you as a result of this collection by Us. Your use of the Website and your various interactions with Sabam imply your acceptance of this Privacy Statement.

Legal Basis

We process your personal data based on your explicit consent (Article 6, 1(a) of the General Data Protection Regulation, hereinafter referred to as “GDPR”), or based on the necessity for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) of the GDPR), or based on the necessity of the processing for legitimate interests (Article 6(1)(f) of the GDPR).

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

Personal Data Collected

We collect personal data about you (hereinafter referred to as“Personal Data”) in various ways:

  • By collecting information directly from you: through registration and submission of information you choose to enter on certain pages of the Website, through the communication of your data during your membership with Sabam, during contact (by phone, email, verbally, or in writing) with Sabam, or, among other things, while using the various services and tools that Sabam makes available to you;
  • In connection with the management of licenses;
  • In connection with the management of our shareholders’ affairs within Sabam;
  • In connection with the management of legal cases or a specific case;
  • Through CISAC (Confédération Internationale des Sociétés d'Auteurs), through our sister organizations, and through databases associated with CISAC or our sister organizations, in particular the IPI, SIS, ICE, CISNET, Fasttrack, IDA, and AIR databases.

    This Personal Data must be provided to enable us to carry out the processing as described below. This Personal Data includes identification information: your first and last name, password, pseudonym, date of birth or age, place of birth, gender, nationality, national identification number, language, personal or professional address, personal or professional email address, personal or professional cell phone or other phone number, the contact information of the person to whom you grant power of attorney, your occupation, your profession, education, diplomas, and/or awards received in the creative field, a copy of your ID card, information related to your corporate shareholding; your membership information; your information regarding your bank account and e-account; your information regarding the social and cultural fund; your handwritten or digital signature; your information regarding your online payments; your information as an event organizer; your information regarding the works: title, last and first names of the rights holders, last and first names of the performers, distribution keys, IP name number, IP base number, role, name of the company of which the rights holder is a shareholder or member, work code; data related to the rights holders’ contracts; your financial data regarding the distribution of royalties for works in Sabam’s national and international repertoire; your data related to sound recordings of the works; data related to the publications of the works; data and images of your photographic, graphic, and visual artworks; your data regarding the identification of works in Sabam’s repertoire; data related to unidentified works: title of the work, first and last names of identified rights holders, first and last names of identified performers, role, work code, and an indication of the amounts of royalties collected; information regarding audiovisual works produced in the U.S. that have generated private copying rights for authors on Belgian territory; billing information: billing address, customers’ VAT numbers, bank account; your messages, or other personal data or contact information that you provide to Us. We may also ask for your comments, suggestions, or other information regarding the Website, Our services, or Our company. Other specific types of information may be requested in connection with contests, sweepstakes, or other marketing activities, including the uploading of text, video, or audio content.
  • via cookies. More information about cookies can be found below.

 

Use of Personal Data

Your Personal Data will be used solely to the extent necessary to enable Us, within the framework of our statutory and legal mandate to collect and distribute copyrights as a collecting society, to (Chapter 9, Collective Management of Copyright and Related Rights, Book XI “Intellectual Property” of the Code of Economic Law; Sabam’s Articles of Association and General Regulations):

