GDPR Policy

Our GDPR policy aims to give you information on how In It Together collects and processes your personal data through your use of our websites, including any data you may provide through our websites, when you sign up to our Emails, purchase a product or service, take part in a competition or use our mobile apps.

This website is not intended for children under 16 years of age and we do not knowingly collect data relating to children.

It is important that you read this GDPR notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This GDPR notice supplements the other notices and is not intended to override them.

1. Data Controller And Contact Details

In It Together is a brand of Climax Promotions and Events LTD and is the controller and responsible for your personal data (referred to as "Climax Live", "we", "us" or "our" in this privacy notice). Climax Live is the controller and responsible for this website.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact dataprotection@climaxlive.co.uk.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please advise us of your personal data changes as it is your duty to inform us of changes.

2. Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit.

3. The Data We Collect From You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth, personal photograph and gender.
• Contact Data includes billing address, delivery address, residential address, email address and telephone numbers.
• Financial Data includes bank account and the last 4 digits and date of expiry of your payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use and interact with our websites and/or other websites, our mobile apps, products and services, and the frequency with which you use and interact with our websites and/or other websites, our mobile apps, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, where you need to place an order to purchase event tickets). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

5. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, our websites, our apps or otherwise. This includes personal data you provide when you:
  • apply for our products or services (including when tickets are ordered or re-sold);
  • create an account on our websites;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • give us some feedback; or
  • when promoters use our guest list manager service
• Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar tracking technologies such as pixels and web beacons to analyse trends, administer our websites, track your movements around our websites, provide targeted advertisements and gather demographic information about you.
  
  We may receive Technical Data about you if you visit other websites employing our cookies.
  
  We may also receive Profile Data about you if you;
  • use 'white label' websites that we design and/or host for promoters that we provide services for ("White Label Websites");
  • consent to providing us with your preferences stored on third party websites and/or platforms;
• Cookies. Examples of the cookies we use:
  • Preference cookies – to remember your preferences and settings in order to provide you with an enhanced service
  • Security cookies – for security purposes
  • Advertising cookies – to provide you with advertisements that may be relevant to you
  • Functional cookies – to provide enhanced functionality and personalisation
  • Targeting cookies – to build a profile of your interests and show you relevant adverts on other sites
  • Social Media cookies – to enable you to share our content with your friends and networks
• Web beacons. We use web beacons on our websites, White Label Websites, and in our e-newsletters and e-flyers ("Email" or "Emails"). When we send Emails to people that have opted-in to receive Emails ("Members") we may track who opened the Emails and/or who clicked on links contained within those Emails by using single pixel gifs to collect the following information about Members when their Email is opened; their IP address, browser and email client type e.g. Outlook or Hotmail in order to provide us with a measurement of our email campaigns and to improve our features for specific segments of Members list.

We may also collect, store and use your location to improve and provide customised features of our service. You can enable or disable services that we provide which are based on your location at any time through your device settings.

We may use mobile analytics software to collect Usage Data and improve our knowledge as to how frequently you use our mobile apps and gain other usage information.

Third parties or publicly available sources We may receive personal data about you from various third parties, public databases, social media platforms, third party data providers and our joint marketing partners sources as set out below:

• Identity Data from the following: Facebook, other ticket agents
• Contact Data from the following: Facebook
• Profile Data from the following: Facebook, Spotify

Technical Data from the following:

analytics providers; Google Analytics based outside the EU in order to track and report website traffic. Your Technical Data is used to track and monitor the use of our service. The Technical Data is shared with other Google services. Google may use the Technical Data to contextualise and personalise the advertisements of its own advertising network.

You can opt-out of having your activity tracked and monitored by Google Analytics whilst using the services by installing the Google Analytics opt-out browser add-on. The opt-out browser add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics.

(b) advertising networks; such as Google AdSense based outside the EU; and DoubleClick Cookie based outside the EU to help support and maintain our services. Your Technical Data is used to provide targeted adverts.

