Privacy Policy - Rich Mix

Updated: 15 May 2018

PURPOSE OF THIS PRIVACY POLICY

We are committed to protecting your personal information and to 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 relevant and timely information about the work that we do.

Personal information also helps us as a charity to engage with current and potential supporters; members, donors and sponsors. The purpose of this policy is to give you a clear explanation about how we collect and process your personal information. We may process your data through your use of our website or an interaction by phone, by post or in-person in-venue. This includes any data you may provide when you sign up to our e-newsletter(s), purchase a ticket, make a donation or sign up to a particular product or service.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information. This privacy policy supplements our other policies and is not intended to override them.

We will use the information that we collect about you in accordance with:

The Privacy and Electronic Communications (EC Directive) Regulations 2003
The EU General Data Protection Regulation (Regulation EU 2016/679), (‘GDPR’) effective from 25 May 2018

This policy explains:

Who we are
Information we may collect about you
How we collect your data
How we may use your information
Disclosure of your details to third parties
Security of your personal information
How long we keep your data
Your legal rights
Notification of changes to our privacy policy
Contact details and further information

If you have any questions, please contact the Data Controller at Rich Mix using the contact details at the end of this policy.

For our terms and conditions of sale, please click here

WHO WE ARE

Rich Mix Cultural Foundation is a dynamic arts centre and creative hub in the heart of east London; a social enterprise and charity. Rich Mix Cultural Foundation is a company limited by guarantee, registered in England and Wales, number 4293133. Rich Mix Cultural Foundation registered charity number 1089163. Registered office address: 35-47 Bethnal Green Road, London, E1 6LA, England.

We receive approximately 12 per cent of our income from statutory bodies, namely Arts Council England. The rest of our income comes from our social enterprise activities – cinema ticket sales, private hires, tenancies – and donations from individuals, trusts and foundations, and corporate organisations.

INFORMATION WE MAY COLLECT ABOUT YOU

Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices people use to access our website.
Profile Data includes username and password, purchases or orders, interests, preferences, feedback and survey responses.
Usage Data includes information about how people use our website, products and services.
Email Communication Data is emails between us and you, including when they were sent or received, whether they were opened and what links within them were clicked.
Donor Profiling Data is information that is lawfully gathered from a number of sources, including publicly available information about someone’s likely ability or willingness to support charitable or public benefit causes such as ours.
Marketing and Communications Data includes preferences in receiving marketing from us and our third parties, and communication preferences. This also includes us making a note of conversations we have had in person and/or communications sent to Rich Mix. This helps us to manage our relationships and ensures users only receive communications from us that are relevant and timely.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

When carrying out survey or equal opportunities activity, we collect a Special Categories of Personal Data about you (this includes details about your race or ethnicity, marital status, sexual orientation, criminal convictions and offences). This data is anonymised and not saved against your personal records.

If you fail to provide personal information

Where we need to collect personal information by law or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a ticket). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Users under 18

We understand that people aged under 18 may use this website. To request to see our safeguarding policy, please contact us using the contact details at the end of this policy.

HOW WE COLLECT YOUR DATA

We collect different information about you in a number of ways:

Information you give us

When you create an account on our website, buy tickets, sign up to our emails, request marketing materials, give us feedback or make a donation, we will store the personal information you give to us such as your name, email address, postal address, telephone number and card details. We will also keep a record of your purchases and donations.

Automated technologies or interactions

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Information from third parties

We occasionally receive information about you from third parties as set out below:

Analytics providers such as Google
Advertising networks such as Facebook
Search information providers such as Google AdWords

HOW WE MAY USE YOUR INFORMATION

We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where we have your explicit consent before using your personal information in that specific situation. However, generally we do not rely on consent as a legal basis for processing your personal information and you have the right to withdraw consent to direct marketing at any time by contacting us. You will find the relevant contact details at the end of this policy.

