Contents
- Introduction
- What is Let’s Circus?
- Explaining the legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- How we protect your personal data
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- Information about cookies
- What are your rights over your personal data?
- How can you stop the use of your personal data for direct marketing?
- Contact information
- If you live outside the UK
- Any questions?
1. Introduction
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.
Our Data Protection Principals
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
2. What is Let’s Circus?
Let’s Circus is a Limited Liability Partnership business providing entertainment and educational services. We are small business dedicated to Circus Arts activities and performance.
Circus in a Field is a Trading Name of Let’s Circus. www.circusinafield.co.uk
La Bonche is a Project name managed by Let’s Circus. www.labonche.net
Other project names or show names may arise with websites, or social media profiles, but these are subsidiary to Let’s Circus the Organisation.
3. Explaining the legal bases we rely on
The law on data protection, based on the General Data Protection Regulation and formerly the Data Protection Act, sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent. This may be when you have ticked a box to receive regular communications from us in a paper or electronic document or on our website.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations In certain circumstances, we need your personal data to comply with our contractual obligations. If
you have booked us to provide a performance or our entertainment services then we will need your contact details for example.
Legitimate interest In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example if we have worked with or for you before we may use your address details to send you direct marketing information by post telling you about our services that we think my interest you.
4. When do we collect personal data?
- When you visit our websites
- When you make a booking, participate in our activities or visit our circus performances
- When you engage with us on social media
- When you contact us by any means to make enquiries
- When you comment on or review our products and services, or respond to our research projects
- When you visit our online platforms we use cookies. For more information about cookies see Section 11.
5. What sort of personal data do we collect?
- For a booking or enquiry, or participants in training programmes: your name and address and the name of other individual at the event as necessary (for example a participant dependent and their age and gender), event address and on site contact name, email, telephone and mobile numbers. For participants in some circus activities we may also collect data on medical, health, or other access needs to support an individual in the activity as well as next of kin. (We do not collect these medical details if we are not responsible for the individual, ie for a child in a school context.)
- Details of your interactions with us such as with our website, email and social media.
- Copies of documents you provide us or signed contracts
- Payment information.
- Your comments and reviews.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
- We may gather publicly available information for marketing or research purposes.
- We do not intend to collect or knowingly collect information from children, nor information relating to children, unless they are participating in our activities and fall under our duty of care. Our data managers are Enhanced DBS cleared. Our protocols mean that we do not contact children directly without consent of their guardian or parent. We follow UK child safeguarding protocols if a child is deemed at risk of harm.
6. How and why do we use your personal data?
Primarily we use your data in order to inform you of our circus services as a point of interest and as a point of sale and to provide the services that you have requested or participated in. If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
- To perform any contract we’ve agreed with you. If we don’t collect your personal data during this process, we won’t be able to provide the required services and comply with our legal obligations.
- To respond to your queries or complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business from fraud and other illegal activities. We’ll do all of this as part of our legitimate interest.
- With your consent, we will use your personal data to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. You are free to opt out of receiving these requests from us at any time by contacting us.
7. How we protect your personal data
We know how much data security matters to all our clients. With this in mind we will treat your data with the utmost care and do our best to take all appropriate steps to protect it. Our computers and mobile devices are all password protected. We regularly monitor our systems for possible vulnerabilities and constantly review our security and Data protection compliance with our web consultant.
We do our best to keep your Personal Data safe. We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks. Our website has several layers of security enabled and the site installation has been modified on setup for extra security.
Even though we try our best we cannot guarantee the absolute security of information. However, we promise to notify suitable authorities of data breaches we detect. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
For paper documents, we anonymise, burn or shred documents with personal data when no longer needed and keep them in a secure building.
8. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Her Majesty’s Revenue and Customs (HMRC) requires us to keep records of contracts, payments and invoices for 7 years. We will therefore normally hold information of any contracts for this long. For the purposes of Insurances, there are some requirements that last for 40 years. For those who are subcontractors or engaged in activities in we may need to keep your data for longer than 7 years. Particularly if there has been an incident.
9. Who do we share your personal data with?
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with online technical service providers in order to operate our website and social media platforms.
We sometimes share your personal data with trusted third parties. Circumstances may be as follows:
- To have items delivered to site before an event
- If there are other entertainers or performers booked by us as part of an event
Should that be necessary:
- We provide only the information they need to perform their specific services to you or with you.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- We may also share information with emergency services, or other event management in order to maintain safe working environments.
- For arts educational and or funded projects data may be shared with project partners, funders or, evaluators. In these circumstances minimal personal data will be shared, unless already in the public domain. Photographs and video images will be anonymized. Individuals featured prominently will have had consent given appropriately. Usually this is given on a participant consent form on sign up to an activity.
Our processing partners
Kualo: this website is hosted with Kualo in their Data Centre in London. Read their privacy policy here.
Our business partners
Jaijiel Creative: Our website was created and is maintained by Jaijiel Creative in Edinburgh. They have access to the site admin in order to keep the site software updated and attend to any technical issues which may occur, they will not access user or customer data unless required for the technical upkeep of the site.
Place of processing: UK
Read their privacy policy here.
BookWhen: We use BookWhen to handle bookings and tickets for some of the events we organise. All transactions are handled by them (not by this website).
Place of processing: UK
Read their privacy policy here.
Connected third parties
Google Analytics: Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage data.
Place of processing: US
Analytics Privacy Policy
Google Privacy Policy
Opt-out
Mailchimp: We use Mailchimp to handle out newsletter subscriptions and mailouts. Read their privacy policy here.
Dropbox (Dropbox, Inc.): Dropbox is a service to save and manage backups provided by Dropbox Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States
Privacy Policy
External content
This type of services allows you to view content hosted on external platforms directly from the pages of this website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
YouTube (Google Inc.): YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage data.
Place of processing: US
Privacy Policy
Google Fonts: Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Usage data and various types of Data as specified in the privacy policy of the service.
Place of processing: US
Privacy Policy
Google Maps: Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage data.
Place of processing: US
Privacy Policy
Facebook: Like button and social widgets (Facebook, Inc.) – The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States
Privacy Policy
Twitter: Twitter Tweet button and social widgets (Twitter, Inc.) – The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States
Privacy Policy
Font Awesome: This website makes use of FontAwesome icons. Read their privacy policy here.
10. Where your personal data may be processed
Let’s Circus will process your data for simple marketing purposes. However our website and social media suppliers will have access to some of the data in order for our media to function more effectively. As a result, although processing primarily takes place in the UK, it may also take place in the EU and the US.
11. Information about cookies
Cookies and other technology we use. See our Cookie Policy here.
We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
We use cookies for the following purposes:
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.
12. What are your rights over personal data
An overview of your rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- The right to deletion, for example when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact us at helen@letscircus.com. If we decide not to action your request we will explain to you the reasons for our refusal.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
13. How can you stop the use of your data for direct marketing
You can stop direct marketing communications from us by contacting us by email or post or via the unsubscribe button on our Mailchimp newsletters.
14. Contact information
Site Owner/Data Controller
Helen Averley
Let’s Circus LLP
Email: helen@letscircus.com
Supervisory Authority
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: +303 123 1113
Email: https://ico.org.uk/global/contact-us/email/
Website: https://ico.org.uk
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
15. If you live outside the UK
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
16. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact us.
Changes to this privacy policy
We reserve the right to make changes to this privacy policy.
Last updated: 23rd August 2023