ML EVENTS LTD PRIVACY NOTICE
1 WHO WE ARE AND HOW YOU CAN CONTACT US
The ML Events Ltd has a close associated with other linked companies. This privacy notice is issued on behalf of the each of those companies so when we mention “ML Events Ltd”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company responsible for processing your data and that particular company is the controller of your data. ML Events Ltd is responsible for this website. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please email these to email@example.com – You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. In accordance with the UK Data Protection Act 1998, the following companies are registered with the United Kingdom’s Information Commissioner’s Office as a data controller to collect information: Data controller: ML Events Ltd, registered company number 13946833, registered company address 3 The Old Court House, Tenterden Street, Bury, BL9 0AL. CONTACT DETAILS Data privacy manager ML Events Ltd,3 The Old Court House, Tenterden Street, Bury, BL9 0AL.
2 THE DATA WE COLLECT ABOUT YOU
3 HOW YOUR PERSONAL DATA IS COLLECTED
4 HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
Information about our customers, guests and invitees is an important part of our business and we do not sell it to others. We only share it in the circumstances set out below. • Affiliated Businesses we control: As part of a group of companies we share data to other data controllers in the ML Events Ltd group to be used for similar purposes. If your personal data is transferred or disclosed to another data controller within the ML Events Ltd group, that other data controller shall have the same rights and obligations with regard to your personal data. • Affiliated Businesses we do not control: We have relationships with a small number of other companies who are our commercial partners with whom we may share data for the purposes of our events, for prize draws and competitions or for marketing their goods or services. For a list of those business click here. They have access to a limited amount of personal information needed to put their sponsorship rights into effect but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws. • Third Party Service Providers: We employ other companies and individuals to perform functions on our behalf, fulfil our obligations and as activation partners. Examples of such activity include fulfilling orders, providing hospitality, catering and event services, carrying out surveys, analysing data, providing marketing assistance, processing credit card payments, providing customer services, delivering ticketing and merchandise, retailers, social networks, fraud prevention agencies, payroll service providers, land agents, medical practitioners, digital agencies, hosting providers, data storage providers and other technical partners. They have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.• Promotional Offers: Sometimes we send offers to selected groups of customers on behalf of other businesses. When we do this, it will only be in circumstances where you have indicated the necessary marketing preferences. • Protection of ML Events Ltd and third parties: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Conditions of Use and other agreements; or protect the rights, property or safety of ML Events Ltd, our customers or others. This includes exchanging information with Health and Safety and Food Safety consultants, our brokers and insurers, the emergency services, other organisations for fraud protection and credit risk reduction. Obviously, however, this does not include selling, renting, sharing or otherwise disclosing personally identifiable information from customers for commercial purposes in a way that is contrary to the commitments made in this Privacy Notice. • With Your Consent: other than as set out above, you will receive notice when information about you might go to third parties and you will have an opportunity to choose not to share the information.
6 INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
7 DATA SECURITY
We may monitor or record telephone calls for security purposes and to improve the quality of services that we provide to you. Please note that for your safety and security, CCTV is in operation in all of our premises which are open to the public. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. You have the right to ask ML Events Ltd to provide you with all the information it stores on you, you can make a Subject Data Access Request by contacting firstname.lastname@example.org
You have the right to ask ML Events Ltd to rectify, block, complete and delete your personal data, to restrict its use, and to port your data to another organisation. You also have the right to object to the processing of your data by ML Events Ltd in some circumstances and, where we have asked for consent to process your data, to withdraw this consent. You may contact email@example.com
if you would like assistance with any of the aforementioned rights. There are exceptions to these rights, however. For example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if ML Events Ltd is legally prevented from disclosing such information. In addition, ML Events Ltd may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your data.
8 DATA RETENTION – HOW LONG WILL WE USE YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9 YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: • Request access to your personal data • Request correction of your personal data • Request erasure of your personal data • Object to processing of your personal data • Request restriction of processing your personal data • Request transfer of your personal data • Right to withdraw consent Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact the privacy manager at firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.