The Circus People Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.thecircuspeople.co.uk Our website will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Our Site is owned and operated by The Circus People Ltd, a limited company registered in England under company number 07804252 .
Registered address: Epstein Building, Mivart Street, Bristol BS5 6JF.
Main trading address: Epstein Building, Mivart Street, Bristol BS5 6JF.
Data Protection Officer: Sara Bjerking.
Email address: firstname.lastname@example.org.
Telephone number: 01179355353.
Postal Address: Epstein Building, Mivart Street, Bristol BS5 6JF
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the GDPR, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, and we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
• Address(es): venue addresses, invoice addresses and postal addresses
• Email address (and all data contained within them);
• Telephone number;
• Business name;
• Job title;
• VAT number;
• Bank details/payment information;
• IP address;
• Web browser type and version;
• Operating system;
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one or more of the following purposes:
• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying our products and/or services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products and/or services for you.
• Communicating with you. This may include responding to emails or calls or online chat from you.
• Supplying you with information by email, and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by (you may unsubscribe or opt-out at any time by contacting us using details included in Part 15).
• Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
• Contact details, including names, email addresses and telephone numbers, will not be deleted after a fixed period. They will be deleted if you request it, or if we determine that our services are of no further interest to you (if we receive no reply from you to our communications for an extended period of time, for example).
• Details about bookings and payment information, including venue addresses, invoice addresses and postal addresses, VAT numbers and bank details, will be deleted after six years (we are required by law to keep this information for at least six years).
• Emails (and all personal data contained within them) will be deleted after six years.
• Information about your preferences and interests will not be deleted after a fixed period. This information will be deleted if you request it, or if we determine that your preferences/interests have changed.
You have the right to request that we delete any of your personal data at any time. If you ask us to delete your personal data, we will do so within one month, unless we are legally obliged to keep the data.
In general, We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.]
In addition, We may transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.]
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.]]
We may share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguard is applied to such transfers:
- We will send all data via an encrypted service as shown below
Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
We use Norton and Malewarebytes to monitor and scan our email and web activity, to guard against security, maleware and phising attacks.
We use both hardware and software firewalls in our office.
All relevant software is kept up to date through automatic and periodic manual updates.
Your data is stored by us on secure servers located in the EEA, the US, New Zealand or other countries where the European Commission has deemed data protection is at similar levels to Europe. All data is encrypted during transmission and at rest.
Transmission of your data is done via:
• Email (Microsoft Exchange): encrypted via Virtru (see details at https://www.virtru.com/gdpr-compliance/ )
• Text (Whatsapp):
Encrypted (see details at https://www.whatsapp.com/legal?eea=1#key-updates )
• We Transfer:
encrypted (see details at https://wetransfer.com/legal/privacy )
• Cloud sharing (Microsoft Onedrive Business): encrypted (see details at https://www.microsoft.com/en-us/TrustCenter/Privacy/gdpr/FAQ )
Please note that if you send personal data to us through services not listed here, your data may not be secure or encrypted. It is your responsibility to send sensitive data in a manner that you find acceptable.
We use email (Microsoft Exchange), text (Whatsapp) and phone for sales communications
Our artists are professional entertainers who have been informed about their responsibilities under GDPR.
As an agency, we may contract with third parties (artists) to supply entertainment services to you on our behalf. In some cases, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8. Personal data will only be transferred outside of the EEA if necessary for an overseas booking.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account.
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
Purpose Strictly Necessary
Name of Cookie: BIGipServerTethys | Purpose: Load balancing | Stricly necessary: yes
Name of Cookie: TawkConnectionTime | Purpose: Chat service | Strictly necessary: yes
Name of Cookie: TS01a0c22a | Purpose: Pending | Strictly necessary: yes
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and/or services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie: _gid | 1st/3rd Party: First | Provider: Google | Purpose: Distinguish user
Name of Cookie: _gat | 1st/3rd Party: First | Provider: Google | Purpose: Throttle request rate
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Sara Bjerking):
Email address: email@example.com
Telephone number: +44 (0)1179355353.
Postal Address: Epstein Building, Mivart Street, Bristol, BS5 6JF.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.