1. Introduction

This Policy sets out the obligations of Kidderminster Harriers Football Club Limited, a company registered in England under number :484523, whose head office is at Aggborough Stadium, Hoo Road, Kidderminster, Worcestershire, DY10 1NB, England, United Kingdom (“the Company”) regarding data protection and the rights of employees and clients (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

1. The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

• Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
• Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
• Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
• Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

1. The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

• The right to be informed (Part 12).
• The right of access (Part 13);
• The right to rectification (Part 14);
• The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
• The right to restrict processing (Part 16);
• The right to data portability (Part 17);
• The right to object (Part 18); d
• Rights with respect to automated decision-making and profiling (Parts 19 and 20).

1. Lawful, Fair, and Transparent Data Processing
   • The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:
     • The data subject has given consent to the processing of their personal data for one or more specific purposes;
     • The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
     • The processing is necessary for compliance with a legal obligation to which the data controller is subject;
     • The processing is necessary to protect the vital interests of the data subject or of another natural person;
     • The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
     • The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
   • If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:
     • The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
     • The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);
     • The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
     • The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;
     • The processing relates to personal data which is clearly made public by the data subject;
     • The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
     • The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
     • The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;
     • The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
     • The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
2. Specified, Explicit, and Legitimate Purposes
   • The Company collects and processes the personal data set out in Part 21 of this Policy. This includes:
     • Personal data collected directly from data subjects
   • The Company only collects, processes, and holds personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the GDPR).
   • Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.
3. Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.

1. Accuracy of Data and Keeping Data Up-to-Date
   • The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.
   • The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
2. Data Retention
   • The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
   • When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
3. Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

1. Accountability and Record-Keeping
   • The Company’s Data Protection Officer is Keith Mansell (“The data Protection Officer.”)
   • The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.
   • The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
     • The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
     • The purposes for which the Company collects, holds, and processes personal data;
     • Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;
     • Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
     • Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and
     • Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.
2. Data Protection Impact Assessments
   • The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.
   • Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
     • The type(s) of personal data that will be collected, held, and processed;
     • The purpose(s) for which personal data is to be used;
     • The Company’s objectives;
     • How personal data is to be used;
     • The parties (internal and/or external) who are to be consulted;
     • The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
     • Risks posed to data subjects;
     • Risks posed both within and to the Company; and
     • Proposed measures to minimise and handle identified risks.
3. Keeping Data Subjects Informed
   • The Company shall provide the information set out in Part 12.2 to every data subject:
     • Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
     • Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:
       1. if the personal data is used to communicate with the data subject, when the first communication is made; or
       2. if the personal data is to be transferred to another party, before that transfer is made; or
       3. as soon as reasonably possible and in any event not more than one month after the personal data is obtained.
     • The following information shall be provided:
       • Details of the Company including, but not limited to, the identity of its Data Protection Officer;
       • The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
       • Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
       • Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
       • Where the personal data is to be transferred to one or more third parties, details of those parties;
       • Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);
       • Details of data retention;
       • Details of the data subject’s rights under the GDPR;
       • Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
       • Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);
       • Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and
       • Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.
4. Data Subject Access
   • Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
   • Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject Access Request Form, or other written communication. SARs should be addressed to the Company’s Data Protection Officer
   • Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
   • All SARs received shall be handled by the Company’s Data Protection Officer or by a named Company Director only.
   • The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
5. Rectification of Personal Data
   • Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.
   • The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
   • In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.
6. Erasure of Personal Data
   • Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:
     • It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
     • The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
     • The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);
     • The personal data has been processed unlawfully;
     • The personal data needs to be erased in order for the Company to comply with a particular legal obligation
   • Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
   • In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
7. Restriction of Personal Data Processing
   • Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.
   • In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
8. Data Portability
   • The Company processes personal data using automated means.
   • Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).
   • To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format:
     • A full download of data held on internal system;
   • Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.
   • All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.
9. Objections to Personal Data Processing
   • Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling)
   • Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
   • Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.
10. Data Security – Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

• Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
• Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted
• Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
• Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient

1. Data Security – Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

• All electronic copies of personal data should be stored securely using passwords and data encryption;
• All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
• All personal data stored electronically should be backed up
• No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise
• No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

