Introduction

This Privacy Policy sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read the following Privacy Policy to understand how we use and protect the information that you provide to us.

Both Bedford Theatre Trust Limited, which manages the Place Bedford, and Bedford Players Trust [the joint responsible bodies {JRB}] respect your privacy and are committed to protecting your personal data and being transparent about what data is held and giving you control over how it is used.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

  1. Contacting Us

For the purpose of UK data protection laws, the data controller in respect of any personal data that we collect about you or which you provide to us is Bedford Theatre Trust Limited, a company and charity registered in England under company number 1166013 and charity number 267522 with our registered address as set out below. If you want to know what information we hold about you or if you have any other queries in relation to this Privacy Policy, our contact details are as follows:

Postal Address:

Bedford Theatre Trust Limited.

The Place Theatre

Bradgate Road

Bedford MK40 3DE

Email: datarequest@theplacebedford.org.uk

How do we collect your personal information?

We collect your information when you interact with us. This could include booking tickets online, by phone, or in person or when you sign up to receive updates from us by email and other digital channels. We also monitor how audiences use the website to help us understand how it could be improved.

We collect personal information when you:

  1. Either
  2. Buy tickets or vouchers, if available
  3. Join as a member
  4. Make a donation
  5. Register for special interest lists e.g. film showings, family events, folk evenings
  6. Contact us by phone to book tickets.
  7. Book tickets in person.
  8. Contact us by post, e.g. application forms for Memberships or our special interest lists.
  9. Visit our website.
  10. Attend an event by invitation, such as a gala performance or a charity event.

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From time to time, we may also get data about you from third parties. For more information, see ‘Information we receive from third parties’ below.

What information do we collect about you?

We only collect the information that is necessary to carry on our business, provide the particular service you have requested and to keep you informed. There are occasions when you can choose not to give us certain information, but this may mean that we cannot provide you with certain services and that our communications are less relevant and personalised. For example, you may not hear about an event that we think would appeal to you.

The type of information we collect depends on where and when it is gathered. Read on to find out more.

Information we obtain directly from you:

When you register on our website, purchase tickets or other items from us, ask us for information or make an application (such as for membership) either online, by post or phone, we need to collect information from you in order to provide the service or information you are requesting or to process your application.

We collect the following information in the registration and booking process:

Prefix and name

Email address

Date of birth

Contact phone number(s)

Payment card details

Delivery address(es)

Billing address

If you are a teacher we collect:

Name of institution

Address of institution

Type of institution

Key stages and subject

If you are applying for a place on a course, class or workshop we collect:

Prefix and name

Contact phone number

Postcode

Email address

Date of birth

We may also collect:

Gender

Whether you receive state benefits such as income support.

This information, recorded for monitoring purposes, is anonymised once places on the course have been confirmed.

If you have specific needs, such as a disability, we collect:

Details of how we can best support your future visits; for example, a need for wheelchair space and seats which are accessible where you may have mobility issues.

When you visit our website we may collect the following information:

Automatically populated IP address. A public IP address is a unique number which allows a computer, group of computers or other internet-connected device to browse the internet. The log file records the time and date of your visit, the pages that were requested, the referring website (if provided) and your internet browser version.

Cookies. For further information about Cookies and how the Place Bedford uses them, please read our Cookie Policy.

If you contact us with feedback online, by email, by phone or in person:

We keep a record of the correspondence on our database to help us improve our customer service.

When you visit our premises:

We use CCTV recording equipment in and around our premises for monitoring and security purposes. CCTV cameras operate on all public access points and in the ‘front of house’ public areas of the theatre, such as the car parks and foyer. They do not operate in private areas such as toilets.

Information we receive from third parties:

In certain circumstances, your information will be shared with us by third parties. For example:

  • Arts organisations: we collect personal information from other arts organisations that we work with.
  • Service providers: we collect personal information from our website developer, IT support provider and payment services provider. For donors, we may be required by law to use service providers to verify source of funds.
  • Publicly available sources: we combine information you have given to us with information available from external sources. This will only be done when you give permission to the relevant third-party organisations to share with us the data they hold on you, or if the data is already publicly available, or if we are required by law or requested by the police or a regulatory or government authority investigating potentially illegal activities.
  • Social media plugins: we may use social media plugins from the following service providers who are based both inside and outside the EU: Facebook; WhatsApp; and Twitter. Such plugins allow you to register with us using your social media account, and you will be aware when this is happening. By providing your social media account details you are authorising that third party to share with us certain information about you.
  • Employers and referees: if you are a job applicant we may contact your recruiters, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application.

