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The Digital Picture House respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our website (“Site”) and in the purchase of tickets and other items over the counter and by telephone, and tell you about your privacy rights and how the law protects you.
Who we are
Our address is: The Digital Picture House, High Street, Uckfield. East Sussex, TN22 1AS
How to contact us
Our Data Protection Officer
By law you have the right to:
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown here [LINK TO “Who We Are and How to Contact Us”])].
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data 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.
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.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
You can ask us to stop sending you marketing messages at any time by following the opt-out links at the bottom of any marketing email sent to you or by contacting us at any time using this email address: email@example.com
Where you opt out of receiving these marketing messages, this will specifically relate to marketing information and not apply to any Personal Data provided to us as a result of online or over the counter purchases, membership communications or subscription renewals.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, username or similar identifier, title, date of birth|
|Contact Data||Your email address and telephone numbers. In case of Premier Members, their home address.|
|Financial Data||Your bank account and payment card details are collected by a card processor, we do not keep this information on file.|
|Transaction Data||Data in respect of your transactions with us, details about payments to and from you and other details of memberships, subscriptions and services you have purchased from us.|
|Marketing and Communications Data||Your purchase history and preferences in receiving marketing from us.|
No Special Categories of Personal Data
We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
Generally, we do not rely on your Consent as a legal basis for using your Personal Data.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|Membership Account Creation||· Identity Data
· Contact Data
· Finance Data
|To register you as a member and set up any renewals||Contractual Necessity|
|To process payments for purchases, subscriptions to the Sites (and their associated services and functionalities)||· Identity Data
· Contact Data
· Finance Data
· Transaction Data
|To process and deliver your order including manage payments, fees and charges.||Contractual Necessity
|Fraud Prevention||· Identity Data
· Contact Data
|To keep our website, our services and associated systems operational and secure.||Legitimate Interests.
We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
|Troubleshooting||· Technical Data||To track issues that might be occurring on our systems.||Legitimate Interests.
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.
|Marketing||· Identity Data
· Contact Data
· Marketing & Communications Data
|To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.||Legitimate Interests.
We have a legitimate interest in providing you with updates on our events, sites and related offers where you have purchased or shown interest in similar services from us.
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data 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 the functionalities of the Site, or to sell you tickets).
In this case, we may have to stop you using our Site or purchasing items with us but we will notify you if this is the case at the time.
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we may also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Category(ies) or other types of personal data received.|
|Credit Reference agencies||No||· Identity Data
· Contact Data
· Transaction Data
|Social Media sites||Yes||· Identity Data
· Contact Data
|Analytics Providers||No||· Behavioural Data
· Technical Data
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We only use first party cookies, served directly by us to your computer or mobile device.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example they help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your member login details. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies]
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
The table below describes who we share your Personal Data with, what we share and why we share it.
|Recipients||Category(ies) of Personal Data we share.||Why we share it||Location(s)|
|Our Affiliates||· Identity Data||Our affiliates help us provide our service and help manage our customer relationships||· Within Europe|
|· Contact Data||· The United States|
|· Purchase History Data|
|Service Providers||· Identity Data||Our service providers provide us with IT and system administration support.||· Within Europe|
|· Contact Data|
|· Technical Data|
|Professional advisers||· Identity Data||Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.||· Within Europe|
|· Contact Data|
|HM Revenue & Customs, regulators and other Authorities||· Identity Data||Authorities may require reporting of processing activities in certain circumstances||· Within Europe|
|· Contact Data|
As you can see from the above, we share your Personal Data with our affiliated companies within the Constant Contact Inc who are based outside the European Economic Area (being the European Union plus Norway, Liechtenstein and Iceland) (“Europe”). Any processing of your Personal Data by these parties will involve an export of your Personal Data outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
The site uses SSL encryption and all transactions are PCI DSS compliant to protect payments and log-in.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Transaction Data||For so long as you remain a customer of ours|
|Marketing and Communications Data||For so long as you remain a customer of ours.|
|Identity and Contact Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used.|
|Financial Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used by the providing company.|
This Site is not intended for children below 18 and we do not knowingly collect data relating to such children.
The Digital Picture House, 2018