Purposes for which we will use your personal information

We have set out below a description of all the ways we plan to use your personal information, and which 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
Sales: To register you as a new customer, process and deliver ticket/product purchase. This includes managing payments, fees and charges in order to fulfil, collect and recover monies owed to us.	(a) Personal data including contact and financial details	Execute our contract with you.
Marketing and communications: To manage our relationship with you which will include: (a) Notifying you about any changes to a product you have bought from us. (b) Asking you to leave a review or take a survey. (c) Supplying you with pre-show information that you might need to know before arrival.	(a) Personal data including contact details from a purchase with us	Necessary for our legitimate interests to keep you informed and to analyse/improve our products and services.
Marketing and communications: If you opted in to hear from us, we will keep you regularly updated about similar products and services.	(a) Personal data including contact details	You have consented to us getting in touch with you via email to keep you regularly updated about our product and services.
Marketing and communications: If you opted into hear from us about our charitable purpose and future developments including how fundraising benefits the organisation.	(a) Personal data including contact details	You have consented to us getting in touch about our charitable aims via email to seek your support for our philanthropic priorities.
Marketing and communications: In order to fulfil our charitable purpose and future developments, including how fundraising benefits the organisation, we will profile and integrate our data for potential donors using third parties who will support us in this process.	(a) Personal data including contact details (b) Usage data	Necessary for our legitimate interests as a charitable organisation to find potential donors in order to support our philanthropic priorities. This information is lawfully gathered from a number of sources including publicly available information about someone’s likely ability or willingness to support charitable or public benefit causes such as ours.
Business development: To administer, analyse and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), we will seek support and advice from third parties.	(a) Personal data including contact details (b) Usage data Data will be anonymised for analytical purposes.	Necessary for our legitimate interests as business and charity to protect and analyse our services/output.
Business development: In order to realise our business aims that ultimately serve our charitable purpose, as an organisation we will contact peers in the sector and other businesses of whom we already have a or want a relationship with. These communications with be tailored accordingly and may include marketing and fundraising.	(a) Data including contact details	Necessary for our legitimate interests as a charitable organisation to secure repeat and/or new business as well as potential philanthropic support in order for us to realise our organisational priorities. These relationships and communications we consider business to business as well as relevant and appropriate to the nature of the relationship held or a prospective one anticipated.
Public safety: In order to protect us and users of the building we will record and store CCTV footage.	(a) Footage inside and parameters of building	Necessary for our legitimate interests to keep everyone safe.

Marketing communications

We aim to communicate with you about the work that we do in ways that you find relevant, timely, respectful and never excessive. 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 contact preferences you may have told us about.

We will obtain consent for any electronic marketing communications sent to individuals.

We will use legitimate organisational interest as the legal basis for marketing communications by post. However, we currently do not carry out any postal marketing.

In the case of postal mailings, you may opt out of receiving them at any time by using the contact details at the end of this policy or by updating your contact preferences in your online account.

In the case of emails, we will give you an opportunity to opt out of receiving electronic marketing communications 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. Alternatively, you can use the contact details at the end of this policy or update your contact preferences in your online account.

As part of our service to you, separate to any marketing communications, we may contact you by email or telephone to provide essential information related to your purchase and/or visit.

Fundraising communications

Rich Mix Cultural Foundation is a registered charity.

Under our legitimate organisational interest, we may contact you by post or occasionally by telephone to seek your support for our philanthropic priorities. This contact will not be more frequent than once per month and 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.

Additionally, and only if you have given your consent, we may contact you by email to seek your financial support.

Other processing activities

We may use profiling techniques or third-party wealth screening and insight companies such as Prospecting for Gold 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.

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.

DISCLOSURE OF YOUR DETAILS TO THIRD PARTIES

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

To our service providers who process data on our behalf and on our instructions (for example, our ticketing system software provider, Spektrix). We require all third parties to respect the privacy of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
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).
To specific, named visiting companies whose performances you have attended. In these cases, we will always ask for your explicit consent before disclosing your personal information. In accordance with our Data Sharing Policy, we will always ask for your consent to pass on personal details to other Arts Council England (ACE) National Portfolio Organisations and Grants for the Arts recipients in line with ACE data-sharing requirements.

We may share anonymised personal information with other organisations, particularly Arts Council England and The Audience Agency, who use this to analyse our audience development programmes, ticket sales and self-generated funding to understand the impact of the public investment made in Rich Mix against the sector.

We do not sell personal details to third parties for any purpose.

SECURITY OF YOUR PERSONAL INFORMATION

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 online at https://www.pcisecuritystandards.org/pci_security/).

We store your card details safely for use in future transactions or to issue any refunds required. This is carried out in compliance with PCI-DSS and in a way where none of our staff members can see your full card number. We never store your three or four-digit security code (CVV or CVS).

Security of your personal information

We have 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 and that they will only process your personal information on our instructions. The third parties will also be subject to a duty of confidentiality.

We will not transfer, process or store your data anywhere that is outside of the European Economic Area (EEA), unless we have a contractual agreement in place that is of an equivalent standard to GDPR.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows:

a) Request access to your personal information

You have a right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right, or any of the rights listed below. If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

b) Request correction of your personal information

You have the right to request that we correct the personal information we hold about you, although we may need to verify the accuracy of the new information you provide to us.

c) Request erasure of your personal information

You have the right to request that we delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for erasure if there are specific legal reasons, which will be notified to you at the time of your request.

d) Object to processing of your personal information

You have the right to object to the processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

e) Request restriction of processing your personal information

You have the right to request that we suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

f) Request transfer of your personal information

You have the right to request that the personal information we hold about you is transferred to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

g) Right to withdraw consent

In circumstances where we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please also note the following:

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

NOTIFICATION OF CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time. We will always communicate any changes to our patrons and supporters where we have accurate contact details and where they would expect to receive communications from Rich Mix. Please visit this section of our website periodically in order to keep up to date with changes in our privacy policy.

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 organisational interests.

Please also contact us if you have any questions about the information we hold about you, or to change your contact preferences with us:

For any queries, contact our Box Office on 020 7613 7498, email dataprotection@richmix.org.uk or write to us (address below).