We might also receive information about you from third parties if you have indicated to such third parties that you would like to hear from us.

Why do we collect this information, and what do we do with it?

The main reasons we collect information are to provide a service you have requested, to keep you up to date with news and events, to personalise your communications, or to contact you if we need to obtain or provide additional information (e.g. change of time or cancellations). The information we collect about our audiences also helps us understand how we can best meet their needs.

We will use your information for the purposes listed below on the basis of:

  • our performance of our contract with you and the provision of our services to you;
  • your consent (where we request it);
  • our need to comply with a legal or regulatory obligation; or
  • our legitimate interests

(see below for further information).

Specifically, we use the information we collect from you in the following ways:

To manage your booking or purchase with us.

We will use your personal information to:

  • fulfill ticket, donation and membership requests (on the basis of performing our contract with you);
  • process payments (on the basis of performing our contract with you). Please note that Bedford Theatre Trust Limited does not store any Credit Card or other payment information once the transaction has been completed unless you have asked us to store your card details for future bookings;
  • provide good customer service at the theatre or by phone (on the basis of performing our contract with you or on the basis of our legitimate interests to provide you with customer service); and
  • contact you with important information relating to your booking either of tickets, classes, courses or workshops, such as confirming your order, reminding you of an upcoming performance you have booked for or letting you know about cancellations or changes to event times that may affect your visit (on the basis of performing our contract with you or on the basis of our legitimate interests to provide you with service information).

To send you marketing communications.

We will use your personal information to:

  • keep you up-to-date with news, offers, talks and events, products and information, and let you know about opportunities to support our work at the Place Bedford and in and around Bedford (where you have provided your consent or on the basis of our legitimate interests to provide you with marketing communications where we may lawfully do so). You can tailor your preferences at any time by logging into the website;
  • send information by post about how you can support the Place Bedford (on the basis of our legitimate business interests to seek support); and
  • send marketing information to companies and organisations about ways to support us (on the basis of our legitimate business interests to promote the Place Bedford); and
  • provide you with special assistance, if required (on the basis of our legitimate interests to provide you with assistance or where you have provided your consent when you have provided sensitive information about your health).

To personalise your experience (on the basis of our legitimate interests to present you with the right kinds of products and services).

We will use your personal information to:

  • help us target our marketing communications so that they are more relevant to you. You can opt-out of personalised communications by selecting ‘Remove profiling’ in the Contact preferences section of your account:
  • keep track of your interests and preferences so that we can contact you with information that is relevant to you;
  • show you advertising on such Social Media platforms such as Facebook and Instagram or via other third-party advertising that may appear on other websites you use. You can opt-out of targeted advertising (please note that you may not see fewer ads, but they will be less relevant to your interests);
  • help make the experience of using our website better and to personalise the service you receive from us – this means we will remember your previous visits and track the pages on our website that you visit; and
  • understand your interests and personalise communications to you. For more information, please see our Cookie Policy.

To conduct research (on the basis of our legitimate interests to improve our products, services and customer service).

We will use your personal information to:

  • classify our audiences into groups or segments, using information from bookings and digital interactions, and publicly available information. We do this to better understand our audience and tailor messaging accordingly;
  • measure and understand how our audiences respond to a variety of marketing activity so we can ensure our activity is well targeted, relevant and effective;
  • undertake audience research via an online or telephone survey or in person. Participation in these is entirely voluntary, so you can choose whether or not to disclose any information requested. We will make it clear whether your response to surveys is anonymous or not and, should you provide any further information, we will inform you how it will be used;
  • analyse and continually improve the services we offer, including our artistic programme, our website and our other products;
  • help us run the test version of our website that we use internally to pilot new features and ensure the smooth running of our web services; and
  • help diagnose and manage the website, to audit the geographical make-up of users, and to establish how they have arrived at the website.

To ensure security and protect our business interests.

In certain circumstances, we use your information to ensure the security of our services, buildings, and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).

To comply with our legal obligations.

In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders or subpoenas, carry out due diligence in accordance with statutory regulations or keep our database accurate and relevant (on the basis of our complying with a legal obligation).

