1.1 We are a company registered in England and Wales under company number 11851961, with our registered address as set out below.
1.2 You can contact us as follows:
FAO: Data Team
Address: 11 Maiden Lane, London, WC2E 7NA, UK
INFORMATION WE MAY COLLECT ABOUT YOU
2.1 Information that you provide to us
2.1.1 We may collect and process any information that you provide to us when you:
a) fill in forms on our website www.sohoplace.org (“our Site”). This includes our email forms or when you request further services, information (for example, on accessibility) or theatre tickets from us;
b) register for an account with us;
c) book with or purchase theatre tickets and/or other products or services from us, whether that be online, over the telephone, or in person;
d) attend a show or event at one of our theatres;
e) apply for a job with us;
f) subscribe to our mailing lists or subscribe through us to a third party’s mailing lists;
g) report a problem with our Site;
h) contact or otherwise correspond with us, including to provide us with feedback, make a complaint or ask a question;
i) enter one of our promotions;
j) enter one of our competitions;
k) complete one of our surveys (which we may ask you to complete, although you do not have to respond to them).
2.1.2 The information you provide to us might include your name, delivery and billing address, email address, phone number and if you are creating an account you may also provide a password. If you are ordering theatre tickets you will also need to provide your card payment details but we will not permanently store your payment card details on our systems unless you choose to save your card details on your profile for future purchases in which case your card details will be stored by way of tokenisation. If you are submitting a job application you may also provide your CV, additional information about your academic and work history, references, and any other such similar or related information as may be supplied. We might also collect certain other specific information that you disclose to us, for example we may keep a record of any items you have lost so that we can contact you if we find them or we may make a record of any feedback you leave us.
2.2 Information that we collect about you
2.2.1 We may collect any information contained in any correspondence between us or information which relates to your booking with us (e.g. the date of your booking and the show or event which you have booked to attend). If you contact us using a form on our Site or by email or telephone, we may also keep a record of that correspondence.
2.2.2 We may also collect information about you when you visit us. We collect images of you through the CCTV cameras that we operate at our theatres and head office and we may also record details of any accident you might have.
2.2.3 We may collect details of your visits to our Site, the resources that you access, and the device that you use to access our Site (including, but not limited to, traffic data, location data, weblogs and other communication data. This information may be collected by a third party website analytics service provider on our behalf and/or may be collected using cookies, pixels, and other web tools. For more information on this please read section 3 below.
2.3 Information that we receive from third parties
2.3.1 In certain circumstances, we will receive information about you from third parties. For example:
(a) we collect personal information from our website developers, IT support providers, payment services providers, and ticket agents (our ticket agents will pass your name to us as well as details of your booking (such as the show or event you have booked and the date of your booking), and, if you correspond with them, they might refer this correspondence, including your email address and other relevant information, on to us); and
(b) if you are a job applicant we may contact your referees to provide information about you.
2.3.2 If you have entered into a prize draw or competition with a third party for tickets to one of our performances and you have indicated to them that you would like to receive our marketing emails and have provided your name and email address for this purpose, we will receive this data, add you to our marketing list (or provide you with tickets if you have won) and your data will be handled in accordance with this Policy and you will be able to unsubscribe at any time as set out in this Policy.
COOKIES, PIXELS, AND OTHER WEB TOOLS
3.1.2 We do not store sensitive information such as account numbers or passwords in “persistent” cookies.
3.2 PIXELS AND OTHER WEB TOOLS
3.2.1 In addition to using cookies, we might also use pixels and other web tools to collect information about your browsing activities whilst on our Site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
3.3 The names of the cookies, pixels, and other web tools used on our Site and the purposes for which these are used are set out in the table below:
3.3 Any information that we acquire about you using cookies, pixels or other web tools is subject to the same restrictions and conditions as any other information we collect about you.
WHERE WE STORE YOUR PERSONAL DATA
4.1 Our company is located in the UK.
4.2 All information we collect about you is automatically transferred to our database and stored on our secure servers in the UK. CCTV footage is stored on site at the theatre it relates to.
4.4 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 personal data, we will use strict procedures and security features to try to prevent unauthorised access.
HOW WE LOOK AFTER YOUR PERSONAL DATA AND HOW LONG WE KEEP IT FOR
5.1 We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you and only to use your information in ways which are respectful of your rights. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
5.1.1 ensuring the physical security of our offices, theatres or other sites;
5.1.2 ensuring the physical and digital security of our equipment and devices by using appropriate password protection;
5.1.3 maintaining an internal data protection policy for, and delivering data protection training to, our employees; and
5.1.4 limiting access to your personal information to those in our company who need to use it in the course of their work.