  • process your applications for membership in Sabam, your membership procedures, and in particular your online payment and the handwritten or digital signature on your membership and fiduciary assignment agreements (Article 6(1)(b) of the GDPR);
  • to collect and distribute your copyrights as a Sabam shareholder, and more generally to manage your status as a shareholder within Sabam, handle your complaints, and take legal action to defend your interests (Article 6(1)(b) of the GDPR);
  • to keep your Personal Data up to date as a shareholder, contracting party (Article 6(1)(b) of the GDPR), or as a customer (Article 6(1)(f) of the GDPR);
  • to keep the statutory shareholder register up to date;
  • to populate the various databases (notably IPI, SIS, Ice, CISNET, Fasttrack, IDA, Air, etc.) that are necessary for the collection and distribution of your copyright royalties generated in Belgium and worldwide—thanks to the network of sister collective management organizations around the world (Article 6(1)(b) of the GDPR)
  • to process registrations of your works, document works in the Sabam repertoire, and manage distribution keys (Article 6(1)(b) of the GDPR);
  • to document the publishing contracts for works in the Sabam repertoire (Article 6(1)(b) of the GDPR);
  • to grant licensing authorizations and collect copyright and related rights for the use of the Sabam repertoire, within the framework of its collaboration with Auvibel and Reprobel or another collecting society designated by the King, or within the framework of its collaboration with Simim and Playright (Article 6(1)(b) (shareholders, contractors) and Article 6(1)(f) (customers) of the GDPR);
  • to manage the digital signatures and online payments of Sabam’s shareholders, contractors (Article 6(1)(b) of the GDPR), and customers (Article 6(1)(f) of the GDPR);
  • to provide the data subjects or authorized persons and the other relevant collective management organizations with the necessary data for the settlement of royalties relating to works in the national and international Sabam repertoire, including financial data (Article 6(1)(b) of the GDPR);
  • to process your data in connection with the management of statutory licenses (Article 6(1)(b) (shareholders, contractors) and Article 6(1)(f) (clients) of the GDPR);
  • to respond to your direct request, as described at the time We collect your Personal Data or as otherwise described to you prior to the use of your Personal Data (Article 6(1)(f) of the GDPR);
  • to upload audio recordings of your musical works, which are part of the Sabam repertoire, to process them in digital format on an online interface made available to you in order to collaborate with an external company that offers a service for automatically identifying works performed during broadcasts (Article 6(1)(b) of the GDPR);
  • processing the transmission of images of photographic, graphic, and visual works from the national and international Sabam repertoire to include them in a database created as part of the AIR (Automated Image Recognition) project in order to track the exploitation of these categories of works (Article 6(1)(b) of the GDPR);
  • to process notifications regarding the performance of works from the Sabam repertoire (Article 6(1)(b) of the GDPR). These reports enable Sabam to verify the list of performed works and thus correctly distribute the collected royalties to the rights holders of the protected works that were performed;
  • to publish the list of unidentified works so that Sabam can identify the rights holders of these works for the purpose of distributing royalties (Article 6(1)(b) of the GDPR);
  • to publish the list of audiovisual works produced in the U.S. that have generated private copying rights for authors on Belgian territory, so that Sabam can identify the holders of these works and thus correctly distribute the royalties collected for these works (Article 6(1)(f) of the GDPR);
  • to make Sabam’s repertoire accessible to the public so that the public can identify Sabam’s repertoire and its rights holders (Article 6(1)(b) of the GDPR);
  • to enable temporary support measures granted by the government in response to the COVID-19 pandemic (Article 6(1)(c) of the GDPR);
  • to manage your use of the Website, including, where applicable, your participation in contests or other marketing activities (provided that you have given Us and/or our partners explicit prior consent to do so, if required under applicable law) (Article 6(1)(a) (shareholders, contractors) and Article 6(1)(f) (customers) of the GDPR);
  • to send you newsletters, mailings, press releases, or other information via email, mail, or text message that may be of interest to you (Article 6(1)(a) (shareholders, contractors) and Article 6(1)(f) (customers) of the GDPR)
  • to process your data for purposes of legitimate interest (Article 6(1)(f) of the GDPR). For example, collecting your data when you enter the Sabam building, informing you about new licenses, inviting you to Sabam’s general meeting or conferences, informing you about new or evolving copyright issues, asking you about certain copyright issues, informing you about a new procedure at Sabam, etc.

