1.1 Belarus Free Theatre is committed to protecting the privacy of those who use our services and our websites (belarusfreetheatre.com and moc.media). In this policy we explain when and why we collect your personal information, how we use it, how we keep it secure and how long we keep it for. It also explains how you can control the data we hold, including how to update your information when it changes.
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3. How we use your personal data
3.1 When you engage with us as an audience member, donor or participant, we collect your information. This could be when you purchase a ticket, make a donation, sign up to our mailing list or register on our website. These interactions may occur online, in person or over the phone. We may also collect information from publicly available sources as part of our fundraising practice. This may include obtaining information from individuals working on our behalf such as our Trustees. In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data ("account data"). The account data may include your name, email address and contact preferences. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address and contact preferences. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.5 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, address, telephone number, email address, gender, contact preferences, access requirements, dietary requirements. The source of the service data is you, your employer, or a person working on your behalf with your consent such as a personal assistant. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.6 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this our legitimate interests, namely the proper administration of our website and business.
3.7 We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent, namely being able to respond to your enquiry.
3.8 We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests. We collect this data in order to be able to complete the transaction, to supply the purchased goods and services, and keeping proper records of the transaction. We also collect this data to ensure the proper administration of our website and business.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, namely being able to send you the email notifications and/or newsletters that you have requested. You can withdraw your consent at any time.
3.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 Information Available Publicly: We may process publicly available information via Google, Companies House, Charities Commission, Donor Boards, information published in articles and newspapers. The information may include your job history, trusteeships, political preferences, locality and philanthropic activities. We collect this information in order to better inform ourselves about prospective donors and to fulfil our fundraising goals as a charity. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. For more information on fundraising please see clause 4.
3.13 Social Media: depending on your settings or the privacy policies for social media services like Facebook, Instagram or Twitter, you may give us permission to access information from those accounts or services such as your behaviour on these services and across our site. The majority of this behaviour is anonymised. For more information on how to control your privacy settings for these services, please see their individual privacy policies.
3.14 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.15 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.16 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4.1 We are a registered charity and we rely on charitable support to continue our work. We are committed to fundraising best practice and abide by the Fundraising Regulator’s key principles and behaviours of a fundraising organisation: to be legal, open, honest and respectful. We undertake to comply with relevant law and regulations, including the Proceeds of Crime Act, Data Protection, Tax and Gift Aid legislation and Charity Commission guidance. In order to raise voluntary income we aim to better understand both our audience’s engagement with us to ascertain any potential interest in supporting us further, and to identify potential future audiences and prospect individual, corporate and trust and foundation supporters through specific research.
We will do this in a number of ways:
(a) Current audience
We will seek additional information from a small number of our audience including shows and events they have attended, individual connections, business network information and publicly available information relating to residential locations, wealth and assets, family, donations to other organisations, hobbies and interests to create a profile of their interests and preferences. This helps us to understand the background and interests of people who are currently engaging with our work and may subsequently choose to support us, enabling us to make appropriate invitations and requests for donations. We may also use publicly sourced information and images to help identify individuals who attend special events and we may send information about upcoming events and other invitations, if we believe these may be of interest.
(b) Current donors
We will ask all individual donors for their consent for us to email them specific fundraising email communications, or email them invitations as per the benefits of their engagement with us. We will also ask for permission or preference for accreditation in programmes, online or in our annual report. We respect the rights to anonymity if the donor so requests.
(c) Prospect research
We will use research from a number of different publicly available sources to identity potential supporters and their interests in addition to those of our current supporters, aiding us in our fundraising activities. This may include newspaper websites and archives, the electoral roll and official websites of companies, charities and other arts and human rights organisations. In addition to this research we also make use of company, director and shareholder information from publicly available, officially registered information providers, such as LinkedIn and 192.com.
