Privacy Policy

Effective as of September 13, 2018.

This “Privacy Policy” describes the privacy practices of Steinway, Inc. d/b/a Steinway & Sons and our subsidiaries and affiliates (collectively, “Steinway”, “we”, “us”, or “our”) and the rights and choices available to individuals with respect to their information in connection with the www.steinway.com website, the Spirio mobile application, and any other website, or mobile app that we own or control and which posts this Privacy Policy. For convenience, our websites and mobile apps covered by this Privacy Policy are collectively referred to as the “Sites.” Steinway may provide additional or supplemental privacy notices to individuals at the time we collect their data, which will govern how we may process the information provided at that time.

This Privacy Policy does not apply to Steinway’s processing of employee or contractor data, your offline dealings with Steinway, or your interactions with any Steinway dealers.

We provide important information for individuals located in the European Union here.

 

CONTENTS

Cookies and Similar Technologies
Do Not Track Signals
How We Use Your Personal Information
How We Share your Personal Information
Your Choices
Security
Sensitive Personal Information
International Transfer
Other Sites and Services
Changes to this Privacy Policy
Contact Us
Additional Information for European Union Users

 

Personal Information We Collect

Information you give us

Personal information that you may provide through the Sites or otherwise communicate with us, including via our pages on social networks, includes:

  • Contact information, such as your first name, last name, mailing address, phone number, and email address
  • Profile information, such as your Steinway Customer ID, your website or link to your profile on a social networking website, photographs you may choose to provide, information about yourself or services you offer that you may choose to provide, and information about your interests and preferences
  • Feedback and correspondence, such as information you provide when you receive customer support or otherwise correspond with us online
  • Transaction information, such as details about purchases you make through the Sites or directly with one of our service providers, and information you provide when you enter into one of our contests or other promotions
  • Usage information, such as information about how you use the Sites and interact with us, including information associated with any content you upload to the Sites or otherwise submit to us through the Sites, and information you provide when you use any interactive features of the Sites
  • Precise geolocation information, if you authorize our mobile application to access your location
  • Marketing information, such your preferences for receiving marketing communications and details about how you engage with marketing communications
  • Other personal information you submit to us through the Sites or our pages on social networks, such as information you provide when interacting with us on Facebook, Twitter, Google+, YouTube, and Instagram

 

Referrals

Existing users of our Sites may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us.

 

Information we obtain from our business partners and social media networks

We may partner with third party companies that share personal information with us, including partners that provide us with information about visitors to our Sites. When you provide personal information to one of our partners, your information is subject to the partner’s privacy policy, and any information we receive from the partner is subject to this Privacy Policy. For example, we use Eventbrite (Privacy Policy) to manage registration and ticketing for our factory tours and Acceptd (Privacy Policy) to manage applications for our piano competitions.

We may also maintain pages for our company and our products on a variety of third-party platforms, such as Facebook, Twitter, Google+, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third party platform provides us with information about our pages on those platforms or your interactions with them, we will treat that information in accordance with this Privacy Policy.

 

Information automatically collected

When you access our Sites, we, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity on our Sites. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our Sites, general location information such as city, state or geographic area; and information about your use of and actions on our Sites, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites. This information is collected using cookies and similar technologies. Please refer to the Cookies and Similar Technologies section for more details.

 

Cookies and Similar Technologies

What are cookies?

Cookies are small data files stored on your computer or mobile device by a website. Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers or business partners on our Sites, and can be used by such service providers or business partners to recognise your computer or mobile device when it visits other websites.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Essential Cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Sites to remember choices you make when you use our Sites. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.

Analytics and Performance Cookies

These cookies collect information about traffic to our Sites and about how individuals use our Sites. The information gathered may include the types of information described above in the section titled “Information automatically collected.” We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site.

We use Google Analytics and Mouseflow for this purpose. Google Analytics and Mouseflow use their own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here. You can find out more about Mouseflow’s services here, its privacy practices here, and opt out of Mouseflow’s cookies here.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” (or similar) button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this. Social networks use their own cookies.

Targeted and advertising cookies

These cookies track your browsing habits to enable us and third-party advertising networks to deliver ads that may be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests or browsing behaviour. Based on the cookies that the third-party advertising network sets on our Site and other sites, advertisers can display or otherwise deliver to you advertisements that may be relevant to your interests on our Site and while you are on third party websites.

You can choose to disable cookies, as described below, or to opt out of the use of your browsing behaviour for purposes of targeted advertising. For opt out instructions, please review the “Targeted online advertising” portion of the “Your Choices” section of this Privacy Policy.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” menus). Many browsers are set to accept cookies until you change your settings.

For further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

Other technologies

In addition to cookies, our Sites may use other technologies, such as pixel tags, and software development kits (or SDKs) to collect information automatically.

Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site and in our HTML formatted emails to track the actions of users on our Site and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Site, so that we can manage our content more effectively.

Software Development Kits

Our mobile applications may use software development kits (“SDKs”) provided by third parties. SDKs enable us to provide features and functionality developed by third-party developers, including to provide us with analytics, social media integration, and advertising. The SDKs we use may enable third parties to collect information about the users of our mobile applications. The types of SDKs we use include:

  • Analytics SDKs. These SDKs are used to collect information about use of our mobile applications. The information gathered may include the types of information described above in the section titled “Information automatically collected.” We use this information to help operate our mobile applications more efficiently, to gather broad demographic information, monitor the level of activity on and within the application, diagnose errors, and improve the mobile application.
  • Social Media SDKs. These SDKs help you to interact with social networks you are signed into while using our mobile application, such as by sharing content with the social network and other features you use with the social network. Social networks may also work with our apps for analytics or advertising purposes, as discussed above.
  • Advertising SDKs. These SDKs allow our advertising partners to collect information about your devices, and how you use our mobile application and other sites and applications over time; and to use this information to show you ads of potential interest and measure how the ads perform. These third parties’ collection, use, and sharing of your personal information is subject to their own privacy policies. You may be able to control or limit use of certain information collected through advertising SDKs for purposes of targeted advertising. For additional information, please review the “Targeted online advertising” portion of the “Your Choices” section of this Privacy Policy.

