Privacy Policy Statement

Circulate and the Circulate website are owned and operated by a consortium of venues incorporating Watermans, Millfield Theatre, the Albany, Stratford Circus Arts Centre, with The Greater London Authority and ISAN.  We are committed to safeguarding your privacy online. We’ve written this Privacy Policy to explain what data we collect, why we collect it, and what we do with it. Personal data is very important, and we hope you can take the time to read the Policy carefully.
This may change from time to time so please do check it periodically.

Personal data

Personal data is information about you: for example, your name, address, date of birth, credit card details and so on. It’s information that can be used to identify you.
Circulate collects personal data for various reasons which we explain here. Circulate is the Data Controller. Sometimes we will process your data ourselves, sometimes (for example, sending out emails), a third party company will do the processing. This is called data processing. We’ll explain this too.
The person in charge of Data Processing for Circulate is the Data Protection Officer. You can contact them by email on dataprotection@watermans.org.uk

We only process your data if there is a legal basis to do so. We’ll explain this as we go along.
There are several ways in which we might collect and process your personal data:

1    Mailing List and Surveys
We like to let you know what we’re doing and what’s coming up; and we like to know what you think about us and what we do. We do this through our mailing list and through surveys, and only with your consent. Your consent would provide the legal basis for us to do this.
You can choose to join our mailing list at one of our events or on our website. You can opt in to receive email and/or mail from Circulate, and choose whether Circulate can share your data with artists you have seen. You can choose what you would like us to tell you about by ticking the relevant boxes. You can update your preferences at any time and as often as you like by updating your preferences in any email we send, or by contacting the data protection officer as described. This data is used to send marketing updates and/or information on how you can support Circulate.  The data processor is Mailchimp, as above.
 
We gather statistics about email opening and clicks, using industry standard technologies to help us monitor and improve our marketing. 
The legal basis for this processing would be your consent. No consent: no processing.

2    Direct Feedback
Whenever you get in touch with us to give direct feedback (by email, or in person) about your experiences of our service, we store and process the personal data you give, in order to assure that every piece of feedback is given an appropriate and timely response.   This processing is done on site by our Customer Relations team.  Our legal basis for this processing is in the legitimate interest of all parties so that we can better serve you in future.  Your data is retained in line with our retention statement (see the next section). 

3    Consent Data
For certain events we might ask you to give additional information about a young person when you give consent for them to take part in an activity.  This data is held alongside your normal customer data within Ticketsolve and then processed locally so that workshop leaders have it at their fingertips in case of an emergency.  Our legal basis for this processing is so that we can fulfil our contract to safely support your young person throughout their visit.  
Paper copies of this data are made and then destroyed on the day of the event, and digital data is retained in line with our retention statement (see the next section). 

4    Our Data Processing Partners
MailChimp and Survey Monkey have implemented appropriate technological measures to protect against accidental loss, destruction, damage, alteration and disclosure. If you’d like to know more about these organisations, here are links to their Privacy Policies.
https://mailchimp.com/legal/privacy/
https://www.surveymonkey.co.uk/mp/legal/privacy-policy/

5    Retention
We keep your data only as long as we need to, or the law tells us to, or you want us to.
We will retain your data until you tell us not to.

6    Examination, Correction and Deletion
At all times you have the right to view your personal data that we hold. This is called a Subject Access Request. 
Contact hello@circulate.london and we’ll get onto it.
You will be asked to verify your identity before we release any information to you, and we will endeavour to provide a full report within 30 days of verification.
In fact if you would like to revise the information provided to us at any time, or feel what we currently have on record is incorrect, you can update the information by e-mailing hello@circulate.london
We may from time to time ask you for further information in order to update our records or for particular purposes. 
We will always tell you how we will use any further personal information received from you.

7    Log Files
Every time someone visits our web site a log file is generated.
The log file records the time and date of your visit, the files that were requested, your IP (Internet Protocol) address, the referrer URL (if provided) and the browser version. We collect this information to help us diagnose problems and administer our   

systems and to audit the geographical make-up of users and how they have arrived at our site; that is, from what other sites have visitors arrived – this information being obtained from the referrer URL.
We do not link IP addresses to anything personally identifiable, which means that you remain anonymous even though we include your IP address in our aggregate information. However, we can and will attempt to use IP addresses to identify a user when we feel it is necessary to enforce compliance with our terms and conditions, or to protect our services and other users.

8    Cookies
Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. They make it possible for us to provide our online ticketing service and track visitor statistics, such as returning visitors.
Cookie        
Universal Analytics (Google)    
Data
_ga
_gali
_gat_UA-XXXX
_gid    
Purpose
These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, device used, where visitors have come to the website from and the pages they visited.

9    Use and Disclosure of Personal Data
If we are requested by the police, or a regulatory or government authority investigating illegal activities to provide information concerning your activities whilst using the network, we must do so. 

10    Protecting Your Personal Data
We take every precaution to protect your information. 
To this end all Personal Data is kept on a server in a secure environment. Only employees and approved contractors/developers we may appoint from time to time and who need the information to perform a specific job are granted access to Personal Data.
Please note that our processors Mailchimp and Survey Monkey are based outside of the EEA and use servers located in the United States.  These processors have proven to us that they robustly protect your data by carrying the EU-US Data Shield accreditation that is recognised by our own Information Commissioner’s Office as a standard of excellence.

11    Users Under 18
If you are under 18, please ensure that you obtain your parent/guardian’s consent beforehand whenever you provide Personal Information to Circulate. Users without such consent are not allowed to provide us with Personal Information.

12    Your Right to Query or Complaint
If you have any queries or concerns regarding your personal Information please contact Watermans Data Controller, the Operations Manager 020 8232 1026 or email dataprotection@watermans.org.uk.  
Should you feel that Circulate have in any way mishandled your personal information or are operating illegally you can contact the Information Commissioner’s Office on 0303 123 1113 or navigate to https://ico.org.uk/concerns/ in your web browser.