For the purpose of data protection laws, the data controller(s) of any personal information collected on the Site or at an event are listed below.
ARE YOU AGED 14 OR UNDER?
If you are aged 14 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to us. Users without this consent are not allowed to provide us with personal information.
ARE YOU A SOLE TRADER / PARTNERSHIP OR AN INDIVIDUAL COMMUNICATING WITH US FROM A BUSINESS?
INFORMATION WE MAY COLLECT FROM YOU
The information you provide to us
We may ask you to provide information to us or collect information from you on different occasions.
In some instances, the provision of information will be mandatory, for example if you purchase goods or services from us, otherwise you will be able to choose whether or not to disclose your personal information or not.
The information you give us may include your name, address, date of birth, gender, e-mail address, user name and password, phone number, financial and credit card information, demographic information such as postcode, preferences and interests, feedback regarding our Site or events and other information relevant to customer surveys or offers.
We may also collect and process CCTV images, records of any correspondence and communications with us and telephone calls may also be recorded.
The information we collect about you
We may also collect information about each of your visits to the Site, in particular we may automatically collect the following information: (i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, MAC addresses, traffic data, location data, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and cookies.
Information we receive from other sources
Personal information may also be provided to us from online vendors, service providers who refer you to our Sites or services, from customer lists lawfully acquired from third party vendors and from other third parties who work with us in connection with our Sites or services. Third-party service providers may, without limitation, be appointed to provide technical support, process your transactions and maintain your accounts or to run promotions or marketing campaigns. We may have access to any personal information provided to such vendors, service providers and third party e-commerce services.
HOW MELLORS GROUP USES YOUR INFORMATION
We may use your personal information for the following purposes:
Information you give to us
We will use this information:
· to provide customer support e.g. responding to your enquiries;
· to send you a welcome email to verify your account when you register with us or make a purchase and other emails for the purposes of providing any services, products, competitions or promotions to you, including in relation to account management or system maintenance;
· to ask you to complete surveys in respect of your experience with us (for example, in relation to catering), which you can choose to complete or not;
· to process job applications and diversity data;
· to send information to you that you have requested;
· to notify you about changes to our services and/or products;
· to carry out our obligations arising from any contract that we may enter into with you including to process and fulfil any order or request;
· for statistical and research purposes;
· to provide you with marketing information about other services or products we offer that are the same or similar to those that you have already purchased, or services or products you have consented to receiving. If you do not wish to receive this information please use the unsubscribe function in the information, we send you, update your preferences through the preference centre or alternatively write to the Data Protection Officer at the address above;
· for internal record keeping;
· to improve our products and services;
· to carry out appropriate and necessary investigations and identity checks and discharge our legal and regulatory obligations and duties, including to comply with anti-fraud and anti-money laundering requirements;
· to ensure that content from the Site is presented in the most effective manner for you and for your computer or device (as applicable).
Please note we will not use any financial or credit card information for any purpose other than to discharge our legal/regulatory duties and to process payments paid by you for our products and services or due to you by agreement (e.g. refunds).
We, our holding, subsidiary and sister companies and selected third parties (such as our commercial partners) would like to send you marketing information, by post, e-mail, or SMS. Please see the “consent” section of USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS below. If you change your mind about what marketing you would like to receive from us or third parties (including our commercial partners) at any time, you can unsubscribe via the link in any marketing communication, update your preferences through your account preference centre or alternatively can write to the Data Protection Officer at the address below or email us at email@example.com
If you submit your views to us electronically or otherwise we may circulate them internally for training and management purposes. We may also publish your views on the Site in other media. If you do not want us to do this, please let us know when you submit your views.
We may aggregate the information you send to us with other data (so that you cannot be identified from that data) and use that aggregated data for administrative purposes.
Information we collect about you
We will use this information:
· to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· to carry out appropriate and necessary investigations and identity checks and discharge our legal and regulatory obligations and duties, including to comply with anti-fraud and anti-money laundering requirements, and (where applicable) to safeguard our staff and other customers / users in respect of unlawful, disruptive or objectionable behaviour at any of our
· venues, events or on our Site;
· to improve our Site to ensure that content is presented in the most effective manner for you and for your computer or device;
· to enhance our Site to ensure you receive a continuously improving customer service;
· to allow you to participate in interactive features of our Site, when you choose to do so;
· as part of our efforts to keep our Site, venues, and events safe and secure;
· for data-matching purposes in respect of your use of our Site or services and your use of certain third party services;
· to deliver (whether directly or indirectly via third parties) effective and personalised marketing material and content of Mellors Group and where you have consented, other companies and to assist us in the improvement and optimisation of advertising, marketing material and content, our services and the Sites
· to measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties;
· to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you where permitted; and/or
· to make suggestions and recommendations to you and other users of our Site or services about goods or services that may interest you or them.
