PRIVACY POLICY

1. Purpose

This Privacy Policy sets out how W1 Music MNGMT Ltd t/a W1 MUSIC, 5th Floor, 167 - 169 Great Portland Street, London, W1W 5PF, Company number 16530951 (hereafter “W1”) collects, uses, stores, and protects personal data in connection with its services and the booking, management, and promotion of musical acts and events.

W1 is committed to complying with applicable data protection laws, including the 

  • UK General Data Protection Regulation (“UK GDPR”);

  • the Data Protection Act 2018;

  • the Privacy and Electronic Communications Regulations 2003 (“PECR”); 

  • Data (Use and Access) Act 2025; and

  • other applicable laws in England and Wales.

2. Scope

This Privacy Policy applies to all personal data of employees, contractors, freelancers (including bands and artists), and temporary staff (collectively hereafter “you” or “your”), processed by or on behalf of W1.

3. Personal Data Collected

W1 may collect and process the following information:

Identity Data

  • Band or artist professional name

  • Artists first name and surname

  • Gender

  • CV’s for employees and temporary staff

Contact Data

  • Postal address

  • Email address

  • Telephone number

Profile Data

  • Music speciality

  • Dietary requirements 

  • Any medical (physical or mental) needs when performing

  • Food allergies

  • Clothing size, for performance costumes/ outfits

  • Socials; such as Instagram, LinkedIn, YouTube, Tik Tok

  • High resolution current photograph of the band and/or artist

  • Website address of the band or artist

Transaction Data

  • Booking and contractual information

  • Payment records

Financial Data

  • Invoice details including VAT number

  • Public liability insurance details

Dietary and medical personal data is regarded as “Special Category Personal Data”. W1 collects the dietary and medical personal data for the following specific purposes:

  • Managing your food allergies and safety 

  • Maintaining your healthcare or wellness to provide your services 

  • Making reasonable adjustments for your disabilities 

  • W1’s client’s support 

  • Regulatory compliance 

W1 processes the Special Category Personal Data under Article 6 of UK GDPR the following lawful basis;

  • Your explicit consent via the Musician Database Form sent via W1; 

  • A Contract between W1 and you; 

  • W1’s Legal obligation; and/or

  • W1’s Legitimate interests (where appropriate). 

AND an additional condition under Article 9 of UK GDPR, W1 processes the Special Category Personal Data under:

  • Your explicit consent (Article 9(2)(a));

  • Employment, social security and social protection obligations (Article 9(2)(b)); and/or 

  • Public health reasons. 

If you choose not to provide dietary or medical information, W1 may be unable to make appropriate arrangements for catering, accessibility, health and safety requirements or reasonable adjustments.

W1 will only share special category personal data where necessary for the performance of services, health and safety requirements, accessibility arrangements, legal obligations, or with your explicit consent.

W1 will only collect personal data under its lawful basis for processing as set out below and where necessary carry out a Data Protection Impact Assessment (DPIA).

4. Lawful Basis for Processing

W1 processes personal data under one or more of the following lawful bases:

Consent

You have given W1 consent to collect the personal data.

Contract

Where processing is necessary to enter into or perform a contract with you, a band, artist, employee, temporary staff, venue, supplier, or W1 client.

Legitimate Interests

Where processing is necessary for W1’s legitimate business interests, including event management, maintaining contact databases, and business administration, provided such interests do not override individuals' rights and freedoms.

Legal Obligation

Where processing is necessary to comply with legal, accounting, taxation, or regulatory requirements.

5. How your personal data is collected

W1 collects personal data: 

  • directly, for example, when W1 sends the “Musician Database Form” to the artist/band or when you directly contact W1 via its website or via email; and 

  • indirectly, such as via the band/artist’s website or your social media pages.

W1 also collect personal data from other public sources such as Companies House, for Identity Data purposes, Legitimate Interests and Contract, as explained above.

6. Use of Personal Data

The personal data collected by W1 may be used for:

  • Managing event bookings

  • Communicating with bands and artists

  • Preparing contracts and invoices

  • Maintaining business and employment records

  • Organising event logistics

  • Responding to enquiries

  • Complying with legal obligations

Personal data must not be used for purposes unrelated to W1’s business without appropriate authorisation.

7. Data Sharing

W1 may share your personal data with:

W1 only allow those organisations to handle your personal data if W1 is satisfied they take appropriate measures to protect your personal data.

