This policy was last updated on 19 September 2023.
1 IMPORTANT INFORMATION AND WHO WE ARE
1.4 Third-party links
2 THE TYPES OF DATA WE 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data email address.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data country and optional date of birth.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Whilst this may be derived from your personal data, it is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
3 HOW YOUR PERSONAL DATA IS COLLECTED AND OUR PARTNERS
We use different methods to collect data from and about you, depending on how you interact with us and our website.
3.1 Using our website
3.2 Contacting us and/or registering for our marketing communications
You may give us your Identity and Contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you sign up to our mailing lists.
Our mailing list is hosted by MailChimp. We will only send you marketing communications with your consent. You have the right to withdraw consent to marketing communications at any time. If you would like to update your mailing options or unsubscribe from our list, you will find a link to do so at the bottom of every mailer we send.
We do not sell, share or transfer any of your data without your express consent. Emails you receive from us will always be relevant and we do not allow external companies to promote products to our mailing list.
3.3 Other third parties or publicly available sources.
We may also receive personal data about you from various third parties and public sources. We do this to enable us to engage with our fans where they have made this information public. For example:
- We may embed YouTube videos on our website form time-to-time. You should check the settings of your Google account to see what data is being tracked or shared about the videos you upload or watch.
- We may also embed user-generated content from Instagram and/or Twitter (or other social media content) on our website. We curate and highlight this content, which has already been made publicly available and we take no responsibility for miss-attribution of content, or if the personal information shared is not accurate. If we embed a post which you would like removed, please contact us.
4 DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5 INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it, by ensuring that:
- We only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or
- We use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
6 DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. When processing personal data on our behalf, they will only process your personal data on our instructions and will be subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7 HOW LONG WE WILL USE YOUR PERSONAL DATA FOR
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
8 YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are summarised below.
You have the right to:
- Request access. Commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing. You may object to our processing where we are relying on a legitimate interest and you feel the processing impacts on your fundamental rights and freedoms or where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
- Request restriction. This enables you to ask us to suspend the processing of your personal data in the certain scenarios, such as if you want us to establish the data’s accuracy or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer. We 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 us to use or where we used the information to perform a contract with you.
- Right to withdraw consent. Where we are relying on consent to process your personal data, you can withdraw this consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We 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 us.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
8.1 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, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
8.2 What we may need from you
We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.3 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9 OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we have (or are about to) enter into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
9.1 Purposes for which we will use your personal data
Purpose/Activity / Type of Data / Lawful basis for processing including basis of legitimate interest
To manage our relationship with you, which will include responding to your queries, getting feedback from you. / Identity, Contact, Profile, Usage and Marketing and Communications. / (a) To perform of a contract with you, or (b) because it is necessary to comply with a legal obligation, or (c) because it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey. / Identity, Contact, Profile, Usage and Marketing and Communications. / (a) To perform of a contract with you, or (b) because it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). / Identity, Contact and Technical / (a) It is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), or (b) It is necessary to comply with a legal obligation.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. / Technical and Usage / It is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about related goods or services that may be of interest to you. / Identity, Contact, Profile, Usage and Marketing and Communications. / It is necessary for our legitimate interests (to develop our products/services and grow our business).
9.2 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.