To identify individuals for memberships and philanthropic support (on the basis of our legitimate interests to seek support, promote fundraising and to issue invitations to some of our fundraising events).

We explain this further below.

We are a registered charity (no. 267522) and rely heavily on voluntary contributions from our audience and other funders for our work at the Place Bedford and in communities throughout the county. Based on the frequency of visits and purchasing patterns, we may promote our memberships to you or ask you for additional support for our work.

This information will also help us to meet our obligations to protect the charity from financial fraud and risk.

In addition to general use of the internet for research we make use of information from publicly available sources.

Legitimate interests

Where we refer to using your information on the basis of our ‘legitimate interests’, we mean our legitimate business interests in conducting and managing our business or our relationship with you, including the legitimate interests we have in:

  • personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
  • detecting and preventing fraud and operating a safe and lawful business;
  • improving security and optimisation of our network, sites and services; and
  • providing you with customer service.

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests do not automatically override yours and we will not use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing, please refer to the ‘How can you manage your personal information?’ section below.

Where do we keep your information?

We are committed to protecting your personal information. We adopt robust and appropriate technologies and policies to protect it from unauthorised access and improper use. In addition, whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as it would have in the EEA.

As part of the services offered to you, the personal information you provide may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if any of the computer servers used to host the website are located in a country outside of the EEA. If we transfer your personal information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following transfer solutions are implemented:

(a) where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

For further details, see European Commission: Model contracts for the transfer of personal data to third countries; and

(b) where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

For further details, see European Commission: EU-US Privacy Shield.

How long do we keep your information for?

We will keep your information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy and to fulfil our legal obligations. We will not keep more information than we need.

The retention period will vary according to the purpose, for example if purchasing a ticket only, we will typically keep your data for up to eight years from the date of your last transaction whereas, if you have pledged a legacy to the National Theatre, we will hold your details until notified by your executors. For further information about how long we will keep your information, please contact us using the contact details set out in the ‘Contacting us’ section above.

Is your information shared with any third parties?

We will never share, sell, rent or trade your personal information with or to any third parties in any circumstance. We will ask for your consent to share personal information with arts organisations who have collaborated with us on shows you have seen.

Some of our service providers may have access to your data in order to perform services on our behalf (payment processing is a good example of this) or to advise us (such as legal advisors). 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 or advice that they are providing.

We may also disclose personal information to appropriate third parties to assist in anti-fraud checks and investigations.

How can you manage your personal information?

You can access and amend the personal information that we hold for you, or request that we stop contacting you at any time.

If you have an online account with us, you can amend your personal details and contact preferences. Simply log into the website and access your account

Or you can contact us by phoning, emailing, or writing using our contact details set out at the top of this Privacy Policy.

You have certain rights in respect of the information that we hold about you, including:

  • the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Policy;
  • the right to ask us not to process your personal data for marketing purposes;
  • the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
  • The right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/);
  • the right to withdraw your consent for our use of your information in reliance on your consent (refer to ‘Why do we collect this information, and what do we do with it?’ above to see when we are relying on your consent), which you can do by contacting us using the contact details at the top of this Privacy Policy;
  • the right to object to us using your information on the basis of our legitimate interests (refer to ‘Why do we collect this information, and what do we do with 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;
  • the right to receive a copy of any information we hold about you in connection with the performance of our contract with you or on the basis of your consent (or request that we transfer this to another service provider) in a structured, commonly-used, machine-readable format, in certain circumstances; and
  • the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.

How to exercise your rights

​You may exercise your rights above by contacting us using the contact details at the bottom of this Privacy Policy and we will comply with your requests unless we have a lawful reason not to do so.

Every email we send to you will include details on how to change your communications preferences or unsubscribe from future communications.

You can learn how to manage cookies here

 

What we need from you to process your requests

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.

You will not have to pay a fee to access your personal data (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. We will 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.

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 relating to your website user account even when you have requested not to receive marketing communications.

Are you under 18?

If you are under 18, please ensure that you obtain your parent/guardian’s consent beforehand whenever you provide personal information to our website. If you don’t have that consent, you must not provide personal information to us.

Changes to this Privacy Policy and your duty to inform us of changes

We may make changes to this Privacy Policy from time to time. We will post any changes to our website, and we may notify you of any material changes by e-mail.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information or contacting us via the contact details at the top of this Privacy Policy.

This Privacy Policy was approved by the Board of Trustees on the 8th day of June 2019.