5.2 We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes (such as for the purposes of exercising our legal rights), or for as long as the law otherwise permits.
5.3 We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example:
5.3.1 we archive our email and paper correspondence regularly and destroy information older than 6 years unless we are required to retain it for evidential or legal purposes;
5.3.2 we retain information relating to orders, refunds and customer queries for as long as is reasonably necessary up to approximately 6 years unless we are required to retain it for evidential or legal purposes;
5.3.3 we retain CCTV footage for one month after the date of capture, although we may process footage for a longer period, for example if the footage is relevant to an investigation; and
5.3.4 we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes, we must store this information permanently.
USES MADE OF THE INFORMATION
6.1 We will use your information for the purposes listed below either on the basis of:
6.1.1 performance of your contract with us and the provision of our services to you;
6.1.2 your consent (where we request it);
6.1.3 our legitimate interests (see section 6.3 below);
6.1.4 complying with our legal obligations;
6.1.5 establishing, exercising or defending legal claims;
6.1.6 performing a task in the public interest; or
6.1.7 protecting your, or another person’s vital interests.
6.2 We use your information for the following purposes:
6.2.1 to ensure that your visit to our theatres runs smoothly – in particular to accommodate your needs, such as any accessibility requirements that you might have, to rebook you into another performance if you cannot attend the performance in question, or to contact you about any items you have reported lost or stolen (on the basis of our legitimate interest in providing you with a quality service, or, alternatively, on the basis of your consent where we have requested it);
6.2.2 to ensure your safety and security when you visit our facilities, including to assist you and make any necessary reports should you have an accident (on the basis of our legitimate interest of ensuring the safety of our audiences, or where necessary, to establish, exercise or defend legal claims, to perform a task in the public interest, or to protect your, or another person’s vital interests);
6.2.3 to provide you with access to our Site in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure that content from our Site is presented in the most effective manner);
6.2.4 to carry out our obligations arising from any communications or bookings made between you and us or you and one of our third party service providers, including the provision to you by mail (if so requested) of theatre tickets purchased or won (including in conjunction with a third party offering, such as hotel accommodation) by you (on the basis of your consent where we have requested it, our legitimate interests in providing you with tickets, or, alternatively, on the basis of performing our contract with you);
6.2.5 to provide customer service and support (on the basis of our contract with you), to notify you about changes to our service, deal with enquiries or complaints about your visit or our Site and share your information with our website developer, IT support provider, delivery service provider, payment services provider as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our Site users and customers);
6.2.6 to provide you with information about our news, theatrical productions, events, special offers, new website features, or other services which may be of interest to you, provided that we have the requisite permission to do so (either on the basis of your consent where we have requested it, or, alternatively, our legitimate interests to provide you with marketing communications where we may lawfully do so), and provided that you have not asked us to not contact you;
6.2.7 to share your information with selected third parties (including producers of theatrical productions you have booked or other theatres with whom we are partnering), either (a) to enable them to contact you with information about things that may interest you (where we have your consent to do so), or (b) to enable them to check whether you are already on their mailing list and/or to inform their marketing strategy generally in relation to the relevant production (on the basis of our legitimate interests to engage in promotional and marketing activity with our business partners), provided in each case that you have not asked us not to share your data in this way;
6.2.8 to carry out, and share with third parties, aggregated and anonymised research and statistical analysis about general engagement with our Site (on the basis of our legitimate interest in providing the right kinds of products and services to our Site users and customers and to conduct marketing). We may, for example, perform statistical analyses of the behaviour of the users of our Site in order to measure interest in the various areas of our Site and to inform advertisers as to how many consumers have seen or “clicked” their advertising banners. This information, and any other general information about our users that we share with advertisers and other partners, will be always aggregated and anonymised;
6.2.9 to process any job applications you submit to us (on the basis of your consent where we have requested it, or, alternatively, our legitimate interests to consider job applications, or where we have a legal obligation to process certain information about our job applicants);
6.2.10 to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business, or where we otherwise have a legal obligation to do so); and
6.2.11 to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees, and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business, or where we otherwise have a legal obligation to do so).
6.3 Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have in:
6.3.1 personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing and serving you with advertising that is relevant and likely to be of interest to you;
6.3.2 detecting and preventing fraud and operating a safe and lawful business;
6.3.3 improving security and optimisation of our network, Site and services; and
6.3.4 confirming information that you provide to us in a CV or application, by reference to past employers and/or publicly available employment or business profiles.
