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Privacy Notice: Germany (English)

PRIVACY NOTICES   
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     >Privacy Notice: Germany (English)
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PRIVACY NOTICE: GERMANY (ENGLISH)

Thank you for choosing HMV. We value your trust and are committed to protecting your privacy. This Privacy Notice: Germany (English) applies to your interactions with us, including through our apps, online at hmv.com, and via any other means of communication you use to interact with us. Please read this privacy notice carefully.

DEFINITIONS

Privacy Notice’ refers to this Privacy Notice: Germany (English), as may be updated periodically.
we’, ‘us’, and ‘our’ refers to Sunrise Records and Entertainment Limited of Mermaid House, Puddle Dock, Blackfriars, London, EC4V 3DB, United Kingdom, and where relevant, other companies in our UK and Europe group of companies
our website’ refers to the website hmv.com, which is operated by Sunrise Records and Entertainment Limited of Mermaid House, Puddle Dock, Blackfriars, London, EC4V 3DB, United Kingdom.

COMMITMENT TO PRIVACY

We are committed to protecting your personal information and keeping it secure. This Privacy Notice explains how we, along with our affiliates and service providers, collect, protect, and use the information you provide. It also details how this information helps us enhance our products and services, both online and in-store, for all our customers.

HOW WE USE YOUR INFORMATION

The personal information you provide, along with data from your interactions with our websites, helps us better understand our customers. This includes your preferences both as a group and individually. With this knowledge, we can recommend products and services that suit your needs.

PLAIN LANGUAGE APPROACH

This Privacy Notice uses clear and concise language to explain how we collect and use your personal information. We avoid using technical jargon whenever possible.

DATA CONTROLLERS

Sunrise Records and Entertainment Limited, whose registered address is at Mermaid House, Puddle Dock, Blackfriars, London, EC4V 3DB, United Kingdom, is the data controller responsible for the processing of your personal information in relation to your use of hmv.com.

HMV.COM

When you place an order on hmv.com, the contract is between you and Sunrise Records and Entertainment Limited. The Terms and Conditions of Sale: Germany can be found HERE.


INFORMATION WE COLLECT

We are committed to collecting, storing, and processing your personal information in compliance with: (i) the General Data Protection Regulation (GDPR) (EU) 2016/679; (ii) the Dutch Implementation Act of the General Data Protection Regulation (Uitvoeringswet Algemene verordening gegevensbescherming – UAVG); (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003, as applicable; (iv) the ePrivacy Directive 2002/58/EC, pending adoption of the EU ePrivacy Regulation; and (v) any other applicable data protection laws.

The information we collect may include, but is not limited to:

  • Website Usage Data: Information about your computer and your visits to and use of hmv.com, such as your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths.
  • Search and Preference Data: Data related to the searches you complete and preferences you select when using hmv.com.
  • Registration Information: Details you provide when registering on hmv.com, including your name and email address.
  • Subscription Information: Data you provide for subscribing to our email notifications and/or marketing emails, including your name and email address.
  • Profile Information: Information you provide when completing your profile onhmv.com, such as your name, email address, telephone number, mobile number, and date of birth.
  • Purchase and Transaction Data: Information related to purchases you make on hmv.com or any other transactions, including your name, email address, physical address, phone number, and payment details.
  • Promotional Participation Data: Information you provide when participating in promotions, prize draws, competitions, customer surveys, and questionnaires.
  • Social Media Interaction Data: Information gathered from your interactions with us on social media platforms.
  • App Installation Data: Information collected when you install any of our apps.
  • Communication Data: Data you provide when contacting us in writing, email, chat or by phone.
  • Additional Information: Any other personal information you choose to share with us.

Additionally, we may receive information about you from third parties who are legally authorised to disclose that information (e.g., such as from local loss prevention retail schemes).


LAWFUL BASIS

We only process your data when we have a legal reason to do so. This includes:

  • Contracts: When you use our services.
  • Your permission: When you agree to us using your data.
  • Our legitimate interests: To provide you with the best service and protect our business.
  • Legal requirements: To comply with laws and regulations.

