Privacy Policy

Effective date: 24/01/2026
Last updated: 24/01/2026

This Privacy Policy explains how HARMONYPRIME LIMITED (“we”, “us”, “our”) collects, uses, stores, and protects personal data when you use our services or visit our website at www.harmonyprime.co.uk.


1. Who We Are (Data Controller)

HARMONYPRIME LIMITED
Company Number: 16070709
Registered Address: 18 Beau Court, Hitchin Lane, Stanmore, England, HA7 1FJ
ICO Registration Number: CSN3635738

We act as the Data Controller for all personal data we process.


2. Personal Data We Collect

We may collect and process the following categories of personal data:

  • Contact Information: Name, email address, and telephone number.
  • Student Information: Age, skill level, learning progress, attendance records, assessment notes, and learning objectives.
  • Payment Information: Payment history and billing details.
    We do not store or have access to full card numbers. Card payments are processed securely by approved third-party payment providers.
  • Technical Data: IP address, browser type, device information, and website usage data collected through cookies and similar technologies.
  • Student Media and Images: Photographs or video recordings taken during lessons, rehearsals, concerts, events, or other school activities.

Photographs or video recordings of students under 18 are collected or used only with prior explicit written consent from a parent or legal guardian via our Media Consent Form.

Consent may specify how media may be used (for example: internal learning records, certificates, portfolios, website content, or social media).

Consent may be withdrawn at any time without affecting participation in lessons or activities.
To withdraw consent, please contact: info@harmonyprime.co.uk


3. How We Use Personal Data

We use personal data to:

  • Provide music lessons, courses, examinations, and learning materials

  • Communicate with students and parents or guardians

  • Manage lesson scheduling, payments, billing, and student records

  • Support teaching, assessment, and individual learning development

  • Improve our website, services, curriculum, and student experience

  • Comply with legal, safeguarding, and regulatory obligations

We do not sell, rent, or trade personal data to third parties.


4. Lawful Basis for Processing

We process personal data under the following lawful bases in accordance with UK GDPR:

  • Contract: To deliver lessons, manage bookings, provide learning materials, assess progress, and administer attendance.
  • Legitimate Interests: To operate, manage, and improve our services in ways that do not override your rights and freedoms, such as internal administration, lesson quality assurance, responding to enquiries, and ensuring educational continuity.
    Where applicable, we carry out a Legitimate Interests Assessment (LIA).
  • Consent: For optional cookies, analytics, marketing communications, and the use of student photographs or video recordings.
    Consent may be withdrawn at any time by contacting info@harmonyprime.co.uk. Once withdrawn, we will stop using the material and remove or securely delete identifiable media where reasonably possible.
  • Legal Obligation (Including Safeguarding): To meet safeguarding, child protection, financial record-keeping, and regulatory requirements.

5. Data Sharing

We share personal data only where necessary and only with:

  • Trusted service providers (such as lesson scheduling platforms, invoicing systems, and secure payment processors)

  • IT and communication services required for lesson delivery and administration

  • Awarding or examination bodies, where required to process exam entries or certifications

  • Regulatory, safeguarding, or child protection authorities where legally required or necessary to protect a child or vulnerable person

All third parties operate under data processing agreements and must keep personal data secure and confidential.
They are not permitted to use personal data for their own purposes.

Where personal data is transferred outside the UK, we apply appropriate safeguards, including the UK International Data Transfer Agreement (IDTA) or Standard Contractual Clauses (SCCs) with a UK Addendum, together with transfer risk assessments where required.


6. Data Retention

We retain personal data only for as long as necessary and in line with legal requirements:

  • Student and parent records: up to 7 years after lessons end

  • Email and communication records: up to 3 years

  • Lesson progress, assessment, and attendance records: up to 7 years after the final lesson

  • Exam and certification records: retained in line with awarding body requirements

  • Safeguarding / child protection records: until the learner’s 25th birthday or longer where legally required

After the retention period expires, data is securely deleted or anonymised.


7. Data Security

We apply appropriate technical and organisational measures to protect personal data, including:

  • Secure, password-protected systems with role-based access

  • Encryption in transit (HTTPS/TLS) and, where appropriate, at rest

  • Restricted access for staff and tutors on a need-to-know basis

  • Multi-factor authentication where supported

  • Regular backups and secure data storage

  • Secure deletion or anonymisation after retention periods

While no system is completely secure, we regularly review and update our security practices.


8. Your Rights

Under UK GDPR, you have the right to:

  • Access your personal data

  • Correct inaccurate or incomplete data

  • Request erasure where there is no lawful reason to retain data

  • Restrict processing in certain circumstances

  • Object to processing based on legitimate interests

  • Request data portability

  • Withdraw consent at any time

We respond to requests within one month and may request proof of identity.

To exercise your rights, contact:
info@harmonyprime.co.uk

You also have the right to complain to the ICO:

Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
https://ico.org.uk


9. Cookies

We use essential and optional cookies:

  • Essential cookies: required for website functionality and security

  • Analytics cookies: used only with consent to improve services

  • Marketing cookies: used only with consent to personalise content or measure engagement

Cookie preferences can be managed at any time via the Cookie Settings on our website.


10. Changes to This Policy

We may update this Privacy Policy from time to time.
The “Last updated” date reflects the most recent revision.


Contact Us

Email: info@harmonyprime.co.uk
Phone (English/Russian/Ukrainian): +44 7506 802710