PRIVACY POLICY

Shoreditch Town Hall Trust (referred to as STHT) is a charity and receives no regular or revenue funding. Our registered charity number in England and Wales is 1069617 and we are also registered as a company in England and Wales under registration number 3539597.

We aim to be open and transparent about the customer data we use. Collecting data makes it easy for you to book for performances, keep up to date with our activities and enquire about hiring our venue. We do not obtain personal data that users would likely object to, and we are happy to inform you about the information about you that we hold.

We collect various types of information and in a number of ways:

Information you give us
When you register on our website or buy tickets, we’ll store personal information you give us, including, but not limited to: your name, email address, postal address, billing address, date of birth, telephone number, card details, access requirements, purchase history, employer and gender. We will also store your marketing preferences for communications from STHT and third parties.

If you submit an Event Enquiry form, we will store information including, but not limited to: your name, company/organisation, charity number, address, telephone number, email address, website and client. Additionally, we will hold information about your event that you have provided in order for us to supply a quote, as well as your marketing communication preferences.
We reserve the right to collect and share images of you from when you visit the building.

Information about your interactions with us
When you visit our website, we collect information about how you interact with our content.

We collect anonymised information, including but not limited to: your IP address; your Operating System; and Cookies.

When we send you a mailing we store a record of this, and in the case of email, we keep a record of which ones you have opened and which links you have clicked on.

Interaction with, and information from, third parties
Our website contains hyperlinks to websites owned and operated by third parties, with their own privacy policies and we therefore advise you to review them. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

We may occasionally receive information about you from third parties. For example, we may use third-party research companies to provide general information about you, compiled using publicly available data.

Sensitive personal data
Data protection law recognises that certain categories of personal information are more sensitive, such as health information, race, religious beliefs and political opinions. We do not usually collect this type of information about our audiences unless there is a clear reason to do so. For example, we may collect information about access requirements ahead of a performance in order to ensure that we are able to meet that customer’s needs and that the customer has an enjoyable trip to our venue.

Why we collect and use this information
We use your data for these specific purposes, unless you ask us not to:

• To enable you to book and pay for tickets via our website, the telephone or in person by setting up a customer account in your name.
• To enable us to contact you to provide important information in advance of a production for which you have booked, including, but not limited to: a change in start time, a change in location, or a cancellation.
• To allow you to enquire about hiring STHT and to book an event.
• To enable us to contact you to provide important information regarding a room booking or event hire including, but not limited to, a change in venue, a change in staffing requirements or additional charges.
• To enable us to contact you via post, telephone and email about upcoming productions, ticket promotions and event hire opportunities.
• To share your personal information with other organisations who would like to contact you, if you have provided consent.
• To store saved shopping carts as you navigate our website (using Cookies)
• To identify visitors and analyse their browsing habits (using Cookies)
• To identify people in our system who are returning customers
• For promoting our shows and events or for archival or reference purposes, by the use of photographs and videos taken of our audiences and theatre-users.
• For storing CCTV images of people within the premises for security
• To share anonymised information with producing partners
• To help us investigate complains, legal claims, or important incidents.

How we collect and use this information
STHT is the data controller for all the data we store. We use Data Processors to help us collect, process and safely store the data that we obtain.

• We use our website to allow customers to sign up to our email newsletter database. Our website is provided by Dash Creative.
• We use our website to receive Event enquiry forms relating to room or venue hire.
• We use Spektrix Ltd to process our Box Office ticketing system and to report on our order history and to show trends in sales patterns.
• We use Artifax to process and store information relating to Event enquiries and hires
• We use Dotmailer to send email newsletters
• We may use other similar services provided by other parties but which do not adversely affect your rights on the terms of notice.
• We do not use any services that include automated decision making of any significance to the individual.

Legal basis
There are three bases under which we may process your data:

Contract purposes
When you make a purchase from us, you are entering into a contract with us. In order to perform this contract we need to process and store your data.

• To confirm your booking and send print-at-home/e-tickets by email, or to confirm your identity when collecting tickets.
• To enable us to contact you to provide important information in advance of your booked production, such as details of the location of the event or if the production has been cancelled
• To enable you to book and pay for tickets and merchandise via our website, over the telephone and in person by setting up a customer account in your name.

With your explicit consent
When appropriate, we will ask you for your explicit consent before using your personal information in that specific situation. We will update your consent periodically, you have the right to withdraw consent at any time and this can be done via your customer account on the website, or by emailing marketing@shoreditchtownhall.com. Examples of such situations include:

• To share your information with other organisations who would like to contact you if you have provided consent.

