Purpose of policy

We are committed to protecting your personal information and being transparent about what information we hold about you.

Using personal information allows us to develop a better understanding of our customers’ needs and in turn provide relevant and timely information about the work that we do. As a charity, it also helps us to engage with potential donors and supporters.

The purpose of this policy is to give you a clear explanation about how we and our subsidiaries gather and use the information we collect from you directly and from third parties.

We use your information in accordance with all applicable laws concerning the protection of personal information.

This policy explains:

• What information we may collect about you
• How we may use that information
• In what situations we may disclose your details to third parties
• Our use of internet cookies
• Information about how we keep your personal information secure, how long we maintain it and your rights to be able to access it.

If you have any queries about this policy, please contact Data Compliance at the National Centre for Circus Arts on 020 7613 4141 or email: data@nationalcircus.org.uk

Who we are

The National Centre for Circus Arts is a charity and national portfolio organisation funded by Arts Council England as well as various trusts, foundations and individual donors and supporters. Our registered charity number in England and Wales is 1001839 and we are also registered as a company in England and Wales under registration number 2553293. We also operate two subsidiaries.

Circus Space Events Property Company Ltd – Company Number 4027679
Circus Space Events Ltd – Company Number 4027679

Information collection

We collect various types of information and in a number of different ways:

• Information you give us.
  For example, when you register on our website, buy tickets or make a donation, we’ll store personal information you give us such as your name, email address, postal address, telephone number. We will also store a record of your purchases and donations.
• Information about your interactions with us.
  For example, when you visit our website, we collect information about how you interact with our content. 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.
• Sensitive personal data
  Data Protection law recognises that certain categories of personal information are more sensitive than others, such as health information, race, religious beliefs etc. We do not usually collect this type of information unless there is a clear reason for doing so. As an example, we do collect medical information about course participants so that our teachers are aware of any issues, and can adapt the session to accommodate these needs and ensure overall safety and wellbeing.

Legal basis

There are three main bases under which we may process your data:

• Contract purposes
  When you make a purchase from us or make a donation to us, 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 email or telephone in the case of cancellation of a show, or in the case of problems with your payment.
• Legitimate interests
  In certain situations, we collect and process your personal info for purposes that are in our legitimate organisational 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 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 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 which events you have booked for in the past, as well as any preferences you may have told us about.

We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may object to receiving these at any time 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.

We may also contact you about our work by telephone however we will always get explicit consent from you before doing this. Please bear in mind that this does not apply to telephone calls that we may need to make to you related to your purchases.

Other processing activities

In addition to marketing communications, we also process personal information in the following ways that are within our legitimate organisational interests:

• We may analyse data we hold about you in order to identify and prevent fraud.
• In order to improve our website, we may analyse information about how you use it.
• We may collect information on existing and potential new supporters or donors who might be interested in becoming involved with the NCCA (for example publicly available information on philanthropists or people with a public profile), but will only do this where we have a legitimate interest.

We will always ensure that your fundamental rights and freedoms are not overridden by our own rights and interests

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 tasks above, that are for your benefit.

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 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 is being used and what improvements we can make.

Third parties

There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:

• 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.
• To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software provider). 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 government bodies and law enforcement agencies).

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). You can find more information about this standard here.

Maintaining your personal information

We store your personal data for as long as required to operate the service we are providing to you or for archival purposes and in accordance with legal requirements and tax and accounting rules.

If you have not engaged with us for a period of two years and we do not need to keep your personal data for archival, legal or business reasons, we will delete or suppress your personal information.

Where your information is no longer required, we will ensure it is disposed of in a secure manner.

If there are aspects of your record that are inaccurate or that you would like to change, you can usually do this by logging in to your account through our website. If you don’t have an account, and wish to change or delete your record, please use the contact details below.

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 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.

We will not transfer, process or store your data anywhere that is outside of the European Economic Area, unless that country has been approved by the European Commission or has signed up to the EU-US Privacy Shield framework.

Your rights to your personal information

1. The Right to be informed
2. The Right to Access
3. The Right to Rectification
4. The right to be forgotten
5. The right to restrict processing
6. The right to data portability
7. The right to Object
8. The Right not to be subject to automated decision-making including profiling

Contact details and further information

If you have any queries about this policy, or wish to object to any processing of your personal information please contact Data Compliance at the National Centre for Circus Arts on 020 7613 4141 or email: data@nationalcircus.org.uk

National Centre for Circus Arts, Coronet Street, London, N1 6HD

Last Revised

22nd May 2018