PRIVACY STATEMENT

INTRODUCTION

Here at Capital Theatres, 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, fundraise more efficiently and, ultimately, helps us to reach our goal of presenting work of the highest quality that inspires, develops and educates audiences without geographic or demographic boundaries. 

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:

• Name
• 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. From time to time we might ask customers to take part in surveys to assess 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 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. 

You can read more about cookies in our policy here or contact us (details below).

When we send you emails, we may include a web beacon. This helps us keep a record of the emails 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 Capital Theatres 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 campaigning 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. For example, we work with visiting producers and agencies to create relevant advertising for future events, and this might be displayed based on your device’s IP address. 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 or colleague contacts 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 in order 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 for the purposes listed below either on the basis of: performance of your contract; your consent (where we require it); where we need to comply with a legal obligation; or our legitimate interest or those of a third party.

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 Capital Theatres.

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
• to ensure that the information we already hold is accurate and up to date
• to improve our products, services and information in the future
• as a charity we’d like to send you occasional updates on our charitable work and we may invite you to support some of our projects
• 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.
• wealth screening and research to help us understand our Friends, Patrons and potential donors including gathering information from publicly available resources to give an insight into your philanthropic interest and ability to support Capital Theatres
• 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
• 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 the theatre 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, and the recommendations would only ever be supplementary to other Capital Theatres information, for example, by way of a P.S. or a ticket offer on an email update, or within a newsletter sent by the Capital Theatres)

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.

Profiling allows us to target our resources effectively, to understand the background of the people who attend our theatres, and who support us. This helps us to make appropriate requests to customers and supporters who may be able and willing to give more than they already do.  Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would.

You can opt-out of your data being utilised for wealth screening, data cleansing or analysis (with the aims of targeting communications with you appropriately or finding up-to-date contact information in the case of gone away mail) simply by contacting – support@capitaltheatres.com

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 direct debit confirmation, thank you letters, Friends member benefits and cards, Group priority booking, renewal reminders, Gift Aid confirmation letters and querying returned mail or bounced Direct Debit payments with you.

Sharing your data with third parties: We will only share data with third-party providers on the legal bases as listed below:

For fulfilment of contract: services such as our ticketing system (Spektrix), email service and mailing houses. We have agreements in place with each provider to ensure your data is secure and cannot be accessed or used for any other purpose. Your personal data is never sold to any agencies or companies.

Legitimate business interests: we may make data available to approved suppliers for analysis and research purposes only, for example identifying sales trends, assessing campaign effectiveness, or postcode mapping etc (e.g. this might include for instance UK Theatre, Indigo, Purple 7, Baker Richards). This assists us with reporting and with our strategic planning, helping us apply our resources more intelligently. All such agencies will be carefully checked and have a separate data sharing agreement with us including non-disclosure agreements, and their Privacy Policies will have to be at least as secure as our own.

Sharing data outside the EU: We are located in the UK. Some our suppliers run operations outside the European Economic Area (EEA). Although they may not be subject to the same data protection laws as in the UK, we take steps to make sure they provide an adequate level of protection in accordance with UK law. By submitting your personal information to us you acknowledge that you understand that your personal information may be transferred, and processed, outside the EEA. Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

How can you update you preferences?

You can set and update your personal contact and interest preferences at any time, by visiting your account online capitaltheatres.com or through our Box Office, in person or over the phone on 0131 529 6000. Every email we send to you will contain an option to unsubscribe, or you can contact us via the details below. In accordance with this Privacy Policy we will always contact you if there is any important change to your booking. Unless you ask us not to, we will tell you about our future events, ticket offers, our other relevant services (e.g. memberships), or opportunities to support our charitable work.  

Managing your cookies settings

Managing your cookies settings in your browser

It is easy to manage your cookies by adjusting your browser settings. For more information about cookies and how to opt-out, visit any of the following industry bodies:

• European interactive digital advertising alliance
• Digital Advertising Alliance
• Network Advertising Initiative

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.  If required by law (e.g. by police, regulatory bodies or legal advisers) we may need to disclose your details. 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 Capital Theatres and that organisation, to protect the security of your data.

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 regularly review email and paper correspondence and minimise our storage through archiving and destruction of out of date materials. We will store data in our ticketing system for a maximum of 10 years after your last transaction or communication with us. We have considered the nature, relevance and volume of this data, the potential risks, and the purposes for which we process your data. We have also considered legal requirements including financial (e.g. Gift Aid declaration and reporting timescales).

Changes to this policy

We may change or update this Privacy Policy from time to time. Any significant changes will be communicated on our website or by contacting you directly.

Your Rights

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 through the Fundraising Regulator, 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?

Email us: gdpr@capitaltheatres.com

Write to us:

Data Protection
Capital Theatres,
13/ 29 Nicolson Street
Edinburgh,
EH8 9FT.

Call us: 0131 662 1112

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.

June 2018