Privacy And Cookies Policy

FROM WHOM DOES TRL COLLECT DATA:

TRL collects information from three groups of people:

1. “Individuals”, who have signed up for our mailing lists, entered one of our competitions, engaged with us on social media, completed a customer survey or otherwise interacted with us (excluding interaction in the course of business between TRL and such individual);
2. “Website Users”, who visit this page, any content specific website which is owned or controlled by TRL or use our services via a third-party platform; and
3. Business clients and providers (“B2B”), licensors and rights holders with whom we interact for the purpose of acquiring content for distribution, venues and platforms who have booked (or have expressed interest in booking) our content for exhibition, marketing partners, third parties whom provide us a service and/or any other individual with whom we interact solely in the course of business.

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WHAT INFORMATION DOES TRL COLLECT:

TRL collects two basic types of information personal information (which can be used to identify a specific individual) and anonymous information (which provides analytical information, but cannot be used to identify a specific individual); and may use personal information to create a third type of information aggregate information (i.e. a collection of similar or related data).

1. Individuals:

TRL collects the information you provide to us when you sign up to one of our mailing lists, request services or information from us, respond to customer surveys, participate in our activities (such as engaging with our social networks or entering our competitions), participate in other activities related to TRL communications and/or content, or otherwise interact with us using one or more devices. Such information shall include but may not be limited to:

• If you sign up for our mailing lists or respond to customer surveys: name, age, email address, postal/zip code, city/country of residence.
• If you interact with us on social media (and depending on your own privacy settings): campaign tag information (e.g. hashtags), name, social network ID, image/profile picture, email address, gender, location, date of birth and/or such other information which you have explicitly made available, either by granting access specifically to TRL or by making such information visible to the general public.
• If you enter one of our competitions: name, age, email address, postal/zip code, city/country of residence, telephone number.*

*Please note that we may need to obtain additional information you if you win one of our competitions, the relevant information we need will depend on the prize you have won and may include (but shall not be limited to): your mailing address (if we need to mail you your prize) and/or your passport details (if we need to arrange travel as part of the prize).

TRL may also receive information about you from third parties either where those third parties are permitted by law to share your data; or in certain circumstances where you have expressly consented to such third party sharing your information with us for specific purposes (e.g. where you have indicated to such third party that you wish to hear more about TRL and its services and/or content) and/or information received pursuant to a contract we may have in respect of a specific piece of content or activity.

Please be aware that when you provide information to TRL through a third-party site or platform (for example, via social networks or mailing list service providers) the information which you provide may be separately collected by such third-party. TRL does not control third-party sites or platforms (e.g. Facebook, Twitter, Instagram, MailChimp, SurveyMonkey, and Powster) and this Policy does not apply to them. Please consult the policy of the relevant third party to find out how they collect and use your information.

2. Website Users:

You make certain information available to us when you visit one of our websites or use our services via a third-party platform using one or more devices and TRL uses technology such as cookies to collect such information, insofar as we are permitted by law and where applicable, subject to your explicit consent. Such information shall include but may not be limited to:

• user client ID generated by Cookies which are unique to you;
• referrer information (e.g. location of the link you clicked to reach our page);
• campaign tag information (e.g. hashtags);
• user agent information (e.g. browser type);
• device type (e.g. iPhone, iPad, Android);
• your IP address;
• country and city location data (based on IP); and
• user’s click events (i.e. where you point and click on our site).

Further information on TRL’s use of Cookies can be found below.

3. B2B:

TRL also collects personal information provided in the course of business, such as names, e-mail addresses, telephone numbers, job titles, and financial/payment information, as may be necessary to perform the functions required for the specific business relationship in question.

