The Brighton Centre is strongly committed to preserving the privacy of our customers. This Privacy Policy lets you know about our policies for the collection and use of information about you.
Who we are
We are The Brighton Centre (“we”, “us” or “our”), of Kings Road, Brighton, BN1 2GR and are owned and operated by Brighton & Hove City Council, of Hove Town Hall, Norton Road, Hove, BN3 3BQ. You can find the Brighton & Hove City Council Privacy Policy here.
The Council is the Data Controller for the purposes of the General Data Protection Regulation and for any UK legislation with the purpose of implementing or amending it in British law, and is registered as a data controller with the Information Commissioner’s Office (ICO) under registration number Z5840053.
Brighton and Hove City Council is committed to protecting your personal information. As a data controller we have a responsibility to make sure you know why and how your personal information is being collected in accordance with relevant data protection law in connection with any personal information collected or received by us arising from your use of any of our products, services, applications, websites and customer support communications.
Summary
This Policy explains the types of information that we may collect and hold, how that information is used and with whom the data is shared. It also sets out how you can contact us if you have any queries or concerns about this information.
We will not sell any of your personal information to third parties. We don't share your information with other companies without your prior permission or if outlined below and we will only send you marketing emails if you specifically give us your consent to do so.
Please also be aware that we may also obtain information about you from our Contractors and Event Partners, for example a complete list of customers who are due to attend an Event, we are not responsible for the security or policies of these companies, and recommend that you review their Privacy Policies before sharing your personal data with them.
To remain transparent we have also listed specific Privacy Notices at the bottom of this policy, they cover the following;
Getting in touch with us directly
Signing up to and being on our Access Address Book
Contractors
These are companies who work directly with us, under contract, to supply us and you with certain products, and we reference them in our Privacy Policy below.
Event Partners
These are companies we are working with to put on an Event. For example event promoters, artist agents, VIP experience suppliers and promoter ticketing agencies and affiliates, and we reference them in our Privacy Policy below.
If you’d like information on which Contractors and / or Event Partners are involved with the Event you are attending or may be gaining access to your data as outlined below please contact us on brightoncentre@brighton-hove.gov.uk
Information we collect
We may collect information about you in several different ways including when you sign up to our newsletter, purchase products or services from us, when you contact us, send us feedback, use our websites or social media channels, complete customer surveys or take part in promotions or competitions run by us.
Information that we gather about you may include your name, gender, contact details [including email address, telephone number and postal address], date of birth, payment details, social media profiles and sensitive information such as your access requirements. This information may also be shared with and/or used by certain other parties such as our Contractors or Event Partners, as outlined below in our Privacy Notices.
We may also collect personal information when you purchase a ticket for an event from our ticketing agent, Ticketmaster, in order to assist us with event planning activities and to enable us to contact you with details of any changes to the scheduled event, and to share with Government agencies or other authorised bodies where permitted or required by law. We may keep a record of your name address, delivery details, email address, telephone number and bank details.
Our website and services are not intended for children. We do not knowingly collect personal information from children. If you are a parent or legal guardian and think your child has given us information please can contact us on brightoncentre@brighton-hove.gov.uk so that we can review, and you may, subject to applicable law, request access to and deletion of that child’s personal data. Please note that we will ask you to prove your relationship to the child. A child is considered to be anyone under the age of 16.
Supplying us with other people’s data
If you supply us with information on a third party, such as your children, spouse, employees, etc. we will process it as described in this Privacy Policy and you confirm that the other person has agreed that you can:
- Give consent on their behalf to the processing of their personal data
- Receive and consent to data protection notices on their behalf
- Give consent to the processing of their potentially sensitive personal data (e.g. their access requirements)
It is also of the upmost importance the person is able to understand what consent is and the reason their data is being passed to us for processing. Disclosure of phone numbers, addresses, age or other personally identifying information that may breach someone else’s privacy is prohibited.
