Our Privacy Policy
Updated 21st May 2018
Purpose of Policy
Harrogate International Festivals are committed to protecting your personal information and being transparent about the information we hold about you.
Using personal information allows us to develop a better understanding of our patrons and in turn to provide you with the relevant and timely information about the work we do. As a charity, it also helps us to engage with potential and existing donors, sponsors and supporters.
The purpose of this policy is to give you a clear explanation about how we collect and use the information that we collect from you directly. This policy applies to all personal data processed by the Charity.
We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:
- What information we hold about you
- How we may use that information
- In what situations we may disclose your details to third parties
- Our use of cookies to improve your use of our website
- Information about how we keep your personal information secure, how we maintain it and for your right to be able to access it
If you have any queries about this policy please contact the Data Controller at 32 Cheltenham Parade, Harrogate, HG1 1DB or telephone Harrogate International Festivals office on 01423 562303.
Who We Are
Harrogate International Festivals is a registered charity. Our registered charity number in England and Wales is: 244861 and we are also a registered company in England and Wales under registration number: 858029.
Who is responsible for your personal information?
We control the information that is collected by us about you and the purposes for which we use that information. This means that we are the data controller (for the purposes of the GDPR) in respect of your personal information and are responsible for complying with the GDPR in the way that we use and disclose your personal information.
Information Collection & How We May Use Your Data
We collect various types of information and in a number of ways:
Information you give us:
For example, when you register on our website, buy tickets, donate, and sign a contract with us we’ll store the personal information that you give us such as your name, email address, postal address and telephone number. In the case of ticket buyers we will also store a record of your purchases and donations.
Information about your interactions with us:
For example, when we send you a mailing we store a record of this, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on alongside any further correspondence you send us.
When you visit our website, or view a post on social media, we collect information about how you interact with our content.
We use technologies like cookies, and unique device identifiers to anonymously identify your computer or device so we can deliver a better experience. Our systems also log information aggregate statistics like your browser, operating system and IP address, rates of visit to different websites, errors experienced and related site information.
No ad companies collect data through our service. We do not allow advertising companies to collect data through our service for ad targeting.
We may collect your image and likeness (as captured on videos or photographs we use for promotional purposes)
Unless you provide with the information to do so, we do not collect personally identifiable information about you. In other words, we do not collect information such as your name, address, phone number or email address.
We do not knowingly contact or collect personal information from children under 13. If you believe we have inadvertently collected such information, please contact us so we can promptly obtain parental consent or remove the information.
We do not collect, use or share your precise geographic location.
Information from third parties:
We occasionally may receive information about you from third parties. For example, we may use third party research companies to provide general information about you, compiled using publicly available data.
Sensitive personal data:
Data protection law recognises that certain categories of personal information are more sensitive than others. We do not usually collect sensitive personal data about our patrons unless there is a reason for doing so. As an example, we collect health information about the participants in our children’s programmes when a responsible adult will not be present.
We will only use your personal information when the law allows us to.
Purposes for which we will use your personal information
We have set out below, in a simple table format, a description of ways we may use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer or contact | (a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver your ticket purchase including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Inform you of any changes to the event |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) 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 or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) 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) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing and communications with you, customer relationships and experiences | (a) Technical (b) Usage |
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 goods or services or opportunities that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To manage our relationship with you as a sponsor, contact or performer. | (a) Identity (b) Contact (c) Financial (d) Technical (e) Usage (f) Profile |
(a) Performance of a contract with you (b)Necessary for our legitimate interests (to develop our products/services and offer and to grow our business and define our marketing strategy) |
Legal Basis
There are three bases under which we may process your data:
Contract purposes:
When you make a purchase from us or make a donation you are entering into a contract with us. In order to perform this contract, we need to process and store your data. For example, we may need to contact you by phone or email in the case of cancellation of an event, or in case of problems with your payment.
Legitimate Business Interests:
In certain situations, we collect and process your personal information for purposes that are in our legitimate organisation interests. However, we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all the situations where we may use this basis for processing.
With your explicit consent:
For any situations where the two bases above are not appropriate, we will instead ask you for your explicit consent before using your personal information in that specific situation.
Marketing Communications
We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this we use data that we have stored about you, such as what events you have booked for in the past, as well as any preferences you may have told us about.
We use consent as the legal basis for communications by post and email. We may use legitimate interest guided by your previous booking history to guide our communications; ensuring that we provide you with the information about events that interest you the most.