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HOW TRL USES YOUR INFORMATION:

You agree that we may use your information for the following purposes:

• to monitor performance of, optimise or improve our products, services and operations;
• create anonymous, aggregated statistics about the use of our websites, content, services and associated loyalty programs, which we may share with third parties and/or make available to the public;
• to enforce, protect and defend legal rights (including those of third party rights owners in respect of any content distributed by TRL) and to detect, investigate and prevent activities which may violate our policies or be illegal;

and in accordance with local laws, and choices and controls which may be available to you, we may use information collected from you or devices associated with you to:

1. Individuals:

• to respond to any enquiry you may have sent to us;
• to ask your opinion on our content or services;
• to process your competition entry and, if your entry is successful, to provide you with any relevant prize; and
• provided that you have opted in to such activity:
  • to keep in contact with you about your chosen release, other upcoming content, events and/or services provided by us that we believe may be of interest to you;
  • to send you offers and promotions for its content, events and services or relevant third-party content or services; and
  • personalise content and experiences.

2. Website Users:

• to provide you with access to the relevant website, and provide any services or information that you may have requested from us;
• to improve this website, and ensure that information on it is presented in the most effective and optimal manner;
• provide you with advertising based on your activity on this website and TRL’s social networks and on third-party sites and applications;
• for security purposes. This information may be passed to the police or to other appropriate authorities. We base this processing on our legitimate interests to protect you and our company, systems, employees and partners, or on a legal obligation to cooperate with competent authorities.

3. B2B:

• to provide Content and/or materials pursuant to a written contractual agreement between us; and
• checking that a payment is not made fraudulently.

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SHARING YOUR INFORMATION WITH OTHER COMPANIES:

We will not share your information with any third party, save for the following circumstances:

• sharing with our affiliates and group companies where applicable and in connection with the one or more of the uses listed above;
• where such information is shared with a third party in connection with:
  • the sale of a business;
  • to enforce our Terms of Use or rules;
  • to protect Trafalgar and/or a third-party rights holder’s rights or property;
  • to comply with legal process or other cases if we believes in good faith that such disclosure is required by law;
• sharing with content owners or rights holders so that they can send you offers and promotions about their content, products or services or in connection with the one or more of the uses listed above;
• where you have directed us to share your information with third-party sites or platforms, including social networks and select third parties with whom TRL works whereby sharing such information is necessary for the purpose of delivering the services that you have requested (e.g. MailChimp, SurveyMonkey, and Powster).

In certain circumstances the above may involve transferring your data outside of the European Economic Area (“EEA“). Whenever we transfer your data outside of the EEA we will ensure that a similar degree of protection is afforded to it by ensuring that the recipient has, or is located in a jurisdiction which has, been approved by the European Commission as being capable of providing the appropriate level of protection, that the recipient has signed a contract in the format approved by the European Commission, and/or, with your express consent to do so.

Please note that once your information has been shared with another company, the information received by such company becomes subject to that company’s own privacy practices.

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HOW YOUR INFORMATION IS STORED:

We use industry standard technological and operational security measures to protect your information against any unauthorised access to or unlawful use. However, no method of transmission over the internet or method of electronic storage is 100% secure and we cannot guarantee its absolute security.

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HOW LONG IS YOUR INFORMATION KEPT FOR?

Save as expressly set out below, we will retain information collected pursuant to this Policy for as long as is necessary to provide you with the services that you have requested from us or for as long as otherwise permitted by law.

1. Individuals:

Without prejudice to the above, to ensure that we always have the most up to date consent and accurate data from you, TRL will endeavour to contact you by e-mail to seek renewed consent at least once during a specified time period depending on the type of Content we are contacting you about and how frequently we are able predict future releases of similar content. Using commercially reasonable endeavours and with such time period starting to run as of January 1^st 2019:

• TRL will contact subscribers who have opted in hear more about our seasonal Opera and Ballet Content at least once every two (2) calendar years; and
• TRL will contact subscribers who have opted in hear more about our Theatre Content (including Musical Theatre), Music Performance (i.e. Live Concerts/Gigs) Releases, Motion-Picture or Documentary Films or any other type of Content which is not listed here, at least once every five (5) calendar years.