We maintain a list of SDKs used in our App here.

 

Do Not Track Signals

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

 

How We Use Your Personal Information

To provide our Sites

If you use our Sites, we use your personal information to:

  • operate, maintain, administer and improve the Sites
  • manage and communicate with you regarding your account with us, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages
  • process and manage purchases and registrations you make through the Sites, including to administer contests and other promotions
  • manage individual referrals
  • better understand your needs and interests, and personalize your experience with the Sites
  • provide support and maintenance for the Sites
  • respond to your service-related requests, questions and feedback

To market our products and services to you

If you request information from us (such as signing up for our newsletter), register on the Sites, or participate in our contests or promotions, we may send you Steinway-related marketing communications as permitted by law. Our marketing communications may be tailored to you and your interests. You will have the ability to opt out of such communications.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent

We will request your consent to use your personal information where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal information, you have the right to withdraw your consent at any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third party partners, you may withdraw your consent by contacting those partners directly.

To create anonymous data for analytics

We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Sites; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

 

How We Share your Personal Information

Affiliates

We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

Steinway Dealers

We may share your personal information with Steinway dealers, which typically are separate legal entities that are outside of the Steinway & Sons group of companies. We typically share information with a Steinway dealer in your area if you request information about our products or services or express interest in purchasing our products or services. Steinway dealers may use the personal information they receive from us for their own marketing purposes, and dealers’ use of your personal information is not subject to this Privacy Policy.

Visitors to the Sites

Content you submit to the Sites for public posting will be viewable by other users of the Sites. For example, if you complete a teacher profile for display on our website, we may post the profile using the information you provided. You may remove your profile at any time. If you participate in a Steinway contest or promotion, we may share contestant names as disclosed in the terms of the contest or promotion, including by posting the winner’s name on our Sites.

Service providers

We may employ third party companies and individuals to administer and provide services on our behalf (such as customer support, order fulfillment, hosting, email delivery, marketing, and database management services). These third parties may use your information only as directed by Steinway and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Compliance with Laws and Law Enforcement; Protection and Safety

Steinway may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Sites; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Business Transfers

Steinway may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

 

Your Choices

Update, Correct or Delete Your Information

You may contact us at info@steinway.com to update or correct the personal information Steinway maintains about you, or if you have additional requests or questions.

Marketing communications

You may opt out of marketing-related emails by clicking on a link at the bottom of each such email, by contacting us at info@steinway.com or, if applicable, logging in and changing your account settings. You may continue to receive service-related and other non-marketing emails.

Targeted advertising

Some of the business partners that collect information about users’ activities on our Sites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Mobile app users may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices.

Users may opt out of receiving targeted advertising by postal mail based on browsing behavior from Pebble Post by clicking here and then clicking the “Opt-out” link in the page footer.

Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioural advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.

In addition, your mobile device settings may limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide services or the Sites to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the services by designating it as required in or on the Sites or through other appropriate means.

 

Security

The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

Children

Our Sites are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

 

Sensitive Personal Information

We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on the Sites, or otherwise to us.

If you send or disclose any sensitive personal information to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Sites.

 

International Transfer

Steinway is headquartered in the United States and has service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

European Union users should read the important information provided here about transfer of personal information outside of the European Economic Area.

 

Other Sites and Services

The Sites may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services may follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

 

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Sites and in the app stores where our mobile applications are available for download. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Sites.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Sites after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

 

Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at info@steinway.com or write to us at:

Steinway & Sons
Attn: Legal – Privacy
One Steinway Place
Astoria, NY 11105

In addition, individuals who are located in the European Union may contact us by mail at:

Steinway & Sons Europe
Attn: Legal – Privacy
Rondenbarg 10
22525 Hamburg, Germany

 

Additional Information for European Union Users

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller

Steinway & Sons is the controller of your personal information for purposes of European data protection legislation. See the Contact Us section above for contact details.

Legal bases for processing

We use your personal information only as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at info@steinway.com.

Processing purpose 

Legal basis

To provide our Sites

Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.

To market our products and services to you

To create anonymous data for analytics

For compliance, fraud prevention and safety

These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To comply with law

Processing is necessary to comply with our legal obligations

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at info@steinway.com.

 

 

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give European Union users certain rights regarding their personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

  • Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.

You can submit these requests by email to info@steinway.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based:

  • Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield, or Binding Corporate Rules
  • Pursuant to the consent of the individual to whom the personal information pertains
  • As otherwise permitted by applicable EEA requirements.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

SDKs Used in Steinway Mobile Applications

In this section, we list the third-party software development kits (“SDKs”) that Steinway, Inc. d/b/a Steinway & Sons and our subsidiaries and affiliates (“Steinway”) use in connection with our mobile applications.

Although our SDKs may change over time, some key SDKs that we use include:

SDK TYPE SDK SDK Provider Privacy Policy
Analytics Crashlytics Google LLC. Link

Analytics

Fabric Google LLC. Link

We may modify this list of SDKs at any time and without prior notice. When we update this list, we will update the “Last updated” date below.

Last updated 9/13/2018.

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