Google AdSense uses cookies to provide advertisements on our service. Google's use of the DoubleClick cookie enables it and its partners to provide advertisements to our users based on their visit to receive our services or to other websites on the Internet.

(c) behavioural re-marketing services; such as Google AdWords which is provided by Google Inc. based outside the EU; and Facebook which is provided by Facebook Inc. based outside the EU so that we can advertise on third party websites to you after you visited our websites and used our services. Your Technical Data and Identity Data is collected by Skiddle and its third party service providers using cookies to inform, optimise and serve advertisements based on your past visits to our websites.

You can opt-out of Google Analytics for display advertising and customise the Google Display Network advertisements by visiting the Google Ads Settings page at http://www.google.com/settings/ads.

(d) payments providers; such as Apple Store In-App Payments based outside the EU; and Google Play In-App Payments; Stripe based outside the EU; PayPal based outside the EU; and Braintree based outside the EU. Your Contact, Financial, Transaction and Technical Data is collected in order to provide technical, payment and delivery services for products and/or services that you order and to track IP addresses.

(e) search information providers; such as Experian Limited and/or Companies House both based inside the EU to assess certain promoter deals.

• Identity and Contact Data from data brokers or aggregators such as Experian Limited based inside the EU.
• Identity and Contact Data from publicly available sources such as Companies House based inside the EU.

6. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To complete orders placed by you including; sending you emails, invoices, receipts, tickets and alerting you of any issues with the order. To enable third parties to process credit card transactions securely, we send your billing information to the same third parties to process your orders and credit card payments.
• Where you purchase tickets for an event, your Identity Data, Contact Data and Financial Data may be shared with the event promoter so they can contact you directly about their event. By placing a ticket order you consent to the event promoter using your information to contact you in relation to that event, you may then opt-in to further marketing including from that event promoter.
• To send you messages about our services, including temporary or permanent changes to our services such as planned outages, new features & releases, abuse warnings and changes to this policy.
• To communicate with our users about their account and provide customer care.
• To promote our services to you.
• To send you Emails and other information and promotional content in accordance with your marketing preferences.
• To enforce compliance with our Terms & Conditions and applicable law.
• To protect the rights and safety of our users and third parties as well as our own.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal, professional, security or regulatory obligation.
• Where we need to protect against legal liability and/or protect and defend our rights or property.

The information we collect about how you and when you use our services may be stored in log files associated with your account and may be linked to other information we collect about you. This information may include Technical Data such as your IP address and the browser that you used, and the time and date you used our websites and/or mobile apps and any actions you have taken within the websites, White Label Websites and/or our mobile apps. Linking the information we collect about you helps us to improve our services for you and other users of our websites and mobile apps.

7. Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive Emails from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

8. Opting out

You can opt out of receiving Emails, other information and promotional content by editing your profile preferences, or following the unsubscribe link or instructions provided in any Email or communication we send.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, notification of service changes, an update to this policy, warranty registration, product/service experience or other transactions.

9. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here.

10. Change Of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the Contact Details listed in this policy.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11. Disclosures of your personal data

We may have to share your personal data with the parties set out below.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;

• Analytical providers (Google Analytics, New Relic and Fabric) are sent Technical Data;
• Ticket insurance providers who provide ticket refund protection are sent Identity Data, Profile Data and Technical Data; and

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

12. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting the data privacy manager at the email address stated at paragraph 2 to this policy.

14. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data which give you the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You can also update your details by logging in and editing your profile.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You can delete your account here.

Object to processing of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can update your preferences at anytime.

If you wish to exercise any of the rights set out above, please contact the data privacy manager at the contact details stated in this policy.

15. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

16. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

17. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

18. Changes to this policy

We may update this policy from time to time. We will notify you of any changes by posting the new policy on this page and will let you know via email and/or a prominent notice on our websites, prior to the change becoming effective and update the "effective date" at the top of this policy.

You are advised to review this policy periodically for any changes.

19. Contact Us

If you have any questions about this policy, please contact dataprotection@climaxlive.co.uk