HOW WE PROCESS DATA AND WHAT LAWFUL BASIS DO WE RELY ON

We process your personal data for a variety of reasons, depending on how you interact with us, including:

Performance of a contract with you.

  • Order Processing: To manage the delivery of goods ordered online or in person, such as in-store purchases.
  • Order Updates: To contact you to provide updates on your orders, such as shipping status, delivery delays, or changes to your orders via email and/or text message.
  • Returns Processing: To process returns of goods that you have purchased from us.
  • Contract Fulfilment: To carry out any agreements between you and us.
  • Account Management: To operate and manage any account you hold with us.
  • Behavioural Analysis: To analyse your shopping behaviour and improve our products and services.
  • Feedback Requests: To request feedback on our services.
  • Transaction Processing: To handle your purchases.
  • Customer Support: To respond to queries, refund requests, and complaints.
  • Legal Compliance: To meet legal and regulatory requirements.

You have given consent.

  • Marketing Communications: With your consent, to send you information about products and services we believe may interest you, or to conduct market research.
  • Third-Party Communication: With your consent, to share your details (including name, email, phone number, address, and date of birth) with third parties who need this information to deliver prizes from competitions or prize draws.
  • Marketing Opt-In Confirmation: To confirm your preferences for receiving marketing emails.

Necessary for our legitimate interest.

  • Personalised Experience: To tailor your browsing experience on our websites.
  • Identity Verification: To verify your identity and prevent or detect fraud.
  • Electronic Receipt Processing: To generate, store, and send you electronic receipts via email (e-receipts) for your purchases.
  • Feedback: We distribute online feedback forms in order to assess and enhance our operational efficiency.

MARKETING CONSENT

We will only use your data for marketing communication purposes if you have explicitly given consent, such as by ticking a box during account registration, opting in through your account settings, or subscribing to our mailing lists. With your consent, we may contact you with offers and information about our products and services.

You can provide or withdraw your consent by:

  • Ticking relevant boxes when signing up to our websites.
  • Opting out in our preference centre by clicking on the unsubscribe link in marketing emails.
  • Adjusting your marketing email preferences in your online account settings.
  • Contacting us via email using the online orders option.

If you wish to opt-out of marketing emails, please follow the instructions provided in our communications or Contact Us directly.


SOCIAL MEDIA

We actively engage with both customers and potential customers to promote our products and events through various social media platforms, including but not limited to; Facebook, Instagram, X, TikTok, Discord, LinkedIn. This section explains how we manage personal data in connection with our social media activities.

Purpose of Data Collection and Use:

  • To interact with customers, respond to inquiries, and provide customer support through social media channels.
  • To promote our products, services, and events by sharing content, such as images, videos, and other media, on our social media pages.
  • To conduct marketing campaigns, prize draws, and promotions that may involve collecting and processing personal data, including names, usernames, and contact information.
  • To analyse interactions and engagement on our social media pages to enhance our services and improve the customer experience.

Data Collection and Use:

  • We may collect personal data when you interact with us on social media, such as when you like, comment on, or share our posts, send us direct messages, or participate in our promotions.
  • We may also gather publicly available information from your social media profiles, in accordance with the platform’s terms of service and your privacy settings.

Data Sharing:

  • Personal data collected through social media interactions may be shared with social media platform providers as governed by their respective privacy notices.
  • We do not sell or rent your personal information to third parties for marketing purposes. However, we may use social media advertising tools to target relevant audiences based on their interests and behaviours as identified by the platform.

Your Rights and Choices:

  • You have control over the personal information you share with us on social media by adjusting your privacy settings on the respective platforms.
  • You can manage your social media preferences, including opting out of certain types of communication or data sharing, through the settings provided by each platform.

PAYMENT PROVIDERS

WorldPay: For all financial transactions on hmv.com, we use WorldPay (UK) Limited as our payment services provider. We share your information with WorldPay only as necessary to process your payments, handle refunds, and address any related complaints or queries.
WorldPay Privacy Centre

PayPal: WorldPay also handles payments made by PayPal.
PayPal Privacy Statement

Your data will be retained by the relevant payment provider in accordance with their data retention policies.