We may combine the Personal Data you provide with other personal data we have obtained about you from other sources for the same purposes, even if you have provided your information to us in other places or through another medium (such as social media channels). These sources include: databases, business cards, SIS, IPI, ICE, CISNET, IDA, Air; the Verint and Norriq systems; social networks (Facebook, Twitter, LinkedIn, YouTube, Instagram, Google+); Hubspot, Eventbrite, Outlook, the databases of Roularta and Graydon, the web crawling system, websites, event organizers, Sabam’s servers, work reports submitted on paper or via email, CWR, playlists from radio stations and concerts, customers, representatives, the Crossroads Bank for Enterprises, Oracle Finance, service providers specializing in the management of digital signatures, such as ItsMe, or in the management of online payments, such as Mollie, and the data subjects.

We may not use your Personal Data for new purposes not previously set forth in this Privacy Statement, except based on applicable legal authorization. In any case, We will inform you of any such change to this Privacy Statement before We use Personal Data for other purposes. In the case of consent-based activities, We will not process your Personal Data for such new purposes without first obtaining your consent.

 

Special Categories of Personal Data

We will not collect or process any special categories of personal data relating to you. Special categories of Personal Data include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or other similar beliefs; trade union membership; genetic data; biometric data for the purpose of 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 permitted under applicable law.

If at any time you decide not to receive commercial or promotional information from Us, you may opt out of direct marketing campaigns free of charge and without providing a reason, and you may object to the future processing of your Personal Data for such purposes by sending Us an email at newsletter@sabam.be and including “opt-out” in the subject line of your email. You may also use the opt-out procedure provided in every promotional message you receive from Us.

Please note: if you opt out of receiving promotional messages from Us, this will not prevent you from receiving information related to any contract you may have entered into with Us.

 

Automated Decision-Making

We will not use automated decision-making processes, including profiling, except where permitted by applicable law. In that case, we will inform you of the logic behind the decision and the significance and intended consequences of such processing for you.

 

Sharing and Transferring Personal Data to Third Countries

We will not make your Personal Data available to third parties and will not disclose the Personal Data, unless such transfers are based on specific consent, or are necessary for the performance of a contract entered into between you and Us, or when such transfer of Personal Data is otherwise permitted or required by law or by order of a government agency or judicial authority.

As part of our mandate to collect and distribute your copyrights, we transfer your Personal Data to the following recipients: affiliates, partners—in particular regarding the databases of works and rights holders (SIS, IPI, CISAC database, Fasttrack, ICE, IDA, CISNET, Air, …), sister organizations with which we have entered into representation agreements, Reprobel cvba and Auvibel cvba, which collect collective rights on our behalf under statutory licenses, the single resale right platform: www.resaleright.be; the single-point-of-contact Unisono: www.unisono.be, hosting providers, suppliers, subcontractors, and joint controllers of personal data such as SUISA as the controller of the IPI database; service providers specializing in printing and mailing letters or sending email campaigns, service providers specializing in the management of digital signatures, such as Connective and Itsme, or in managing online payments, such as Mollie; service providers specializing in fingerprinting; contractors under general agreements; government agencies; tax and social security administrations; public oversight bodies such as the audit department of the management companies; Sabam’s attorneys; bailiffs, Sabam’s advisors, accountants, auditors, banking institutions, etc.

Please note that when your Personal Data is transferred to processors or third parties outside the European Economic Area in countries that, according to the European Commission, do not ensure an adequate level of personal data protection, we will ensure that appropriate measures are implemented in accordance with applicable national and European data protection laws. You can obtain a copy of the appropriate safeguards that have been implemented or information on where they are available by sending us an email at dpo@sabam.be.

 

Use of Cookies

Cookies are small text files placed on your computer or other device by the websites you visit. They are used to make websites work, to make them run more efficiently, and to provide information to the website owners.

General information about the cookies used

This website uses cookies to improve your user experience, save your language preferences, analyze your use of the website, distinguish your preferences from those of other users, and measure the effectiveness of our website’s content. By using cookies, we can also optimize our website and gain a better understanding of our users’ interests without having to collect information that identifies them.  Without your prior consent, we only place the cookies necessary for our website to function properly. For all other cookies, we first ask for your consent.

