SPILL privacy policy
Purpose of Privacy Policy
At SPILL we are committed to protecting your personal information and being transparent about what information we hold about you.
Using personal information allows us to develop a better understanding of our patrons and in turn to provide you with relevant and timely information about the work that we do – both on and off stage. As a charity, it also helps us to engage with potential donors and supporters.
The purpose of this policy is to give you a clear explanation about how we collect and use the information we collect from you directly and from third parties.
We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:
What information we may collect about you.
How we may use that information.
In what situations we may disclose your details to third parties.
Our use of cookies to improve your use of our website.
Information about how we keep your personal information secure, how we maintain it for and your rights to be able to access it.
If you have any queries about this policy, please contact the Data Protection Officer, Andy Brumwell, at Pacitti Company or email: info@spillfestival.com
Who We Are
SPILL Festival Ltd is a charity and is funded by Arts Council England as well as various trusts & Foundations, individual donors and supporters. Our registered charity number in England and Wales is 1075462, we are also registered as a Limited Company in England and Wales under registration number 3701419. SPILL Festival Ltd trades as SPILL.
Information Collected
We collect various types of information and in several ways:
1. Information You Give Us
For example, when you register on our website, buy tickets or donate money, we will store personal information you give us such as your name, email address, postal address and telephone number. We will also store a record of your purchases and donations.
2. Information About Your Interactions with Us
For example, when you visit our website, we collect information about how you interact with our content and ads. When we send you a mailing, we store a record of this, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on.
3. Information From Third Parties
We occasionally receive information about you from third parties. SPILL sometimes operates a box office through Ticket Tailor, in which case when you book through our websites you may be directed to the Ticket Tailor website. Information you share with them for booking SPILL events, will be shared with us, unless you choose not to share your information.
4. Special Category Data
Data Protection law recognises that certain categories of personal information are more sensitive, such as information detailing race and ethnic origin, religious beliefs, political opinions and sexual orientation. We do not usually collect this type of information about our patrons unless there is a clear reason for doing so, for example we will record your request for an accessible theatre seat with any reasons you provide for the request; and we collect data on ethnicity, age and sexual orientation to understand the diversity of our audiences and as part of our obligation to report to Arts Council England (ACE). We will always do this lawfully and in-line with GDPR regulations and any data of this type we share with ACE will be aggregated and anonymised.
Legal Basis
There are three bases under which we may process your data:
Performance of Contract
When you make a purchase from us or donate money to us, you are entering into a contract with us. In order to perform this contract, we need to process and store your data. For example, we may need to contact you by email or telephone in the case of cancellation of a performance, or in the case of problems with your payment.
Legitimate Interest
In certain situations, we collect and process your personal data for purposes that are in our legitimate organisational interests. However, we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
Consent
In some situations, for example if you request to be added to our mailing list, we will ask for your explicit consent before using your personal information in that specific situation.
Marketing Communications
We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this we use data that we have stored about you, such as what events you have booked for in the past, as well as any preferences you may have told us about.
We use our 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 them during your first purchase with us. 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 also contact you about our work by telephone, however, 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 purchases you have made (as above).
Other Processing Activities
In addition to marketing communications, we also process personal information in the following ways that are within our legitimate organisational interests:
We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
We may analyse data we hold about you in order to identify and prevent fraud.
In order to improve our website, we may analyse information about how you use it and the content and advertisements that you interact with and to develop and display content and advertising tailored to your interests on our site and other sites.
We may use profiling techniques or third-party wealth screening and insight companies to provide us with information about you that will help us to communicate in a relevant way with you, particularly when we make approaches about potential philanthropic support. Such information is compiled solely using publicly available data about you.
In these instances, we will always keep your rights and interests at the forefront to ensure they are not overridden by your own interests or 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.
Third Parties
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. In these cases, we require that these third parties comply strictly with our instructions and with GDPR law.
Where 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
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 well to provide website operators with information on how the site is being used. We use cookies to keep track of your basket on the shop section of our website, as well as to identify how the website is being used and what improvements we can make.
Vimeo and YouTube Videos
We use Vimeo and YouTube to provide videos on some pages of the SPILL website. Vimeo and YouTube set cookies when you visit one of these pages.
Measuring Website Usage
We use Google Analytics software to collect information about how you use our website. We do this to help make sure the site is meeting the needs of its users and to help us make improvements. You can opt out of Google Analytics cookies.
Google Analytics stores information about:
How you got to the website.
The pages you visit on a website.
How long you spend on each page of the website.
What you click on whilst you’re visiting that website.
Your Debit and Credit Card Information
If you use your credit or debit card to purchase from us or to donate money, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS).
We will sometimes offer the facility for you to store your card details for use in a future transaction. This is carried out in compliance with PCI-DSS and in a way that allows none of our staff members to see your full card number. We will never store your 3- or 4-digit security code.
When we use third party service providers to process payments on our behalf (for example Stripe, iZettle, CAF and box office providers such as Ticket Tailor) we will ensure that these third parties comply strictly with our instructions and are covered by and comply with the PCI-DSS.
Your Rights and Your Personal Information
You have the right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right.
You have the right to have any inaccuracies in the data we hold on you corrected and if there are any aspects of this data that you that you would like amended or removed, you can make a request be contacting us using the 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.
Security of Your Personal Information
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.
Changes to the Privacy Policy
SPILL may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the website. You are advised to review this Privacy Policy periodically for any changes.
SPILL Contact Details and Further Information
Please get in touch with us if you have any questions about any aspect of this Privacy Policy or if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.
Kathryn Kirton - Data Protection Officer
SPILL Think Tank, High Street, Ipswich, IP1 3QH
T: +44 (01)473 216 545
E: info@spillfestival.com
ICO information
If you are unhappy with how we have used your data, you can contact the Information Commissioner’s Office (ICO):
ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
T: +44 (0)303 123 1113