INTRODUCTION
Welcome to the First Access Entertainment Limited (“First Access”) privacy notice. It sets out how we look after your personal data (i.e. data that can identify you) when you interact with us and the acts we represent (“our Roster”) and tells you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how First Access collects and processes your personal data through our digital platforms, including any data you may provide through this website, social media, when you sign up to our newsletter, any of our Roster’s newsletter, purchase a product or service or take part in a competition.
We do not knowingly collect data relating to children, without parental consent.
It is important that you read this privacy notice together with any other notice we may provide on specific occasions so that you are fully aware of how and why we are using your data.
CONTROLLER
First Access is made up of two different legal entities:
This privacy notice is issued on behalf of all First Access entities so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the First Access group responsible for processing your data. First Access Entertainment Limited is the controller of any personal data held by the First Access group of companies.
If you have any questions about this privacy notice or about your personal data you may contact us using the details set out below.
CONTACT DETAILS
First Access Entertainment Limited,
a company incorporated in England and Wales with number 09790120
Grove Studios
Adie Road
London, ENGLAND
W6 0PW
Should you have any concerns regarding our management of your personal data please contact us and we will do our best to address them. You may 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 in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 21 May 2018. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current so please let us know if any of your personal data changes.
THIRD-PARTY LINKS
Our website may include links to third-party websites, plug-ins and applications, which we do not control. We encourage you to read the privacy notice of any of those sites or applications to confirm how they will process your personal data.
We may collect, use, store and transfer different kinds of personal data about you as follows:
Providing your personal data may be required for us to supply our products, services, promotions or marketing information. If you are not willing to supply certain personal data to us, it may limit our ability to supply these to you.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Please contact us if you would like more information about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data.
You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
In the below table we have a list of activities we carry that involve some form of processing of your personal data. The data
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of legitimate interest
|
To register you as a new customer, user or subscriber
|
(a) Identity
(b) Contact (c) Marketing (d) Technical
|
Necessary for our legitimate interest
|
To administer and deliver any order for products and services you make | (a) Identity
(b) Contact (c) Marketing (d) Purchases (e) Communications (f) Financial Data |
Performance of a contract with you
|
To notify you about changes to our terms or privacy policy | (a) Identity
(b) Contact
|
Necessary to comply with a legal obligation
|
To enable you to partake in a prize draw, competition or complete a survey and for us to administer the same
|
(a) Identity
(b) Contact (c) Online Profile (d) Usage (e) Marketing (f) Communications
|
Necessary for our legitimate interests
|
To administer, maintain and protect our business, our digital platforms and our Roster’s digital platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical (d) Usage
|
Necessary for our legitimate interests |
To deliver relevant digital content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
|
(a) Identity
(b) Contact (c) Online Profile (d) Usage (e) Marketing (f) Communications (g) Technical
|
Necessary for our legitimate interests
|
To use data analytics to improve our digital platforms, products/services, marketing, customer relationships and experiences
|
(a) Technical
(b) Usage
|
Necessary for our legitimate interests
|
To make suggestions and recommendations to you about products, services or events related to us or our Roster that may be of interest to you
|
(a) Identity
(b) Contact (c) Online Profile (d) Usage (e) Marketing (f) Communications
|
Necessary for our legitimate interests
|
To measure our performance and the performance of our Roster | (a) Identity
(b) Purchases (c) Online Profile (d) Usage
|
Necessary for our legitimate interests
|
To develop and implement direct and indirect marketing campaigns | a) Identity
(b) Contact (c) Online Profile (d) Usage (e) Marketing (f) Communications (g) Technical Device |
Necessary for our legitimate interests
|
MARKETING
If at any time you decide that you do not wish to receive marketing communications from us or those providing services on our behalf, you may either use the unsubscribe function on any recent communication from us, or you may contact us via [email protected]
We may use your Identity, Contact, Usage, Communications, Marketing and Online Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us, signed up to newsletters or notifications or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside the First Access group of companies for marketing purposes unrelated to First Access or our Roster.
COOKIES
We use cookies to provide personalised information through our digital platforms. We also use cookies to better target our advertising to you, both through our digital platforms and other platforms you may visit. We store these cookies for a maximum of 180 days.
You can set your browser to refuse all or some browser cookies but please note that some parts of our platforms may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason. We may without your knowledge or consent, process your data for a further purpose but only if the further purpose is compatible with the original reason for why we collected your data. If you would like an explanation of how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may share your personal data with certain parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the First Access group and with external service providers. This will involve transferring your data outside the European Economic Area (EEA). We ensure your personal data is protected by requiring all our group companies and contractors to follow the same rules when processing your personal data.
Many of our external third parties and service providers 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 have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Communications and Purchase data) for six years after they cease being customers for tax and audit purposes.
We will keep your Contact, Online Profile, Identity, Marketing and Communications data for a period of 6 years after the relevant act on our Roster stops being active.
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:
If you wish to exercise any of the rights set out above, please Contact us
NO FEE USUALLY REQUIRED
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.
WHAT WE MAY NEED FROM YOU
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.
TIME LIMIT TO RESPOND
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.