INFORMATION SHARING

We share your information in the following circumstances:

  • If you register with our websites or use our services, we may share your information with affiliates involved in providing certain services. Details of these affiliates are listed under Affiliates and Service Providers.
  • We share your information with payment service providers to facilitate the processing of purchases made on hmv.com. Details of these providers are listed under Payment Providers.
  • We share your information with delivery service providers to ensure the delivery of purchases made on hmv.com. Details of these affiliates are listed under Affiliates and Service Providers.

We will use your information solely as described in this Privacy Notice. We will not sell, rent, or disclose your information to others for marketing purposes without your explicit consent.

We may also disclose your information:

  • When we believe in good faith that such release is necessary to comply with legal obligations.
  • To prevent theft and in association with local loss prevention retail schemes.
  • In connection with the sale, transfer, or disposal of our business, provided that any third party involved continues to use your information in accordance with this Privacy Notice.

Your data may also be passed on to other companies in our group of companies based in the UK and Europe for the performance of our services or for our legitimate business purposes. Use cases may include:

  • If you have consented to receive marketing communications, your personal data may be shared with other companies within our corporate group located in the UK, Ireland, and Belgium. This sharing enables us to tailor and deliver relevant marketing materials to you.
  • Where goods purchased by customers are lost or misplaced, we may share and process customers' personal data in order to complete the customer experience and reunite them with their goods (e.g. by communicating with customers using email addresses provided during the e-receipt provision process).
  • If goods are sent to the wrong address we may share personal information with other group companies in order to facilitate the return of those goods and correct shipping discrepancies.

All such transfers remain within our group of companies and within the European Economic Area (EEA) and are carried out in compliance with applicable data protection laws. You may request a list of the group companies that may receive your data for these purposes.

DATA RETENTION

We will retain your personal information only as long as necessary to fulfil the purposes for which it was collected. This includes, for example, to comply with legal obligations. If the law requires or permits us to retain your information for longer periods, we will do so accordingly.

COOKIES & TRACKING

Our websites use cookies and other tracking technologies to collect information about your online preference. Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. Please refer to How we use cookies to manage and learn more about how we use cookie data.

OTHER TRACKING TECHNOLOGIES

In addition to cookies, we use your IP address and User Agent (which is a string of text sent by your web browser or application to our website during interactions), to collect non-personal information about your activity on hmv.com. When you visit hmv.com, your IP address and User Agent are assigned a random ID using SHA256 encryption. Once this encryption process is complete, the raw IP address and User Agent data are deleted. This tracking method ensures no personally identifiable information is captured and does not rely on cookies.

HOW INFORMATION IS KEPT SAFE

We implement stringent technical and organisational security measures to protect the personal information you provide. These measures are designed to prevent loss, unauthorised access, or unlawful processing of your data. Your information is kept confidential and stored on a secure, password-protected server that is shielded by a firewall. Despite our best efforts to secure your data, please note that we cannot guarantee the absolute security of information transmitted over the internet.

We (or our affiliates and service providers acting on our behalf) may store or process your information within the European Economic Area (EEA), the United Kingdom (UK), and/or Germany, in compliance with: (i) the General Data Protection Regulation (GDPR) (EU) 2016/679; (ii) the ePrivacy Directive 2002/58/EC, pending adoption of the EU ePrivacy Regulation; (iii) national data protection laws in EU Member States (including, for Germany, the Federal Data Protection Act – Bundesdatenschutzgesetz (BDSG)) that implement or supplement the GDPR and ePrivacy Directive; and (iv) any other applicable data protection legislation.


YOUR RIGHTS

You have several rights concerning your personal information, including:

  • Subject Access Request: The right to request access to and obtain a copy of your personal information.
  • Right To Rectification: The right to correct or update your personal information if it is inaccurate or incomplete.
  • Right to Erasure: The right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected.
  • Right To Object: The right to object to the processing of your personal information in certain circumstances.
  • Right To Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format, and to transfer it to another organisation (if applicable).
  • Right To Restrict Processing: The right to restrict the way your personal information is used.