Why we are processing your data
We may use the personal information you provide to us or which we collect for the following purposes:
- Providing services to you and fulfilling those services, for example posting tickets to you
- Marketing our business and services to you, such as sending newsletters
- Asking you to participate in market research, for example sending you surveys about your experiences when you visit us
- To contact you if any services you requested are unavailable or to notify you in the event of any changes to an Event, such as if an Event cancels or postpones
- Customer analysis, to help us better understand who our customers are
- To prepare anonymous, aggregate or generic data (including “generic” statistics), for example to report how many people have bought tickets, visited our website, are on our mailing list or have opened our newsletter
- Operational reasons, like recording transactions and internal training
- Improving our services and your experience, such as keeping a record of your access requirement to ensure we are booking the best area of the auditorium for you
- Providing customer service, such as responding to emails, contacting you with information updates or arranging call backs
- Analysing customer feedback, to improve the service that we are offering
- Tracking activity on our website, marketing emails and social media channels, so as to improve the user experience
- Investigating complaints and carrying out internal investigations
- To prevent or detect unlawful behaviour or to protect or enforce legal rights, for example, we may use your information to prevent ticket touting
- Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
- We may also use your information for other purposes such as sharing with Government agencies or other authorised bodies where permitted or required by law
CCTV (Closed Circuit Television)
In addition to the above we record Closed Circuit Television (CCTV) images of you when you are at the venue or within its vicinity for your safety and security. The purpose of the CCTV is for staff safety and crime prevention and detection. The footage is normally held for 30 days and may be shared with the police for crime prevention and detection purposes. All staff who have access to CCTV are fully trained in data protection and compliance practices associated with working in such an environment.
What we use to process your data
When we gather data from you via the methods listed above or if you make direct contact with us, we may use the following systems to process this information:
- Our computer networks, email systems and internet facilities
- Our telephones, voicemail and mobile phone records
- Third party systems including Ticketmaster [and their sub-processors], Sales Force and Google Analytics
We, all our staff and any third parties hired to provide support services, will be required to observe our privacy standards and to allow us to audit them for compliance.
How long we keep your data for
We will retain your personal data as set out in the policy and as required by applicable law. We may also retain certain information in order to conduct audits; comply with our legal obligations (and to demonstrate compliance) and to resolve disputes. However, we will not retain your personal data for longer than reasonably necessary and when it is no longer necessary to retain your personal data we will delete or anonymise it.
Sharing your data
In general, we do not share or disclose information about you to third parties without your consent. However, there are exceptions:
We may use other third party service providers to provide certain data processing services for us (acting as our authorised data processors). For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services and provide customer services.
When acting as our authorised data processors, our service providers are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations.
Some of the service providers we and our data processors use are outside of Europe. When transferring information in this way, there are strict rules and documentation in place to ensure your data is still protected to a high standard. For more information, or to get a copy of the relevant documentation, please contact us.
We may use and/or disclose to third parties information about you:
(i) To government bodies and law enforcement agencies to prevent fraud, to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies
(ii) To third parties (including professional advisors) to enforce or defend our legal rights or the terms and conditions of any of our websites, products or services
(iii) To a third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a reorganisation, merger, business acquisition or insolvency situation.
We may also prepare anonymous, aggregate or generic data (including “generic” statistics) for a number of purposes. As we consider that you cannot be identified from this information, we may share it with any third party (such as our Contractors, Event Partners, industry bodies, the media and/or the general public).
Keeping your data secure
The security of your data is of the upmost importance to us. While we can’t guarantee that unauthorised access will never occur, rest assured that we take great care in maintaining the security of your personal data to prevent unauthorised access to it, through the use of appropriate technology and internal procedures. We also limit access to your personal information to those who have a genuine business need to know it. Some of the technical and organisational measures we use to safeguard your personal data are:
- Storing your personal data, in all forms, in a secure environment and putting in place physical, electronic, and procedural safeguards in line with industry standards
- Employing SSL (secure sockets layer) encryption on our website
- Training our staff on the importance of data protection and limiting access to the information we collect about you
We also have policies and procedures in place to deal with any suspected data breach so that we can act quickly to minimise any potential damage.
What we will do if there is an update to this Privacy Policy or our Privacy Notice(s)
From time to time we may change our privacy practices. We will notify you of any changes to this Policy as required by law. We will also post an updated copy on our website. It will have a different date and version number from the one set out at the bottom of this page. Please check our site periodically for updates.
Privacy Notice(s) - transparency of data protection
Being transparent and providing information to our customers about how we will use personal data is important to us. The following Privacy Notices detail how we collect data and what we will do with it, please ensure you have read our over-arching Privacy Policy above to ensure you understand all the ways in which we may use your data and how we keep it safe, the information below is not finite but designed to support you in understanding our practices.
Using our website
When using our website please ensure you are familiar with our Terms of Use and Cookies Policy which gives a full breakdown of what and how we collect information about you when you use our website. We also use Urchin Tracking Module Links (UTMs) between our website and Ticketmaster’s website, this means we are able to track how many people click on the “Buy Tickets” button on our website, and from there how many buy tickets. We do this so that we can better understand the customer journey through our website. We cannot identify you from the UTMs.