Information we receive from other sources
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS
· Compliance with legal obligations: As an entity established under the laws of England and Wales, Mellors Group is obliged to comply with UK laws and guidance provided by UK regulatory bodies. In particular, we will need to process your personal information to verify your identity, in some circumstances establish your age, establish your source of funds for anti-money laundering, anti-terrorism and fraud purposes, and to establish whether you have been barred from any of our venues or from using our Site due to objectionable behaviour. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.
· Necessary for the entry into / performance of a contract: When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to purchase a ticket or membership from us), we will need to collect and process your personal information. Failure to provide the requisite personal information on sign-up and financial information on entering into the transaction or objecting to this type of processing/exercising your deletion rights will unfortunately mean we cannot provide our goods/services to you.
· Consent: We may send you electronic marketing messages about us and our venues, events and offers where you have not unsubscribed and where you have purchased tickets to our venues or events or bought goods or other services from us. We provide easy ways to stop our marketing, and you can opt out at any time.
If you are not a customer of ours but have provided us with consent to use your details for marketing purposes, then we may also contact you about our events, goods and services.
If you have confirmed that you would like to hear from us about other party’s goods and services then we will use your details to contact you with marketing information about such party’s goods and services.
If you have confirmed that you would like to hear directly from a third party (including other members of our Group) about such party’s goods and services then we will share your details with such third party so they can contact you about their goods and services.
In each of the situations above, you have the right to withdraw your consent at any time and can object to processing of this nature.
o We have a legitimate interest in processing your personal data as: (a) We need the information to respond to your enquiries (and where relevant process your CV/ job application); (b) We need the information to be able to send you information; and (c) We would be unable to provide our products and/or services without processing your information.
o Necessity: We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as we process your personal data only so far as is necessary for such purpose.
o Impact: We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as it can be reasonably expected for us to process your personal information in this way for the purposes set out above. In most cases the information is being processed for your benefit as well as ours.
HOW LONG WE KEEP YOUR INFORMATION FOR
When your data is no longer required for the purposes listed above, we will delete it within the periods set out below:
· Where a customer has purchased a product or service .eg. a ticket, marketing consents will be refreshed after 5 years and data deleted after a further period of 12 months;
· We may keep your personal information beyond 7 years, in transactional platforms to maintain transactional record completeness to enable us to retain the information we may require for legal, regulatory and anti-fraud purposes.
· Where a subscriber (being an individual who has not purchased a ticket, but has subscribed to marketing), marketing consents will be refreshed after 24 months and data deleted after a further period of 12 months.
· Marketing emails and other communications where possible will typically be deleted after 5 years;
· Call recordings will typically be deleted after 24 months;
· CCTV will typically be deleted after 90 days;
· Unsuccessful job applications will typically be deleted after 12 months.
We may keep your personal information for up to 7 years, to enable us to retain the information we may require for legal and regulatory purposes.
We may keep your personal information for an amount of time which is different to that stated above, in certain circumstances. Where this is the case, you will be supplied with a supplemental policy or privacy statement, which will explain the relevant retention periods to you.
We will only share your personal information with our affiliates and the third party service providers if this is necessary or reasonably required for any of the purposes listed above. Such third party service providers are not entitled to use your information for their own purposes.
We will only disclose your information to:
· business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
· members of the third party suppliers and service providers for the purposes listed under HOW MELLORS GROUP USES YOUR INFORMATION above;
· selected commercial partners so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes (see “consent” under USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS above:
· analytics and search engine providers that assist us in the improvement and optimisation of our Site and other selected third parties; and
· your employer, educational institution (e.g. school, college or university), email or internet provider, parents (if you are under the age of 18) or law enforcement agencies, or other appropriate third parties, where we consider your behaviour to be unlawful, offensive, inappropriate or objectionable at one of our venues, events or on our Site.
We will disclose your personal information to third parties:
· in the event that we consider selling or buying any business or assets or merge or enter into a joint venture with another business entity in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
· in the event of any insolvency situation (e.g. the administration or liquidation) of Mellors Group.
· if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
· in order to enforce or apply our Site, venue or event terms and conditions;
· to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other third parties, your employer, educational institution, email or internet provider, your parents (if you are under the age of 18) and/or the metropolitan police or other law enforcement agencies) for the purposes of staff and customer safety (whether this is in-store or online), crime prevention, fraud protection and credit risk reduction; and
· if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime
Where we store your personal data
All information you provide to us is stored on our secure servers, or those of our suppliers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have a number of rights under data protection law in relation to the way we process your personal data, although these are not absolute and in some instances we may be unable to accept your request, in which case we will respond to you to explain why. You may contact us using the details on our Site (or by contacting us directly – details below) to exercise any of these rights and we will respond to any request received from you within one month from the date of the request.