Privacy Policy

Bruno Peek Pageantmaster Ltd Privacy Notice

Privacy Notice Control.

This Privacy Notice is v1.3.2 and is valid from 0001hrs on 12 August 2019. It replaces and supersedes all other Privacy Notices associated with VE Day 75 and other Bruno Peek Pageantmaster Ltd events.

We take your privacy very seriously. This Privacy Notice details what Personal Data we collect and how we shall use it. Please take time to read this Privacy Notice and ensure that you understand its contents.

 Changes to this Policy

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notices for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall email you to inform you.

 Our Name & Contact Details.

The Data Controller of your Personal Data is Bruno Peek Pageantmaster Ltd. This means the organisation decides how your personal data is processed and for what purposes. Our contact details are:

Bruno Peek Pageantmaster Ltd

Pageantmaster’s House

110 Lowestoft Road

Gorleston-on-Sea

Great Yarmouth

Norfolk NR31 6ND

Data Protection Officer Contact Details.

Bruno Peek Pageantmaster Ltd takes its data protection obligations extremely seriously. In observance of the General Data Protection Regulation and the Data Protection Act 2018, Bruno Peek Pageantmaster Ltd have chosen to establish a Data Protection Officer.

Should you wish to contact our Data Protection Officer regarding a data protection matter you can do so by emailing pageantmaster@veday75.org  or writing to:

Data Protection Officer

Pageantmaster’s House

110 Lowestoft Road

Gorleston-on-Sea

Great Yarmouth

Norfolk NR31 6ND

International Personal Data Transfer – Countries & Organisations.

Bruno Peek Pageantmaster Ltd does not presently transfer personal data to any countries outside of the EU or international organisation. If in the future we choose to do so, and the country to which we transfer your personal data does not have a recognised EU or UK Adequacy Agreement, we shall ensure that the endorsed ICO Safeguard contract is in place with the Data Controller or Data Processor within the Country which contractually obliges them to protect your information to the same standard required by the General Data Protection Regulation.

Automated decision-making, including profiling.

Bruno Peek Pageantmaster Ltd does not use currently use automated decision-making tools or profiling in the processing of your Personal Data.

For what purposes do we process personal data, and what are the lawful basis’ by which we process data?

 Bruno Peek Pageantmaster Ltd processes your Personal Data for the following purposes:

 

For What Purposes Do We Process Personal Data? What are the lawful basis’ by which we process data?
Communicate with supporters / sponsors on the Victory in Europe 75 Event (VE 75) related matters where we have your consent to do so via email, telephone, SMS text, postal mail Consent
Communicate with supporters on matters where we have a legal obligation to do so via email, telephone, SMS text, postal mail Legal Obligation
Communicate with supporters / sponsors on matters where we have a legitimate Interest to do so (see legitimate interest section below), via email, telephone, SMS text, postal mail Legitimate Interest
To send supporters packs to supporters via email or postal mail Consent
To connect and introduce supporters to one another to facilitate collaboration Consent
Share and display personal data of supporters / sponsors on the website and online Consent
Share and display personal data of supporters / sponsors in print media Consent
To gather post event feedback for event improvement via email, telephone, SMS text, postal mail Legitimate Interest
To share testimonials, case studies and feedback on Bruno Peek Pageantmaster Ltd on website and future marketing Consent
To verify the identity of individuals where necessary including for Subject Access Requests Legitimate Interest
Inform existing supporters / sponsors about our own future events Legitimate Interest
To resolve complaints and/or disputes Legitimate Interest
Inform existing supporters / sponsors about aligned SSAFA’s future events Legitimate Interest
Request continuation of Consent prior to consent expiry Consent
To request specific consent to share information about aligned/similar future events supported by the Pageantmaster Legitimate Interest
To update supporters / sponsors about significant changes to our Privacy Notice or new or changes to how we process data via email, telephone, SMS text, postal mail Legal Obligation
To collect payments or arrears should we have the need to do so Legitimate Interest
To protect our organisation, supporters, sponsors, volunteers, staff, suppliers, partners and clients; Legitimate Interest
To prevent, detect and investigate fraud; Legitimate Interest
To prevent, detect and investigate crime; Legitimate Interest
To comply with the law; Legal obligation
To fulfil our statutory or regulatory obligations; Legal obligation
To maintain our own accounts and records; Legal obligation,
For reporting, analytics and product/service improvement (including training) Legitimate Interest
To improve data accuracy or completeness Legitimate Interest
To track your email engagement Legitimate Interest
To personalise your online experience Legitimate Interest
To conduct market research Legitimate Interest

 

What are our legitimate interests for processing your data?

