Privacy Policy

PROTECTING YOUR PRIVACY - Applicable from 25th May 2018

One of the biggest changes to UK data privacy law comes into effect on 25 May 2018. The General Data Protection Regulation, also known as GDPR, means that you'll have more control over how your data is used. And it ensures that organisations protect your personal data better. To reflect these changes and new obligations, we've updated our Privacy Potice which now tells you what we do with your personal data, how it's used and your rights as an individual under the new law. The new Privacy Policy will be available from 25 May 2018.

CONTENTS OF THE PRIVACY POLICY

Introduction
What is Belmont Theatre Company?
Explaining the legal bases we rely on
When do we collect your personal data?
What sort of personal data do we collect?
How and why do we use your personal data?
How we protect your personal data
How long will we keep your personal data?
Who do we share your personal data with?
Where your personal data may be processed
What are your rights over your personal data?
How can you stop the use of your personal data for direct marketing?
Contacting the Regulator
If you live outside the UK

Any questions?

APPENDIX 1 - Privacy Policy specifically for Members and Patrons

Any questions?

1. Introduction

This Privacy Document explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Belmont Theatre Company uses your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Document from time to time. We’ll notify you of any significant changes, but you can always come back and check it whenever you wish.

2. What is Belmont Theatre Company?
Belmont Theatre Company is a members’ club for which operates under the name of ‘Belmont Theatre’ which will be referred to as such in this document.
For simplicity throughout this document, ‘we’ and ‘us’ refers to ‘Belmont Theatre’.

3. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

3.1 Consent

In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

3.2 Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order a ticket for a theatre performance, we’ll collect your address details to deliver your purchase, or contact you in connection with the transaction.

3.3 Legal compliance

If the law requires us to, we may need to collect and process your data.
For example, we may be required to pass on details of people involved in fraud or other criminal activity affecting Belmont Theatre to law enforcement agencies.

3.4 Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our activities and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised information that we believe may also serve your legitimate interests.
We may also use your address details to send you direct marketing information by post, telling you about theatrical events we stage and which we think might interest you as an audience member or with a view to your active participation.

4. When do we collect your personal data?

When you visit any of our websites and complete an enquiry form

When you purchase a theatre ticket by phone or post or through our contracted third-party ticket processing agent Ticketsource or when provided by anyone purchasing tickets on your behalf.
When you engage with us on social media.
When you become a signed up Member or Patron of Belmont Theatre.
When you contact us by any means with queries, etc.
When you ask us to email you information about a product or service.
When you enter prize draws or competitions.
When you book to attend an event, for example an open day at the theatre.
When you choose to complete any surveys we send you.
When you comment on or review our shows.
Any individual may access personal data related to them, including opinions. So if your comment or review includes information about a Club Member or helper, it may be passed on to them if requested.
When you fill in any forms. For example, whilst attending one of our shows or on our website.
When you’ve given a third party permission to share with us the information they hold about you.

5. What sort of personal data do we collect?

Details of your interactions with us.

For example, we note our conversations with you, details of any complaints or comments you make, details of purchases you made and how and when you contact us.

Personal details which help us to recommend items of interest.

We’ll only ask for and use your personal data collected for recommending shows we stage which may be of legitimate interest to you either as an audience member or possible participant. Of course, it’s always your choice whether you share such details with us.
We do not receive your payment card information and therefore do not hold it.

Your comments and production reviews.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

6. How and why do we use your personal data?

We want to give you the best possible experience of Belmont Theatre. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you theatrical productions and promotions that are most likely to interest you. In the case of people who have expressed interest in actively participating in Belmont Theatre as a Member or Patron we again use your information to offer opportunities that may be of interest.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for including telling you about our theatrical events or casting opportunities.
6.1. Here’s how we’ll use your personal data and why:

To process any orders that you make by using our websites, internal box office, external box office agent supplier (Ticketsource) or at shows.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our company from fraud and other illegal activities. This includes safeguarding your personal information. We’ll do this as part of our legitimate interest.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate interests. This also helps to protect our customers from fraud.

With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, post and telephone about relevant activities including special offers, discounts, promotions, events, competitions and so on.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Document, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message.

Of course, you are free to opt out of hearing from us by any of these channels at any time, be that by (any or all of) email, phone, text and mail.
We’ll do this on the basis of your and our legitimate interest on the basis of our records of your past preferences and wishes.

6.2. Obligations.

To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
To comply with our contractual or legal obligations to share data with law enforcement.

For example, when a court order is served on us to share data with law enforcement agencies or a court of law.

To send you survey and feedback requests to help improve our shows. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our shows more relevant to you.

7. How we protect your personal data?

We know how much data security matters to all our audiences, Members, Patrons and prospective members. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
Access to your personal data is password-protected. We do not hold sensitive data (such as payment card information).

8. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and planning of theatrical productions.
As an example of customer data retention periods, when you place a ticket order, we’ll keep the personal data you give us for five years from the date of your last order unless we have received your renewed permission to retain it for longer .

9. Who do we share your personal data with?

We hold personal data for audiences on box office software provided by our contracted third-party booking agents Ticketsource. Ticketsource only uses that data expressly as requested by individuals providing them with that information e.g. when booking theatre tickets or donating to the nominated charity for a theatrical production.
We hold mailing list data on third-party mailing software provider Mailchimp, which is used to email customers and interested parties about matters deemed of legitimate interest to them.
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We may, at some point, transfer or merge the operation of Belmont Theatre to/with another organisation. If this happens, your personal data will, where relevant, be transferred to the new entity, under the terms of this Privacy Document.

For further information please contact our Data Protection Officer.

10. Where your personal data may be processed

We will process your data within the relevant administrative section of Belmont Theatre in the UK. For example this may be one or more of Box Office, Membership, Marketing or Treasury departments as applicable.
Sometimes we will need to share your personal data with our contracted third party box office agent, Ticketsource or our mailing software provider Mailchimp.
If you are based outside the UK and place an order with us, we will maintain the personal data we collect from you in the UK.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Document.

11. What are your rights over your personal data?

An overview of your different rights:

11.1 You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
A copy of any information about you that Belmont Theatre holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact The Data Protection Officer, Belmont Theatre, c/o 12 Plaitford Close, Rickmansworth, Herts, WD3 1NJ or email [email protected] . To ask for your information to be amended, please update your information online, or email [email protected] .

If we choose not to action your request we will explain to you the reasons for our refusal.

11.2 Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

11.3 Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

11.4 Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

12. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then restrict any further emails to you to matters you still wish to hear from us about.
Email [email protected] asking us to stop sending information.
Write to Belmont Theatre Company, c/o 12 Plaitford Close, Rickmansworth, Herts, WD3 1NJ

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

13. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 14.

14. If you live outside the UK

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes in the ordinary course of our activities we may need to transfer your personal data for processing to our third party mailing service provider or our ticket agents who may be based outside of the UK to enable us to supply the services you’ve requested. By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence in the ordinary course of our activities.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Document. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
If you are contacting us to complain about an alleged breach of this Privacy Document or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.
We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.
We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this Privacy Document restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

Any questions?
We hope this Privacy Document has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Email us at [email protected]
Or write to us at Data Protection Officer, Belmont Theatre, c/o 12 Plaitford Close, Rickmansworth, Herts, England WD3 1NJ.

There is an Appendix to this policy: APPENDIX 1, which is specifically for Members and Patrons of Belmont Theatre Company (click HERE).

This Document is applicable from 25/5/2018