Privacy & Cookies
PRIVACY POLICY
Policy version: 18/12/2024
1 Introduction
This Privacy Policy is provided by Whitsun Brook Academy of Dramatic Art, (‘we’, ‘our’ or ‘us’) for use of our website, being www.whitsunbrookacademy.com (Website).
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
2 What this policy applies to
This privacy policy relates to your use of the Website and accessing the services provided through the Website.
The Website may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with the services through the Website. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies and we shall in no way be liable or responsible for any such third parties. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3 Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through the Website. We will collect and use the following personal data about you:
(a) Data you input into the Website – this includes:
(i) Your name, mobile number and email address
(ii) Your interests, preferences, reviews, feedback and survey responses
(iii) Your social media log-in details, user name, profile photo etc., where you log-in on the Website using the social media profile or connect your social media account to your account on the Website.
(b) Data collected when you use specific functions in the Website – Data you store online with us using the Website including your access history, review history or preferences (while such data may not always be personal data as defined by law in all cases, we will assume it is and treat it in accordance with this policy as if it were)
(c) Data collected when you place a review or comment on the Website – Details of the blogs, articles and materials which you browse on the Website, blogs, articles and materials for which you put a review or comment on the Website.
(d) Data collected when you permit the collection of location data – Details of your location with a high degree of precision, see the section ‘Location services/data’ below data concerning location is collected when using the Maps function of the Website.
(e) Other data the Website collects automatically when you use it – this includes:
(i) Your activities on, and use of, the Website which reveal your preferences, interests or manner of use of the Website and the times of use
(ii) Other information such as entry and exit pages, CTR to third party links, affiliate links, device type, IMEA numbers, MAC address of networks, other unique device identification, device operating system, mobile network information, data usage, time zone settings etc.
(f) Data collected when you make an enquiry with us – Your name, mobile number and email address.
(g) Marketing and communications data – Your preferences in receiving marketing emails from us and our third parties and your communication preferences.
If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services to you through the Website.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ usage data (including information about how users interact with and use the Website and products and services offered through the Website) to calculate the percentage of users accessing a specific feature of the Website in order to analyse general trends in how users are interacting with the Website to help improve the Website and our offerings.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4 Sensitive Data
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Website (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public and will not be responsible for protection of any such sensitive data. In case any such sensitive data is provided by you, you may contact us for deletion of such sensitive data.
5 Location services/data
The Website will request your consent to use location services to precisely identify your location each session (i.e. each time the Website is opened or has been placed in the background for more than 30 seconds).
If you do not provide your consent, you may use the Website but that will mean the “geo-location” feature on the Website will not be available. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.
The location services in the Website will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.
We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site - https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.
6 How your personal data is collected
We use different methods to collect data from and about you including by way of:
(i) Your interaction with us: We collect personal data from you directly when you access the Website, post a review/rating on the Website, click on ads, share social media logins/connect to your social media profile, subscribe to our communications, request for marketing emails to be sent to you, contact us directly or reach out to us via social media, make submissions via the Website when a forum element is available, or indirectly, such as your activity while using the Website, participate in any feedback or survey.
(ii) Automated technologies or interactions: As you interact with the Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie police available at https://www.whitsunbrookacademy.com/about-5 for further details.
7 How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
(i) where you have given consent
(ii) to comply with our legal and regulatory obligations
(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or
(iv) for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your statutory rights. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
Below are the details as to what we use your personal data for and why:
(a) Providing services and/or the functionalities of the Website to you – Depending on the circumstances:
(i) to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website)
(ii) the geolocation feature will use data relating to your location only based on your consent as described in ‘Location services/data’ (above)
(b) To enforce legal rights or defend or undertake legal proceedings – Depending on the circumstances:
(i) to comply with our legal and regulatory obligations
(ii) in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
(c) Sending relevant marketing communications and for making personalised suggestions and recommendations to you about the products that may be of interest to you based on your profile data – For our legitimate interests, to carry out direct marketing, improve and develop our services and offerings and grow our business and having obtained your consent to receive direct marketing communications.
(d) Carry out market research through your voluntary participation in surveys – Necessary for our legitimate interests to study how customers use the Website and to help us improve and develop our Website and services offered through the Website.
(e) Communications with you not related to marketing, including about changes to our terms or policies or updates concerning the requests submitted by you through the Website or changes to the Website or service or other important notices – Depending on the circumstances:
(i) to comply with our legal and regulatory obligations;
(ii) to keep you updated on any requests submitted by you through the Website; and
(iii) in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
(f) Protect the security of systems and data – To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
(g) Operational reasons, such as improving efficiency, training, and quality control or to provide support to you – For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you.