Where we have used legitimate interest as the lawful basis for processing your personal data we may use your personal data to:

  • Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our current and historic events;
  • To prevent, detect and investigate fraud;
  • To prevent, detect and investigate crime;
  • To fulfil our statutory or regulatory obligations;
  • To maintain our own accounts and records, including recording any contact we have with you via post, emails, telephone, SMS text and push notifications;
  • For reporting, analytics and product/service improvement, (including internal training);
  • To resolve complaints and/or disputes;
  • To improve data accuracy or completeness;
  • To track your email engagement;
  • To personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;
  • To conduct market research. Including research on the demographics, interests and behaviour of our customers in order to help us gain a better understanding of different audiences and enable us to improve our service. This research may be carried out internally by our employees or we may ask another company to do this work for us. Data will be anonymised to protect your data rights for research purposes.
  • To verify staff suitability and experience for employment.
  • To verify eligibility to work in the UK.

Sharing your personal data

Bruno Peek Pageantmaster Ltd may choose to share your personal data internally and/or share/sell your personal data externally to the business. Where we choose to share/sell your information, we shall do so for the following reasons:

  • Where we have your “Consent” to do so. Where we process your data under the consent lawful basis you have the right to withdraw consent. Please refer to “Your Right to Withdraw Consent” section
  • Where necessary to fulfil services and/or products we are “Contracted” to provide to you
  • Where we have a “Legal Obligation” and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data;
  • Where we have “Legitimate Interest” to do so, including; o For the purposes listed in the “What are our legitimate interests for processing your data?” section above.
  • For reporting, analytics improvement purposes across our trading styles and/or within any future group construct should Bruno Peek Pageantmaster Ltd establish or become part of a group.
  • Where an external 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and which we reasonably believe would be of benefit to you and you would reasonably expect to receive and is similar/aligned to our organisation. In this case we would contact you using Legitimate Interest to request specific Consent to share your Personal Data.
  • Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
  • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
  • Where we outsource support functions of our organisations to trusted partners. The categories of these recipients include:
  • Email and chat support providers;
  • Marketing service provider;
  • Web analytics service providers.
  • Legal support providers;
  • Data protection support providers;
  • Where we choose and/or have your permission to share/sell your personal data with 3rd Party’s we will ensure that they have signed a contract that requires them to:
  • Abide by the requirements of all relevant data protection and privacy legislation;
  • Treat your information as carefully as we would;
  • Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation); and
  • Allow us to carry out checks to ensure they are doing all these things.

Personal Data Retention Period

Bruno Peek Pageantmaster Ltd has the following data retention policies:

  • Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years;
  • Sponsor contact details. Where you have provided us your personal data to sponsor a Bruno Peek Pageantmaster Ltd organised event, we shall retain your personal data for 3 years after the event. When we no longer need this information, we will erase or anonymise your data and/or dispose of it securely.
  • The rights available to individuals in respect of the processing.

Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

  • Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about your Right to Access here.

In most cases Bruno Peek Pageantmaster Ltd will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information). Fees will not exceed £50. Information will be provided within 30 calendar days from the day you request it. We will take all reasonable steps to verify your identity before providing you with details of any personal information we may hold about you.

  • Your right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about your Right to Rectification here.
  • Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances. You can read more about your Right to Erasure here.
  • Your right to the restriction of processing. You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about your Right to the Restriction of Processing here.
  • Your right to object to processing. You have the right to object to processing if we are able to process your information because the process forms part of our public task, or is in our legitimate interests. You can read more about your Right to Object to Processing here.
  • Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about your Right to Data Portability here.

If you wish to exercise any of your Individual Rights, you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing pageantmaster@veday75.org, or writing to:

Data Protection Officer

Pageantmaster’s House

110 Lowestoft Road

Gorleston-on-Sea

Great Yarmouth

Norfolk NR31 6ND

Your Right to Withdraw Consent

You have the right to withdraw your consent to Bruno Peek Pageantmaster Ltd processing your data at any time. Please note that this only applies for personal data processed under the Consent Lawful Basis. To determine what of your personal data is processed under the Consent Lawful Basis, please refer to the “What are the lawful basis’ by which we process data?” section above. If you decide you wish to withdraw your Consent from a processing activity that uses the lawful basis of Consent you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing pageantmaster@veday75.org, or writing to:

Data Protection Officer

Pageantmaster’s House

110 Lowestoft Road

Gorleston-on-Sea

Great Yarmouth

Norfolk NR31 6ND

Your Right to Lodge a Complaint with the ICO

You have the right to lodge a complaint with the UK’s Supervising Authority: The Information Commissioners Office. Prior to lodging a compliant, Bruno Peek Pageantmaster Ltd would like the opportunity to address any complaint you may have. Should you have a complaint please in the first instance contact our Data Protection Officer by emailing pageantmaster@veday75.org, or writing to:

Data Protection Officer

Pageantmaster’s House

110 Lowestoft Road

Gorleston-on-Sea

Great Yarmouth

Norfolk NR31 6ND

If your complaint has not been resolved, you can lodge a complaint with the Information Commissioners Office via email https://ico.org.uk/global/contact-us/email/  or by writing to:

Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire. SK9 5AF.

Or by telephone on 0303 123 1113.

Bruno Peek Pageantmaster Ltd Privacy Notice version 1.3.2, valid from 0001hrs on 12 August 2019.