- What information is being collected: IP Address
- Legal Basis for Processing: Explicit Consent
- Who is collecting it: The Brighton Centre
- How is it collected: via Google Analytics
- Why is it being collected: to better understand the way our customers view and use our website, to prepare generic statistics
- How will it be used: to improve the functionality and customer experience when using our website and to report generic statistics to internal departments
- Who will it be shared with: generally this information is kept internal to us however, we may share the statistics with other internal Council departments, our Contractors and Event Partners if the statistics are relevant to their products, for example the promoter of an event or a pre-show dining page
- How long we will keep it for: 38 months
When you visit our website a Cookies “pop-up” will appear which you will need to action for it to be removed. By continuing to use our website without disabling Cookies or blocking Google Analytics you consent to this data being logged.
Important: None of the above collect personal information about you and you are not identifiable via this data.
Getting in touch with us directly
When you get in touch with us for customer service assistance by any means of communication including written or via our website, telephone, email, SMS, or our social media channels, we may record all customer service communications and keep information about the particular communication, including your name, the product(s) you bought, the reason why you contacted us, and the advice we gave you so we can track the resolution of any customer service issues and for customer service training purposes.
- What information is being collected: Name, Contact Details
- Legal Basis for Processing: Explicit Consent
- Who is collecting it: The Brighton Centre
- How is it collected: directly from the customer
- Why is it being collected: to provide customer service assistance, such as responding to emails, contacting you with information updates or arranging call backs, and to improve our services and analyse feedback
- How will it be used: customer service assistance, internal investigations, staff training, improving our policies and procedures, best practice, to compile KPIs, to report generic statistics
- Who will it be shared with: generally this information is kept internal to us however, we may share communications with other internal departments to the Council or our Contractors and Event Partners should they be referenced in the communications and their input to response be required. For example if you make a complaint about an Event where they were at fault we may forward your communication so that the party at fault can conduct an internal investigation and formulate a response or if we receive a compliment about us or our staff we will pass this to the Council’s Customer Feedback team
- How long we will keep it for: as long as reasonably required, following this time it will either be deleted or anonymised
Important: when using this information to report generic statistics, personal information about you will not be used and you are not identifiable via this data.
Purchasing tickets & packages directly with our Box Office (over-the-counter, on the phone or via email)
When you purchase tickets or packages directly from our Box Office the minimum amount of information we need to collect from you is your name and payment details, and if you require tickets to be sent to you we will also require your postal address. We request your name so that we can identify your account in situations such as you losing your tickets or tickets becoming damaged, if you do not provide us with your name we may not be able to assist you in these circumstances.
We will request a contact telephone number and your postal address, even if your tickets are not being sent, and although you do not have to provide this information we request these details so that we can contact you should there be a change to the Event, such as postponement or cancellation. Your telephone number is our primary contact and your postal address is secondary if we cannot get hold of you via telephone. We would also use your postal address as a second form of identification should we need to refund your account if you paid by cash or if you lose your tickets and we need to reprint them.
- What information is being collected: Name, Contact Details [telephone number, email address and postal address], Payment Details
- Legal Basis for Processing: Performance of a Contract
- Who is collecting it: The Brighton Centre, this information is processed by Ticketmaster who are our Data Processor for ticket sales
- How is it collected: directly from the customer
- Why is it being collected: to provide you with a service, such as selling you a ticket and posting the tickets to you, to be able to contact you in circumstances of changes to an Event
- How will it be used: we will only use contact details provided if you require your tickets to be posted or should we need to contact you regarding the event, for example if we need to reseat you, an Event is postponing or cancelling, or if we need to check the details that we hold [such as your postal address] is still correct to fulfil a service [such as posting your tickets to you]
- Who will it be shared with: Ticketmaster only, though please be aware that we may also process these details should we suspect unlawful or fraudulent behaviour, in such circumstances we may share your information with third parties. These details may also be shared with Government agencies or other authorised bodies where permitted or required by law.
- How long we will keep it for: 7 years
Ticketmaster’s Privacy Policy is available to read here.
Important: if you purchase an Event specific package, such as a VIP or a Merchandise Package we may also collect your email address so that we can contact you in advance of the Event with arrival or collection instructions. Alongside this we may share your name and contact details [generally email only] with the Event Partners running that package, such as the Promoter or VIP Experience Provider, so that they can contact you directly with Event specific information. If you’d like information on which Event Partners are involved with the Event you are attending or may be gaining access to your data as outlined below please contact us on brightoncentre@brighton-hove.gov.uk
Signing up to and being on our Access Address Book
Our Access Address Book allows us to hold information about your access requirements and as to whether or not you are eligible for a free Personal Assistant ticket, this information is considered Sensitive Data. We hold this information so that we are better able to understand your requirements, book tickets in the most suitable location within the auditorium for you, and we do not have to ask you questions about your access requirements every time you make a booking with us.