(h) Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures – For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop the Website.
(i) Updating and enhancing user records – Depending on the circumstances:
(i) to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website);
(ii) to comply with our legal and regulatory obligations; and
(iii) where neither of the above apply, for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website and the products and services offered through the Website.
(j) To comply with our legal and regulatory obligations – Depending on the circumstances:
(i) to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website); or
(ii) to comply with our legal and regulatory obligations,
where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website
(k) To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency (In such cases information will be anonymised where possible and only shared where necessary) – Depending on the circumstances:
(i) to comply with our legal and regulatory obligations; and
(ii) in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets.
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
8 Marketing
We intend to send you email marketing to inform you of the products such as promotions, any new products, any new services offered through the Website, feedback/update on reviews submitted by other users of the Website, recommending products for your reviews etc.
We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
o contacting us at info@whitsunbrookacademy.com
o using the ‘unsubscribe’ link included in all marketing emails you may receive from us
We will always treat your personal data with the utmost respect and will not sell or share it with other organisations in violation of the applicable laws.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
9 Who we share your personal data with
We routinely share personal data with service providers we use to help us run our business, help us with fulfilment of any requests submitted through the Website, provide the services or functionalities in the Website, including developers, cloud storage providers etc.
We only allow service providers to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
§ external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
§ professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
§ law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
§ other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party, except for the purposes identified in this privacy policy.
10 How long your personal data will be kept
We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
11 Transferring your personal data out of the UK
Under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
§ The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
§ Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
12 Your rights
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
(a) Access to a copy of your personal data – the right to be provided with a copy of your personal data.
(b) Correction (also known as rectification) – the right to require us to correct any mistakes in your personal data.
(c) Erasure (also known as the right to be forgotten) – the right to require us to delete your personal data—in certain situations.
(d) Restriction of use – the right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
(e) Data portability – the right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
(f) To object to use – the right to object at any time to your personal data being used for direct marketing (including profiling); and in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
(g) Not to be subject to decisions without human involvement – the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
o provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
o let us know which right(s) you want to exercise and the information to which your request relates
13 Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
14 How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
15 Changes to this privacy policy
We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example via the Website or by other means, such as email.
16 How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
§ info@whitsunbrookacademy.com
§ 07831 426300
COOKIES POLICY
Policy version: 12/12/2024
Please read this cookie policy carefully as it contains important information on who we are and how we use cookies on our website, being www.whitsunbrookacademy.com (Website). This policy should be read together with our Privacy Policy (available here) www.whitsunbrookacademy.com/about-5 which sets out who we are, how to contact us, what data is collected, how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.
1 Cookies
A cookie is a small text file which is placed onto your device (e.g. your smartphone or other electronic device) when you use the Website. When we use cookies on the Website, you will always be informed by a pop-up within the Website.
Cookies help us to recognise you and your device and allow us to store some information about your preferences or past actions, and remember your preferences next time you visit the Website.
For example, we may monitor how many times you use our Website, which parts of the Website you go to, service accessed by you, sections browsed by you etc. This information helps us to understand use of the Website by our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.
For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
2 Consent to use cookies and changing settings
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to allow you to remain logged-in to the Website as you navigate within the Website and use the Website functionalities).
You can withdraw any consent to the use of cookies or manage any other cookie preferences by using the tool made available to you within the Website itself. You can then adjust sliders or untick boxes as appropriate to reflect your choice. It may be necessary to refresh or restart the Website for the updated settings to take effect.
3 Our use of cookies
We use the following cookies:
(i) Strictly necessary cookies: These are cookies that are required for the operation of our Website. These essential cookies are always enabled because the Website will not work properly without them. They include, for example, cookies that enable you to log into secure areas of the Website, maintain record of the areas of the Website access by you etc. You can switch off these cookies in your browser settings but then you may not be able to access all or parts of our Website.
(ii) Analytical or performance cookies: These allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
(iii) Functionality cookies: These are used to recognise when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences.
(iv) Targeting cookies: These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests.
4 How to turn off all cookies and consequences of doing so
If you do not want to accept any cookies, you may be able to change your device settings so that cookies (including those which are essential to the service requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of the Website. For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
5 Changes to this policy
This policy was published on 18/12/2024 and last updated on 12/12/2024 We may change this cookies policy from time to time, when we do, we will inform you via the Website or by sending an email to the email address you provided when you signed up to the Website.