W1 or the third parties mentioned above, occasionally also share personal data with:

  • W1’s clients that have booked you (the band/artist).

  • the event venues that have booked you.

  • any technical and production suppliers.

  • W1’s external auditors, e.g. in relation to the audit of W1’s accounts, in which case the recipient of the information will be bound by confidentiality obligations.

  • W1’s professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.

  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with W1’s legal and regulatory obligations.

  • public authorities, regulators and other bodies exercising official functions, where they make a written request for personal data they need for their public task or official functions and W1 decide it is necessary and appropriate to disclose it.

  • other parties that have or may acquire control or ownership of W1’s business (and their or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of W1’s insolvency—usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

W1 and its employees must not disclose personal data to unauthorised persons.

8. Marketing

W1 may use the personal data to send updates (by email, text message, WhatsApp, post or telephone) about W1’s services.

W1 may send marketing communications where:

  • you have consented; or

  • W1 is permitted to do so under PECR.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting W1 at info@W1music.com using the word ‘unsubscribe’ in the email title; or

  • using the ‘unsubscribe’ link in emails.

W1 may ask you to confirm or update your marketing preferences if you ask W1 to provide further services in the future, or if there are changes in the law, regulation, or the structure of W1’s business.

W1 will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your Rights’ below.

9. Data Security

W1 takes appropriate technical and organisational measures to protect the personal data collected, including:

  • Password-protected systems

  • Restricted access to records

  • Secure storage of physical documents

  • Regular software and security updates

  • Staff awareness and training

W1 will assess all personal data breaches and will notify the Information Commissioner's Office and affected individuals where required by law. 

If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

10. Data Retention

Personal data will be retained only for as long as necessary to fulfil the purposes for which it was collected and to meet legal, tax, and accounting obligations.

Typical retention periods include:

  • W1 client’s and W1’s financial records: 6 years;

  • CV, employment or temporary staff records: no longer than the purpose of which the personal data was processed, for example 12 months from the last meaningful contact;

  • safeguarding records: retained in accordance with safeguarding requirements; or

  • marketing records: until consent is withdrawn or data is no longer required.

At the end of the retention period, data will be securely deleted or destroyed.

Band/ artist profile information will generally be retained for six years after the last booking or interaction.

Special category personal data will be deleted when no longer required for the purpose for which it was collected and will not normally be retained beyond the period necessary to manage bookings and legal obligations.

W1 may retain anonymised information for statistical or research purposes.

11. Transferring your personal data out of the UK

Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for W1 to transfer your personal data to countries outside the UK, for example Stripe is based in San Francisco, California, USA, PayPal is based in San Jose, California, USA. In those cases, W1 will comply with applicable UK laws designed to ensure the privacy of your personal data.

Under data protection laws, W1 can only transfer your personal data to a country outside the UK where:

  • the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45A of UK GDPR;

  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or

  • a specific exception applies under relevant data protection law.

Where W1 transfer your personal data outside the UK W1 do so on the basis of an adequacy regulation or legally approved standard data protection clauses recognised or issued further to Article 46(2) of UK GDPR and UK GDPR Article 28 requirements. 

12. Your Rights

You generally have the following rights, which you can usually exercise, free of charge:

Access to a copy of your personal data

The right to be provided with a copy of your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data W1 holds about you and to check that W1 is lawfully processing it.

Correction (also known as rectification)

The right to require W1 to correct any mistakes in your personal data. This enables you to have any incomplete or inaccurate data W1 hold about you corrected, though W1 may need to verify the accuracy of the new data you provide to W1.

Erasure (also known as the right to be forgotten)

The right to require W1 to delete your personal data—in certain situations. This enables you to ask W1 to delete or remove personal data where there is no good reason for W1 continuing to process it.

Restriction of use

The right to require W1 to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

This enables you to ask W1 to suspend the processing of your personal data in the following scenarios: (a) if you want W1 to establish the data's accuracy; (b) where W1’s use of the data is unlawful but you do not want W1 to erase it; (c) where you need W1 to hold the data even if W1 no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to W1’s use of your data but W1 need to verify whether W1 have overriding legitimate grounds to use it.

Data portability

The right to receive the personal data you provided to W1, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. 

To object to use

The right to object:

—at any time to your personal data being used for direct marketing (including profiling)

—in certain other situations to W1’s continued use of your personal data, e.g. where W1 use your personal data for W1’s recognised legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.