6.4 Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent, or a legal obligation we have). If you have any concerns about our processing please refer to details of “Your Rights” in section 8 below.
6.5 As we outline in section 8 below, you will have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above.
6.6 COVID 19
6.6.1 In addition to the purposes described above, for any performances scheduled to take place during the Covid 19 pandemic, we may collect and process your given name, family name, email address, and ticket agent transaction ID.
6.6.2 The information referred to in section 6.6.1 above is required so that we can administer an advance check-in process using an online questionnaire that will be emailed to you in advance of the relevant performance (the “Check-In Process”). The Check-In Process is used to assist the NHS Track and Trace programme. We will also use the information referred to in section 6.6.1 for customer support purposes in relation to the Check-In Process.
6.6.3 Processing the information as described in sections 6.6.1 and 6.6.2 is necessary for us to comply with our legal obligations as well as our legitimate interests and the legitimate interests of others to support the public health efforts to tackle COVID-19.
6.6.4 The information referred to in section 6.6.1 above is provided to us by our ticket agents.
6.6.5 We will retain the information referred to in section 6.6.1 above for 21 days for the purposes of the NHS Track and Trace Programme. We do not however store and retain any information you submit to the online questionnaire referred to above.
6.6.6 Please see the Covid 19 Secure page on our website for more details regarding the measures we have put in place as part of our Covid-safe reopening plan.
DISCLOSURE OF YOUR INFORMATION
7.1 In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we may disclose your personal information to:
7.1.1 third parties we work with to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions (including for example, hosting or operating the website and our databases and site analytics);
7.1.2 third parties we work with to provide any of our products or services to you (including, for example, our ticket agents and other third parties we may partner with to provide competition prizes, such as accommodation providers where the prize includes third party hotel accommodation in addition to tickets to one of our shows);
7.1.3 our insurers if you have an accident while visiting one of our theatres;
7.1.4 any selected third party that you consent to our sharing your information with for marketing purposes;
7.1.5 in the event that we sell or buy any business or assets, to any prospective seller or buyer of such business or assets;
7.1.6 if stardanced ltd, or substantially all of its assets, is acquired by a third party, to that third party;
7.1.7 other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if necessary to enable us to enforce or apply our “Terms and Conditions”, our “Ticketing Terms and Conditions” and other agreements, or to protect the rights, property, or safety of stardanced ltd, our subsidiaries, affiliates, employees or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and disclosing CCTV images to our third party CCTV management company and/or certain bodies of authority such as the police and emergency services.
7.2 Where we do share your information with third parties, we will require such third parties to maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with regulatory authorities or courts).
SALE AND SUPPLY
8.1 We shall comply with the following restrictions in relation to your personal information:
8.1.1 we shall not sell your personal information to anyone else; and
8.1.2 subject to the exceptions in sections 5 and 6 above, we shall not supply your personal data to anyone else so that they can use it for their own purposes.
9.1 Overview of your rights
9.1.1 You have certain rights in respect of the information that we hold about you, including:
b) the right to ask us not to process your personal data for marketing purposes;
c) the right to request access to the information that we hold about you;
d) the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
e) in certain circumstances, the right to ask us to stop processing information about you;
f) the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence;
g) the right to withdraw your consent for our use of your information in reliance on your consent (refer to section 6 above to see when we are relying on your consent);
h) the right to object to our using your information on the basis of our legitimate interests (refer to section 6 above to see when we are relying on our legitimate interests);
i) the right to receive a copy of any information we hold about you in connection with the performance of our contract with you or on the basis of your consent (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format; and
j) the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.
9.1.2Please note that, notwithstanding these rights, we reserve the right to retain certain information for our own record-keeping and to defend ourselves against any claims. We may also need to send you service-related communications relating to your Site user account even when you have requested not to receive marketing communications.
9.2 How to exercise your rights?
9.2.2 We will comply with your requests unless we have a lawful reason not to do so.
ACCESS TO YOUR INFORMATION
10.1 As outlined above, you have the right to access information held about you. In certain circumstances we may need to charge a fee to meet our costs in providing you with details of the information we hold about you; if this is the case we will inform you of this.
10.2 In order to make a request to access information we hold about you we encourage you to use our Data Subject Access Request Form however we will still accept your request if it contains the details required by the Form and you provide the forms of identification as set out in the Form.