These e-mail communications will ask you to expressly re-subscribe and provide your current details. If you do not respond, we will assume that you no longer wish to hear from us and will remove you from the mailing list until such time as you actively re-subscribe.

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WHERE YOUR INFORMATION IS STORED:

Our servers are situated in the European Economic Area (predominately the UK and Ireland) and all of the information that we collect about you will be stored on these servers.

Save as expressly set out herein, and/or unless permitted by any specific law or regulation, we will not share your information outside of the European Economic Area without your explicit consent.

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YOUR RIGHTS, CONTROLS AND CHOICES:

We provide you with the ability to exercise certain controls regarding its collection, use and sharing of your information. In accordance with local law, your controls and choices may include:

• You may change your choices for subscriptions, newsletters and alerts;
• You may choose whether to receive from us offers and promotions regarding our content or services, or content, products or services which we believe may be of interest to you;
• You may choose whether we share your information with other companies outside of the Trafalgar group so that they can send you offers and promotions about their products and services;
• You may choose whether to receive targeted advertising from any ad networks, data exchanges, marketing analytics and other service providers by visiting http://www.aboutads.info/choices.

In addition, you have certain rights in respect of the information which we hold about you, including:

• the right to ask us not to process your personal information for marketing purposes;
• the right to request access to the information we hold about you;
• the right to object to processing likely to cause or is causing damage or distress;
• the right to object to decisions being taken by automatic means; and
• the right, in certain circumstances, to have inaccuracies in your personal information rectified, or to have your information blocked, erased or destroyed.

You may exercise your controls and choices by following instructions provided in any communications sent to you or by contacting us via email on [email protected]. Please be aware that in order to process your request we may first require you to provide further information in order to verify your identity as the owner of such personal information.

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CHILDREN’S PRIVACY:

We consider a child to be anyone under the age of 13. However, we do not knowingly target or collect personal information from or about individuals under the age of 15, without the consent of a parent or guardian.

CHILDREN: You must be over the age of 15 to use this website or register for our mailing lists. Please do not sign up to any of our mailing lists if you are under the age of 15.

PARENTS/GUARDIANS: Whilst we do not knowingly target or collect personal information from under 15s, we do recommend that parents monitor their child’s online activity and, wherever possible, consider using any available ‘parental control tools’ that help-provide for a child friendly environment online. These tools can prevent children from disclosing their name, address and other personal information without parental consent. Any parent or guardian with queries regarding our website and/or processing of personal information relating to their child should contact us at [email protected]. 

Once TRL becomes aware that personal information that has been submitted to us relates to a child without the consent of a parent or guardian, TRL will use reasonable efforts to:

• Delete that personal information from its files as soon as possible;
• Ensure, where deletion is not possible, that this personal information is not used further for any purpose, nor disclosed further to any third party.

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COOKIES:

Cookies are small pieces of information, often in the form of encrypted text files, that are placed on your device when you visit a website which allow the website owner to monitor your use of their site, simplify your user experience and to bring together information which is collected about you.

You have the ability to choose to have your device warn you each time a cookie is being sent, or you can choose to turn off all cookies, by changing your browser settings. However, if you turn cookies off, you will lose access to certain features that may make your user experience more efficient and some services will not function properly.

For information about how to change the way your browser interacts with cookies, please visit the ‘Help’ section of your internet browser or visit http://allaboutcookies.org for further general information regarding the way in which cookies work.

This website may also contain content and links to third-party websites that also operate cookies. TRL does not control these third-party websites or cookies and this Policy does not apply to them. Please consult the policy of the relevant third party to find out how they collect and use your information.

CHANGES TO THIS PRIVACY POLICY:

TRL reserves the right to make changes to this Policy from time to time and as may be necessary to new technologies, industry practices, regulatory requirements or other purposes.

In the event that any such changes are material, TRL will notify you, and, where required by applicable law, obtain your consent.

For transparency, the date on which significant and material changes were last made to this Policy is set forth at the top of this page.