- What information is being collected: Name, Contact Details [telephone number, email address and postal address], Access Requirement
- Legal Basis for Processing: Performance of a Contract & Explicit Consent
- Who is collecting it: The Brighton Centre
- How is it collected: directly from the customer
- Why is it being collected: to offer faster and simpler booking processes for our Deaf and disabled customers
- How will it be used: for quick reference by our Box Office team to ensure they are booking the right ticket for a customer’s specific access requirements and to confirm as to whether a customer requires a free Personal Assistant ticket
- Who will it be shared with: no-one
- How long we will keep it for: 3 years, after 3 years we will contact you to ask if you want to remain on our address book and if the information we hold is still correct
When signing up to the Access Address Book you also have options to consent to receive marketing communications from us, to take part in satisfaction surveys and offer your thoughts and feedback on new access projects we are undertaking. If you consent to any of these communications they will come directly from us and we will not use a third party Data Processor without contacting you for further consent.
Important: any evidence or documents submitted to confirm requirement for a free Personal Assistant ticket are destroyed once reviewed, marked as “seen” on the Access Address Book and not kept by us.
Marketing Emails
We will only send you marketing emails if you have consented to us doing so.
- What information is being collected: Mandatory: Name, Email Address. Optional: Mobile Number, Post Code.
- Legal Basis for Processing: Explicit Consent
- Who is collecting it: The Brighton Centre
- How is it collected: directly from the customer
- Why is it being collected: for communication with customers who are interested in receiving information from The Brighton Centre
- How will it be used: to email you with marketing communications such as event information, latest news and newsletters, presale and offer information, customer satisfaction surveys
- Who will it be shared with: Ticketmaster and Sales Force, but please be aware this is only as processors and they will not contact you for marketing purposes unless you have signed up to their services directly
- How long we will keep it for: until stated
Important: We use an email service provider, Sales Force, to send our marketing emails to you. The mailing list is maintained on their servers. For more information on their Privacy Practices see https://www.salesforce.com/uk/company/privacy/
Opting In: when you sign-up to our email services or when you edit your email service account you will be provided with options for individual preferences and what personal information we hold about you. The only information that is mandatory is your name and email address*, post code and mobile number are optional. This information is managed by you and you can edit them at any time, apart from your email address. If you wish to change the email address being used you will need to create a new account.
*if you signed up via the one-off form on our website prior to April 2018 we may also have requested the following information: Title, Postal Address, Telephone Number(s), Gender, Date of Birth
No personal information provided by you will be used for marketing purposes unless you have agreed to be contacted by us / Event Partners**
**if you signed up to receive marketing emails during the ticket buying process on Ticketmaster’s website prior to 25 May 2018 we would have been called an “Event Partner”, after this date we will have been named.
When you sign-up via the one-off form on our website you will be supplied with a link to this Privacy Policy. Please read through this before submitting your information.
Opting out: You can unsubscribe from this service at any time by following the unsubscribe link on the bottom of the emails you receive from us or editing your preferences within your email service account. If you are struggling with this please contact us on brightoncentre@brighton-hove.gov.uk and we will be happy to assist.
You can manage your preferences via this page on our website.
Your information rights
As a data controller we have a duty to inform you of not only why your personal information is being processed but what rights you have around your personal information too.
You have the right to:
- Be informed of how your personal information is being used
- Have access to information held about you, this is commonly known as a Subject Access Request (SAR)
- Have your personal information deleted in certain circumstances
- Have inaccuracies within your personal information corrected
- Restrict processing of your personal information until inaccuracies are corrected or if there is a dispute around legal basis for processing the personal information
- Object to processing of your personal information in certain circumstances
- Have your personal data transferred to another provider
- Be informed of where automated decision making (ADM) takes place and be given an option to opt out of ADM
Further information
Further information on your rights are available on the Brighton & Hove City Council website or if you would like to discuss any of the above information in more detail our Information Governance Team can be contacted on 01273 295959 or data.protection@brighton-hove.gov.uk or on gdpr@brighton-hove.gov.uk
Alternatively if you would like to speak directly with The Brighton Centre regarding this Policy, our practices or have any questions or concerns please contact us on brightoncentre@brighton-hove.gov.uk or at;
Brighton Centre
Kings Road
Brighton, BN1 2 GR
If you would like this notice in another format (for example, audio, large print, braille) please contact us using any of the methods above.
Last updated: 18 October 2020