Legitimate business interests
In certain situations we collect and process your personal information for purposes that are in our legitimate organisational interests. However, we can only do this if there is no overriding prejudice to you by using your personal information this way. You have the right to object, and this is explained in detail later in this document. We describe below all situations where we may use this basis for processing:

Marketing communications
We aim to communicate with you about the work we do in ways that you find relevant, timely and respectful. To do this we use data about you that we have stored, such as what events you have booked for and enquiries you have made in the past, as well as any preferences you may have told us about.

• We use legitimate organisational interest as the legal basis for communications by post and email.
• In the case of postal mailings, you may object to receiving these at any time using the contact details at the end of this policy.
• In the case of email, we will give you an opportunity to opt out of receiving these during your first purchase with us if you are booking for a performance; or when you complete an event enquiry form, if you are interested in hiring the venue. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the end of this policy.
• We may email you about upcoming productions, services, events hire information and offers, as well as a post-show survey to evaluate the success of the production, and STHT’s programme and facilities.
• We use email to allow you to enquire about our Event hire services, book your event, and to keep in touch with you about all the necessary arrangements before and after the event date.
• We analyse data to evaluate the productions, events and services we provide, and may report on these anonymously to organisations including funding bodies and local authorities.
• We use Cookies to store saved shopping carts on our website
• We analyse the way in which our email to you are received, and how you interact with the content and links in order to improve our communications with you. We also analyse data to ensure that the content and timing of our communications are as relevant as possible.
• We maintain notes on our customers according to customer booking history, and other personal customer account data you provide us, as well as publicly available internet research for the purposes of our marketing communications to you, and to enable us to communicate in a relevant way with you, but not to make any automated decisions based on profiling of any consequence to you whatsoever.
• We may also contact you about our work by telephone, providing you are not registered on the Telephone Preference Service. We will always get explicit consent from you before doing this. Please bear in mind that this does not apply to telephone calls that we may need to make to you related to your purchases (as above).
• We may promote our shows and events by the use of photographs and videos taken if audiences and events
• We record and store CCTV media within the premises for security purposes.
• We may analyse data we hold about you in order to identify and prevent fraud.

In any of the above cases, we will always keep your rights and interests at the forefront to ensure they are not overridden by your fundamental rights and freedoms. 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. Please bear in mind that if you object this may affect our ability to carry out tasks above that are for your benefit.

Recruitment
Shoreditch Town Hall reserves the right to collect personal data for the purposes of recruitment. The personal data supplied in an applicant’s Application Form is handled, processed and stored securely within STH and on STHT’s servers for legitimate human resource and business management interests in the following ways:

• Identifying and evaluating applicants for potential employment, as well as for future roles that become available. We store all applicants’ data until we have successfully filled the role in question. At this point, we will either delete the data (both hard and electronic copies) or keep it on our electronic database for future roles, subject to written permission from the applicant.
• Recordkeeping in relation to recruitment and training.
• Ensuring compliance with legal requirements including diversity and inclusion requirements and practices.
• Conducting Criminal Record checks as permitted by applicable law.
• Emergency situations where the health and safety of one or more individuals may be endangered.

STH may also analyse applicants’ personal data or aggregated/pseudonymised data to improve our recruitment and hiring process.

STH will not share any applicant data with any third party or recruitment agency.

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

• To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software provider, Spektrix). In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example, around security of personal data.
• When 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 doing so.

Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function (for example, to keep track of your basket) as well as to provide website operators with information on how the site is being used.

We use cookies to keep track of your basket as well as to identify how the website is being used and what improvements can be made. Our website uses the following cookies:

Google Analytics cookies
_ga
_gat
_gid

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Functional cookies
ce_cookie (used to register if an user already accepted the cookie policy)
phpsessid (session cookie)

Cookies installed just to website administrators
wp-settings-1
wp-settings-time-1

STHT use Google Analytics and Google Tag Manager to monitor traffic levels, search queries and visits to this website.

Our implementation of Google Analytics includes Display Advertising features such as Remarketing, Google Display Network Reporting and Google Analytics Demographics and Interest Reporting. We use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google and Facebook, may show our adverts on sites across the Internet. STHT, and third-party vendors, including Google and Facebook, use cookies (such as the Google Analytics cookie) to inform, optimise and serve adverts based on our users' past visits to STHT’s website.