1. Data Security – Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.

1. Data Security – Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal data:

• No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the Data Protection Officer or a named Director of the company only;
• No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of from the Data Protection Officer or a named Director of the company only.
• Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
• If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
• Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of from the Data Protection Officer or a named Director of the company only to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

1. Data Security – IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

• All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols.
• Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
• All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates after the updates are made available by the publisher or manufacturer

1. Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

• All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;
• Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
• Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
• All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
• The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;
• All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and
• Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

1. Transferring Personal Data to a Country Outside the EEA
   • The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
   • The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
     • The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
     • The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
     • The transfer is made with the informed consent of the relevant data subject(s);
     • The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
     • The transfer is necessary for important public interest reasons;
     • The transfer is necessary for the conduct of legal claims;
     • The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
     • The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
2. Data Breach Notification
   • All personal data breaches must be reported immediately to the Company’s Data Protection Officer.
   • If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
   • In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
   • Data breach notifications shall include the following information:
     • The categories and approximate number of data subjects concerned;
     • The categories and approximate number of personal data records concerned;
     • The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
     • The likely consequences of the breach;
     • Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
3. Implementation of Policy

This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

介绍

本政策规定了我们如何收集、处理和保存您的个人数据，如果您访问我们的在线商店或以其他方式向我们提供个人数据。我们是位于伦敦N13 4BS Green Lanes 459b的Kaizen Ticketing Solutions LTD。我们是您个人数据的数据控制者。

本政策影响您的法律权利和义务，请仔细阅读。如果您有任何问题，请通过电子邮件联系我们或拨打0208 858 0709。

我们收集的个人数据

当您预订门票或购买商品时，我们会收集、处理、存储和使用个人数据，包括您的姓名、地址和电子邮件地址以及支付信息。如果您为他人注册参加活动，我们也可能收集您提供的关于其他人的个人数据。您同意您已通知任何其他人您向我们提供的个人数据的隐私声明，并在必要时获得他们的同意，以便我们可以根据本政策合法处理他们的个人数据。

您提供给我们的所有个人数据必须真实、完整和准确。如果您向我们提供不准确或虚假的数据，并且我们怀疑身份欺诈，我们将记录此情况。

您无需提供任何个人数据即可查看我们的在线商店。但是，我们可能仍会根据本政策的数据自动收集部分收集信息，并根据本政策的营销通信部分进行营销通信。

当您通过电子邮件或邮寄方式联系我们时，我们可能会保留通信记录，并且我们可能会记录与您的任何电话通话。

我们自动收集的数据

当您访问我们的在线商店时，我们或代表我们的第三方会自动收集并存储有关您的设备和活动的信息。此信息可能包括(a)您的计算机或其他设备的唯一ID号；(b)有关您的设备的技术信息，例如设备类型、网络浏览器或操作系统；(c)您的偏好和设置，例如时区和语言；以及(d)有关您的浏览行为和模式的统计数据。我们根据本政策的Cookie部分使用Cookie收集此信息，并以匿名方式使用我们收集的信息来改进我们的在线商店和我们提供的服务，并用于分析和研究目的。

营销通信

如果您选择接收我们的营销通信，您同意处理您的数据以发送此类通信，其中可能包括新闻通讯、博客文章、调查和有关新活动的信息。我们保留您的同意记录。

您可以选择不再接收营销通信，方法是通过电子邮件联系我们，点击营销电子邮件中的取消订阅或在您的在线账户中更新您的偏好。如果您取消订阅营销通信，可能需要长达5个工作日才能使您的新偏好生效。因此，我们将在记录中保留您的个人数据用于营销目的，直到您通知我们您不再希望接收我们的营销电子邮件。

合法处理您的个人数据

我们将使用您的个人数据以履行我们向您提供您预订的活动门票或您订购的商品的合同义务，包括与您联系有关活动或商品的任何信息，并处理您对活动或商品的任何问题、评论或投诉。

我们也可能出于我们的合法利益使用您的个人数据，包括处理您需要的任何客户服务，执行我们之间任何其他协议的条款，出于监管和法律目的（例如反洗钱），用于审计目的，并与您联系有关本政策的更改。