Sabam uses only first-party cookies, i.e., cookies created and managed by the Sabam website itself. When you first visit our website, you will be asked to accept our cookies. You can then manage your preferences at any time via the preferences menu in the cookie banner.

Essential cookies

Essential cookies are necessary for our website to function properly. For example, they are used for page navigation or to restrict access to secure areas of our website. We never use the data we collect through these cookies for any other purposes, nor do we share it with third parties.

Statistical cookies

Statistical cookies help us understand how visitors interact with the website by collecting and reporting anonymous information. These cookies enable us to improve our website and our services. Statistical cookies are very important to us—and, in fact, to you as a visitor as well. However, we never place statistical cookies without your consent, and we never use the data we collect for any other purposes or share it with third parties.

 

Sharing on Social Networks

We use a social media plugin to allow you to share information from the Website on Twitter, LinkedIn, YouTube, Facebook, Instagram, and Google via the “Share” buttons.

For data protection reasons, we have deliberately chosen not to use direct social media plugins on our Website. Instead, we use an alternative technical solution that allows you to decide whether and when to send data to the operators of social networks. Therefore, when you visit the Website, data is never automatically sent to a social network. Only when you actively click the relevant button does your web browser connect to the social network’s servers; that is, if you click on elements and then on the social network icon, you indicate that you consent to your browser connecting to the social network’s servers and sending usage data to the operator of that social network, regardless of whether or not you are a subscriber to that social network.

We have no influence over the nature or scope of the data that social networks may collect in this way. For information on the purpose and scope of data collection, the further processing and use of data by social networks, and your data protection rights and relevant configuration settings, please refer to the respective privacy policies of the social networks.

 

Links to Third-Party Websites

In certain sections of this Website, We may include links to third-party websites that are not subject to this Privacy Policy. These links are provided for your convenience; however, please be aware that We have no control over such third parties or their websites, and that these third parties will have a different privacy policy that applies to information collected from you while you are on their websites. We recommend that you carefully read the privacy policies of all websites before providing any personally identifiable information.

 

Retention period

We will not retain your Personal Data for longer than is necessary to fulfill the purposes described above or as required by law, taking into account the following criteria: legislation, legal requirements, practices, and industry standards for management companies.

 

Security and Confidentiality

We have implemented technical and organizational measures in accordance with industry standard practices to ensure an appropriate level of security for the Personal Data we process. However, security requires efforts from all parties involved. We therefore recommend that you contribute to these efforts by taking appropriate security measures yourself, including using strong passwords and keeping all usernames and passwords confidential (if applicable).

 

Children on the Website

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

 

Your Rights

You may exercise your right at any time to request access to, or rectification of, and, where applicable, the erasure of all Personal Data relating to you. You may also object to the processing or request a restriction on processing and exercise your right to data portability (where applicable), in accordance with applicable data protection laws, by sending a signed request form along with a copy of your ID card, passport, or other proof of identity to dpo@sabam.be, or in writing to Sabam, DPO, Tweekerkenstraat 41-43, 1000 Brussels.

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

As a data subject, you have the right to file a complaint with a supervisory authority (in particular in the European Union member state of your habitual residence, your place of work, or the place where the infringement occurred) if you believe that the processing of Personal Data relating to you violates applicable data protection laws.

 

Data Protection Officer

We have appointed a Data Protection Officer, whose contact information is as follows: dpo@sabam.be, DPO, Sabam, Tweekerkenstraat 41-43, 1000 Brussels.

You may contact our Data Protection Officer regarding any matters related to the processing of your Personal Data and the exercise of your rights under applicable national and European data protection laws.

 

Effective Date and Changes

This Privacy Statement has been in effect since May 25, 2018. We reserve the right to change, modify, add to, or remove portions of this Privacy Statement at any time and at our sole discretion. You should visit this page regularly to review the most recent version of this Privacy Statement, as your continued use of this Website or continued contact with Sabam after changes are made to these terms constitutes your acceptance of those changes.

Thank you very much for visiting.