STHT may also use data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender and interests) with Google Analytics in order to optimise and serve adverts. Visitors may opt out of Google Analytics for Display Advertising and customise Google Display Network ads by clicking on the Ads Settings on Google Ads. If visitors would like the ability to prevent their data from being used by Google Analytics please see Google Analytics' currently available opt outs for the web.

Google Analytics stores IP address (anonymously) on its servers in the United States, and neither STHT or Google associate an individual’s IP address with any personally identifiable information.
A mixture of both persistent and session cookies are used to enable Google to determine whether a person is a return visitor to STHT’s site and to track the pages visited during a session.

These cookies are: __utma, __utmb, __utmc, __utmz

More information about Google’s cookie policy can be read at www.google.com/intl/en/analytics/privacyoverview.html

You can login to your customer account here.

Any information that we ask for other than those listed below is entirely voluntary. Not providing any of the voluntary information will not preclude you from any of the products or services we order or effect you in any other way.

In order to sign up for our eNewsletter, we require your:
• First name
• Last name
• Email address

In order to create a customer account, we require your:
• First name
• Last name
• Email address
• Date of birth
• Phone number
• Billing address

Once a customer account has been created, we need to store the following information on your account:
• Purchase history

In order to book and pay for tickets, we require:
• Your customer account details as above and:
• Card type
• Card number
• Expiry date
• Start date (if required by your bank)
• Issue code (if required by your bank)
• Security code

If you use a credit or debit card to purchase from us, 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 here

We optionally allow you to store you card details for use in a future transaction. This is carried out in compliance with PCI-DSS and in a way where none of our staff members are able to see your full card number. We never store your three or four digit security code.

For hire enquiries and bookings, we will need your personal data in order to provide a quotation, a contractual agreement, an invoice, and any other relevant correspondence relating to your booking. If you do not provide your personal data, we will be unable to create a quotation or agreement and you will not be able to book your event with us.

We store your personal information indefinitely such that for any subsequent purchases you make we are able to link them back to a single unique record that we hold for you on our system.

If there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging into your account through our website. Alternatively please use the contact details at the end of this policy.

Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.

If you are concerned that your customer account could have been compromised (for example, if someone has discovered your password), please email marketing@shoreditchtownhall.com as soon as possible.

We will 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.

We limit internal access to your personal data to only those who require it, and provide all our staff with Data Protection and Information Security training. We ensure that high standards of security and protection are met by abiding by our Data Protection Policies and Procedures and these are governed by the Senior Management Team and the Board of Trustees.

When we do send you information, we do so securely and are committed to reporting any breaches of data during its transit. Whenever possible all information that identifies you will be removed.

We will not transfer, process or store your data anywhere that is outside the European Economic Area.

We only retain information for as long as we deem necessary. We are bound by law to retain certain financial records and these circumstances override our other retention periods.

We may ask you to check and update your contact preferences periodically so that we know our database is up-to-date. You can withdraw your consent, or make changes to your contact preferences at any time.

You have a right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected. Please us the contact details at the end of this policy if you would like to exercise this right.

We do not sell any of your information for the purposes of marketing, nor do we share your personal information with third parties unless you have given us specific consent to do so, or if we are required to do so in order to deliver a Box Office service at another venue, or due to our obligations to comply with current legislation and bank transactions, or our duty to comply with a Court Order.

We employ the services of other parties’ software and services in order to collect and store your personal information. For example, we use Spektrix as our ticketing system software provider for booking tickets and creating customer accounts that can be accessed on our website. The providers of such services may have access to certain personal data provided by you. Any data used by such parties is used only to the extent required by them to perform the services that STHT requests. Any use for other purposes is strictly prohibited within a data sharing agreement between us and the provider. Furthermore, any data that is processed by third parties must be processed within the terms of this policy and in accordance with the United Kingdom Data Protection Act 1998 and General Data Protection Regulation 2018.

You have the right to:

• Object to processing of personal data that is likely to cause, or is causing, damage or distress
• Object to the processing of your data where STHT is relying on its legitimate interest as the legal grounds for processing
• Prevent processing of your personal data
• Port your data using an open format, such as a .CSV file
• Object to decisions being taken by automated means
• In certain circumstances, have inaccurate personal data rectified, blocked, eras or destroyed and to claim compensation for damages caused by a breach of the Data Protection regulations.

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.

You can login to your account by clicking here

You can contact us at:

Shoreditch Town Hall Trust,
380 Old Street,
London,
EC1V 9LT,
United Kingdom

marketing@shoreditchtownall.com

Tel: (+44) 020 7739 6176