Here at Giffords Circus, we take your privacy seriously. We promise to respect any personal data you share with us and keep it safe. We aim to be clear when we collect your data and not do anything you wouldn’t reasonably expect. This policy explains who we are, what information we collect, which partners we work with, and your rights with regards to any information you share with us. It also describes why developing a better understanding of our customers and supporters through their personal data allows us to make better decisions about shows and programming, and, ultimately, helps us to reach our goal of making work of the highest quality available to all.
Please read this information carefully, as by providing your data to us you acknowledge you have read this policy and understand we will process your data in accordance with its terms.
We promise to use the information we collect about you in accordance with the General Data Protection Regulation (2018) (GDPR), the Data Protection Act (2018) and the Privacy and Electronic Communications Regulations (PECR, 2003). We aim to be clear when we handle your data, and not do anything you wouldn’t reasonably expect.
What information do we collect?
You may be required to give us your information in order to book tickets, sign up to a newsletter, make a donation or join a membership scheme, update your preferences, sign up for an event, visit our offices, apply for a job, book a conference or communicate with us. When you book tickets we need to collect information about you to process the transaction and fulfil your order.
We may collect the following information from or about you:
- Postal address
- Telephone number(s)
- Email address
- Ticketing history
- Billing/payment information (we keep the last four digits of a card number to help us
- identify transactions)
- Donation history
- Communications preferences
- Access requirements (for you or your party)
- Allergies and dietary requirements (for you or your party)
- Qualitative opinions or attitudes about our services and programme through surveys
- Any other information you provide to us by email, letter, telephone, social media, via our websites or apps, or in person
- CCTV security recordings, and possible photography or video at performances/events
- Information that is publicly available
Sensitive Information: As recorded above, this includes health information such as disability needs (e.g. to assist with seating) or allergies (e.g. for a catering requirements) which we may require. We may ask for other information specific to a job or volunteering role you are applying for, and a Privacy Notice for Applicants is available on our website. From time to time we might ask customers to take part in surveys to assess age, gender and ethnicity, amongst other aspects; this is optional, rather than mandatory, and you always have the right to decline providing us with this information.
Online Information: Through our websites and apps, we may receive and store certain details through “cookies” which record how the sites are being used to help us provide improved services, analyse usage and enable transactions. Cookies are small text documents that are stored by your web browser on your computer or mobile device when you visit our website. They enable an enhanced experience for you by storing things such as your user details or preferences. The benefit for us is that they track your use of our site, so we can analyse trends and improve our service. They don’t tell us who you are. Our website can only see cookies that it has created, not those issued from any other website. You can decide whether or not to allow cookies on your computer.
When we send you emails, we may include a web beacon. This helps us keep a record of the emails we send you, and we may track whether you receive or open them so we can make sure we are sending you the most relevant information. When you click on a link in an email, we may record this individual response to allow us to customise our offerings to you. Web beacons collect only limited information, such as a cookie identifier, time and date of a page being viewed, and a description of the page on which the Web Beacon resides (the URL). Web Beacons can be refused when delivered via email. If you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.
We use social media to provide updates on our activities and to promote events and projects. We may tailor adverts on social media and elsewhere online relevant to your interests. Depending on your own privacy settings, you may control Giffords Circus permission to access information via social media platforms.
We use some online tracking and analysis services such as Google Analytics to find out how our websites are being used, which activities are working best, and how we can improve customer experience.
From time to time, for certain marketing campaigns, you may receive personalised online advertising after visiting our website. Many of these online adverts allow a facility to opt-out completely or refine your preferences to make advertising more relevant to you.
Data from third parties: We may also obtain or collect personal information about you from other third-party sources, for example:
- a family member, friend, carer, or colleague contact us on your behalf, for instance to purchase a gift membership
- we may ask parents/guardians to supply information about under 16s for workshops or projects
- if we run an event in partnership with another third-party organisation, your details may be shared to help us run that event
- if we engage an external supplier for photography or video.
Why do we collect this information, and how do we use it?
We will use your information: with your consent (where we require it); for performance of your contract; where we need to comply with a legal obligation; or for our legitimate interest or that of a third party.
The information will be used in developing a good understanding of visitors, participants, ticket-buyers and supporters through personal data allows us to make better business decisions enabling us to operate, market our services, and fundraise more efficiently. We believe this will help us reach our goal of ensuring everyone is welcome at Giffords Circus.
We use the information we collect about you:
- to contact you if there is any important change to your booking or visit
- to fulfil our contract with you
- to keep a record of the relationship we have with you
- to process a transaction and carry out completion of a purchase (your personal information and card details may be passed to third party service providers; card details will only be used in this way for the purpose of handling an individual transaction)
- to inform you about relevant events, services, or activities we believe will be of interest, as well as opportunities to support our work as an arts charity
- to provide a personalised service and ensure the best possible experience when you visit us
- to administer any donations you may make, including processing Gift Aid if relevant
- to ensure that the information we already hold is accurate and up to date
- to improve our products, services, and information in the future
- we may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you.