我们与谁共享您的数据？

我们可能会与我们可能委任的任何服务提供商、分包商和代理商共享您的个人数据，以代表我们并根据我们的指示执行功能，包括支付提供商、电子邮件通信提供商、IT服务提供商、会计师、审计师和律师。

在某些情况下，我们可能需要根据适用的法律和/或法规披露您的个人数据，例如，作为反洗钱流程的一部分或保护第三方的权利、财产或安全。

我们也可能在与任何合并、资产出售、合并或重组、融资或我们业务的全部或部分被另一家公司收购的谈判中或与之相关的情况下共享您的个人数据。

我们在哪里保存和处理您的个人数据

您的部分或全部个人数据可能会因任何原因存储或转移到欧盟（EU）以外的地方，例如，如果我们的电子邮件服务器位于欧盟以外的国家，或者我们的任何服务提供商或其服务器位于欧盟以外。我们将仅将您的个人数据转移给已提供足够保障的组织。

Cookies

Cookie是一个包含唯一识别号的小文本文件，通过您的浏览器从网站传输到您计算机的硬盘。Cookie识别您的浏览器，但不会让网站知道您的任何个人数据，例如您的姓名和/或地址。这些文件随后被网站用来识别用户何时重新访问该网站。

我们的在线商店使用Cookie，以便我们可以在您返回时识别您并个性化您的设置和偏好。大多数浏览器最初设置为接受Cookie。您可以更改浏览器设置，以便在您收到Cookie时通知您，或拒绝接受Cookie。请注意，如果您拒绝接受Cookie，我们的在线商店可能无法高效运行。

我们还使用Google Analytics来监控在线商店的使用情况。Google Analytics匿名收集信息并生成报告，详细说明访问在线商店的次数、访问者通常来自哪里、在网站上停留的时间以及访问了哪些页面。Google Analytics在您计算机的硬盘上放置了几个持久性Cookie。这些不收集任何个人数据。如果您不同意此操作，您可以在浏览器中禁用持久性Cookie。这将阻止Google Analytics记录您的访问。

安全

我们将以确保个人数据适当安全的方式处理您的个人数据，包括防止未经授权或非法处理以及意外丢失、破坏或损坏，使用适当的技术或组织措施。您提供给我们的所有信息都存储在我们的安全服务器上。任何支付交易都使用SSL技术加密。

如果我们已提供或您选择了密码，您有责任对该密码保密。

但是，您承认没有系统可以完全安全。因此，尽管我们采取这些步骤来保护您的个人数据，但我们不承诺您的个人数据将始终保持完全安全。

您的权利

您有权从我们这里获得我们持有的您的个人数据的副本，并要求我们纠正不准确或不完整的个人数据中的错误。您也有权随时要求我们删除您的个人数据。要行使这些权利或您根据适用法律可能拥有的任何其他权利，请通过电子邮件联系我们。

请注意，如果您的请求明显没有根据或过度，我们保留收取管理费的权利。
如果您对本政策或我们处理您的个人数据有任何投诉，您应联系英国监管机构：信息专员（www.ico.org.uk）。

我们的在线商店可能包含其他感兴趣网站的链接。一旦您使用这些链接离开我们的网站，您应该注意我们对该其他网站没有任何控制。因此，我们不能对您在访问此类网站时提供的任何信息的保护和隐私负责，此类网站不受本政策的约束。您应谨慎行事，并查看相关网站的隐私政策。

保留

如果您在我们这里注册，我们将保留您的个人数据，直到您关闭您的账户。
如果您接收我们的营销通信，我们将保留您的个人数据，直到您选择不再接收此类通信。
如果您与我们进行了预订或联系我们提出问题或评论，我们将在此类联系后的48个月内保留您的个人数据，以便回应您可能有的任何进一步查询。

一般

如果本政策的任何条款被有管辖权的法院认定为无效或不可执行，则该条款应尽可能地解释为反映各方的意图，所有其他条款应保持完全有效。

本政策应受英格兰和威尔士法律管辖并根据其解释，您同意提交给英格兰法院的专属管辖权。
我们可能会不时更改本政策的条款。您有责任定期查看本政策，以便了解其任何更改。如果您在我们声明更改生效的时间后继续使用我们的在线商店，您将接受这些更改。