Rights in respect of automated decision-making

Where significant decisions (those which produce a legal or similarly significant effect on you) are made using your personal data and based on solely automated processing with no meaningful human involvement, you have the right to have certain safeguards in place to protect your data subject rights, freedoms and legitimate interests. These safeguards include giving you information about the decision and enabling you to make representations, obtain human intervention, and contest the decision

In addition to also requiring the above safeguards, significant decisions made using special category personal data and based on solely automated processing are only permissible in certain specified scenarios (e.g. where you have given your explicit consent for the decision to be made using such data).

W1 do not make any such decisions based on data collected by W1’s website.

The right to withdraw consents

If you have provided W1 with a consent to use your personal data you have a right to withdraw that consent easily at any time.

Withdrawing a consent will not affect the lawfulness of W1’s use of your personal data in reliance on that consent before it was withdrawn.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact W1 (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under UK GDPR. 

If you would like to exercise any of those rights, please email W1 at info@w1music.com. When contacting W1 please:

  • provide enough information to identify yourself (e.g. your full name, address and matter reference) and any additional identity information W1 may reasonably request from you;

  • let W1 know which right(s) you want to exercise and the information to which your request relates; and

  • W1 aim to respond to all legitimate requests within one (1) month.

13. Staff Responsibilities

All W1’s personnel will:

  • Handle personal data confidentially;

  • Follow this Privacy Policy, the law associated with it, and any related procedures;

  • Report suspected breaches promptly; and

  • Access personal data only when necessary for their role.

Failure to comply with this Privacy Policy will result in disciplinary action.

14. How to complain either to W1 or the ICO

Please contact W1 if you have any queries or concerns about W1’s use of your personal data (see below ‘How to contact us’).

You also have the right to lodge a complaint with the Information Commissioner’s Office. They may be contacted using the details at www.ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

15. Changes to this Privacy Policy

W1 may change this Privacy Policy from time to time, when W1 make significant changes W1 will take steps to inform you via the email you supplied W1.

This Privacy Policy was updated in June 2026.

16. How to contact us

You can contact W1 and/or W1’s Data Protection Contact by post or email if you have any questions about this Privacy Policy or the information W1 hold about you, to exercise a right under data protection law or to make a complaint.

W1’s contact details are shown below:

Our Data Protection Contact Details

Data Protection Contact: Brian Crawford

Email: info@W1music.com 

Address: W1 MUSIC, 5th Floor, 167 - 169 Great Portland Street, London, W1W 5PF

ICO registered number: 00011637632

17. Severability 

If Clause herein becomes illegal, invalid or unenforceable, the rest of the Clauses and this Privacy Policy will continue in force. Each of the Clauses of these terms operates separately. If any court, law or relevant authority decides that any of them are illegal, invalid or unenforceable, the remaining Clauses will remain in full force and effect and the Clause in question will be deleted or amended. 

18. Partnership 

Nothing herein contained shall give rise to a partnership or a contract of employment between you and W1. 

19. Assignment 

You may not assign, mortgage or otherwise transfer this Privacy Policy, data or any rights, duties and obligations hereunder. It is acknowledged by you that W1 may use W1’s employees, officers, representatives or third-party consultants to carry out W1’s work within this Privacy Policy. W1 may assign the benefit of this Privacy Policy, data or any rights, duties or obligations to any firm or company in which W1 hereafter acquire a controlling interest, or which acquires a controlling interest in W1 without prior approval from you. Save that W1 shall remain primarily liable hereunder until such time as the prospective assignee enters into an agreement to fulfil W1’s obligations hereunder. 

20. Waiver 

No waiver or affirmation of any breach of or non-compliance with any term hereof by the parties shall be deemed to be a waiver or affirmation of any preceding or succeeding breach of or non-compliance with the same or any other term. 

21. Third Parties 

Save to the extent expressly set out herein, this Privacy Policy and is not intended to nor shall it create any rights, entitlements, claims or benefits enforceable by any person that is not a party hereto. Accordingly, save to the extent expressly set out in this Privacy Policy, no person shall derive any benefit or have any right entitlement or claim in relation to this agreement by virtue of the Contract (Rights of Third Parties) 1999. 

22. Governing Law

This Privacy Policy shall be governed by the laws of England and Wales.

The courts of England and Wales shall have exclusive jurisdiction over disputes arising in connection with this Privacy Policy.