Privacy Policy

Who we are

Hugh Hanley DBA Circle of Songs With Hugh Hanley

Our website address is:

What personal data we collect and why we collect it


When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: After approval of your comment, your profile picture is visible to the public in the context of your comment.

When you purchase an item from our shop we collect the data you enter into the checkout form.

If you opt-in to our newsletter we collect the information you enter on the opt-in form and that is stored externally in our newsletter software.


If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

We do store the information you enter into any of our forms with the exception of creditcard/payment information which is stored in PAYPAL

Paypal’s privacty policy can be found here:


If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

At this writing, we’re not using any tracking or analytics cookies.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.


We are not using analytics at this time.

Who we share your data with

Our newsletter provider (we are planning to use MailChimp), and with PayPal only when you make a purchase.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

If you have a subscription the data is retained for the length of your subscription plus one year. 

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Our newsletter is managed separate from the site and you may remove your personal data from the newsletter anytime you wish. This will not prohibit us from emailing you regarding your subscription(s), memberships(s), or issue with your purchases.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Your contact information

Anything you provide when you purchase or message us may be stored. If you purchase you will have a profile that is also stored. 

How we protect your data

We have installed an SSL certificate that encrypts messages sent from our site.

What data breach procedures we have in place

If our data is compromised you will be notified within 72 hours. We do not store your payment information on our site.  All credit cards are managed at PayPal.

What third parties we receive data from

Papal processes our payments and subscription billing.

Mailchimp is used for our newsletters.

What automated decision making and/or profiling we do with user data



Under 18: Our site is accessible to anyone. We do not market products to anyone under 18. Although the product itself is intended for very young children, the purchase of our products and the information provided is intended for adults. 

Under 13: We do not allow anyone declaring they are under 13 to provide us with data and we do not intentionally store information about anyone under 13 unless permission is provided by a parent. 

What are your data protection rights?

Our Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.

The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions. (We can no erase purchases until our accounting has been archived and if you have an active subscription we can not remove your data and still provide access to the website.)

The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions. (We don’t “process” anything except payments which are processed via Paypal).

The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions. (but again we don’t process anything you don’t already have control over.)

The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions. (we only collect basic information but if you need a copy of invoices or something like that – happy to provide it for you).

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email:


Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology

For further information, visit

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

  • Login/Password access for subscribers.
  • To provide access to your subscribed content when you sign in
  • We may add analytics tracking in the future to understand how people are using the site. This would be tabulated information such as region, pages visited, and the average time people spend on a page. (your identity would not be attached to this information unless you make a purchase during your visit.)

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

  • Functionality Cookies – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location (general regional area) you are in.  

How to manage cookies

You can set your browser not to accept cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

The website may contain links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

Our Company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 9 January 2019.

How to contact us

If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at:

Please see our terms of use policy

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