Privacy Policy

Version dated 13 June 2018


Welcome to the James Rhodes and Instrumental:records web sites operated by James Rhodes Limited. This my privacy policy. James Rhodes Limited is a private company limited by shares incorporated in England and Wales with registered number 07152408 (referred to as “James”, “me” or “I”).

On 25 May 2018 the Data Protection Act 1998 was replaced by the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This policy has been prepared to comply with the requirements of the GDPR. The GDPR will be followed by additional national implementing law, regulations and secondary legislation so this policy may be further amended to take into account any additional requirements. Please do check back regularly.

I respect your privacy and am committed to protecting your personal data. This privacy policy will inform you as to how I look after your personal data, including when you visit my websites (regardless of where you visit it from) at or and tells you about your privacy rights and how the law protects you. Please read this privacy policy carefully.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. Important information and who I am
  2. The data I collect about you
  3. How is your personal data collected
  4. How I use your personal data
  5. Disclosures of your personal data
  6. International transfers
  7. Data security
  8. Data retention
  9. Your legal rights
  10. Glossary

Important information and who I am

Purpose of this privacy policy

This privacy policy aims to give you information on how I collect and process your personal data through your use of this website and tablet devices, including any data you may provide through this website when you ask a question on the contact page.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy policy supplements the other policies and is not intended to override them.


James Rhodes Limited is the controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact me using the contact page on my web site, or by post to Keith Graham c/o Haines Watts Westbury, 2nd Floor, 145 157 St John Street, London, EC1V 4PY.


If you have any complaints or queries about matters affecting your privacy, or any other general data protection matters, then please do let me know by contacting me as set out above and I will endeavour to resolve the problem. In any event you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. The ICO can be contacted on their helpline number which is 0303 123 1113 between 9am and 5pm Monday to Friday, or by other contact methods as set out on their website.   Please go to their website at for more information.

Changes to the privacy policy and your duty to inform me of changes

The data protection law in the UK changed on 25 May 2018. Although this privacy policy sets out most of your rights under the new laws, I may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until a later date.

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and am not responsible for their privacy statements. When you leave our website, I encourage you to read the privacy policy of every website you visit.

The data I collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:

  • Identity Data includes first name, maiden name, last name or similar identifier.
  • Contact Data includes where supplied email address and telephone numbers.

I do not collect any transactional data such as payments details. If you go to my shop or by tickets you will be re-directed to another web site.

I do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

How is your personal data collected?

I only collect data about you by:

Direct interactions. You may give me your identity and contact details by filling in forms or by corresponding with me by post, phone, email or otherwise.

Automated technologies or interactions. As you interact with the websites, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. I may also receive Technical Data about you if you visit other websites employing our cookies. Please see the cookie statement below for further details.

How I use your personal data

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data to respond to any queries you send me.

Purposes for which I will use your personal data

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To manage any communications with you (a) Identity

(b) Contact

(a) consent


To administer and protect my business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve the websites, products and experiences (a) Technical

(b) Usage

Necessary for my legitimate interests (to define types of customers for our products and services, to keep the websites updated and relevant, to develop my business)


My websites uses cookies. A cookie is a small file of letters and numbers that I put on your computer if you agree. These cookies allow me to distinguish you from other users of my website, which helps me to provide you with a good experience when you browse my websites and also allows me to improve my site. The cookies I use are “analytical” cookies (Google Analytics). They allow me to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps me to improve the way the websites work, for example by ensuring that users are finding what they are looking for easily.

Change of purpose

I will only use your personal data for the purposes for which it was collected, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose.

If I need to use your personal data for an unrelated purpose, I will notify you and explain the legal basis which allows me to do so.

Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

I may have to share your personal data with external third parties such as marketing, ticketing or press companies.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow any third-party service providers to use your personal data for their own purposes save where you have requested certain information or have consented and only permit them to process your personal data for specified purposes and in accordance with my instructions.

International transfers

I do not transfer your personal data outside the European Economic Area (EEA).

Data security

I have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Data retention

How long will you use my personal data for?

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

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

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.
  • Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected.
  • Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it.
  • Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data’s accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.
  • Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products, services or respond to your query. I will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact me via my web site.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

What I may need from you

I may need to request specific information from you to help confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

Time limit to respond

I will try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.



Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service/product and the best and most secure experience. I will make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.

“From the outset, it is evident that Rhodes is a thoughtful and attentive pianist.”

Richard Whitehouse, International Piano

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