MISUSE OF PERSONAL DATA

Improper collection or misuse of personal information is a violation of this Privacy Notice. If you suspect any misuse of personal data, please report it to our Data Protection Office using the contact details provided in this Privacy Notice.

RIGHT TO BE FORGOTTEN

  • When you request an hmv.com account closure and have a registered account with us, the account will be closed.
  • When you request an hmv.com account deletion and have a registered account with us, the account will be deleted, along with all your order details.
  • When you request an hmv.com account closure and data deletion, and have a registered account with us, the account will be deleted, and all your order details will be disassociated.
  • When you request data removal or deletion, all the data we hold will be deleted.
  • When you request a Right to be Forgotten, the data we hold will be deleted, along with any data we have made public or shared, using reasonable efforts to facilitate this request.
  • When you request a careers.hmv.com account closure and have a registered account with us, the account will be closed.
  • When you request a careers.hmv.com account deletion and have a registered account with us, the account will be deleted.

DATA PROTECTION OFFICE

If you wish to exercise any of your rights in relation to your personal information, please send your request to our Data Protection Office in writing via any of the following means:

  • email: [email protected]
  • Post: Data Protection Office, Sunrise Records and Entertainment Limited, Mermaid House, Puddle Dock, Blackfriars, London, EC4V 3DB, United Kingdom

If you are dissatisfied with how we handle your personal information or our privacy practices as described in this Privacy Notice, you have the right to contact the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données). Further information, including contact details, is available at www.bfdi.bund.de.


AFFILIATES AND SERVICE PROVIDERS

Below are the details of our affiliates and service providers, along with links to their respective privacy details. Please note that we cannot be held responsible for the content of external websites.

GLS: we use GLD as a delivery option for items ordered on hmv.com.
General Logistics Systems Germany GmbH & Co. OHG registered in Germany.
Straße 1 - 7, 36286 Neuenstein, Germany.
GLS Privacy

Google: we use Google Forms to obtain information when dealing with customer service enquiries.
Google UK Limited registered in England and Wales with company number 03977902.
Belgrave House, 76 Buckingham Palace Road, London, SW1W 9TQ, United Kingdom.
Google UK Privacy

Deutsche Post AG: we use Deutsche Post as a delivery option for items ordered on hmv.com.
Deutsche Post AG registered in Germany.
Registered office: Charles-de-Gaulle-Str. 20, 53113 Bonn, Germany
bpost General Privacy Policy

Royal Mail: we use Royal Mail to collect orders placed on hmv.com from our UK premises for delivery to The Netherlands.
Royal Mail Group Limited registered in England and Wales with company number 03087786.
100 Victoria Embankment, London, EC4Y 0HQ, United Kingdom.
Royal Mail Privacy

SMG: we use SMG to collect feedback on customer experiences in our stores and on hmv.com through surveys.
Service Management Group Limited (SMG) registered in England and Wales with company number 06353322.
Governor's House, 5 Laurence Poutney Hill, London, EC4R 0BR, United Kingdom.
SMG Privacy

Trustpilot: we may contact you to give you the option to leave reviews of our services on the Trustpilot website.
Trustpilot Limited registerd in England and Wales with company number 08595623.
5th Floor, The Minster Building, 21 Mincing Lane, London, EC3R 7AG, United Kingdom.
Trustpilot Privacy

UNiDAYS: we offer student discounts on selected products in our stores and online through UNiDAYS.
Myunidays Limited registered in England and Wales with company number 07552253.
2 Castle Boulevard, Nottingham, Nottinghamshire, NG7 1FB, United Kingdom.
UNiDAYS Privacy

Zendesk: we use Zendesk to manage contact to and from our customer services team.
Zendesk Inc. registered in the USA.
989 Market Street, San Francisco, CA 94103, USA.
Zendesk Privacy

ZigZag: we use ZigZag to facilitate returns of goods that were ordered on hmv.com.
ZigZag Global Limited registered in England and Wales with company number 09404819.
4th Floor, 7-10 Chandos Street, London, W1G 8DQ, United Kingdom.
ZigZag Privacy


Last updated: 3 February 2026

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