In case of postal mailings, we will give you the opportunity to opt in to receive them during the process of registering your account with us or during your first purchase with us. You may object to receiving these at any time by using the contact details at the end of this policy.
In the case of email, we will give you an opportunity to opt out of receiving them during your first purchase with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the end of this policy.
Fundraising communications
Harrogate International Festivals is a registered charity.
Under our legitimate organisational interest, we may contact you by post or as part of a wider marketing email to seek your support for our philanthropic priorities. You are able to opt out at any time by using the contact details at the end of this policy or by updating your contact preferences in your online account with us.
Photography
At certain events we may have Press Photographers or Official Festival Photographers taking photos or filming elements of the event, including audience reactions. As part of our legitimate organisational interest these images of your likeness may be used for marketing purposes including social media, printing in marketing brochures or the press. All events where photography is taking place will have signage displayed.
As part of our terms and conditions of purchase online we ask you to agree to the taking and use of images of you and your party, you are able to opt out at any time by using the contact details at the end of this policy, contacting the Box Office, or making yourself known to us at an event where photography is taking place. These images will be held indefinitely.
Other Processing Activities
In addition to marketing communications, we also process personal information in the following ways that are within our legitimate organisational interests:
In order to fulfil our contractual obligation to you as the ticket purchaser we may use your data to deliver tickets or to contact you about any changes to a booked event.
We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
We may analyse data we hold about you in order to identify and prevent fraud.
To analyse and evaluate in order to improve and develop our service and sales performance, we may analyse data taken from customer bookings.
In order to improve our website, we may analyse information about how you use it and the content and ads that you interact with.
We may use profiling techniques or third-party wealth screening and insight companies to provide us with information about you that will help us to communicate in a relevant way with you, in particular when we are approaching you about potential philanthropic support. Such information is compiled using publicly available data about you.
In order to train staff and develop our in-house Box Office service we may utilise your booking history to continuously improve our services
In all the above cases we will always keep your rights and interests at the forefront to ensure they are not overridden by your own interests or fundamental rights and freedoms. You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy. Please bear in mind that if you object this may affect our ability to carry out the tasks above that are for your benefit.
Third Parties
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
To our own service providers who process data on our behalf and provide services including:
- Third party organisations that provide services to us on our behalf including processing payment details.
- If you have agreed to the claiming of Gift Aid your details will be shared with HMRC in order that we can reclaim this donation from the tax that you have previously paid.
- The carrying out of marketing activities and mailings. This will always be transferred utilising a protected framework to ensure the safety of data.
- Our ticketing system software provider.
- The provision of hotel rooms to customers as part of package bookings.
To the subsidiaries described above when it is necessary for them to be able to provide you with products or services that you’ve requested.
In these cases, we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data.
Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to governing bodies and law enforcement agencies).
To specific named event sponsors whose events you have attended. In these cases, we will always ask for your explicit consent
Cookies
Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function (for example to keep track of your basket) as well as to provide website operators with information on how the site is being used.
We use cookies to keep track of your basket as well as to identify how the website and our social media is being used and what improvements we can make.
Your Debit and Credit Card Information
If you use your credit or debit card to purchase from us or to make a donation, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS).
Maintaining your Personal Information
We store your personal information indefinitely such that for any subsequent purchases you make or business dealings we partake in are able to be linked them back to a single unique record that we hold for you on our system.
If as a customer there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging into your account through our website. Alternatively, please use the contact details at the end of this policy.
Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
Security of your Personal Information
We shall ensure that we comply with the provisions of the GDPR, including but not limited to holding all personal information securely.
We will put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same.
Access to personal data shall be limited to personnel who need access and safeguards are in place to avoid unauthorised sharing of information.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
Your rights to your personal information
You have the right to request a copy of the personal information that we hold about you and to have any inaccuracies in the data corrected. Please use the contact details at the end of this policy if you would like to exercise this right.
Right to withdraw your consent
You may choose to withdraw your consent to the processing of your data at any time. You may request deletion of your user account and enforce your right to be forgotten by writing to us using the details at the end of this policy. Content or other data that you have provided to us such as payment records may continue to remain on our system even though your user account is deleted.
Contact details and further information
Please get in touch with us if you have any questions about any aspect of this privacy policy, and in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisation interests.
Organisation Contact Address:
FAO The Data Controller, Harrogate International Festivals, 32 Cheltenham Parade, Harrogate, HG1 1DB
Organisation Contact Telephone Number:
Harrogate International Festivals office on 01423 562303.