If we have identified a specific company or trust and foundation through this research that we believe may be interested in supporting our work, we may contact the people specifically connected to these bodies via publicly available contact information, such as a relevant work email address. If we identify an individual, we may contact them by phone or by post. As a charity, we believe that this is in the legitimate interest of our fundraising needs. We will always ensure we conduct an appropriate legitimate interest assessment to ensure that we are not infringing on your rights.
We monitor potential donations and corporate partnerships for compliance and risk. Final decisions may be escalated to our Board of Trustees.
5. Providing your personal data to others
5.1 We will never share, sell, rent or trade your personal information to any third parties for marketing without your prior consent. We use a number of data processors in order to help us provide the services you request. These organisations are obliged to act on our instruction in relation to their use of your personal data and do not have any control over your data in their own right. We make sure anyone who provides a service for us enters into an agreement with us and meets our standards for data security. They will not use your data for anything other than the clearly defined purpose relating to the service that they are providing.
5.2 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
5.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes or to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.
5.4 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary in the fulfilment of a contract we have with them or the performance of our legal obligations.
5.5 Financial transactions relating to our website and services handled by our payment services providers, Stripe and Go Cardless. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. Please note that we do not store any credit card and payment information once the transaction has been completed. You can find information about the payment services providers' privacy policies and practices at Stripe (URL https://stripe.com/gb/privacy) Cardless (URL https://gocardless.com/legal/privacy/).
5.6 Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the follow will apply:
(a) Your data will be made available to our website provider.
(b) The data that may be available to them include any of the data we collect as described in section 3 above.
(c) Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
(d) They will store your data for a maximum of 7 years.
5.7 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. International transfers of your personal data
6.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
6.2 We have offices and facilities in Belarus. Transfers to Belarus will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
6.3 If the hosting facilities for our website are situated in a country outside of the EEA, we will take steps to ensure that your privacy rights continue to be protected as outlined in this privacy notice.
6.4 The contractor for the site development, content administration and project coordination for moc.media is situated in Belarus. Transfers to Belarus will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
6.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain and delete your personal data as follows:
(b) If you ask us to stop sending direct marketing communications to you, we will retain the information required (e.g. name, address or email address) to ensure we adhere with such requests.
7.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy by email.
9. Your rights
9.1 Under the Data Protection Act 1998 or the General Data Protection Regulation, you may instruct us to provide you with any personal information we hold about you. Please send a description of the information you would like to see together with proof of your identity to the email address provided below.
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes. If you have an online account with us you can amend your personal details and email contact preferences at any time or you can contact us by phoning, emailing or writing using our contract details below.
9.4 In practice, you will either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10. Third party websites
11. Personal data of children
11.1 Our website and services are targeted at persons over the age of 16.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1 You have the right to get information held about you by us corrected. If you have any concern about the accuracy of your personal data or if you would like us to remove the personal information we hold about you, please let us know by using the contact details below.
13. About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
14. Cookies that we use
15. Cookies used by our service providers
15.1 Our websites (belarusfreetheatre.com and moc.media) use the following service providers:
16. Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
17. Our details
17.1 This website is owned and operated by Belarus Free Theatre.
17.2 We are registered in England and Wales under registration number 07897118, registered charity number 1147374 and our registered office is at 66 The Cut, London, SE1 8LZ.
17.3 Our principal place of business is at 66 The Cut, London, SE1 8LZ.
17.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on +44 (0) 20 7922 2998 or
(d) by email, using email@example.com
18. Data protection registration
18.1 We are registered as a data controller with the UK Information Commissioner's Office.
18.2 Our data protection registration number is ZA334475.
19.1 If you have a complaint about us, or the treatment of your data, you can contact the Charity Commission. The Charity Commission is the independent watchdog for charities. You can make a complaint about a charity on their website at www.charity-commission.gov.uk.
19.2 If you have a complaint about our fundraising activities you can also complain to the Fundraising Regulator here: https://www.fundraisingregulator.org.uk/make-a-complaint/complaints/