- to send you surveys and for market research purposes
- to assist us with reporting and analysis for our own needs or the needs of any funding partners (e.g. the Arts Council)
- to ensure we know how you prefer to be contacted
- to protect against fraud or unlawful activity
- to ensure compliance with policies, procedures, and laws
- to process any recruitment information, whether directly or via an agent
- to share with approved suppliers (for instance for research and direct mail)
- from time to time, to undertake customer research to help us understand how we can improve our services or information
- to promote Giffords Circus and its activities (e.g. imagery, quotes from social media etc)
- from time to time, to make recommendations to you about other relevant cultural activities by approved partner organisations (NB: these organisations would not be in possession of your data unless you purchase a ticket from them)
Building profiles of supporters and targeting communications: We use profiling and screening techniques to ensure communications are relevant and timely, and to provide an improved experience to our customers and supporters. From time to time we may make data available to agencies for analysis and research purposes (for instance, comparison sales trends over time, postcode mapping etc). This assists with marketing activities, reporting to funders and strategic planning, helping us to make better business decisions.
When building a profile, we may analyse geographic, demographic and other information relating to you in order to better understand your interests and preferences in order to contact you with the most relevant communications. In doing this, we may use additional information from third party sources when it is available. Such information is compiled using publicly available data about you, for example addresses, listed Directorships or typical earnings in a given area.
There are some membership and donation communications that we are required to send regardless of your contact preferences. These are essential communications deemed necessary to fulfil our contractual obligations to you. This would include payment confirmation, thank you letters, group booking, ticket offers, Gift Aid confirmation letters and querying returned mail or bounced payments with you.
Sharing your data with third parties: We will not share any of your personal details with any other third parties without your agreement, unless required in order to fulfil our contract with you, or allowed by law (for instance, if a safeguarding issue arises). In general, the third-party providers used by us to fulfil our contract with you will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. These providers include our Ticketing System provider, other database software suppliers, email distribution service and mailing house. We have agreements in place with each to ensure that your data is secure at all times and cannot be accessed or used for any other purpose. We may share personal information with other organisations, particularly The Audience Agency, who use this to analyse ticket sales for national and regional research into patterns of arts attendance in England (for instance, comparison of sales trends over time and geographical comparisons). This assists with reporting to stakeholders and strategic planning, helping us to make better business decisions. Your personal data is never sold on to any other agencies or companies.
Our website may contain links to and from the websites of other organisations. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
How can you update your preferences?
How we keep your data safe?
We are located in the UK. Your data is held in the UK and only accessed by authorised and trained staff. Only employees and approved contractors / developers we may appoint from time to time, and who need the information to perform a specific job, are granted access to personally identifiable information. We will not share any details with any other third parties without your agreement, unless required by law. We will ensure information is held securely, and only those who need access to it can see it. We will delete this information when we no longer need it.
Where we appoint an external party to analyse or process data any such arrangements will be subject to a formal agreement between Giffords Circus and that organisation, to protect the security of your data.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Data retention: We will retain your information for as long as is necessary to provide you with the services you have requested or require from us unless (a) we must keep it to comply with applicable laws or evidence compliance with such applicable laws; (b) there is an outstanding issue, claim or, dispute requiring us to keep such information until the issue, claim, or dispute is resolved; or (c) the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. We will store data in our ticketing system for a maximum of 5 years after your last transaction or communication with us. If you have made a donation and a Gift Aid declaration, we are obliged to keep the declaration and the details of the person who made it, for six years. For data supplied as part of a job application to us, we will keep your details for six months, then delete it.
Changes to this policy
You have rights including the following:
- to be informed of the ways in which we use your information, as we seek to do in this policy
- to request us to stop processing your personal data for marketing purposes
- you can request a copy of the personal information we hold about you
- you can request that inaccuracies are corrected
- you can withdraw any consent to direct marketing (please see the section “Why do we collect this information, and how do we use it?” above to see when we are relying on your consent)
- the right to object to our using your information on the basis of our legitimate interests (refer to the section headed “Why do we collect this information, and how do we use it?” above to see when we are relying on our legitimate interests) (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
- in certain circumstances you can request that we limit or cease processing or erase your personal data
- you can lodge a complaint with the Information Commissioner’s Office or the relevant authority in your country of work or residence
- Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications.
Do you have any questions or concerns?
Please contact us if you have any questions about this policy, or wish to be removed from any communications or data processing activities:
- You can update your communication preferences online at org.ukor call the Giffords Circus Box Office on 01242 691181.
- Email us on: firstname.lastname@example.org or email@example.com
- Or write to us at: Giffords Circus, Fennells Farm, Lypiatt, Stroud, GL6 7NE.
Subject Access Request: If you wish to make a subject access request (SAR), you can contact us through any of these channels in writing. Whilst you are not required to complete it, we can supply you with a SAR form. We will try to respond to all legitimate requests within 30 days. Occasionally it may take us longer if your request is particularly complex or if you have made a number of requests in which case we will keep you notified and updated. We will require specific details and proof of identification. This is a free service though we reserve the right to charge for reasonable administrative costs if your request is clearly unfounded, repetitive or excessive.